15. Submission by Dr. Diarmuid O Grada for Dun Laoghaire Harbour Company

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ALEXANDRA B A m REDEVELOPMENT PROJECT

STRATEGIC INFRASTRUCTURE DEVELOPMENT APPLICATION (SECTION 37E APPLICATION)

REF.29N.PA0034; APPLICANT: DUBLIN PORT COMPANY

rlRIEF OF EVIDENCE

A SUBMISSION TO AN BORD PLEANALA ON BEHALF OF

DUN LAOGHAIRE HARBOUR COMPANY

DR DlARMUlD 0 G ~ D A FlPl

16 OCTOBER 2014

DR DlARMUlD 6 G ~ D A , PLANNING CONSULTANT

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1 CONTEXT This is a submission by Dun Laoghaire Harbour Company (DLHC). We are instructed that It

represents the views of the DCn hoghaire Cruise Stakeholder Group, the members of which

include DQn Laoghaire-Rathdown County CouncR and the Don Laoghaire Business

Improvement Group. In addmon, it takes account of An Bord Pteandla's guidance on

procedure. We note, in particular, how the 80ard states that it will take into account the details contained In those submissions already placed before It. In this additional submission

we wish to pay particular attention to those matters which the Board must assess under

Section 143 of the Planning and Development Act 2000, as amended. We atso note that the Board shall have regard to

(a) The policies and objectives for the time being of the Government, a State

authority, the Minister, planning authorities and any other body which Is a public

authority whose functions have, or may have, a bearing on the proper planning and sustainable development of cities, towns or other areas, whether urban or rural,

(b) The national interest and any effect the performance of the Board's functions may

have on issues of stmtqlc economic or socbl importance to the State, and

(c) The National Spatial Strategy and any regional planning guidelines for the time

being in force.

It is the intended new cruise ship berthing facitii at the North Wall Quay Extension that

causes the greatest concern for DLHC. It Is the case of DLHC that thls apptlmtlon must be

assessed In the context of the future development of Dublin Bay as a major cruise ship

destination. DP cannot meet the demand on its own. In order to achieve this major goal for

Dublin there must be a progressive and coordinated approach to the development of cruise ship berthing facilities. This will, in our view, need to take due account of the contribution of

DQn Laoghaire Harbour.

Dublin is a major international trafic centre and in dealing with its needs we should be aware of the sustainable solutions applied elsewhere. As a major international air traffic hub,

London is senred by several large alrports including Heathrow, Gatwick, Luton, Stansted and London City. Each of these caters for separate segments of the market and they compete

against each other, with a view to attracting the most suitable part of the passenger trade.

Some serve long-haul flights and others cater for short domestic-scale routes. For some of

the client airlines the Importance of low fares is paramount, with this in turn dictating their

airport choice, For others, access to the city centre Is a foremost consideration, with this in

turn moderating the size of aircraft and consequently demanding higher fares. Jointly,

Dl3 DIARMUID 6 GRADA, PLANNING CONSULTANT

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however, these constituent elements satisfy the demand of England's capitol clty, It is this

coordinated and sustainable approach that DLHC is seeking as an outcome of this SID

application. To achieve this sustainable outcome the role of Dhn Laqhaire must be adequately taken into account.

Dan Laaghaire can make a valuable contribution to the phasing of fh development of

Dublln Bays cruise ship traffic over the coming decades. This wntributlon Is regarded as

part of the scenario envisaged by the concept of the Cruise Dublin group previously mooted.

If permission was now forthcoming from An Bord PleanBla for the current propasal that

would still leave a very extended lead-in time at DP, with berths closed andlor out of action

for some years. Ddn Laoghaire would serve to flll thb vacuum. We Inviter the Board to find

that thls Is h e mrrect context for proper planning and sustainable development of Dublin

Bay.

Dublin city and county bendt greatly from tourism, and the strategy (quasi policy) of FFgilte

Ireland (Destination Dublh; A Collective Strategy For Tourism Growfh To 2020, 201 4)

sffpporfed by the four councils involved (and launched by Minister Leo Varadkar)

emphasises that there must be collaboration to secure the capital's overall tourlsm growth.

For the first time, this approach firmly astabllshas that In tourism terns that the Greater

Dublin Area specifically includes Don Laoq halre-Rathdown. Moreover, In the cruise tourfsm

context, it is now eshbllshed that Ddn Laoghaire will, next year, be the leading cruise call destination in Dublin Bay in terms of cruise passengers visiting Dublin.

Consequently, stakeholders must engage across the region, building up a sectoral approach. About 50,000 of the population depend on tourism, in whole or in part, for their

livelihood. Tourist spending in theatres, restaurants and public buses is very substantial and greatly enhances the everyday quality of life for ordinary citizens.

This tourism strategy (p.9) states that the annual number of ctuiss visitors to Dublin surpassed 100,000 for the first time last year. Cruise tourism is specIficaly mentioned for growth (p.10) and the strategy intends the establishment of a Cruise Dublin Forum that will

bring together all relevant stakeholders (p. 12). Some difficulties facing the plan are cited. For

example, it is noted (p.51) how the CSO does not count cruise tourists because they do not

stay ashore overnight. This needs to be urgenay corrected in order to place cruise traffic

closer to the heart of tourism policy.

Cruise tourism has been Identified as one of four categories offering the best potential for

growth in Dublln. Over the past decade the number of cruise passengers arriving in the

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capital has trebled (p.37). It is recognized (Appendix 05) that Dublin offers cruise ship

visitors great natural and infrastructural advantages and the potential for substantial future growth is emphasised. It is also recognised how the capltal has two ports sendng cruise

ships, i.e. DP and DOn Laoghalre, and while the former is well-established the latter is in the

early stage of development (p,49):

The new Dublin propasition wlll underpin the overall appeal of Dublln as a potential destination, whM wlll confribuie to demand by cruise passengers for Dublin and, ideally, tead to an eventual growth jn the number of ships cdling at Dublin and Diln Laoghairw. (p.60)

We note that the strategy promofed by the Grow Dublin Taskforce seeks to include all

stakeholders. In the document's introduction (p J) , the chairperson (Lucy McCaffrey) states

Assuming thaf the fine coiIaborafion evident in the wwk of the Grow Dublin Taskforce prevails Into fhe implementation phase, there is every cause fur optimism about a successful oufcoma,

We note from the website of the applicant that the chairperson of the Dublln Port Company

bears the name Lucy McCaffrey. We invite the B a r d to note this,

There is, in addition, a clear reason for this coordinated approach, arising from the need to

maximisa the use of the shrinking resources of DP kelf. Permission for a major extension of

DP, by reclamation of 21h, was refused in 2010. That decision has put great pressure on

the space now available for port activities, most obviously the freight exports and Imports,

Growing competition for spaw proves that the remaining resources need to be selectiwly

allocated. Moreover, the Dublin City Develapment Plan reveals how the port zoning allows

bad neighbour uses that might be considered incompatible with cruise ship traffic.

This interpretation of the proper planning and sustainable development of Dublin Bay

indicates that a substantial proportion of the cruise ship traffic would be better

accommodated in Don Laoghaire Harbour. An Bord Pleanfila is accordingly invited to find that the current project is premature, oversized and badly located, and thaf the cruise ship

element needs to be subsfantially reduced, i.e. with not more than 2 cruise berfhs Included. This point is put fonrvard in the context of module 6 of the Board's OH agenda, i.e. where

parties are afforded the opportunity to make submissions regarding conditions that might be

attached to the Board's decision.

DR BlARMUlD 6 G ~ D A , PLANNING CONSULTANT

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PLANNING HlSTORY In 1976, in a landmark decision, the Minister for Local Government refused planning

permission (ref.29/5123957) for the erection of storage and processing units for petroleum

products within the port area on a site east of the Pigeon House (8) Power Station. Amongst

the refusal reasons was the following,

The proposed development would be vjsually intrusive, obsfnrcf views across the bay and defracf from the open aspect of the bay and the amenity of Sandymounf Strand

This was a major decision for Dubtin Bay because it established how the planning code must

take a w u n t of the impact of such activities across the surrounding area. That wider context

of Dublin Bay must now be addressed again.

The main item of recent planning history was the application under Section 37E of the

Planning and Development Act 2000, as amended, for h e development of additional port facilities with access to deep water berths, off Afexandra Road Extension, Dublin 1 (ABP ref.

29N,PA0007). That proposal included reclamation of 21ha of foreshore within the port. Dublin City Council decided that such extensive reclamation was not justifred in light of the

remaining port lands that were either unused or underused. In 2810 permission for that

project was refused by An Bard PleanBla, essentially because of the potentially darnaglng

impact on the natural heritage of Dublin Bay (the proposed SPA).

That assessment by the City Council has notable implications for the currenf proposal. The

remaining land bank within the 27 zone has been put under greater pressure. Cruise ships of the scale and quantity now put foward would consume an exceseive proportion of that

remaining space. This finding should be considered in light of the more appropriate location

for cruise ship berths close by at DDirn Laoghaire.

The remarks of the Board's Inspector in that earlier case bear significantly on the

assessment of the proper planning and sustainable development of the area. He accepted

that capacity at Dublln Port was being gradually absorbed (p.221), and that demand could

exceed capacity for Lo-Lo and Ro-Fio by 2017 or 2018. Slnce then the pressure on capacity

has grown further and it will increase agajn as the current economic recovery proceeds.

The B-oard's inspector pointed to the possibility of DP occupying a monopoly position,

counter to government policy (p,223):

It is dMcuff not to conclude that the proposed development would diminish effective competition with other ports and give rrse to a monopoly ~~'tuation.

The inspector noted that Dublin City Council's support for continued development of the port

is subject to qualifications, favouring the relocation of the port, albeit as a long-term strategy

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(p.207). His assessment of the National Spatial Strategy context (p.225) pointed to the

capacity shortage. Options put forward were the relocation, in the medium to long term, of

some port activities and additional handling of more port business by other natbnally

strategic ports. According to the inspector (p.224) the Indecon report appeared to favour a new pert at Sremore over the proposed development of DP,

That inspector's report referred to the oral hearing submission made on behalf of DP (p.f28),

dealing with the trend of ports locating outside dties, 'where there is a more a~racflwe

location from an economic point of vjew, normally because room is constrained or reclamation is not feasible'. We invite the Board to find that the position described four years ago has now been reached.

That report by the Boards inspector recommended other reasons for refusal, induding the

implications of the proposal for balanced regional development and the need to avoid

monopollstic conditions. In overruling its inspector the Board noted, inter alia, the heavy

infrastruckrral investment already made to serve DP and how the National Spaual Strategy,

although commenting on the port capacity limitations and referring to possible alternative

development at other ports, did not advocate any specific limit on the development of DP.

We note that there has been a material change of clrcumsbnces since #at previous SID

case. In February 2013 It was announced by the Minister for the Environment that the

National Spatial Strategy was being scrapped and that it would be reptaced within a year. Therefore th8 NSS does not retain the significance it had when the previous decision of

20 1 0 was made.

In our opinion, these aspects of the planning history have not been adequately taken Into account. We are now highlighting them because we know how the Board is keen to have

due regard to all the earlier planning decisions that can inform tha proper planning and

sustainable development of the area concerned. We note, in particular, how the planning authority has addressed the matter at this hearing. It cited just one case, albeit the most

significant one (ref. 29N.PA0007).

We invite the Board to note how the City Council has drawn no conclusion from that

decision. It has, for example, failed to consider the consequences for the port, such as the

unesapable intensification of uses, and in further consequence, the pressure on the cruise berths in terms of actual space and tourist amenity.

DR DIARMUID 6 GRADA, PLANNING CONSULTANT

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3 DUBLIN CITY DEVELOPMENT PLAN

3.1 Zoning Objective The subject lands are included in zone Z? where the stated objective is 'To provide for the protection and creation of industria/ uses and faci!jtafe opportunities for employment creation'. Section 15,10.7 of the Plan acknowledges that the primary uses within the port

cause amenity loss that would not be tolerated elsewhere. This is a very significant

obsewation for the context of tourist traffic. If is highly unusual for a planning authority to

point out the damaging impact of this zone on other activities in the vicinity. The Council

admits the uses within the Z7zone

'. . .can unavoidably cause bad neighbour probhms due to the generation of dlsamenifies such as noise, smells and heavy gmds &&mc 8tC. Activities hciidde industry other than light industry, manufacfurfng repaits, open stomge, waste material treatment, and hnsporf operating services'.

