WFD SWMI Consultation,
Water Quality Section,
Department of the Environment, Community & Local Government,
Newtown Road,
Wexford.

3rd December, 2015.

 

RE: Significant Water Management Issues in Ireland – Public Consultation

 

Dear Sir/Madam,

Thank you for the opportunity to input into the preliminary consultation for the next cycle of River Basin Management Planning in Ireland.

I have read the Significant Water Management Issues in Ireland document in full. It identifies most of the primary issues affecting water quality in Ireland. The introduction of the Integrated Catchment Management Concept is welcome. I support it strongly as the only way by which good water quality management will be achieved. The increased focus on community involvement is long overdue and also very welcome.

However, like so many of our responses to European Directives in Ireland, the document is very strong on identifying targets to be achieved, problems to be tackled and not so strong on the ways in which we in Ireland must change our modus operandi by which to achieve these targets. But we will never hit the environmental targets we set with a “business as usual” approach.

 

• Agriculture

One of the aims of Food Harvest 2020 is to increase milk production by 50% now that milk quotas have been abolished. Cork County Council has also spoken positively about the potential the rich grasslands of the county offer for massively increased dairy production. Significant Water Management mentions the difficulty of achieving the Water Framework Directive targets in the context of Food Harvest 2020. It does not dwell on this issue, other than to comment on how research work currently underway will identify better how agriculture impacts on water at a catchment level.

Whilst research is always valuable, we already know how agriculture impacts on water quality, both at the individual stream level and at catchment level. The fact is that to increase the numbers of cows is to increase the volume of slurry produced. It is to increase poaching along riverbanks where cattle get direct access to flowing water. It is to increase the need to intensify grassland management. There is no getting away from this and if we are to attempt Food Harvest 2020 with any cognisance of the Water Framework Directive, Ireland will need to invest heavily in farmer education, slurry treatment and guidelines to protect watercourses from direct access by cattle. It will also be necessary to build centralised biogas plants similar to those in Denmark and Germany for improved management of agricultural slurries. These could offer tremendous potential to rural communities but have never been incentivised in Ireland.

Incentives such as planting of riparian zones and the designation of buffer zones for water source protection are only ever offered to farmers availing of agri-environmental schemes. It is necessary to introduce them across the board. Most farmers are stewards of the countryside. With education and guidance, they will be happy to work towards achieving better water quality. But it is no longer good enough that such agri-related water quality measures are conducted only on farms participating in agri-environmental schemes.

 

• Urban Wastewater Treatment Discharges

Irish Water is putting investment into several of the major wastewater treatment schemes without which Ireland continues to fail the requirements of the Urban Wastewater Treatment Directive. The Cork Lower Harbour wastewater treatment plant is a stark example of a long-awaited wastewater treatment scheme which, when delivered, will end the discharge of significant volumes of raw sewerage.

However, the discussion of urban wastewater in the Sustainable Water Management Issues document does not link wastewater with land use policy. I believe this link is critical. We as a country need to carefully examine our policy of one-off house construction. In particular, we need to consider the impact on the environment of disparate house-building in rural areas. Haphazard siting of houses requires installation of a septic tank or biocycle unit. Treatment of wastewater in discrete units in this way is less effective, less efficient and more difficult to monitor than treatment of wastewater in a communal treatment plant. Planning houses in clusters rather than scattered or in a linear form along a country roadside would allow far greater control of domestic wastewater treatment and discharge.

We are also culpable at all planning levels of building on flood plains. Flood plains perform an essential riparian function. Not merely do they allow vast areas onto which a full river can spill. They also soak rainwater running towards a river, filtering sediment and other pollutants from it before it reaches the water. Yet because they have been constructed on, many floodplains in our larger towns are no longer available to perform this essential function. It is critical that the impact of building on floodplains would be acknowledged as being highly retrograde in terms of water quality.

 

• Hazardous chemicals

Issue 13 discusses hazardous chemicals, particularly heavy metals and PAHs, in our watercourses. It is essential that endocrine disruptors would also be considered. These insidious chemicals strike at the heart of many of the most fundamental aspects of nature.

It is critical that we examine the source of these chemicals in our discharges to water.

One of the key contributors to hazardous chemicals in the water environment is urban wastewater. When wastewater is treated, much of the hazardous content is captured in the sludge. Irish government policy is for the beneficial use of sewage sludge (biosolids) in agriculture. Although the Code of Best Practice advises for the spreading of sludge at a rate which optimises the trapping of these hazardous compounds in soil, it is an indisputable fact that the sludge to land policy may permit levels of hazardous compounds in our agricultural environment to accumulate. The assimilative capacity of soil is limited and so, ultimately, these compounds will make their way to watercourses.

Ireland’s sludge to land policy was drawn up almost 20 years ago. It is well past time that it was revisited. In 2013, almost 24,000 tonnes of untreated sludge was landspread in Ireland. Septic tank sludges are regularly disposed of by landspreading. Research, technology and the microchemical composition of sewage sludge have all moved on. The Sustainable Water Management Issues document needs to identify this sludge policy as being in need of updating.

