The first public consultation project on DART + West closed on 21 October 2020.
In advance of that deadline, we put together tips on preparing submissions and ideas for issues to raise in submissions, which are shown below.
General Tips
Don’t focus narrowly on the impact of the proposed road bridge on your own property, include some consideration of the ways it will impact the wider community.
Focus the impact of the proposed road bridge in your submission rather than spending a great deal of time trying to convince Irish Rail to consider alternative solutions. Other options were considered and the bridge through Riverwood is the ’emerging preferred option’. We must focus on making sure this option is taken off the table.
We advise that you maintain a respectful and constructive tone in your submissions.
Remember there are four ways to make a submission to Irish rail:
- Via a feedback form on their website
- Download, print and post back a feedback form
- Phoneline: (01) 823 5127
- Email: DARTMaynooth@irishrail.ie
We have also created an online app to guide you through creating a submission. You do not have to install anything. It provides ideas of points to include in your submission and creates a draft email. It does not send the email – you can edit it before sending. It does not store your email address or your email.
- Follow this link to download the app.
- Follow this link to watch a ‘How To’ video to help you use the app.
We invite you to send a copy of your submission to us so that we can make it available to others and to local representatives so that they are clear on your views. A list of representatives and their contact details is available on our ‘background and documents’ page.
Inadequate public consultation process
The time frame for the public consultation has been extremely short, particularly as it is taking place at a time when it is difficult for residents to meet and discuss issues raised due to Covid-19 restrictions.
Many residents of Riverwood did not receive notification from Irish Rail that a public consultation was underway.
The information available on the Irish Rail website is difficult to find, read and navigate. For those without computer equipment and/or strong ICT and literacy skills it is extremely difficult, if not impossible, to access. Public webinars held by Irish Rail to date have not been well advertised.
Errors and Omissions
Keep and Upgrade the Level Crossing
Keeping one level crossing open will not prevent the electrification of the Maynooth line. This option would have the least impact on the community, traffic and the environment. It is also an option (the ‘do nothing’ option) that rates highly in their own multi criteria analysis. Irish Rail only considered keeping the level crossing open exactly as it operates today, they have not looked at possibilities for improving safety or gate closure times.
The UK’s Network Rail acknowledge that ‘closing our level crossings isn’t always a realistic option for the communities they serve. That’s why since 2009, we have invested over £200 million in improving safety at thousands of crossings’ (Network Rail, Enhancing Level Crossing Safety, 2019-2029, p. 5). According to the same document, Ireland already has the safest level crossings in Europe (p. 10). Why can’t Irish Rail invest their money and energy in safety improvements for Coolmine Level Crossing instead of building unwanted and expensive bridges?
Irish Rail also argue that the increased number of trains the DART+ project will deliver will make Coolmine Level Crossing untenable. Their data is based on current gate closures at peak times. They have not explained if it is possible to reduce gate closure times (e.g. through automation and improved signalling) as is the case with the DART line on the Southside. We also need to know why other potential solutions, such as peak time gate closures, have not been considered in this case.
Errors in Multi Criteria Analysis
There are a number of colour coding errors evident in the multi criteria analysis matrices prepared by Irish Rail to justify their decision to identify Option 3 / the proposed bridge as their ’emerging preferred option’. The errors relate to discrepancies between the text provided in the MCA 1 and MCA 2 matrices (i.e. ‘Significant comparative advantage over all other options’ etc) and the colour coding system used. In MCA 1 (See ‘Annex 9.3B Stage 1 MCA Level Crossing matrices’), the following sub-criteria have been assigned the wrong colour code: Option 3, 4.1 and 4.2; Option 4, 4.1 and 4.2; Option 5, 4.1 and 4.2. In MCA 2 (See ‘Annex 9.3B Stage 2 MCA Level Crossing matrices’), the following sub-criteria have been assigned the wrong colour code: Option 1, 1.1, 1.2, 5.3, 6.2; Option 3, 3.2; Option 4, 3.6; Option 6, 3.2, 5.3 and 6.2. Once these colour coding errors are accounted for, it is very difficult to see how Option 3 / the proposed bridge through Riverwood was identified as the ’emerging preferred option’ for Coolmine Level Crossing.