Permissible uses in the ZP zone include chernicai prowssing and scrap yards. The port

contalns numerous potential major-accident hazards kvolving dangerous substances

(Seveso ll sites). There are thirteen of these properties on the north side, and three of them

are situated within 300m of Alexandra Basin East. It can be expected that DP will respond to

the growing pressure on its land bank by acquiring underused lands in private ownership.

INDUSTRIAL STREETSCAPE, DUBLIN PORT

Port views from the cruise ships would be over lands that are dull, dark and depressing. Only

half of those passengers disembarking at DP express satisfaction with its appearance. East

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Wall Road canies very heavy fraffic between East Link Bfldge and fhe port tunnel Cruise

passengers would emerge in the early morning, unfamiliar with the local left-hand driving

pattern. Moreover, this disembarkation would coincide with the city's peak hour movement,

generating a traffic hazard.

We respedfulty suggest there is now a need to pursue other options within Dublin Bay.

Cruise ships seek destinations with admirable surroundings for the sightseers. This expectation would be better met by Dan Laoghaire than by DP. Moreover, the applicant has

acknowledged that DP is a large industrial estate (Dublin Port Masterplan, p.80) and we

suggest that a congested industrial port is not the most suitable place for cruise vessels, Ddn Laoghaire Harbour offen a remarkable contrast. The place is much more welcoming,

offering a clean and pleasant berthing area for cruise ships. The applicant has already

conceded fiat it presents an appealing visual environment.

VIEW ON EAST PIER, DON LaOGHAtRE HARBOUR

i

Tourists arriving at O h boghaire find a fine modern passenger terminal with ample spare capacity. The seafront is gaining large civic/public buildings, thereby enhancing the visitor's

experience. Such bright sumrundings are an integral part of D6n Lawhaire's sustainable

tourism attraction.

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3.2 Strategic Context Map K of the City Development Plan ('Key Developing Area8 and Key District Centres')

promotes the Docklands as the largest of the key developfng areas. SectIon 4.4.4.1 of the

Plan identifies the Docklands as an area where substantial provision can be made far taller

buildings, allowing more sustainable densities supported by good public transport. The

Docklands Key Development Area is intended to accommodate almost 2,000 housing units

occupying over 200 ha (Tabie 3.2.3, 'Estimated Capacity of Key Developing Areas'), There have already been notable additions to the local infrastructure, most obviously the new LUAS line. We predict that interest in residential sites wilt Incrementally move eastwards,

building up pressure an the porh land bank, thereby forcing a reconsideration of whether port activities should be relocated 9lseWhwe.

Section 4.4.1.2 of the Plan rdects a wider vision for the port area then that expressed by the

applicant. The support of the City Council ernbrams the wider region and it keeps open the

option of 'relocation in the longer term',

We belteve that An Bord Pleanilfa will give due weighl to these wider considerations. The

alternatives include fhe possibilities offered by Dun Laleghaire, where fhe zoning is much more amenable, viz. the potential cruise ship berths at Dun Laoghaire are included in the W

zone (providing for waterfront development and harbour related uses).

4 NATIONAL PORTS POLICY 2013 The National Ports Policy is loosely formed. It deals sparingly with the detail expected from a

national policy, leaving the task of preparing harbour master-plans to the ports themselves.

Section 4.1 states the policy is not prescriptive regarding the specific location of future port

capacity. This vagueness Is a major weakness. It Is stated that the role of the NPP is

To establish a framework for setting out the Ijkely requirements in the future, to highlight the sfrategic Importance of providing for the continued development of the commercial port nehvork and Lo set out the bodies tasked with developing this additional capacity.

The priorities of the NPP are clear from the outset. Its first sentence states "In 2011, 72,057

vessels caving 45 miIIion tonnes called at 19 lrlsh ports." We note this priority attached to

cargo quantities and the document does not reveal how much weight was given to the

contribution made by passenger traffic (and cruise ship traffic). Section 2.3 makes it clear

that the classification of the national ports was prompted by the volume of commercial freight

vir . 'National Porfs Policy therefore categorizes those ports that handle commercial freght.. . '

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We have now established (per Maritime Transport Section, Department of Transport, 2"

April 201 4, personal communication) that the NPP's port classification was based solely on

the measurement of cargo traffic. It gave no weight to passenger traffic. It thereby ignored

the passenger traffic on which ports such as Don Laoghaire have established their reputations. This is a material consideration, raising further questions about the reliability of

the NPP. We would draw an analogy with a service such as postal deliveries, solely measuring its plans on the volume of letters and entirely overlooking parcels. It is a serious

omission and we invite the Board to find the NPP is incomplete,

We view the NPP as guidelines rather than a conventional plan. The document can be

interpreted more laosety than a statutory plan made under the planning code. It says wry

little about cruise ships. In Section 4.1 it states, almost as an afterthought:

In addition to the above, there are other emerging mpacl'fy requirements and opportunit/es in other areas, lnciuding cruise tourism and the &hwe energy market. In fhe cruise tuurism market, a number of jnifiatives are under way or under considwat'ion by different W s . National Po& Poljcy recognizes the potential afforded by this growing market and encourages those pods fa continue to work closely with relevant public and private stakeholders to ensure that the Indhrdual p o ~ s and the wider economy Benefit from the expected future growth h this sector.

No port is iderntfied for cruise tourism and this suggests that those ports wifh the best potential will be encouraged to proceed. Dan Laoghaire offers itself strongly in this regard.

Other points in the NPP have a bearing on the current proposal. It is emphasized how the

trend in global shipping is towards larger vessels requiring deepw water. The NPP foresees the need for significant additional unitized port capacity within GDA in the two decades

following 2020.

The NPP designated three Tier 1 Ports of National Significance Ports, i.e. Dublin Port

Company, the Port of Cork Company and Shannon Foynes Post Company. However, it

acknowledged that Irish pods wry considerably In their potential. We have established that

these designations are based on the volume of commarclal freight, taking no account of

passenger traffic votumes. There is nothing in the NPP #at debars Dun LaogRa1m from

aspiring to the rank of Tier 1.

There are two Tier 2 Ports of National Significance viz. the Port of Waterford and Rosslare

Europort. Dun Laoghaire has been inoluded in the category entitled Po& of Regional

Significance.

Categorbtion of ports Is inconsistent with the central aim of the NPP viz. 'The core objective [, ..] is to faciIitate a c o m p t M and effective market for marltime transport

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services.' This Is a broad all-embracing definition, and its significance Is put beyond doubt because It is repeated verbailm at Section 2.3.1. Maritime transport embraces much more than commercial freight, and its constituent elements have very different requirements in terms of access and infrastructure. We invite the Board to find that some of these elements

wuld be incompatible in certain circumshnces, a point that is central to our submission.

Notwithstanding its shortcomings, the NPP has pointed to the future role of Dun hoghaire Harbour in the marine, leisure and tourism sectors. Dun Laoghaire's tourism role uniquely

marks it out. Section 2.3.1 points out how cornpetltion between ports can be limited due to

goographtwl location and it refers to the consequences regarding access to major shipping

routes and domestic marketplaces. DlSn Laoghaire is better placed to allay environmental

concerns. Its scenic location is amenable and this situation conveys other benefits.

The NPP anticipates largsr vessels, together with deeper berthing facilities. These are issues that Dun Laoghdre is well placed to cater for. DLHC is encouraged by the provision

('Ports Policy and the Pianning and Development Systsm') where Ft is stated 'The provision

of adequate and efficient capacw into the future remain a crucial strategic objective;

however, pmk policy is nof prescriptive as regards the location of future port capacity.. .'

The NPP emphasizes the potential impact of port activity on ssnsit'we ecosystems and this is

certainly an area where D h Laoghaire is a preferable location. R would r e d m the pressure

on scarce resources, something that has already prompted consideration of unwelcome reclamation wifhin environmentally sensitive parts of Dublin Bay.

It is proposed by the EU that the Greater Dubtin Area Ports Cluster be included in the Trans

European Network-Transport (TEN-T) as a cure port. This ports cluster of the GDA

embraces the existing ports as well as any future port facilities developed up to 2050.

It could be argued that the NPP is inconsistent with the EU's pollcy which uses a wider

definition of the ports cluster within the GDA. This is conceded where the NPP states

'However Nafional Po& Policy categorizes onIy Dublln Pod Company as a Port of National

Signiflance (Tier I ) with the Greater Dublin Area.'

5 LOCAL AREA PLAN FOR CRUISE TRAFFIC AND URBAN REGENERATION

This tAP is a non-statutory plan. It is not included in Appendix I of the Dublin City

Development Plan which tlsts those plans used by the Council for development management

purposes. It is not of material significance.

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DUBLIN PORT COMPANY MASTERPLAN 2012-2040

The main thrust of this non-statutory master-plan is that cruise ships can generate income

but that the associated infrastructure Is too costly for the port company to provide on its own.

It acknowledges that the cost of the cruise ship facilities would reach about €30 million (p.321, including the cost of new quay walls, dredging, relocating underwater ESB cables,

relocating existing Ro-Ro facilities etc. Many of those costs woutd be avoided by location in D6n Laog haire.

As a result of h is heavy cost it is conceded there would be a relianm on a partnership that

would see Dublin City Council, the Department of Transport or Fdilte Ireland coming foward

with supporting finance. It is accepted also that considerable pressure Is building up on the

port's land bank and that this concern relates especially to the unaccompanied ReRo traffic, a use that could require 24.4ha by 2040 (p.31). Likewise, It Is accepted that an additional

4.5ha would be needed for accompanied Ro-Ro traffic. The challenge to provide lands for

unaccompanied Ro-Ro traffic is increased by the use-specific need for praximity to

dedicated berths. This competition for berths will grow as ships get larger (p.60). This raises

the distinct possibility of further pressure buijding up for very undesirable reclamation

projects:

On the basis of current land usage and in light of the Eoss of some Ra-Ro capaclfy if fhe proposed cruise berths are built on North Quay Extension, some element of new land (reclamation) may be required over the period of the Masferplan fo meet demand. (p.3 I )

This admission is at odds with the earlier part of the master-plan which envisaged h e port

developing in a series of 'bite sized' project investments that wouId restrict the financial risk

for the company. This current proposal could not be described as bite-sized. It also reveals

the excessive intrusion that would be caused by the intended crulse ship berths. They would renew requests for reclamation that would be both undesirable and Inappropriate. The

decision in the previous application ref.29N.0007 is very relevant in that context. As a result

of the reclamation option having been cut off the master-plan should have been revised.

Since that did not happen its value must be questioned.

In light of these admissions we invite the Board to question the scale of the cruise ship

element of the application. The land use mismatch within DP would be avoided in Ddn

Laoghaire. It is stated (p.32) that three alternative locations were considered for the cruise

ship terminal but it is not revealed whether Ddn Laoghaire was on that list.

It is acknowledged in the master-plan (p.49) that cruise ships would not make a significant

contribution to DP's revenue. Rather is the attraction related to what these $hips would bring

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I

to the Dublin region. The cruise ship business generates €50 million for the lo71 community

but the direct revenue to the pork company is only €0.7 million (p.32). Thus, thb port

b company gets little more than 1% of the return, despite all the drawbacks and. e problems

far other traffic. This is a consideration that works in favour of an increased apbortionment in Dun Laoghaire's benefit.

The integration of the port with the city Is put forward as a core point of the master-plan (p.70). Thk aspiration of building wnn~cliv&y with the dty 1s admirable but it is also exaggerated. An excessiw proportion of DP is out of bounds for safetylsecurity reasons and

the presence of so many Seveso II sites is a condderation in this regard. As the

intansificaman envisaged by the master-plan progresses it will tend to raise more barriers to

public access. We acknowledge that this is an issue in many ports but them are clear

benefits at DOn Laoghaire in being frge of those bad nelghbour or hazardous sites. This is a

consideration that favoum D13n Laoghaim's casa for gaining a higher proportion of the cruise

ship services within Dublin Bay.

7 DUN LAOGHAIRE-WHDQWN DEVELOPMENT PLAN 2010- 201 6

The County Development PIan for DQn Laoghaire-Rathdown makes provision for the

continued development of Don Laoghaire Harbour. It states that this development will be

balanced to take account of the constituent elements that make use of the harbour facilities.