The Sustainable Water Management Issues document does not identify the link between industry and hazardous chemicals in our watercourses. Producer responsibility dictates that industry must take cognisance of the ingredients of cosmetics, pharmaceuticals, etc. It is time that Ireland focused on this link with a view to reducing the ongoing build-up of hazardous compounds such as these in our environment generally.

 

• Road drainage

Runoff from roads is not mentioned at all in the Sustainable Water Management Issues document. Yet this is a significant source of water pollution. Rainwater running off our impervious urban surfaces contains petrol, oil, heavy metals and PAHs. Fertiliser use on golf courses and residential gardens increases the nutrient load of runoff. Runoff also raises the temperature of smaller water bodies, often with adverse effects on fish life.

Drainage in Ireland typically involves collecting as much stormwater as possible and removing it quickly to avoid flooding. But this approach not just maximises the direct introduction of these pollutants into surface water, it also causes flooding further downstream.

There are many best practice methods by which road drainage and stormwater generally can be more effectively managed. Many local level policy changes can make a real difference. These include incentives towards the installation of green roofs, the development of neighbourhood-constructed wetlands, bioretention systems and infiltration basins.

Sustainable Urban Drainage Systems need to become the norm rather than the exception in Ireland if we are to combat the unsustainable effects of our “collect and dispose” method of stormwater management.

 

• Determination and the allocation of resources

The very first issue listed for consideration in the Sustainable Water Management Issues document is affordability. If the starting point towards achieving any targets is what we cannot afford, then we will never achieve those targets.

The hesitancy of the “Can we really do it?” ethos is reflected throughout the document. Thus the document lacks determination, punch and the will to succeed. It is essential that resources are dedicated to achieving compliance with the Water Framework Directive. It is essential that if additional tasks are to be undertaken by local authorities, they would be adequately staffed and financed. It is essential that all community stakeholders buy into achieving Ireland’s targets under the Water Framework Directive.

But equally and perhaps more important is that the same level of buy-in is committed to by both industry and the government. Industry is the source of much of the cyclical and difficult to treat compounds found in Ireland’s rivers and lakes. Policies and strategies of other governmental departments have the potential to significantly impact on achieving the targets of the Water Framework Directive. It is not sufficient to address achieving these targets in an integrated way merely at catchment level. A multi-sectoral, cross-departmental approach is also essential.

Yours faithfully,

______________________________________

Marcia D’Alton, B.E., M.Eng,Sc.,
Independent Member, Cork County Council

Project Engineer,
M28 Cork to Ringaskiddy Motorway Scheme,
Cork National Roads Office,
Richmond,
Glanmire,
Co. Cork.

29^th November, 2015.

 

RE: Proposed Carr’s Hill Interchange and associated works

 

Dear Sir/Madam,

Thank you for the opportunity to respond to proposals for a new interchange at Carr’s Hill to facilitate the anticipated upgrade of the existing N28 to motorway status.

The N28 connects the Strategic Employment Area of Ringaskiddy to Cork City and beyond. As of An Bord Pleanala’s decision last year to grant planning permission to the Port of Cork for relocation and construction of new facilities at Ringaskiddy, the N28 will also need to connect port traffic to the rest of the country. This is a significant ask for a road that is already suffering extreme congestion. Much investment has gone into the Ringaskiddy cluster and both the relevant authorities and the local population put tremendous store by what Ringaskiddy can deliver for employment and the economy generally. There is widespread support for upgrading the N28 such that it may ease current traffic congestion and help Ringaskiddy to become more efficient in every way.

Despite this widespread support for the upgrade of the N28, the current proposals for the Carr’s Hill Interchange and associated works have engendered an unprecedented level of concern. Socio-economically, the local population is dominated by working families who are well educated and who contribute significantly to the local economy. They are busy people who devote the majority of their lives to their children, their work and to the commuting associated with both. Typically, these people simply do not have the time to engage in public consultations.

There is a clear message being delivered to the Cork National Roads Office when these people, in their hundreds, have expressed their massive concern about the Carr’s Hill Interchange proposals. These are people who live in the N28 corridor and who have an incomparable level of familiarity with the regional and local roads within the N28 corridor. They use those roads every day, at all times of the day. They use them for school deliveries, for getting to work, for shopping, for going to church, for calling to friends. With the single exception of the Greenway along the former railway line connecting Passage West to Cork City, the regional and local roads in the N28 Corridor are notably devoid of cycling infrastructure. The pattern of development is too linear to facilitate easy walking. Housing in and around Rochestown in particular is on steep hills. Local facilities are few and far between. Those that are available are generally at the bottom of these hills. It follows that, of necessity, these people are highly car-dependent.

This is one of the primary reasons that extreme congestion is not seen just on the N28. It is seen throughout the N28 corridor. Those who live with and negotiate that congestion every day are those most qualified to voice opinions on the proposed Carr’s Hill Interchange and associated works. I concur strongly with all of their concerns.

