M28 Cork to Ringaskiddy Motorway Scheme,
Cork National Roads Office,
29th November, 2015.
RE: Proposed Carr’s Hill Interchange and associated works
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 PM2.5, 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.
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.
Marcia D’Alton, B.E., M.Eng.Sc.
Independent Member, Cork County Council.