Special Local Objective no.13 slates, inter alia,

To hcilifate the continued development offhe Harbour in accordance wfitt a herbour maderplan to be prepared by Dun Laoghaire Harbour Board in close conjunction with the Pianning Aufhohfy.

The details of the Harbour Company's strategy are laid out in its current master-plan, as

described below,

8.1 DQn Laoghaire Harbour Masterplan This master-plan was prepared by the DLHC. It is a non-statutory plan that has due regard

to the Dun hoghaire-Rathdown County Development Plan 2010-2016. This function of the

County PIan is cited in Special Local Objective no. 13 where it is stated, infer alia,

DR DlARMUID 0 G ~ D A , PLANNING CONSULTANT

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To faciIii8fe the mnfinued dewlopmenf of the Harbour in accordance with a harbour ma@rp!an to be ppamd by Dun Laoghajre Hahour Board in close conjunction wltR the Phnning Authonfy.

Amongst the Strategic Objectives of the DGn Laoghaim Harbour Masterplan is the following

(no.5):

Accommodate cruise liner faciiifies, having regard to the needs of other harbour business users, potenfia! environmental impacts and the hasibildy of providing such facilities.

Specific Objective n0.3 is to ensure the development and safe operation of the harbour and to provide such facilities, ssnrices, accommodation for ships, goods, passengers and main

leisure activities. Specific Objective no,W promotes Dbn Laoghaire Harbour as a major

marine leisure facility and a destination for tourism and recreation.

There is provision in the Harbour Plan (pp.102/103) for a potential cruise ship berth. It is

shown centrally located with direct access to the harbour mouth.

GENERAL VIEW, DON LAOGHAf RE HARBOUR

8.2 Dun Laaghaire Harbour Cruise Berth

DLHC is cumntly developing its plans for a dedicated wise berth within the Harbour and

we understand that it will shortly be submitting an application to An Bord PleanBla under Section 37 of the Planning and Development Act 2000, as amended.

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The DLHC proposal is for the provision of a new herth springing northwards from the existing

underutilised marshalling area for the HS5 few. This berth is designed to accommodate

cntise shlps up to 340m in length. The development will include the deepening of the harbour loalty at the neur berth and extending a channel northwards through the mouth of

the harbour, to a turning circle located 400m north of the harbour entrance and 500m in

diameter. A new channel will: extend from the turning circle, heading due east, to deep water,

It is intended that the channel and turning circ3le will be dredged to -90.5rn Chart Datum,

permitting access to the berth far large cruise ships at all stages of the tidal cycle. Due to the

proximity of Dun Laoghaire I-larbur to deep water, the length of the approach channei that is required from deep wakT to b e proposed turning circle is approximately 1 km, and the

total volume of dredging, both within and outside the harbour, is approximately 700,000m3,

or 10% of the total volume of dredging required to provide the slightly lesser channel depth

of -1OmCD proposed at DP. We invite the Board to find that Dhn Laoghaire's cruise ship

facility recommends itself on account of the much lighter Impact I will have on the

environment, compared to DP.

The Dun Laoghaire Harbour cruise facility will make use of the cwrently under-utilised feny marshalling area at the harbour for cruise remption fadlitias and for wach, taxi and ather

transportation offerings. We note that, at this oral hearing, Dublin City Councll has expressed concern at the absence of a terminal building at Dublin port. Pedestrian routes will atso be

provided to afford direct access to the Dun Laoghaire DART Station, ihe adjacent Dublin Bus

terminal and to Dun Laoghaire town centre.

Sirnulatlan studies have been undertaken to test access to the berth under varying

environmental conditions. These studies have confirmed a very high bveJ of availability at

the berth and approach channels, even under onerous cross winds and currents. The provision of a generous turning circle, oufside the harbour mouth, with open water all

around, is a significant positive In this regard.

The Dun Laoghaire Harbour proposal does not affect access to the existing berths in the

Harbour, nor will cruise ship schedules be negatively impacted by clashes with other

commercial trafFic mavements on entering or leaving the harbour. We are informed that this

facility at Dan Laoghaire can be completed within two years, and this relatively short

construction phase places Dan Laoghaire in a very favourable position.

DR DIARMUID 6 G ~ D A , PLANNING CONSULTANT

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PLANNING CONSIDERATIONS

9.1 Tho Local Impact

Several aspects of the Environmental Impact Statement (EIS) have a bearing on the

proposal. Section 1-23 accepts that this project would cause major disruption to existing busfnesses as well as damaging the local economy. It is stated that major disruption in pod

activity would be phased, awlding major disruption of cargo traffic. It must therefore be

asked what would actually suffer this substantial interference and whether it would be the

passenger traffic. Disruption of the local area would be a substantial factor militating against the project. Dredging of Alexandra Basin would continue for at least six years and dredging

of the main river channel would go on much longer.

It must also be considered how a port blockage would pose a great economic threat to DP, much more so than at Don Laoghaire, and we should recall that this threat is avoidable. DQn

Lsoghaire Harbour's development can offer an alternative to crulse vessels accessing Dublin

city and its hinterland but cannot help with other traffic modes which must be accommodated

in Dublin port at all times into the future,

9.2 Statistics

Sectlon 7.1.4 ('Operational Phase Impacts') explains that 201 3's peak summer season saw,

on occasion, 23 cruise ships berthed in the port. There is no expectation of this number of

cruise ships in any one day but 'the number of days when 3-5 cruise ships are berthed are expected to increase.' It is projected (p.7-32) the number of cruise liners would increase from

87 (in 2013) to 160 (in 2040). However, the figure given here for 2013 (87) is at odds with

that in Section 8.7 where it is given as 900. This figure of I00 appears also in Table 8.7.1

(p.8-37). In Section 8,7 the number of cruise ship calls for 2013 is given at 83 (p.8-37); this figure is repeated in Figure 8.7.2 (p.8-38). We invite the Board to find that these statistics

need to be clarified,

Section 8.7 gives the cruise ship passenger total for 2013 as 108,324 and predicts this will

Increase to 342,665 by 2032.

9.3 The Roie of Ddn Laoghaire Harbour

Section 1.3.5 of the EIS states that DP stands aIone as a major attraction and that it is the

most attractive desiination for cruise vessels. Our client does accept this contention. The EtS

does concede, however, that Don Laoghaire could present an exception to this pattern of

DR DIARMUtD d GRADA, PLANNING CONSULTANT

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dominance and it is acknowledged that DIfn Laoghaire benefits from an appealing visual environment.

Dun Laoghafre b now established as the alternative cruise shlp part choioe within Dublin

Bay, albeit using tenders. Cruise companies with larger vessels (over 300m) have endorsed

Don Laoghaim. Already them are 20 cruise calls for 201 5 and 16 for 2016. DQn Laoghaire

will continue to be the only port of call for cruise ships over 300m for at tealst 8 years (taking

account of the DP dredging schedule). Moreover, DlSn Laoghaire could well have a berth in the short term to accept such cnrise caifs.

We ask the Board to give these points due weight. The applicant qualifies these positive

remarks on D ~ n laoghaim by stating the place is constrained by quayside dimensions and

the presence of pleasure craft. DLHC rejects this argument on the basis that a balanced and

viable scheme for the berthing of wuise ships has been devised for Don Laoghaire.

Moreover, DLHC has a timing advantage, with Its cruise facilrty available by 201 7, whereas

DP must wait until at least 2023.

WEW ON EAST PLER, DON LAOGHAtRE HAR8OUR

D M C has cornmidon& a study of the Dulolin Bay's potential mube M c . This study, by

DKM Economic Con~uUehts~ has examined the pattern for Copenhagan, which has a

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population of under 2 million (in the last census Dublin city and county had 1.2 million

people). Next year, Copenhagen is schaduled to host 275 cruise calls, with 500,000

passengers and over 200,000 crew. This is about t h r e ~ times what Dublin Bay expects, so it

reveals the potential that a coordinated approach could yield.

It is anticipated that DLHC's cruise facillty will be completed In 2047, when the projected

aggregate cruise calls could rise to 106 (1 59,915 passengers and 68,982 crew). By 2022,

these figures could rise to 132 calls, 198,479 passengers and 85,629 craw (presuming DP's

facility is operational). The projected figures fw 2048 are 439 calls, 768,592 passengers and 33 1 ,592 crew.

According to the applicant the cruise ship function envisaged for Don Laoghaire is €hat of a

. complementary role but this is not defined. We invite the Board to find that for tourists

arriving in Ireland, first impressions can be lasting impressions. In our opinion, this matter

has not been given due weight by the applicant.

110 CONCLUSIONS =

The applicant has conceded that DP is a large industrial estate with operations that carry

manageable risks to the safety of the public and to damage to the land and marine

environments. The proposed cruise ship berths would be placed at the innermost end of the

port. As a consequence this passenger traffic would be obliged to pass through a wide range

of unsightly industrial properties. This unwelcome experience would be exacerbated by the

near presence of so many Seveso I1 sites. Put simply, we do not bring guests into our homes

through the kitchen. They should not have to pass through the utility rooms and store rooms,

averting their gaze from untidy closets and gtory-holes. These functions should not be

juxtaposed because they are incompatible wlth tourism. The proper plannlng and

sustainable development of the port require these functions to be separated.

There has been a material change in the planning context slnw the Board made its decision

on the previous SID application in 21310. As a result, the place of P6n Laoghaire in the

Dublin Bay cantext has to be brought to the fore. The National Development Plan expired

last year and it has not been replaced. In addition, the National Spatial Strategy has failed.

This failure has been conceded by the Minister for the Environment who undertook to review the NSS (within a year from March 2013). That new strategy has not appeared. We have

revealed signifimnt flaws in the National Ports Policy. These have caused DlSn Laoghaire to

be included in the wrong category of ports, It should have a higher rating.

DR DlARMUlD 0 GRADA, PLANNING CONSULTANT

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We invite the Board to find, in regard to this aspect 07 the background development

guidance, that Dublin City Counci! in its evidene to the oral hearing conceded that the nohble plans, including the National Development Plan, the National Spatial Strategy and

the National Ports Policy, are in notable disarray. We suggest that this is a significant finding

for the evaluation of this SiD application.

What emerges clearly is that the main itam of planning guidance is the Dublin City

Development Plan (the statutory plan). There is, moreover, inadequate cunformity with the

statutory plan in the current proposal. We invite the Board to find that the applicant's case

relies excessively on the non-statutory plans cited above. In addition, cruise calls represent a

mere 1 % of DP's turnover, so they should not allowed to put at risk other functions and traffic

that is more appropriately Iocated there.

CRUISE SHlP BERTH, DUBUN POFU

Dlln hoghaire must be accorded a higher status in the assessment of the expaneion of

wise ship faciliie~ in Dublin. This is a material consideration and in light of the various administrative shortwrnings permission for cruise ship bertRs In DP should be M c t g d . In

the Destination Dublin document c i W already it is stated (p-m)

The new Dublrh ~rnpositbn will unde~pin the overal appeal of Dublin as a pofenfi~l desthaflon, which wll conMbufe to demand by m'se passengers

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for Dublin and, idedly, lead to an eventual growth in the number of ships caillng at Dubtin and Dtin hoghaire.

Later in the same document it is stated (Appendix B5, p.54) that Dun hoghaire also offers 'potentid for declrelopmant as a w i s e port, and the two pws need to work together to make the most of what Dub/!n o m prospective cruise pagsengers'.

There are several reasons why this current proposal must be reduced in scale.

I Dlirn Laoghaire's position has not been adequately represented in the EIS and

discrepancies indude the predicted mise ship traffic, the number of vessels and the number

of passengers. DlSn Laughaire offers several significant advantages over DP, i.e.

Easier access to berths

Clean footprint

Passengers get an extra hour ashore

Environmental benefrts from reduced engineering works (much less dredging)

Shorter sea trip yields fuel savings for operators

Bright and lively surroundings far disembarking passengers

A much more rapid lead-in tlme (just hrvo years)

Moreover, travel times (ashore) to popular destinations (by car) are comparable for both DP and D h Laoghaim.

The dredging operations in DP would be undertaken over a period ranging between 6 years

and 10 years. Therefore the mise ship berthing element needs to take due account of the

contribution of Dun Laoghaire to Dublin Bay as a cruise ship destination.