  

• Inadequate size of roundabout at Maryborough Ridge

One key element of the Carr’s Hill Interchange proposals is the closure of the Mount Oval and Maryborough Hill slip roads. The Cork National Roads Office advises us that these slip roads are not to motorway standard. It is proposed that the thousands of commuters who use these roads every day will instead use the new Carr’s Hill Interchange. This means that Mount Oval residents would come out of Mount Oval, turn right, go up Garryduff and turn right down onto the new roundabout at Maryborough Ridge. Maryborough Hill residents would come up the hill to use the Maryborough Ridge roundabout. Carrigaline, Passage West and Monkstown residents who currently travel up Moneygourney to access the Maryborough Hill slip road would use the Maryborough Ridge roundabout instead. Many Douglas residents choose not to sit in the congested mess that is Douglas village traffic every morning and access the N40 by the Maryborough Hill slip road. It is simply not possible for the roundabout at Maryborough Ridge to accommodate this level of commuting traffic at peak. The roundabout is too small. It was not designed for this. The approach roads are too narrow. Neither the roundabout nor Maryborough Hill will ever accommodate more than one lane of traffic. The Carr’s Hill Interchange proposal falls at this very first hurdle. The Maryborough Ridge roundabout and its approach roads are too small.

 

• Unacceptable volume of traffic through Maryborough Ridge

To drive all this traffic through Maryborough Ridge is extremely unfair. Maryborough Ridge is a residential estate. It was always planned that a distributor road connecting Maryborough Hill to the N28 would run through it. But even the proposal for that distributor road generated concern when the development was at planning stage:

“The proposed through road will become a link road serving the N28 and will result in large volumes of traffic travelling through a built up area at high speed ad will cause segregation of the overall estate into the future. Also such a proposal endangers users of the open green areas adjoining and pedestrians wishing to cross the through road.”

These were the comments of the Assistant Area Engineer of Cork County Council in April, 2004 when the construction of Maryborough Ridge was being considered by Cork County Council. These were concerns expressed about envisaged local commuter traffic even when there were other existing local alternatives by which the local traffic could access the N28. It is incomparable to what is proposed now by the Cork National Roads Design Office. The levels of risk to residents, noise and air pollution are incomparable. It is entirely unsustainable to propose bringing this level of traffic through a residential estate.

 

• Closure of the Mount Oval slip road is unacceptable

The proposed closure of the Mount Oval slip road is unacceptable. The reason it is unacceptable is simple: the development of 800 houses at Mount Oval would not have been approved by the planning authority without the existence of that slip road. The road through Foxwood was always intended as a distributor road to the N28 and was shown as such in a 1999 variation of the 1996 County Development Plan. This variation was prompted by the Bacon Report. It signalled an acceptance of higher density development for suitable sites and made specific proposals for improved road access to lands that were accepting higher density development. The Mount Oval development was considered to be one such parcel of land.

In his comments in February 2000 on the planning application for Mount Oval, the Chief Planning Officer of Cork County Council said that: “This spine of distributor roads will facilitate traffic movement in the area with the off-ramp access from Sli Charrig Dhonn providing an alternative to the local road network. The connection through Foxwood … comprises an integral part of the original estate layout – the section of road through Foxwood has no frontage development and has obviously been designed to link into the spine/distributor road system.”

The use of the word “integral” is highly relevant.

It was again reflected in the comments of the An Bord Pleanala planning inspector: “The construction of the spine road, while it will facilitate traffic management in the wider area, is an essential element of this development…”.

The planning application for high density development in Mount Oval would have been looked at in an entirely different light were the spine road with off-ramp access to the N28 not available. This is because it was widely acknowledged by developers and both planning authorities that the local roads were in need of essential upgrading. It is 16 years since the first major planning application for Mount Oval was lodged. In all this time, with the exception of the short stretch from Garryduff to Maryborough Hill those local roads have not been upgraded in any way. But traffic has increased significantly in that time. So dependence on the Mount Oval slip road is greater than was ever envisaged. Frankly, the Roads Design Office has no authority to propose closure of a road that was deemed essential to permitting high density development. It would be far more appropriate were the plans for the upgrading of the N28 to incorporate proposals to develop the long-promised on-ramp to Mount Oval rather than to eliminate the existing essential off-ramp.

 

• Congestion and inadequacy of local roads around Mount Oval

Because the roundabout at Maryborough Ridge would suffer intolerable congestion and because the journey to that roundabout would increase commuting trips by several kilometres, it is inevitable that local traffic would divert to the Rochestown Road. Mount Oval residents will come down Clarke’s Hill or Coach Hill to access the N28 via the on-ramp at the Rochestown roundabout.