2 Too much traffic would be concentrated within Alexandra Bash. Cruise ship manoeuvres would give dse to lengthy and costly disruption there. In the event of a cruise

ship having a mechanical breakdown in the main channel the economic repercussions woufd

be enormous, This consideration points to the advantages of Dun Lawhaire as the

alternative berthing place for cruise ships, sspeciaily the larger ones,

Arlshg from these concerns, and in the event that the Board decides to allow the proposal,

the Board is requested to include in its decision two conditions, respectively, altowing b o cruise ship berthing spaces only and restricting the length of the permitted cruise ships.

DR DIARMUID 0 GRADA, PLANNING CONSULTANT

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16. Submission by Stephen Reid for Irish Ferries and Stena Line

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Alexandra Basin Redevelopment - Dublin Port !?+when b i d Camuhfng

T&--

An Bord Plea ndla Reference: 29N,PA0034

Submission to Oral Hearing

on behalf of Irish Ferries and Stena Line

Stephen ~eid, Managing Director

Stephen Reid Consulting Traffic and Transportation Limited

Stephm Reid Cdnwking Trsfflc and Tamparmtion UmW unft a, wlawa Marih VIllage Maiahldle Ca OubUn ,,.

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Alexandra Basin Redevelopment - Dublin Port

1. Intduction I am Stephen Reid, Managing Dlmctar of Stephen Reid Consulting TraFnc and Transporntion Umlted. I am a civil and traffic engineer with almost twenty years post-graduate experience in consulting engineering, and have speciallsed in traffic engineering and transportation planning throughout this period.

I graduated in 1995 with a Bachelor of Engirreering (BEng Hons) Degree in Civil and Transportation Engineering h m Napier University, Edinburgh.

I have been based in Ireland since January 1999, managing the development planning, trafftc engineering and transportation aspects of numerous large scab and m p l e x projects for consulting pradw, including:

Dubln City (selected project experience) Spencer Dock Section 25 PJanning, North wall Quay, Dublin 1; Klmalnham Office and Residential Scheme, Inchicore Road, Dublin 8; Collins B a m h TraffIc Management Plan; Hammonds Sie, Sir John Rogerson's Quay, Dublin 2; Grand Canal Plannlng Scheme, Dublin 2; Momtwetro, Barrow Street, Dublin 4 {now Google Dock); Uarence Hotel Redevelopment, We1 tington Quay, Qu blin 2; Residential Development, Castteforbes Road, Dublln 1; Ptayers Square, SCR, Dublln 8 (former John Players factor/ and Bailey Gibson shes);

r Tara Street Station Redevel~pment, Oublin 2; ltAC Moore Mall, Moore Street, Dubln 1; Project Fhl l l lam - ESB Headquarters Redevelopment, Dublfn 2; Central h n k Development, North Wall Quay, Dublin 1; DuMln Metro North Construction Traffic Management Plan (for MetroExpres); Former &kills Printworks Redevelopment, East Wall Road, Dublin 1; Luas BXD (Luas GossCity) T-nical Peer Rwtew of LlNSJG Modelling.

Mher [selected project experience) Phoenlx Park Racecourse and Railway Station; Scotch Hall, Drogheda; W hitewatar, Newbridge; Ballymun Town Centre Redwelopment; Athlone Town Centre Redevelopment; Beacon South Quarter, Sandvford; BMG Co-Located Hospital CUH, Wilton, Cork; Beacon Women's and Children's Hospital, Sandyford; College Proteins CHP, Nobbler, (30 Meath; Water Street/Bar$s Yard Redevelopment, Cork; EirGrid Laols-Kilkenny Reinfomment Project (hduded outsize load route review from Duhlin Port to the MSO); Dun taoghaire Harbour Mastetplan; Greenbank Mixed Use Wdopment, N e w .

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Alexandra Basin Redevelopment - Dubfin Port Stephen Reid Consulting

TraHi: W R - ~ T r a r ~ ~ . r t a w ,

I am presenting this statement on behalf of Irish Ferries and Stena tine, who are both Third Party Observers in relation to the project.

In 2013 lrish Ferries transported 1,052,000 passengers, 210,500 car units, 4,580 motorcycles and 139,000 freight units through Dublin Port, while Stena Une transported 715,000 passengers, 174,000 car units and 186,000 freight units through Dublin Port.

It is submitted that as major maritime transport providers, operating Ro-Ro vessels which mwesigniflcant voluma of goods and passengers on routes between Dublin Port and the UK, my clients have a considerable and valld interest In the proper and sustainable development of Dublin Port.

It is therefore entirely reasonable that Dublin Port Company in their role as managers of the Port would ensure the continuing maintenance of good access for all port related traffic, both within the Port and its connections to the wider strategic road network.

It is on this basis that my clients have objected most strongly to the proposal made within the Environmental Impact Statement (EIS) at "Chapter 8: Material Assets - 8.1 Tmnspo~ion" (page &3) to close the "Alexandra Rocrd Access on Eost WQII Rood ta all operational troffic wlth the exception of access to DK's Hecrd mce (Port CentreJN.

~t the outset and for the benefit of all parties at this Oral Hearing 1 wish to clarify the foflowing timeline in relation to the submissions by lrish Ferries and Stena Une to An Bord Pleanala, the subsequent RPS report issued by DPC to Irish Ferries and Stena Une, and the response to this report issued to DPC by Irish Ferries and Stena Line.

7ih May 2014 -Third Party submissions to An Bord Pleanala Irish Ferries obsewation submission Stena Uns observation submission

18'" September 2014 - DPC contam Irish Fertjes advising further detailed analysis undertaken of Port road network to provide responses to concerns.

1 9 ~ September 2014 - DPC issue Irish Ferries a printed copy and soft copy of RPS report on a memory stick.

29* September 2014 - lrish Ferries and Stena Une joht response correspondence to DPC, Including mpy of Stephen Raid Consulting rwiew of RPS traffic report (dated 28.09.2014).

A copy of the Irish Ferries and Stena Line joint response and a copy of the Stephen Reid Consulting report have been appended to this statement. I do not intend to read my 28.09.2014 response mport in full as part of this presentation but I believe it is only fair and reasonable that this is available to provide balance and context to Ms Daly's witness statement, whlch includes a section 4.5.7 'responding' to hoth my response and the lrish Ferries cover letter of 29.09.2014

There have been some discussions duringthis Oml Hearing as to whether the proposed closure is ot is not part of the planning applimtion under cunslderation, and from my own experience ! would disagree with

Stephen Reid CdnsultFng Trdkshd ~~ L t a w3, ma^^^^ Wbm Makhide ca WIbh

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Alexandra Basin Redevelopment - Dublin Port Stephen Reid Consulting

T~aftK: 51 Trmy~lr ~ 1 0 ' 1

the view of Dubln City Council's Plandng Department that the omission of the closu~e from the planning application site notice is not of concern. The impact of this traffic management proposal should not be underplayed. It is submkted that the onus should not be with a Third Pam to read thmgh an EIS to flnd out about material changes of this scale and nature and it should have been contained in the n o t k in the first instance.

Also I note Ms Celine Daly of RPS chimed in her wkness statement to this Oral Hearing that "the closure of the section of Aiexundra Road to which Irish Ferries refer is not part ofthe ABR scheme" (4~34 refers). It is submitted that this statement completely conflicts with Its tncluslon In the EIS at Chapter 8.1, and the extensive modelling and traffic impatt exercises contained in Chapter 8 and Appendix 8 of the EIS (wherein it is not only included but is dearly denoted with a large blue X and an accompanying legend on each flow diagram Figure).

Looking at the exbthg usage of the Alexandra Road access, please note the following dally volumes on the three existing access polnts (the flows are the two-way summation of the figures in the ABR €15, Appendix 81 Daily T M ~ C Flows f2013) refers):

fable 1: Existing Two-Way Total Volumes (2013) and Percentage by Access (In vefiidas)

This shows that a slgniflcant volume (almost 23%) of the daily traffic entering or exiting the Port is currently using Alexandra Road.

Pemnwge of Total Using Aeeeds 70.1% 22S% 7.4%

100.00%

histing b s s Road Promenade Road Alexandra Road

Terminal 3 (P&O) Total

When comparing the inbound volumes only it is noted that the propartton using Alexandra Road is wen greater, as follows:

2013 Dally TrafRc Flow 12,976 4 , l e 1,376 18,517

I Total 8,675 I 100.0034 1 Table 2: Egisting Inbound Total Volumes (2013) and Percentage by Access (in vehicles)

Existing AeEerP Road Promenade Road Alexandra Road

Terminal 3 IP&Ol

It is therefore submitted that the Alexandra Raad access perfom an impomnt rote In sewing the access needs of the Port, carrying almost one-quarter of the daily traffic, and almost one-third of the daily Inbound tmffic.

Dublin Clty Council Identified to this Oral Hearing that they are promoting a traffic management strategy for Port vehicular access to be all loated to the northern access (tofirom Promenade Road) facilitating the closure of the Alexandra Road junction on East Wall Road, and the dosure of the P&O Terminal 3 access as part of the reiocation to the reconfigured and expanded Eastern Terminals. Mr Eoghan Madden of DCC noted that closure d the Terminal 3 left-in, left-out arxess on East Wall Road, and the remom! of

20U Inbound Daily TrafRc 5,235 2,757 683

Ptrcentage of Total Using Access 6U,3% 31.8% 7.W

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Alexandra Basin Redevelopment - Dublin Port Stephen Reid Consulting

Tr& a d T r w t o t l o n

the existing gate lnto the North Wall Quay would also facilitate the conversion of the existing roundabout a t the junction of North Wall Quay/East Wall ~oad/East Unk Bridge to a traftic signalled junction. It was WentjfiM by Mr Madden that the signall& T-junction would k deliverable In the next two years, independent of the ABR project. Mr Madden also noted that as the u-turn manoeuvre would no longer be passlble Hthe roundabout was cmverted to signak, In the, short term a fourth arm auld have been installed on the east side of East Wall Raad {opposite Sheriff Street) to connect lnto the Port and service the Terminal 3 lands, if the Terminal 3 access was clost?d as part of the proposed signal junction arrangements. However, he also noted that this fourth arm could be redundant (subject to the proposed Inkma1 canfiguration of roads or vehicular routs In the western area of the Pwt, which was presented in a small sale indicative layout plan In Ms Daly's wltness statement (p16, Figure 4 referr).

The net result of the Port access strategy put forward in the EtS and subsequent traffic report prepared by RPS is t~ "put all of the eggs in one bask&, and wtth no proposals to l m p m the a@ty of the Promenade Road route included in thee impact modelling repam, the concerns of Irish Ferries and Stena Lhe have not been addressed. It Is submitted that R k not proper planning and development of the Port to leave such fundamental issues unresolved.

Rerefore R ts submitted that any proposals to close a sealon of Atexandra Road for vehicular traffic between East Wal Road and the main Port area are antlrely premature until adequate caps* improvements are made to the northern access mute via Promenade Road, and therefore the objection of both Irish Ferries and Stena Llne remains firmly in place.

I have prepared a short response to each of the comments in Me Daly"s witness statement in regard to both the original Irish Fnrrksand Stena subrnisslons of my previous mlew document of 28.W.2014.

I I-: T@c orrignment to DuMIn Port Tunnel due ?o the clalosures of thi? accesses &lot@ East Wul/ Rosd. I I note that Ms Daly appean to have missed the point completely in her reading of the Irish Ferries \) submission and In her response to this. My clients and 1 have no issue with enmuraglhg as much traffic to . utfllse the Tunnel as can safely accommodate it, and dearly the maJority of traffic with destinations outside the M5Q Orbital can fall into this category, wlth the exception perhaps of traWic heading to the M11 and South Publn/Co Wicklow, & The point being made m the submissiuns for Irish Ferries and Stena Une was hat c-20% ofthe daily tmr: exitingthe Port accesses onwards mutes vb East Wall Road, and has yo dwtination that can be reasonably reached via the Tunnel (such as the East Unk bridge, Sheriff Street and North Wall Quay), and that by retaining thls access junction tofirurn Alexandra Road, these vehicl& do not unduly increase pressure on the Promenade Road access roads, aj they would still need to travel south on East Wall Road wen W Alexandra Road was dosed off.