The R610 is already massively congested. In his frustration, one resident of Passage West videoed and timed his movement along the R610 in the morning peak. Typically, it took him 7 minutes to travel 900 metres. Delays are caused largely by the pinch point that is the Rochestown roundabout. Cork County Council attempted to improve through-flow by providing an extra lane onto the roundabout west-bound. This helped ease congestion for a while but has shown no capacity to keep pace with car use generally. Tailbacks every morning stretch from the Rochestown roundabout to Hop Island. The R610 cannot accommodate more traffic. Drivers of cars on the R610 always co-operate with traffic from Clarke’s Hill attempting to join the Rochestown roundabout queue. But to expect cars waiting at the bottom of Clarke’s Hill to turn right through that westbound stream of traffic without any visibility of what is coming on the eastbound lane is utterly unreasonable.

 

• Inadequacy of right-hand turning lane at the bottom of Clarke’s Hill

It is equally unreasonable to offer a right-hand turning lane at the bottom of Clarke’s Hill as a solution to the increased number of cars that would leave the N28 at the Rochestown road off-ramp. It would be insufficient. This right-hand turning lane is needed already to ease the tailback in the evening peak to and through the Rochestown roundabout. This congestion in turn creates a tailback on the N28 off-ramp. It is not right that provision of this essential right-hand turning lane should be considered only in the context of the N28 upgrade.

 

There are additional issues for cars attempting to leave the N28 off-ramp to get onto the Rochestown roundabout. Visibility is appalling. It is impossible to see traffic coming from the Douglas direction until it comes past the bridge supports. If increased commuter traffic were to use the Rochestown off-ramp in an attempt to avoid the longer route associated with the proposed Carr’s Hill Interchange, it would be essential to improve visibility and safety at this location.

 

• Clarke’s Hill and Coach Hill cannot accommodate additional traffic

Clarke’s Hill and Coach Hill cannot safely and sustainably their existing volume of traffic. This has not been acknowledged in any part of the proposals by the National Roads Design Office. In fact, Coach Hill has not even been mentioned. At present, Clarke’s Hill is so narrow that a bus and car cannot pass simultaneously at the bend at the top. The pinch point in the middle of Coach Hill is sufficiently wide for only one lane of traffic. Visibility at the bottom of Coach Hill is appalling, particularly for right-hand turning traffic. It is not a panacea to say that upgrades for both Clarke’s Hill and Coach Hill are at design stage. Upgrading of these roads has been planned since Mount Oval was granted planning permission. In the intervening 16 years, it still has not happened.

 

• Increase in noise pollution

What about the residents of Wainsfort, Newlyn Vale and all those who already have heavy traffic in their back gardens? All those whose exposure to noise already keeps them awake at night? Many of these are people for whom an existing tolerable situation was made far worse by TII’s recent destruction of trees along the Bloomfield Interchange and N40. The National Roads Design Office proposals do not contain one reference to existing noise levels currently endured by adjacent residents. That these noise levels will be intensely augmented by the volume and nature of traffic proposed for the M28 is a fundamental consideration. It is not a defence to say that the project is simply at route selection stage; that these issues will be assessed as part of the Environmental Impact Statement for the overall project. These are issues about which people have tremendous concern. Yet when one resident of Wainsfort asked at the public briefing about proposals to provide noise screening to his property as part of the overall upgrading project, he understood from an RPS representative that the Wainsfort section of the N28 may be regarded as existing development rather than a new development and may therefore not even be subject to assessment as part of the Environmental Impact Statement. This is entirely unacceptable.

The proposed leading of all N28-bound local traffic through Maryborough Ridge would also create significant noise pollution for the residents of this estate. Again, it is not adequate to propose noise barriers along either side of the distributor road through the estate. Noise barriers have an unpleasant visual aspect and would cut residents on the south side of the road off from neighbours, play areas and facilities in the northern part of the estate.

 

• Increase in air pollution

The M28 is to carry a significantly higher proportion of heavy vehicles than the existing N28. Port of Cork figures indicate that by 2033, there will be an overall increase of over 3,350 HGVs travelling to and from the Ringaskiddy port facilities each day. That excludes either further port or industrial development in Ringaskiddy.

 

Air pollutants from cars and trucks are found in higher concentrations near major roads. People who live, work or attend school near major roads have increased incidence and severity of asthma, cardiovascular disease, impaired lung development in children, pre-term and low-birthweight infants, childhood leukemia and premature death. Particles largely generated by diesel exhausts have been shown by recent research carried out in the Netherlands to cause problems at levels well below those stipulated in current EU air-quality directives. It found that for every increase of 5 µg/m³ in annual exposure to PM_2.5, the risk of death for men rises by 7%.

Yet yet this proposal for the Carr’s Hill Interchange involves accommodating a massively increased number of HGVs on a road running particularly close to residential housing in Rochestown. It plans to concentrate all N28-bound local traffic through the Maryborough Ridge housing estate. The proposal from the National Roads Design Office does not even mention the new school campus to be provided for both primary and secondary school children in Maryborough Ridge. It is not acceptable that the risks from heavy traffic are not assimilated into the route selection stage of a proposal such as this. It is essential that the adverse effects of air pollution on vulnerable residents are minimised from the outset by good design. Only residual effects should be dealt with by mitigation.