1 also submtt, having rwlewed the hour by hour traffic fiows presented in the RPS September 2014 TFafffc Report, that the majority of the u-turners are actually generated by the Termlnal3 (P8rO) exit, and to a lesser extent trafflcsuch as taxis and wrs dropping &or picking up on the road outslde the 3.llrena venue (formefly known as The Polnt / 0 2 t with only a very small residual volume exiting from Alexandra Road itsekf and making this manoeuvre, which Is counter-intuitive, for the following reasons:

Stephen Wd Conwltlng Traffic and T c a n s p o m ~ Lirnltd Unit 3, MMalaMde Msrina Ylllage M d a W 6 QubHn zkdE&d- www.ste~he~~dconsuItimw~

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Alexandra Basin Redevelopment - Dublin Port

the mute to the tunnel from the eastern Terminals is sigtled via Tolka Quay Road, Bond Drive and Promenade R ~ a d west (i is also identifled as the mute In SatNav, and google map functions, and is dearty highlighted as the route in the mapphg included in the RPS €IS Figure 8.1.1).

a the distance from the Irish Ferries terminal via Tolka Quay Road, Bond Drive Extension and Promenade Raad wat to the Tunnel Toll Plaza is 3.4km (6 minutes drive in normal traffic: conditions) and passes through one set of external tmffic signals at the junction between the northbound exit from the Port to the tunnel and the access to the Port from East Wall Road; the distance from the Irish Ferries terminal via Tolb Quay Road, No1 Branch Road South, Alwandta Raad, East Walt Road southbound, the roundabout u-turn, E a d Wall Road northbound to the Tunnel Toll Plaza Is 4.9 krn (10 minutes drive in normal traffic mndittons) passing through four sets of external trafflc slgnals whkh operate an 2 minute cycle times, and u-turnine at a congested roundabout junction.

It Is clear that at peak times when there b queuing on East Wall Road, the jwrney time from the eastern Termhals via the 'u-turn' route to the Tunnel would be s~nificantly higher. Therefore it is unrealistic and in my view DPC and R E have t r i d to overplay the potential u-turn at: the roundabut for t r d c exiting the Port toctfie Tunnel, us tng this as some form of justification for closing the mute to/f#rn the Port vla Alexandra Road.

1 refer to p d o u s subm isions hy Irish Ferries. 1 also refer to the submission mad$ by MY Tam Spaln of the NRA to thls Oral Hearing which concurs wlth my own view that RPS have wildly averestimated the practical opemtlonal capacity of the Tunnel. I also note in Ms Daly's submission that she states the 2040 predicted volume of traffic to be 36,351vehlcles (for the entire Masterplan), agalnst an estimated capacity In the Irl& Ferries submission of 4Q,000-SOp(K3 vehicles par day. Note that tMs ranges b e e n 73% and 91% of the Tunnel's capacity, and takes no account of the impact: of the Eastern Bypass, which is likely to Increase the volumes through the tunnel should it proceed in this period.

I submit that there will not be ample or si-nt spare capacity and use ofthe wildly Inaccurate eapadty figures quotd in the RPS repom Is a somewhat misguided attempt ta undersell the percentage impact of the ABR and Masterplan traffic on the network.

I &we#3: Umure d Alexandra Road and INernrrl R d Netmrlr - Event af a R w d Bk&uae

RPS have identified a selection af route diagrams In the went of an ernewng situation which results in a section of the Tolka Quay Road or Promenade Road being blocked. It k wetcohe that DPC have a procedure in pla- fox managing ameqency wents, but it is submkted that this is more applimbte to infrequent emergencies or incidents only and Is a wholly inadequate strategy to deal with the ckar tfa*

l s s u ~ which will occuron Promenade Road and Bond Drive Extension (palzkulady at the roundabout) on a daily basis at peak times. It Is noted tfiat the postdevelopment traffic reassignment doubles the predicted traffic using it in 2019, and triples it by the later years of the Materplan (as presented in the RPS report f ow diagrams), I previously identifled this serious capacity issue for these Link and jumt4lons in the Port road network in my report of 28.09.2014 which is appended to thls submission, and I stand over my previous comments.

Stwhen ReM Consulting TrsfRc and TransgWtrltion U r n i d UnhZ hrlalaMde hd%rlna V i b p M L m Ca Mtbk s t e r r h e n r d t t B s t e a h e n r ~ I ~ p

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Alexandra Basin Redevelopment - Dublin Port Stephen k i d Cansvhirlg

Traik md T r : v ~

[ 1ssueiW: C l o w r e of Atexondm Rwd and intern01 Road Network - Rwd CapdW

Please see my response to Issue #3 above, and also the detailed comments In my reporr of 28.09.2Q14.1 note that the RPS Report Identifies extensive queuing and delays within the network (but these are presented in such a way as to be indecipherable to all but those who have experience and knowledge of LltJSlG modelling network diagrams), Furthermore, as RPS have overestimated the capacm of the Toika Quay Road and the roundabout at the junction of Promenade Road and Bond Drive, t submit that the actual results will be even worse.

/sue#: me Inflll Area ot Be& 52 and 53 and the Ccrnstruction ofthe C)ouble Tier Ubkspm - Construction VehicIes and Methodology J

Generally the preparation of a high level CEMP is acceptable, and it is considered the traffic volumes during construction will be significantly lower than the post-dwelogmtnt traffic volumes. Notwlthstandlng thls, the canstnrdion adivftles need to h wall managed throughout the construction programme, to ensure no detrimental impacts on the activitiw and acms within the Port. Howwet, thls does not wnstitvte acceptance of the closure of Alexandra Road on the part of Irish Ferria or Stena Une.

ISSUM: 7 7 ~ Infill Area ot Berths 52 and 53 and the Constrtldion of the Doubie 77er linkspan - Svggested M b ! e Internpal Unk Rood

The submission by lrlsh ferries of Tth May 2014 Identifies this a being an extension of Promenade Road east to Terminal Road Nortf~. This b dearly identifwd in the Masterplan diagrams, but at some point disappeared from the drawing and proposals for the ASR EIS (while at the same time the dosure of Alexandra Road, and the Infilling of the Graving Dock, which were not mentioned in the Masterplan appeared in the ABR application and EIS),

Ms Daly states that this road is not required as a mitigation measure for the ABR Project, However, this is not what Irish Ferries have l m n led to believe from ongolng contacts with DPC during recent weeks prior to the commencement of this Oral Hearing, which seems to contradict Ms Daly's statement.

As 1 have prwlously noted in this submission, Ms Dab states that the "closure afthe sectfon of Alemndm rmd to which Irish FeMes refer Is not port of the ABR scheme." I su bmlt that this statement is only correa Insofar as It t not mentioned in the site notice. However, as the whole tramc impact assessment in the €IS Chapter 8.1 and the subsequent RPS traffic report of Spternber 2014 has the closure of Alexandw Road for all Port traffk except the Port Centre office as a key theme of her assessments, Ms Daly's statement Is incorrect.

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Alexandra Basin Redevelopment - Dublin Port

Ms Daty states in her witness statement that "the trr#ircjIow diogrrrrns urn A3 size and theLihsig djagmms are A1 size* nose diagrams cieorly present the relevant dam. *

I again submit that the report and appendices were suppled by DPC to Irish F e r k and Stena Una in an A4 format paper report document, and on a mernosy stick, Ms DaIy cannot reasonably expect that Irish Ferries, Stena tine or their consuttants would have been in position to print out these diagrams at the enlarged sheet sizes she states, and they should have therefore k e n supplied In a size that was readily readable without resorting to zooming in on the PDF mpy on the memory stick. In fact, wen DPC acknowledged that the trafffc network dlagrams were nut easy to ead In cuntaas with lrkh Ferries.

As per my comments in the previous submissbn, wen zoomed in, this data would not be decipherable to anyone who did not have an advanced understanding of Unsig results diagrams, so the Infomatlon as issued on 19.09.PBl4 was entirely Inadequate for my clients to m e w without expert assistance, and this is unacmpta b k

I q: Tm@c b the jumtkn~~sbuld have &en pmvidd over a week. I Ms Daly responds by Sating "Refer to EtS Volume E Chopter8.I Page 8-26 whlch s#W.thaf mflc wwp were commi~onedfur ? days. A review afthJs do& allawed the selection af the oppru@riote suivey dqts for t h e f i r t k anufyPs. N o t e that midweek s t m y days were selected, wkh 3 cruhe finer$ In the Part and an went en rrf the 02, thereby pmvfdIng robust amIysIs.

The buslest daw for Ro-Ruferries at DubPn Pofi are Monday and Fridiry. Typically volumes of artlwlatd trafflc are much iwer on midweek days. For example the volumes d HGVs on Tuesday 14* ~ctober were less .than 20% of maximum capacity.

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Alexandra Basin Redevelopment - Dublin Port

lsw&U: kid kriie5 have wtwldered r h t ~ n - u p p r i a t e bCU wversion m& far the Dubtin Brf and EnvIrans wdd be 23 as opposed to 2.3 fir hemy ud?i tk

The RPS repork references Phair approach to converting the suwey data to PCU's in Appendix 10, and from a review of this it is noted that the conversion factors used were from the franspol-l for London document Traffic Modelling Guidelines' (fft, 2010).

kn the lrrsh Ferries subrnFssion of M y 2014, A was noted that the normal pract'ke in lrebnd is ta use a factor of 2.9 for artfcuiated HGk, and Indeed this wwld be the approach taken h modelling Mculated HGV traffic Jn NRA studies, 1 note that the El5 for the NRA proposed M7 Naas to Mewbhdge Bypass Upgrade Scheme published in 2013 Inctud'es a reference below fabfe 3.1 of Volurnr 2 Chapter 3 'Ned for the Proposed b a d ' to a fador of3 to be applied to HGVs (this &erne has already k e n the subject &an Oral Hearing earlier this year).

Therefore the mamrppmpriafe HGV to PCU conversion factor would be 2.9, wht& would prwide a more robust and reliabfe set of flow figurn for the fibre year modetiin8 scenarios. It is nuted that the use of this fador would hcrease all of the PCU flow figure5 where HGV V c occurs within the RPS network diagrams.

Mr Daly states in her witness statement that the s d d o n of the peak hour caIwlatb# us Irrdustw remgnrsed rnethadotogy. I refierate my comments in the review 28,042014, an& submit it would have been more valid and useful to present the data in fable af indivtdual Juwtlon total inflows In the first instance, as the move-nts wtthin the network can also be impacted by particular wtesesfof short term surge movements (such as rba fertJes.disembarking] and downstream delays mutting in queuing back through junctions (it is noted that this k a common occurrenae on the East Wail Road during the network AM peak period, between t k Easr Unk Bridge roundabout and the East Wall RW/?ort Tunnel Pofl-mR slips). &greg&ing the f low through all Internal Junetlons together provides an unrealistk presentation ofthe peak hosrr.

Ms Daty atso sta- that delays caused by adverse weather cohditiinc are not typiwl. I note that in my prdous review note I was making the point that white the target time of disembarking the large Ro-Ro vessels such as the UIysses b 30 minuts, thb mn Increase dependins on paAcular volumes and traffk familiarity when exR1ng the vessel and the terminal area. Therefore wfilte fn an Ideal scenario, these uessds would have dlsernbarked and be exiting the Port during the period 06~UO46.34 it is h$hty likely that' there wilt be a groporrbn of disembarked t M c exiting the Pork after 06.30, and if there are weather delays to the crossing t h e w departure time of the W s from the UK, there could b~ a s i g n h t volume of ferry t&c during the 06.30-07.30 'Internal' morning peak hour. This same mornins period woutd also contain a signMmnt proporYron of the arriving traffic that would then embark onto the M.05 Ulyslses, 03.45 Sw Ift or 08-20 Stena departures from Dublin Port.

The selection of limited peak hours dees not prwtde a full picture of the Issues and flows through the Port.

Stephen Wd C b n s u l t ~ T r ~ c ~ T ~ b p ~ o n Limited Untt 3, MaMtde Msrtns Illll;tg% M&* Co M A n ~enhenreid@ne~hreidcdnsuMna.corn w J t p a h ~ r e i d m ~ s u M f l ~ , r r ~ s

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Alexandra Basin Redevelopment - Dublin Port Stephen Reid Consutting

lraff~: jrKf r r m ! a w n

hUeM2; W s R-ng ta the Ugnal&&an afJutdbn 16 ( R B reference for the Tolh Qwy Roa#M2 Brand7 Road F I h Junction)

The RPS modelling assumes that the westbound lanes on Tolka Quay R w d optate as two fuil lanes. It Is submitted that doe to the narrowness of the lanes along the length of the road, where the width between the grass median and the high containment canmete cnsh barrier is only 6m, trudw in the nearside lane often overhang the lane divider, reducing the effective width down t o one lane, whkh has a significant impact of the capacity of the westbound rwte for traffic leaving the eastern terminals. Ms Daly states that DPC are aware of the 'perceived' carrlageway width and will address this as pari of their Internal mad maintenance. It: Is submkted that as this has not been accwntd for in the €IS or sukequenf RPS traffic report, the UN516 results presented by RPS are wed^ optimistic. R wauld have been more appropriate and acceptabte for RPS to have identified thls issue as pae of thelr baseline modelling and then include reference to widenin& (for example into the grass median) as a mitigation measure for the future year modelling.

In terms of the modelling results, R Is noted that the hard mpy results in Appendix 7 are virtually Indedpherable to the nabd eye, and from a review uf the PDF version supplied, it b noted that the cycle times are missing from all of the PM UmIg network results diagrams.

It would qppear that the results Identify Degree of Saturation (DoS) values at Junaton 36 of less than 90% on each a m during the peak hours up to 2034 (on the basis of the RPS modelling whl& uses a number of parameters identified abwe that are likely to underestimate the Impact).

By 2040 the results repoi? that thIs jundion Os signifbntiy over c;zrptky In the PM peak hour wlth a PrsctlcaI Resenre Capacity (PRC) of -51.7% (111.7 paHr delay), In the AM peak hour for the same 2040 year the lunetian is also over capacity to a lesser extent with a PRC d -5,648 (35.0 pmHr deiay).

Thls Is most notable on the PM mutts for the No 2 Branch Road North arm (the southern arm &Junction 16) which, with the proposed signals In place, wll have a D& value af 136,5% and a queue of 89.5 *ti, in a single approach lane. Put in context, using a standard value af 5.75 rrpetreslPCU, this equates to a queue 1-h of 5 s mtres, R Is noted that Alexandra Road Is only 120 metres south of the Tolka Quay Road junction and therefore the net result: is that this guwe wlll extend back southwards an No 2 Branch Road North from Junction 16 through Junction U, extending for some distance along both Alexandra Road east and No,4 Branch Road South (completely blocklng up this area doring the PM peak hours).

1 submit that the RPS modelling of this junction and the InternaI road network k Inadequate and does not provide an amrate representation of future year conditions.

I h w # ! ! : lnuer Reluting to luncrion 10 (RPS r@feren%e/or the P r o ~ n a d e RoW&nd D r k RBundObutl I 1 submit that the roundaboutjunction of Promenade Road, BoRd Drive end Bond Drive Extension (lunction lQln the RPS report) Is probably the most critial junction withln the Port as it provides sass throughout the Port, and following the prowed road amendmeats and ctosures, it will pWde the oniy access for almost all traffic to/from the Port, with even the -c from Bond Road (East Point exlt tram(;) having to

Stephen Reid ConwMngfraffk and TransporWbn Umlted UnR3, W h i d p Marlna Vlktge W M d p Co WbIn ~ h r e k l B s t & m r e i d ~ t i ~ . c o q u u w w ~ ~ ~ ~ n ~ u l t i n ~ ~ ~ m

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Alexandra Basin Redevelopment - Dublin Part Sfephn Reid Consdting

Trdw au! TlltmFlw tabcrn

turn left onto Promenade Road eastbound to Junctlon 10 and u-turn to exit the Port due to the median barriers installed on Promenade Road to prevent right turns out of tbe side roads.

The only other amss to the Port post-development is the access on Alexandra Road west to the DPC office car parking and the new Crulse Berth access road. I u a a

Ms Daiy states that this junction will experience capacity issuestowards the latter years of the Masterplan.

It is dear wW the existing pressures at the roundabout that by doubling the volume entenq on this arm in the opening year of 2019 (AM and PMJ, there wilt be significant queuing and delays, and having regard for the design years it Is noted that by 2034 the traffic is atmost trebled on this arm. While the volumes in the PM peak are slighthtly lower than the AM peak, it should be noted that a greater proportion of the total Inflow on Promenade Road u-turns during the PM peak than the AM peak (being in the order of 27%-28% of the totals in the post development scenarios ii to v above. This has a significant impact on the capacity of the roundabout, as traffic from Bond Drive North and Bond Drive Extension has to yield to the circulating flow.

There Is existing peak hour pressure .on the roundabout, particularly during the PM peak when there is a high proportion of Promenade Road u-turners, in conjunction with the volume of right turners to Bond Drive Extendon, The existing roundabout has a central island diameter sf approximately 16 metres and an outer diameter of approximately 38 metre, meaning the circulating carriageway is approximately 11 metres wide.

Based on roundabout geometry design parameters and on-site obsenratlons it is clear that HGVs and coaches have to negotiate the roundabout at low speeds to remain in the correct Iane and avoid collisions with other circulating traffic, and therefore it is unrealistic to expect the circutatlon to be used as two full lanes as per ttte RPS modelling Linsig resuh.

I submit that the RPS modelling of this junction and the internal road network Is inadequate and does not provtda an accurate representation of future year conditions,

Notwithstanding the clear inadequacies of the RPS modelling, it should be noted that for roundabout junctions a Ratio of Flow to Capacity of 0.90 (1.e. only 90% saturation) is considered the practical upper limit for roundabouts in urban peak hour traffic conditions, abwe which flows bceak down and queuing increases exponentially, not 100% as would be allowed for with traffic signals).

As the optimistic results in the RPS tirrsig modelling suggests there is only 59% (of 10W) remaining a t the roundabout in 2019, it is submked that if this iunction was remodelled using propet site specific parameters rather than the unrealistic RPS approach which uses a full two-lane circulation, It is submitted that the results would show the roundabut is already over capacity in 2019. There 1s no proposal In the RPS report for mitigating the impacts at this junction.

NohrvRhstanding the shortcomings in the RPS modelling of this junction, it is noted from a review of the results that wen the tinslg data predkts problems at this junction in future years.

Stephen ReId bnsuttinglreffi~ jndTmnqmrtatbn Umtaed Unit 3, Mithhlde Marina Village Mdshlde (3r Dubh

Cshh&dransuBim~ smwvst@~hed$mnsu tth~uan

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Alexandra Basin Redevelopment - Dublin Port Stephen Reid Consulting

Tmtric a-d Tramaurtwlon

With pafTicular reference to the PM peak results, it is noted that by 2034, the results nport a queue In the order of 143 + 153 pcw in the two northbound lanes on Bond Drive Extension, which on the basis of a standard 5.75 rnetreslpcu, would equate to a total queue length of 1.7 kilometres (at approx#matdy 850 metres per lane), which would extend hack along Tolka Quay Road through lunctlon 16, alrnmt to Junction 12 fat Breakwater Road North}.

By 22040, the RPS results indlcate saturation uf 133% queuing on the Bond Drive Extension will increase to a total of 2.21 kilometres (or 1.1 kilometres per lane).

On Promenade Road west approaching the roundabut, the results for 2040 PM peak indicate 103% saturation, with queuing of 1.045 kilometres (or 520 metres per lane), which would extend back and block the Bond Road exit, almost reaching the slip road to enter the Porl from theTunnel southbound toll plaza.

Again It Is subrnltted that a fundamental aspect of this project should have been an appropriate assBsment of the road network in the €IS and adequate proposals to mitigate the Impacts. It k not acceptable to say that this Is due to the rest of the Masterpian and propose no mMptbn measures as part of this project. The issue of a report (albeit flawed and Inadequate) only approximately two weeks before the Oral Hearing commenced, and at that note it was only issued selectbely to Irlsh Ferries and Stena Line, so had no f m a l planning status, was tn my view an attempt to confound my clients and deter them from objecting at this Oral Hearing.

-- - 1 ~lluep10: ~ e m l ISSUPS rehhing to the future yoor mmcity ofthe port. I It is also noted that a knock on impact of the queulng on Bond Drive Extension (from Junction 10 in the RPS report) is to prevent traffic M n g from Tolka Quay Road west onto Bond DtJw Extension (Junction 17 in the RPS report). For example, the RPS Linsig results report that dudngtha PM peak hour, Juttetion 17 J11 have a PRC of -63.7% In 2034 and -100% in 2040. In terms of the queuing on Tolka Quay Road west, the saturation in the 2m4 PM peak is 147,6% with a queue length of 539 metres, dslng to m.3% with a queue length of759 metres In the 2040 PM peak hour,

In the 2034 AM p a k the same arm of the iunctlon has a sat-uratlon of 100.7% with a queue length of 192 metres, rising to l32,8% saturation with a queue length of 532 metres by 2040,

This level of queuing in the future years will have a signficant detrimental Impact on the western area of the Port, and wlll lead to a non-functioning network within the Port at peak time, which is dearly not a sustainable appmach to development of the Po& and will Impact negatkly on all Port users and cummercia1 operators, not to mention potential Issues fortrafftc accessing the Port from the Port Tunnel.

I As stated previously, the Topaz roundabout' Is the key junction in the Port (Judctitlbn 10 in the RPS report) -It is already approaching capacity wen on the basis of their own 'optimistic' wpacw modelling in 2019 and is wer capac*w in 2024 during the PM peak hour,

Put simply, the already struggling roundabout will be completely 'broken' within 5 years of completion of the ABR project, even using their own figures and modelling parameters, and if mote realistic parameters were used the results would be wen worse.

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Alexandra Basin Redevelopment - Dublin Port Stephen Reid Consulting

Tt& a n d l r ~ ~

Sweml other junctions within the Port will atso fall In future years, clther through mpacw lsslles on the Junctbn itself or due to blocking badring from downstream junctions which are unable to accommodate the tramc using them in the future.

in addition to measures such as the Promenade Road extension (propas& by Irlsh Ferries) wM& wag discminted in the RPS repoit [atthough DPC ong0'1ng contacts wluth Irish Ferries suggested it: was to be Implemented), It Is considend that a wid.@ ranging sw*w of measures needs to be put in pace to ensure the network can fundion. pmpedy.

A mjew of the arrangemerrts along Promenade Road whlch resuk In a tame volume of u-turners at the Topaz roundabut should a h be considered, and as dated prwiously, r*dq the number of aws5 junctions for a Eommerclal Port of this size while pprolposing future growth d m not date to a strategy for propier and susta3nable development ofthe lands,

It is also noted that there Is a very hi& lwei of car-dcpenhcy for w o r m wMin the Port, due to the IlmRed bus sewice and nature of the network, and It Is submitted that a Port-Wide Sustainable Trawl Plan needs to be put tn plae in the h o e term, with real measures developed to affect a positive madal shift as this could sukbntisily reduce the overall traffic enteAng and mltfng the Port at peak ttmes of the day.

Summary

It ir clearly not good long term planning over the l i i of the DPC Masterplan that a number of key access junctions sewing the Port will fail In future years, and it is clearly common sense to Identify measures now which can b implemented on a phased basis and effectively future-proof the Port access and clrnriation network, as opposed to leaving it to a later time when the Impacts are having a detrimental impact on the muttlple commercial interests and users within the Port,

Stephen Rdd Managing Director Stephen Reid Consulting TrafFic and Trans porhtion Urnited 17.10.20M

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Alexandra Basin Development - Dublin Port

Review of RPSTrafFIc Response to ldsh Ferries and Stena Kne

I . Background

Irish Ferries have requested a review of the RPS docljrncnt {Rw A dated 17.09.2014) prepared on behalf of Dublin Port Company (DPC), The report is in response to earlier observations submitted to An Bord Pleanala by Irtsh Ferries and Stena Une In May 2014,

The subm~sslons by Irish Ferries and Stena Line refated to concerns about the proposals for the Alexandra Basin Redevelopment prqje , with regat& to the impact. of the proposals an traffic capacity and movement within the Port and at key Junctions on the external public road network.