 

 

• Proposal fails to comply with government policy

At the most fundamental of levels, this proposal for the Carr’s Hill Interchange is wrong. In 2009, the government produced an 11-year policy document for the future of transport in Ireland. This policy document, Smarter Travel: A New Transport Policy for Ireland, outlines the actions that must be achieved across all sectors in society to achieve defined goals towards reduced emissions from transport and modal shift.

Through this policy document, the government promises society that “individual and collective quality of life will be enhanced”. It commits to actions which will help to “reduce health risks and the incidence of accidents and fatalities”. Above all, the government pledges that “land use planning and the provision of transport infrastructure and services will be better integrated”.

Despite these commitments from government towards more sustainable transport, the key elements of the Carr’s Hill Interchange proposal are to:

• Eliminate two key local access ramps to the N28
• Replace the two key local access ramps with an interchange system comprising four roundabouts and a longer distance of several kilometres
• Attempt to force all local commuting traffic to the one point of access to the N28
• Bring all local commuting traffic through a residential estate.

The on-the-ground reality of these proposals would lead to:

• Traffic diverting to an already over-congested regional road in an attempt to avoid the unwieldy proposed interchange
• Increased levels of noise endured by a significantly larger number of residents
• Increased levels of air pollution endured by a significantly larger number of residents
• Increased traffic congestion on local roads causing increased commuting times, increased driver frustration and, in turn, increased emissions from crawling traffic.

Each one of these outcomes is contrary to the government’s policy as outlined in Smarter Travel. It is well understood that the purpose of TII is to provide national road infrastructure and services. But the N28 does not exist in a vacuum. There are 7,000 people working in Ringaskiddy. These people do not live on the N28. They must all make their way their way to work and school on regional and local roads connecting to the N28. If the provision of a faster, more efficient N28 impacts negatively on those regional and local roads, the only beneficiary will be HGVs travelling to and from the port. Longer travel times and more congestion impacts negatively on worker mentality, worker delivery and worker wellbeing.

TII would be justified in saying that regional and local roads are within the remit of the local authorities. But fundamentally, Smarter Travel commits to better integration of land use planning and the provision of transport infrastructure. The National Roads Design Office with its close links to both Cork County Council and TII would be in an ideal position to plan for an upgraded N28 whilst delivering improved options to daily commuters on an over-subscribed regional and local road network.

Sadly, the current proposals are diametrically opposed to the Smarter Travel aims and make a mockery of the TII mission statement: to “contribute to the quality of life for the people of Ireland and support the country’s economic growth”. Certainly, it is important to facilitate industry and the port. But industry cannot function without the people that are the power behind the economic growth that industry is designed to drive.

 

Conclusion

The Carr’s Hill Interchange proposals are unacceptable. They would increase congestion on roads that would result in longer journey times for local commuters, thereby wasting time, generating stress, increasing sick days, diminishing family life, diminishing leisure time, fostering obesity and adding to noise and air pollution in established residential environments.

If an interchange is required for the M28, then it needs to increase commuter options, not eliminate them.

Traffic between Ringaskiddy and Cork City does not have to move fast; it simply has to move. I can see little logic in encouraging HGVs to hurtle into the Bloomfield Interchange only to be halted by a one-lane loop onto the N40 eastbound. Far safer to control their speed from further out. Some residents have suggested that if the motorway were to finish before the Maryborough Hill on-ramp, it would allow retention of the Maryborough Hill and Mount Oval slip roads. This appears to be a sensible option. It would allow HGV and other Ringaskiddy-related traffic the benefits of the motorway whilst retaining existing commuter routes for local traffic.

This proposal provides a once in a lifetime opportunity to sort out several long-standing problems in the road network in and around the Bloomfield Interchange:

• Provision of the long planned Mount Oval on-ramp would reduce congestion on local roads and increase overall traffic efficiency for communities along the N28 corridor.
• At present, traffic coming from the city and attempting to come off the N40 at the Rochestown off-ramp has to cross merging traffic coming from Mahon and the Jack Lynch Tunnel. Considerations to improving the safety of this treacherous manoeuvring would be very welcome.
• As mentioned above, visibility at the bottom of the Rochestown off-ramp for traffic wanting to exit onto the R610 is very poor. This needs to be improved for increased safety.
• Drivers attempting to exit from the Rochestown Church direction endure intolerably long delays whilst giving priority to traffic coming from Douglas and from the N40. Those enduring these delays several times each day deserve consideration as part of this project.

Please be open to the feedback received from all those so concerned about this Carr’s Hill Interchange proposal. It is not the right solution. There are better solutions which will encompass a wider range of needs and which will deliver far greater overall better value for money and quality of life.

Yours faithfully,

_____________________________________________

Marcia D’Alton, B.E., M.Eng.Sc.
Independent Member, Cork County Council.