At the outset It is noted that while lrish Ferries remain broadly supportive of overall Porl dwelopment objecthe, much of the concerns raised by these two c;ompanIes in the submissions of May 2014 related to the lack of Information on the trafFic Imparts of the proposed development In the application and supportlng documents, whlch made it dWcult for Irish Fed= and thelr supporting consultants (and Stena Line) to adequately interpret and evaluate the proposals, and draw clear conclusions on the Impacts.

The response prepared by RPS sets out that ic has been prepared to assist DPC in responding to both mrnpani~,

As an initial comment, white the undemklng of a technical traffic impact assessment exercise by RPS for DPC In order to provlde more clarity on the likely frnpacts of the proposals is welcomed, it Is of concern that the presentation of the data is in a format which makes rwiew dicult, with very IHIe .tabulated data, andret!cn~@-on _?e5!F@ .t.@icfl?+wd!ap-~ and-llmig network result diagram In Appendices 3,s 6 and lwhich are practically unreadable on the prirrtea&f ceis'iijtis; and-dtfficlika~d - . -

unwleldy to rwlew on screen In the electronic pdf version, without zooming in so that only part of each diagram is visible at any time.

Tabulated Row and result data should be provided for redew.

2. Key Elements of the RPS Submlssion

The RPS report contains a detailed technical assessment of the impacts of the ABR proposals, on the Northern lands (the Porl lands to the north side of the River Uffey).

Traffic Count Surveys

A series of t ram counts were undertaken on the external junctions along East Wall Road and the Port/Porl Tunnel access slips, and on the Internal junctions throughout the Port. Counts were undertaken at mast junctions on weekdays In late May 2014, with additional aunts undertaken on weekdays in August 2014 at several Internal access junttlons an Tolka Quay Road and Alexandra Road. These were undertaken on peak dav with events occurring: that would be expected to add traffic Into the area (these were listed in Table 2,l).

Stephen Reid CMlsuItrng Trafiand Tr$nspmatlan UmRed Unt 3, Malehide Marlna Vlbge MaWde co &ban

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Alexandra Basin Development - Dublin Port Skphen Reid consulting

Tmw TraxgQItatbn

Havlngrwiewed the traffic count suwey specification and dates,the type and range of data collected is considered acceptabb for the purpose of developing an impact assessment and modelling baseline traffic conditions. However, having regard to the sensitivity of key Junctions wRhin the Port, and to provide a clear picture of the day by day loading on the road network withln the Port a week of volumetric data on the access junctions (ATC data or slmilar) should have been prmtded.

FirctorIng Clussrfted Tmfflc aunt Duta to Pa~~enger Car U n h (PCUs]

TheRPS report references their approach to convertlrrg the suwey data to PCU's !n Appendix 10, and from a revlew of thls it Is noted that themnverslon factors used werefram the Transport for Lond~n document TrafFic: Modelling Guidelines' (Tfl, 2010). These guidetines set out (at Sectfon 2,4,3.1, Table I) that HHG vehicles should be converted by a factor of 5.3, with no difkrentiatton given between r$ld or alticulated types. It is noted that in the RM repalt thb Is presented silghtly differently by referencing tMs vehicle type as OGV2 {all articu tated vehicles).

In the lrkh Ferries su bmhsbn of May 2014 I t was noted that the normal practice Irt rel land Is to use a factor of 2.9 for articulated HGVs, and Indeed this would he the approach taken in modeltlng artkulated HGV tmfk in MRA studies. It is submitted that the TfL factor would have regard for a smahr proportion af large articulated HGVS and a lamer proportton of rigid HGVs in u han stteeps In Landon, and hence a factor of 2.3 wwld be more applicable in that case. SlmIlarly h Dublin Clty Centre there is a !i+ axle HGV ban opwating from O7.W-19.00 each day whlch was tied into the opening of the Dublin Port funnel (DPTJ with tbe exceptton of llmlted scheduled deliveries by permft, and this approach may be considered appropriate for modelling Junctions wlthin the Cm Gentre

However, it Es considered that in a t o d o n such as Dublb Port and at East Wall Road/Dublin Port Tunnel Southern Portal, the greater proportian of HGVs (or OGVZJ vehicles would be gt&&& w, and also there should be regard for the option of k axtevehlcles .to travel along the City Quays or East Wall RoadJAlfie Byrne Road to MaIaUde Ruad between 19,W and 07.011 (outside the operating hours of the HGV ban).

Therefore the more appropriate HGV to PUJ conversion factor would be 2.9, which would provide a more robust and reliable set of fbw figures for the future year rndelllng smnarlos. It is noted that the use ofthis factor would increase all of the PCU flow figures where HGV trafflc occurs wfthin the RPS network diagrams. However as tbe raw count data is not presented In the report no evaluation can be given of the Impact this would have, Havlng regard to the sensitive nature of junctions within the network, and the future scenarios when there ls further dwelopmsnt, it is rammended that thts should be re-run to demcmstrate the impacts wlth the more robust factoring approach,

Approach to Modeiling Peak Hours

The RPS report provides an aggregated total volume for groups of edema1 and Internal junctions, Identifying the followiw as the peak hours:

Stephen Reld Cohsukhg Traffic and Tmnspofmim Ilmlted Unk 3, Malahlde Marlna Vtllaee Malahide Co Dublfn

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External Road Netwwk/Access Junctions:

07.304330 (AM peak), 13.W-l4,[1Q (Inter peak), 17.00-18.00 (PM peak)

Internal Road Network/Acc- Junctions:

06.30-07.30 (AM peak), UJO-13.30 [inter-peak], 17.00-18-00 (PM peak)

It is submitted that it would have been more valid and useful to present the data in table of individual junction total Inflows in the first Instance, as the mwernents within the network can also be Impacted by particular routes for short term surge movements (such as the ferries disembarking) and downstream delays resulting in queuing back through junctions (it is noted that this Is a common occumrre on the East Wall Road during the network A M peak period, between the East Unk Brldge roundabout and the East Wall Road/Port Tunnel Port Exit slips).

By slrnply =regating the flows through all junctions the issue can be compounded and provides an unrealistic presentation of the peak hour. It Is noted that the flow data can obtained by a detailed review of the hourly figures in Appendix 3 of the RPS submission but this b a labour intensive task which would require combining hourly totals by hand from the figure In Appendix 3 and averaghg them to obtain the 'half past the hwf start times given for swml of the peaks in the RPS report as noted above, and it is submitted that this would be dearly unreasonable for RPS to expect of a third patty or their consultants when reviewing the report. Therefore the data should be presented in a more user-friendly format (and having regard ta the facbring issues ralsed above).

Also it is submitted that the arrival times of the Irish Ferries vessel Utysses (at 05.55) and Stem Adwnturer (05.45) are scheduled times, which can be affected by adverse weather oondltions, and therefore there are situations when these could arrive Into Dublln Port a t later times than scheduled.

While the tarpt time of disembarking the Ubses k 30 minutes, this can Increase depending on particular volumes and traffic familiarity when exiting the vessel and the terminal area Therefore while In an ideal scenario, these vessels would have disembarked and be exitfng the Port during the period 06.00-06.30, it Q highly likely that there will be a proporttan of disembarked t d c exitingthe Port after 0630, and ifthere are weather delays to the crossing time or departure tlme of thevessels from the UK, there could be a signfitant volume of few traffic during the 06.30-07.30 'internal' morning peak hour, This same morning period would also cuntain a shnificant proportion of the arriving trafRc that would then embark onto the 08.05 Ulysses, 08.45 Swift or 08.20 Swna departures from Dublin Po*.

Concerns over Key Junctrbns in Dublin Port

The RPS report claims that the key junctjon requiring upgrading to accommodate the redistributed traffic flows resulting from Stages 1-5 of the ABR project Is the Tolka Quay Road/No 2 Branch Road North/Mo2. Bmnch Road North Extensfon (identified in the RPS report as Junction 16). This is due to the significant volume - post development - of addional right turners from No.2 Branch Road North Extensfon to Tolka Quay Road and the signifimnt volume - post dwetopment - of additional traffic westbound on Tolka Quay Road through this priority junction. Therefore it is proposed in the report

Stephen M d Consulting T W i e and Transportation Llmiled Unit 3, Malahide Marina Vlllage Malahlde Co Dublin i r J

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T r n snd Twnsport~tbsn

to signalise the Junction, including converting the southbound No. 2 Branch Road North Extension from a single all movements exit lane (half of the road width which was formerly marked out as a dedicated right turn lane is currently blocked off by barriers) to a 3 lane approach (with the section of barrier removed) allowing for 2 dedicated right turn lanes and a third lane for leftjahead rnwements across the full carrlageway wldth.

The RPS report states that Junction 16 will operate within capacity with the signals in plarje up to 2040, although na detail has been provided as to the swept path requirements for the double right turn (if two articulated trucks are both turning ontoTolka Quay Road at the same time), and as stated previously in this review, the HGV to PCU factoring issue is likely to Increase the PCU totals for each movement if these are amended as recommended.

Furthermore, It appears the RPS modelttng assumes that the westbound lanes on Tolka Quay Road operate as two full lanes, It Is submitted that due to the narrowness of the lanes along the length of the road, where there Is a hlgh containment concrete crash barrier installed on the nearside road edge to protect the pipelines, trucks in the nearside lane often overhang the lane divider, reducing the effective width down to one lane, which has a significant impact of the capacity of the westbound route for tramc leavlnp; the eastern terminals.

In terms of the modelling results, it is noted that the hard copy results in Appendix 7 are virtually indecipherable to the naked eye, and from a review of the PDF version supplied, it is noted that the cycle tlmes are rnlssing from all ofthe PM Unslg network results dlagrarns.

It would appear that the resub identify Degree of Saturation (00s) values at Junction 16 of less than 90% on each arm during the peak hours up to 2034 (on the basis of the RPS modelllng whkh us@ a number of parameters Identified above that are H kely to underestimate the Impact).

By 2040 the results report that this junction is significantly over capacity in the PM peak hour with a Practlml Resenre Capacity (PRC) of -51.7% (111.7 pmHr delay). In the AM peak hour for the same 2040 year the junction is atso wer capacity to a lesser extent with a PRCof -5.6% (35.0 pcuHr delay).

This Is most notable on the PM results for the No 2 Branch Road North arm (the southern arm of Junction 16) which, with the proposed signals In place, will have a DoS value of 136.5% and a queue of 89.5 pcu, In a single approach lane. Put In context, using a standard value of 5.75 metres/PCU, this equates to a queue length of 525 mebes. It is noted that Alexandra Road is only 120 metres south of the Tolka Quay Road Junction and therefore the net result is that this queue will Wend back southwards on No 2 Bmch Road North from lunttton 16 through Junction l5, extending for some dlstance along both Alexandra Road east and N0.4 Branch Road South (completely blocking up this area during the PM peak hours).

If additional green rime at the slgnsls Is allocated to this arm to reduce queuing, the Tolka Quay Road and No.2 Branch Road North Extension a r m will experience Increased queuing as a result so this critical junction clearly requires further assessment. '

In addltion to the issues identified with Junction 16, it is submitted that the taundabout junction of Promenade Road, Bond Drive and Bond Drive Extension (JunclIon 10 in the RPS report) 1s probably ~ r n o s t critical Junction within the Port as it provide access throughout the Port, and following the

Stephen Reid ConsuMng Traffk and fransponatlon U m W UnR 3, Malahlds Marina ViIlage Malahlde Co Dublin steuhwrreldPste~hmre~conwttlnamq ~ . ~ h e n r e l d c o n s u R i n a . m r ~

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Alexandra Basin Development - Dublin Port Stephen b i d Consuhing

ftBtdfmaspwta*m

proposed road amendments, R will provide the only access for almost all traffic toCfrom the Port, with even the traffic from Bond Road havlngto turn left onto Promenade Road eastbound tolunaion 10 and u-turn to exlt the Port due to the medlan barriers installed on Promenade Road to prevent right turns out of the side roads.

The only other access to the Port post development is the access on Alexandra Road west to the OPC office car parking and the new Cruise Berth access road. J 1 i 9 9

With specific regard to the issues at the roundabout, the enlstfng conditions during peak hours show there is clear pressure on the roundabout, partkularly on the circulation (constdered tn terms of a clock face, the section from 12 o'clock (north) to 6 o'clock (south] experiences mast pressure, durfng ail peak timw of the day, and particularly during the PM peak when there is a high proportion of Promenade Road u-turners, In conjunction with the volume of right turi~ers to Bond Drive Extension.