 

 

 

Senior Planner,
Planning Policy Unit,
Cork County Council,
Floor 13,
County Hall,
Cork.

8^th November 2015.

 

RE: Proposed Amendments to the Carrigaline Electoral Area Local Area Plan – Shannonpark Framework Masterplan

 

Sir,

In respect of Proposed Amendment No. 4 to the Carrigaline Electoral Area Local Area Plan which is to give effect to the Shannonpark Framework Masterplan, I appreciate the opportunity to make the following observations:

• There is a significant housing need both nationally and in County Cork. I recognise that Cork County Council has earmarked these lands at Shannonpark for a significant housing development to respond to that need.

• It would be a grave injustice to the future Shannonpark community if the quality of standards of housing quality or environment were to be in any way compromised in an attempt to respond to the urgency of this housing need.

• Although Shannonpark is legitimately regarded as situate on the outskirts of Carrigaline, existing poor road infrastructure and resultant significant traffic congestion will in reality distance the Shannonpark community from Carrigaline town centre. It is recognised that the recommendations of the Carrigaline Area Traffic and Transportation Plan are to improve that infrastructure. However, again reality is that this plan was drafted eight years ago. The road network between Shannonpark and Carrigaline has seen little real improvement in that time, whilst the volume of traffic using it has significantly increased.

• Bearing this infrastructural deficit in mind, it is vital that the new community being planned for Shannonpark in this Framework Masterplan would incorporate a range of housing types: from bigger homes for larger families to small one-bedroom bungalows for the older resident. The proposed neighbourhood centre concept is also welcome with a view to minimising short car trips.

• However, despite welcoming the neighbourhood centre concept, this Framework Masterplan must not lose sight of the CASP Update 2008 aims for Carrigaline as outlined in the Carrigaline Electoral Area Local Area Plan. It clearly states that the focus for Carrigaline is consolidation of the town centre. The Framework Masterplan outlines an aim for 1,000 additional houses on the outskirts of Carrigaline town and does not contribute in any real way to this aim.

• It is also fair to observe that although Paragraph 1.2.1 of the Carrigaline Electoral Area Local Area Plan clearly states the target growth for population in 2020 for Carrigaline to be 14,066, the Census of Population indicates the population of Carrigaline to have been 14,924 in 2011. So according to the latest Census, the 2020 population target for Carrigaline was already exceeded four years ago.

• Whilst the fact that the population aims for Carrigaline appear to have already been exceeded does not negate the need for additional housing in Metropolitan Cork, it highlights the absolute urgency with which current infrastructural deficits in Carrigaline must be addressed. It is essential that the Framework Masterplan would include targeted proposals to improve infrastructural links between Shannonpark and Carrigaline town centre.   The vague intentions of Paragraph 1.4.22 of the Proposed Amendment are by no means sufficient.

• I note Paragraph 1.4.18 of the Proposed Amendment states that the Transport Assessment on the Shannonpark lands identified that the provision of Phase 1a houses would not have a significant impact on prevailing traffic conditions. It would be good to know what the definition of “significant” in this context is. With a current westbound traffic queue of 99 vehicles at the Shannonpark roundabout and a queue of 17 vehicles southbound, it is difficult to appreciate how additional impact could be anything other than significant.

• The Cork County Development Plan 2014 has a clear aim of supporting the principal of independence for older people. Paragraph 5.7.6 advises that the particular needs of ageing people should be incorporated into the design, housing mix and location of new housing development. I would particularly like the Framework Masterplan to have a specific aim for a purpose-designed cluster of either sheltered housing or small, single storey dwellings for the elderly. The best location for such housing would be adjacent to the neighbourhood centre. There is a real deficit of sheltered housing for the elderly in County Cork.   Shannonpark would be the ideal place to start providing for this increasingly pressing need in our society.

• The Framework Masterplan proposes four pedestrian links between the Masterplan lands and the adjacent Heronswood estate. Whilst I recognise that Cork County Council is attempting to increase permeability and thereby reduce the need for private car use, the on-the-ground reality is that this proposal will not work. We have repeated evidence that either permitted or accidental access between estates simply creates rat-runs for anti-social behaviour. Many estates in Cork City are attempting to block off such access at significant financial cost. In the case of Shannonpark, planned linkages between the new estate and the existing Heronswood estate would simply serve to create a massive 2,000 house estate. Not merely would this facilitate anti-social behaviour, it would make parental control of smaller children very difficult. Furthermore, several of the pedestrian links suggested in the Framework Masterplan would run through front gardens of residences in Heronswood. I ask that the Framework Masterplan would exclude these four proposed pedestrian links. This would be reflective of the ethos of Paragraph 3.3.1 of the County Development Plan which recognises that the creation of sustainable communities extends beyond the physical environment to “less tangible issues such as people’s perception of what constitutes an attractive and secure environment”.

• The proposed continuation of the walkway/cycleway along the old railway line through the Masterplan lands and on through Heronswood is a policy that would want separate and careful consideration before statutory inclusion in the Masterplan. Is it fair to bring leisure cyclists and commuter cyclists through residential areas? Would this proposal increase burglaries in the residential areas by providing a quick get-away? Would this proposal increase anti-social behaviour linkages between residential areas? Such issues need serious thought. In principle, I very strongly support the continuation of the walkway/cycleway along the old railway line in all directions. However, none of our Greenway development to date has led users through existing residential housing estates.

• I am very disappointed with the limited scale of the transport interchange proposed in the Framework Masterplan. I am also very disappointed at the public’s inability to contribute its opinion to the possible scale of this transport interchange. Astra Construction indicated at its public information session on Friday last that Cork County Council has indicated it requires 50 car parking spaces to be provided with this phase of the transport interchange.   This is very small. According to the last Census of Population, over 5,000 people travelling to school, work or college currently do so by private car. Fifty car parking spaces will provide no realistic alternative to the private car. In fact, 50 spaces is unlikely to be sufficient to even provide a realistic business opportunity to a private operator offering routes other than those offered by Bus Eireann. If the Framework Masterplan is going to advocate for a transport interchange, then let it be adequately large to give realistic indication of the feasibility of the longer-term larger facility planned for the western side of the R611.

• I have extreme concerns about the link road which the Framework Masterplan proposes should run east-west through the Masterplan lands:

  1.  The link road will serve not just residents of the new housing but also commuters heading for Ringaskiddy who wish to short-cut tailbacks on the Shannonpark roundabout. It will therefore be used as a link road serving the N28, at least until the N28 upgrade is in place. This would potentially result in large volumes of traffic travelling through a built up area at high speed.

  2.  This nature of road would segregate the overall estate into the future.

  3.  The proposed link road would endanger users of the open green areas adjoining and pedestrians wishing to cross it. Children living on the north side of the estate will want to cross to use the neighbourhood centre. No ramps or signalised crossing points are proposed in the Framework Masterplan. Carriageway widths are relatively wide and no traffic calming details at all are specified in the Framework Masterplan.

  4.  In speaking to Astra Construction at their public information evening, the architects indicated that County Council traffic calming for this link road is to comprise consideration of camber and a hedge between both carriageways. This will NOT work as a traffic calming measure. In fact, if a hedge is planted between the two carriageways it runs the risk of increasing rather than decreasing danger to crossing children.

  5.  This link road should benefit the residents of the estate rather than serve as a relief road for others.

  6.  This proposed road would link the R611 and the Fernhill Road. The Framework Masterplan acknowledges that the Fernhill Road needs upgrading. But in reality, Ballyhemiken Bridge on the Rock Road is listed on the National Inventory of Architectural Heritage as being of regional importance. It would be destroyed if it were to be widened and so it will never safely accommodate more than one lane of traffic. We need to be cognizant of how much traffic it is safe to deliberately lead onto the Fernhill Road because of the restriction at Ballyhemiken Bridge.

• I ask that the Framework Masterplan would require ramps for traffic calming throughout the proposed Shannonpark residential development.

• Two high voltage lines currently run through the Masterplan lands. Hundreds of international studies have proven that proximity to the electromagnetic fields from high voltage lines can interfere with sleep cycles, increase stress levels, damage your immune system and cause a range of cancers and other health problems:

  Children living within 650 feet of power lines had a 70% greater risk for leukemia than children living 2,000 feet away or more.  (British Medical Journal, June 2005)

  Several studies have identified occupational exposure to extremely low-frequency electromagnetic fields as a potential risk factor for neurodegenerative disease.  (Epidemiology, July 14 (4), 2003)

  There is strong prospective evidence that prenatal maximum magnetic field exposure above a certain level may be associated with miscarriage risk.  (Epidemiology, Jan 13 (1), 2002)

  In a study of 850 lymphoma, leukemia and related conditions, researchers from the University of Tasmania and Britain’s Bristol University found that living for a prolonged period near high-voltage power lines increased the risk for these conditions later in life.  (Internal Medicine Journal, 2007)

  Electromagnetic fields are responsible for an increase in childhood leukemia, adult brain cancer, Lou Gehrig’s disease and miscarriage.  (California Department of Health, 2002)

• Paragraph 10.2.1 of the Strategic Environmental Assessment mentions the high voltage lines that run east to west across the Masterplan lands. But the Framework Masterplan does not mention their existence even once, nor the need to move them if the lands at Shannonpark are to be developed for residential purposes. This is despite the fact that Paragraph 1.4.11 of the Framework Masterplan specifically states that the “results from the SEA process were fully considered and integrated into the preparation of the Masterplan”. Concerns about the high voltage lines were NOT included in the Framework Masterplan. The need to move these high voltage lines is absolutely essential for protection of human health and needs to be thus stated in the Framework Masterplan.