The existing roundabout has a central island diameter of approximately 16 mbE5 and an outer diameter of approximately 38 metres, meanlng the circulating mrriageway Is approximately 11 metres wlde.

Based on mundabout geometry design parameters and on-site observations it Is clearthat HGVs and coaches have to negotiate the roundabout a t low speeds to remain in the correct lane and avoid colllslons with other circulating traffic, and therefore it is unrealistic to expect the circulation to be used as two full lanes (see following two images) Mote circulating truck in second image has stopped on the roundabout as the red truck is shwly turning out to Promenade Road.

- . -.-A luncdon 30 - Existing roundobaut with 38 metre ICD (outer diameter) source ww.googh?.i~maps

b p k n Reid Cmsultln~ Trafflc and TransponatW Umited Unit 3, Malahide Marlna Vlllage AnabMde Co Dublin 9- wmnv.ste~h~nnldmnrultInawm

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Alexandra Basin Development - Dublin Port Sfuphen Reid CoMufiing

Ttdkandfranqlataolan

In addition to the exit traffic from Bond Road which has to u-turn at Junction l0 to wrZt the Port, due to the location of the Topaz statlon/shop and truck stop, there are a slgnifiwnt number of other NGVs making wtums on this roundabwt throughout the day.

As a result of the restrictive geometry, trucks maklng u-turn manoeuvres at this roundabout have to start from the nearside lane and swing around to the fourth exit, which Is hazardous as the correct starl position for u-turning at roundabout is to approach in the offslde lane (mtrcmost lane).

To demonstrate the exbting pressure pdnt on the roundabout a serles of images have been taken from the Google maps TficfunEllon for the morning peak, interpeak (lunchtime) and evening wak perfods, at tlmes which the R K report claims there are no existing capacity issues at Junction 10. It should be noted that the aerial phNo Is not related to the time In the legend and therefore the same image Is seen in the background of &, but the alwr coded mngestlon overlay changes with the time In the legend.

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Alexandra Basin Development - Dublin Port

Internd Morning Peak flffh p m u r e point at mundcrbout Junction 10

Reid m k h g FaPRe Nfraneportakn Urnstad Unlt 3, Malahlde Msrlna Mmlrhldm bOubltn w

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Alexandra Basin Development - Dublin Port Sbphen RmM Comuhifig

TraRK and B w t a t T o r l

R d ~ H T W Traffk and T n n w UmMd Unit a, Msb hlda Marina Vlllap Mahw8 CaOubRn m -

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Alexandra Basin Development - Dublin Port sfsphen Reid consulting

T m l f # s n d V B

tt Es dear from thesescree~shots that the dmfation arrperiemes slow tmfk and delays durhgall d the pmk periods bn a @plat weekday, even in exbting wnditfuns prlor ta the ABR proposals and future growth in the Port.

From a more detailed review of the m u k praented tn the lfnslg assessment dagranw R Is noted that the industry standard a p p d to dellma roundabout J u W n isto use ARCADY software, and whlle it is pwsibk to model a roundabout uslng the more reamt versions of Unsig whlh a n allow a mix of junction types withln a-network, it would be helpful if R S were to pmvide a scpamte set of modeling a l t s fot the roundabout using MCAOY to pmvW validation of the LInslg d d h g multp.

ansldcrlng the traffic flow enterlng the roundabout on the wrlaus network diagrams # is noted that the flow on Prunenade Road entering the mndabout is pmdlcted by RPS to increase as follows:

AMpeak 1. ti. ill. hr, Y,

PM peak 1.

II. lil.

664 pw (in 2014) Existfng 1,303 pcu (In 2014) Cbmpletlon year 1.463 p~ (in 2024) + 5 Design Year 1,848 pcu (In 2034) +I5 Design Year 2,129 pcu (in 2 W ) end of Masterplan

609 pcu Qn 2014) Existing &I99 pcu (In 2019) Completion year 1,339 peu (in 2024) + 5 Design Year

m e n Rcld C#rurltfn~frdfRc and T r a e U m W Ontt 3, M h i d e MsrlnaVllbpr MetahIda b OubUn

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w k e n d b ~ i a m

iv. 1,678 pcu (in 2034) +15 Design Year v, 1,925 pcu (In 2040) end of Masterplan

R is clear wlth the existing pressures at the roundabout that by doubllng the volume entering on thls arm in the opening year of 2019 (AM and PM), there will be slgnifimnt queuing and delays, and having regard for the design years it is noted that by 2034 the trafflc is almost trebled on thls arm, While the volumes In the PM peak are slightly lower than the AM peak, it should be noted that a greater proportion of the total inflow on Promenade Road u-turns during the PM peak than the AM peak (being in the order of 27%-28% of the totals in the post development scenarios ii to v above. This has a significant impact on the capacity of the roundabout, as traffic from Bond Drive North and Bond Drlve Extension has to yield to the circulating flow,

It should be noted that fbr roundabout junctions a Raio of Flow t8 mpacky ef 0.90 (1.e. only 90% saturation) b consjdesed the practical upper limit br round&outs In urban pesk hour traffic conditions, above which flaws break down and queufng increases ercpane.ntIally, not 1OW as w ~ u l d be allowed b r wlth traWt signals).

As the m u k In the RPS Linslg modelling suggests there Is only 5.9% (of 100%) remaining a t the roundabout in 2019, it is clear that the roundabout Is already at or wer capatlty In the opening year,

If this junction was remodelled wlng proper site spdfic parameters rather than the unrealistic RP5 approach witR two full Ian= on the Promenade Road and Bond Ddve Extension arms, and a full WQ- lane clrculatbn, it k submitted that the results uslng ARCADY roundabout modelling software will show the roundabout is already over capacity in 2019. There k no proposal in the RPS w r t for rnitiiatifig the impacts at this junction.

Notwithstanding the shartcominp in the RPS madeljing of this Junction, It Is noted from a review of the results that wen the Unsig data predicts problems at this Junction in future years, as folkws:

AM Peak (2034) Promenade Road - 99% saturation

Bond Drive - 88.1% saturation

Promenade Road - 114% saturation

Band Drive - 103.1% saturation

Bond Drive Extn - 85.3% saturation

AM Peak (2040)

PM Peak (2024)

PM Peak (2034)

Promenade Road - 79% saturation

Bond Drive M n - 97% saturation

Promenade Road - 96% saturation

Bond Drive Extn- 121% saturation

Zephen Retd ConsuMng Trafflc and 'l5ansportgdon UmWd Unit 3, Malahlde Marina Village Malahahide Co Dublin

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Tr* md Ti-

Promenade Road - 103% saturation

Bond Drive Extn 133% saturation

Wfth particular reference to the PM peak resuh, R is noted that by 2034, the mutts report a queue in the order of 143 + 153 pcus in the two northbound lanes on Bond Drive Extension, whlch on the basis of a standard 5.75 rnetreslpcu, would equate to a total queue length of 1.7 kllometres (or approximately 850 mWes per lane), whlch would extend back along Tolb Quay Road through Junction 16, almost to Junction 12 (at Breakwater Road North).

By 2040, the RPS results Indicate saturation of l33% queuing on the Bond Drive Extenslon will Increase to a total of 2,21 kilometres {or 1.1 kilometres per lane). On Promenade Road west approaching the roundabout, the results for 2040 PM peak indicate 103% sahratiom, with queulng of 1.045 kilometre (or 520 metres per lane), which would extend back and block the Bond Road ah, almost reaching the slip road from the Port Tunnel southbound toll plaza.

It 1s also noted that a kncnock on impat3 of the queuing on Bond Drive Extenslon is to prevent traffic exiting from Tolka Quay Road west onto Bond Drive Extensbn (Junction 17 in the RPS report). For example, the RPS Unsig results report that during the PM peak hwr, Junction 17 will hwe a PRC of -63.7% In 2034 and -100% fn 2040. In terms of the queuing on Tdka Quay Road west, the saturation in the 2034 PM peak is 147.6% with a quaue length of 539 metres, rising to 180.3% with a queue length of 759 metres In the 2WO PM peak hour.

In the 2034 AM peak the same arm of the junction has a saturation of 100.7% with a queue length of 192 metres, rlslng to 132.8% saturation with a queue length of 532 met= by 2440.

This h l of queuing wl l have a simifimnt detrimental impact on the western area of the Port, and will lead to a non-functioning network within the Por& at peak time, which Is cleady not a sustainable approach to development of the Po% and will impact negatively on all Port users and commercial operators, not to mentlon potential Issues for traffic accessing the Port from the Port Tunnel.

It Is dearly not good long term plannlng over the life of the DPC Masterplan that a number of key access junctions serving the Port will fail in future years, and It Is clearly common sense to tdentlfy measures now whlch can be Implemented on a phased basis and effectively future-proof the Port aceess and circulation network, as opposed to leaving it to a later tlme when the impacts are having a detrimental impact on the multiple commercial interests and users wRhln the Port.

In terms of the proposal put forward in the Irish Ferries submission of May 2014 far a one-way eastbound extension of the Promenade Road, to reduce dependence on the Tolka Quay Road for access to the Terminals, it h noted that the RPS report references this proposal by Irkh Ferries at Section 3.23 (p37-38 of pdf). See below:

"3.23 A detailed tmffk a5SeSEment of the DubIln Port Northern lands has been carried out in order to address the m r n s f r o m IF on the changes to the highway netwonk und the changes in trafflccflows withrn the Port. fhe analysis confms:

Witb the proposed sigmlisatlon oflu&n 16, the internal rood network will work within mpcity up to 2Q24fOr both the AM and PM intern1 peak hours.

s e p h Rdd ConrultingTrefAcand TranrportPtlon U m W Unit 3, MatahIda Marina VWp M a W e (j3 Dublin

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Alexandra Basin Development - Dublin Port Stephen Reid Comutring

T m R md T m W

As expected, tawards the latter years of the masterplan (2034 onwards, over c2O years frum the time qf writing) the existing Internd rmd network will experience capacity Issues and further hlghway mitigation works may be required at later stages us the DPC Masterplan, subsequent to the ABR Prujea continues to be implemented.

lt is therefore demonstrated that the section of carriageway as suggested by IF in the extrocr above is not required as a mitigotion measure for the ABR Project "

Contrary to the claim by RPS, clearly their own report identmes that the inwrnal road network will be over capacity after 2024 (I,@. only 5 years after completion of the ABR project), but there Is an attempt to dawnplay this by stating in the second bullet paint that the issues only occur 20 yeas from now.

As stated previously, the 'Topaz roundabout' Is the key junction in the Port (Junction 10 in the RPS report) - it is already approaching capacity even on the bask of thelr own 'optimistic' capacity modelling in 2019 and is over capacity in 2024 dudng the PM peak hour.

Put slmpty, the already struallng roundabout will be csmpletely 'braken' withln 5 years of completion of the ABR project, wen using their own figures and modelllq paramters, and if more reatistic parameters were used the results would be wen worse.

Severat other junctions within the Port will also fail in future years, either through capacity i s s u ~ on the Junction Be8 or due to blocking backing from downstream Junctions which are unable to accommodate the traffic using them in the future.

In addition to measures such as the Promenade Road extension (proposed by Irish Ferrlesj whkh was discounted In the FIPS report, it is considered that a wide ranging series of measures needs to be put in pace to ensure the network tan function properly.

A review of the arrangements along Promenade Road which results in a large volume of u-turners at the Topaz roundabout should also be considered, and as stated pretrfously, reduclng the number of access junctions for a commercial Port of thb size whlle proposing future gram does not relate to a stratw for proper and sustainable development of the lands.

it is ako noted that there k a very high Iwel of cardependency for workers within the Part, due to tfie limited bus serrice and nature of the network, and it Is sufirnltted that a Port-Wide Sustainable Travel Plan nee& to be put in place in the short term, with real measures developed to a m a postthe modal shift, as this could subtantlaIly reduce the overall traffic entering and exiting the Port at peak tMes of the day.

Stephen Reid Managing Director Stephen Reid Consulting Traffic and Tmnsportatlon Umfted 28.09.2014

Stephen k i d consulting Traffic and fransportatbn Umlted Unit3, Malahlde MarIna Wbge Malahide Co Dubnn pdenreld A~enretdm~suhln~corn

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