• At the Astra Construction public information evening, the proposed site layout drawings showed the lower of the two high voltage lines running roughly along the east-west link road, with the larger high voltage line relocated to run in the rough ground between the Masterplan lands and the M28. Yet at several points that larger high voltage line, even though relocated, runs along the back garden of houses in the north west corner of Phase 1 of the Masterplan. This is unacceptably close to these houses. Minimum distances for human health between the high voltage lines and residential homes need to be specified in the Framework Masterplan.

• House at the northern end of the Masterplan site would be those closest to the new M28. These will be susceptible to heavy traffic both visually and audially. It is essential that the Framework Masterplan would incorporate an aim towards mitigating against overlooking and traffic noise for people living in these houses.

Yours faithfully,

Marcia D’Alton
Independent Member, Cork County Council

“That the State would acknowledge its responsibility to people who in attempting to buy their own homes, now find themselves with hazardous properties not constructed in compliance with the building regulations.

And that Cork County Council asks the Department of Environment, Community & Local Government to move away from the current system of self-regulation in the design and construction of buildings and to replace it with an independent Approved Inspector system similar to that operating in the UK.”

 

“The presence of the wall linings with their low surface spread of flame rating played a major part in the disaster. Had the express requirements of the Draft Building Regulations in relation to both these matters been enforced and observed, the consequences of the disaster might have been significantly diminished.” These were the words of Batt O’Keeffe, TD in the Seanad in 1990. He was speaking about the Stardust fire in 1981 and he and other members of the Seanad were debating the new building control laws that were being introduced.

Essentially, those building regulations gave us:

• Priory Hall in Donaghmede, Dublin. A 189 apartment unit in which the fire risk and shoddy workmanship is so great that the current estimate of its remediation is €30m
• The Elm Park office and apartment complex on Dublin’s Merrion Road, comprising 218 apartments and enough office space for 3,500 workers on which NAMA had to spend millions to remedy fire safety risks
• Belmayne, Balgriffin. The largest boom-time residential development on the North side of Dublin in which 300 of the 960 units were shown to need extensive repair work due to fire safety problems
• Longboat Quay in the heart of the Dublin Docklands. A 298 apartment unit in which the fire risks have recently been identified as so extensive that the residents are to be evacuated.
• Hillcrest, Pembroke Wood, Passage West where I live. My family has spent the last 10 years remedying the effects of shoddy building. The low point was discovering an empty roast chicken bag used as a draught stopper behind a skirting in the hall. The culmination was the reconstruction of the external balcony this summer at a cost of €5,000.

Under the acclaimed new regulations introduced in 1990, the system of building certification that was approved in Ireland was the “Opinion on Compliance” system, commonly known as self-certification. The designers and builders of projects, on their own responsibility, provided certificates of compliance with the building regulations. Within this system, there is a recognition that the primary responsibility for designing and construction of buildings rests with the industry itself.

Local authorities as the building control authorities were obliged by the Department of Environment, Heritage and Local Government to inspect 12 – 15% of new buildings for which valid commencement notices were received. So 85% of newly constructed homes were not required to be inspected. Even at that, most local authorities had no written procedures for inspection, no requirement to call to a building site more than once and if they visited at all, they had to take the builder’s word that construction materials were to standard and that behind completed walls and floors, wiring, plumbing and foundations were all up to scratch.

I am angry about this. Council officials were so stretched they could not keep up. They were, as ever, insufficiently resourced by government. The inadequacies of the 1990 building controls were highlighted in the Seanad before they were even passed into law. It was to take a series of evidenced catastrophies arising from those inadequacies before building controls were tightened by new laws in 2014.

The new system now requires an assigned certifier to oversee and sign off on each stage of the building in accordance with an inspection programme agreed prior to the start of development. In fact, the new system is so tight that 38 separate steps are involved in getting the appropriate permissions and permits in place for a simple warehouse.

Paper does not produce good buildings. We are still in a situation where a developer can employ his own assigned certifier for his own projects. We are still in a situation where the local authorities as the building control authorities will be inspecting only 15% of construction projects. And the new system is so onerous that experts believe it runs the risk of simply putting builders off building.

What is missing is a guarantee of ensured third party oversight and independent audit. The UK has had a simple Approved Inspector system in operation since the 1980s with 100% inspection of new builds. 100% inspection is also required in Northern Ireland, the United States and in many other countries across the EU. There is a reason Ireland is ranked 128^th out of 189 nations by the World Bank in respect of our construction process. The UK is ranked 17^th.

A history of inadequate legislation and inadequate enforcement is the key reason rogue builders have been allowed to build profits on the back of the innocent public who will be unearthing their legacy for many years to come. The State is entirely responsible for both the inadequate legislation and the inadequate enforcement. I ask that this Council would support me in calling for the State to take responsibility for this. I ask that this Council would support me in calling for the State to financially safeguard consumers who through no fault of their own are prisoners of a legacy left by rogue builders. And I ask that this Council would support me in asking that Ireland would introduce an Independent Inspector system with 100% inspection of construction projects similar to that operating in the UK for the past 30 years.