Social Inclusion and Accessibility
Irish Rail have provided very little detail in their published documents on the impact of the ’emerging preferred option’ in terms of Social Inclusion and Accessibility, which is a matter that is supposed to be addressed in detail as part of their option selection multi criteria analysis. There is also very little detail on the Pedestrian, Cyclist and Vulnerable Road User Safety sub-parameter and the Physical Activity sub-parameter.
This gap in research may explain why Irish Rail were not aware of the busy pedestrian route through Riverwood Court and Riverwood Hall to the level crossing (per responses to questions at a webinar on 7 Sept. 2020), which is routinely used by Irish Rail customers, as well as individuals and families accessing childcare and other amenities on the other side of the level crossing.
Since there are such severe shortages in the availability of early years childcare services in Dublin 15 at present, any development that will hinder access such facilities, particularly by foot, will have significant equality and social inclusion implications. The failure of Irish Rail to take this route into account in MCA1 or MCA2 raises further questions about the accuracy and reliability of their analysis to date.
Errors and omissions such as these undermine public trust in Irish Rail’s research and the whole consultation process.
Traffic Chaos
The Riverwood distributor (ring) road is already congested at peak times. With the closure of Clonsilla and Porterstown level crossings to traffic, the proposed bridge through Riverwood would bring additional volume of cars through this route, leading to increased traffic congestion. Future development planned for the area (e.g. at Kellystown) will put further pressure on the local road network.
Irish Rail claim that closing level crossings is necessary for safety reasons but any increase in traffic in the local area will have a negative impact on road safety for everyone, particularly pedestrians and cyclists who will have to navigate much busier and more dangerous roads. The impact of increased numbers of cars and increased congestion on the local fire station and other emergency services, as well as access to local schools is not clear.
Local car journeys for residents will also be complicated. Residents of Riverwood will have difficulty leaving their own estates. Simple journeys that we all take for granted (e.g. to go to the nearest supermarket at Roselawn Shopping Centre) will become lengthier and more frustrating.
Irish Rail’s traffic survey does not take into account longer term changes that Covid-19 restrictions and changes in working practices will have on traffic in Dublin 15. Constructing a major new road bridge prioritises the needs of motorists over the community and will cause irreversible damage to the environment and residential amenity.
Other options proposed by Irish Rail provided better integration and traffic flow.
Visual and environmental impacts
The emerging preferred option will see a bridge, similar in height to Dr Troy Bridge, built in a quiet cul-de-sac in Riverwood. This bridge will be visually obtrusive, not only for residents in properties facing it, but for those in the surrounding area.
Moving traffic from its existing route and bringing it into a quiet residential area will have a devastating impact on living conditions, increasing noise and air pollution, and impacting the health and well-being of residents. According to a WHO report ‘Traffic-related noise accounts for over 1 million healthy years of life lost annually to ill health, disability or early death in the western countries in the WHO European Region’. According to Irish Rail’s MCA2, the proposed bridge is the option that will directly impact the most residential properties of the four options considered with increased noise and air pollution.
The proposed bridge will destroy green areas used by resident children and adults. Due to Covid-19 restrictions, these green spaces have become more important than ever for the mental and physical health of residents. These green areas are also used frequently by pedestrians, joggers, walkers and cyclists who live in the surrounding areas, including Irish Rail customers accessing the station.
The environmental impact of the proposed bridge on trees and wildlife in the estate, and on the section of the canal affected (which is part of a proposed Natural Heritage Area), has not been made fully clear by Irish Rail to date.
Other options proposed by Irish Rail are much less disruptive of the existing residential amenity and the environment.
Fingal Development Plan
The Fingal Development Plan includes two local objective points: ‘Preserve the existing pedestrian and vehicular right of way at the Coolmine Level Crossing’, and ‘Prohibit any road bridge’ across the train line and canal at Riverwood/Station Court (Sheet 13 Blanchardstown South Local Objective Points No. 141 & No. 142). All of the options proposed by Irish Rail conflict with one local objective point of Fingal Development Plan but the ’emerging preferred option’ conflicts with two.
It is also worth noting the zoning objectives for the green open spaces affected by the proposed bridge are to ‘Preserve and provide for open space and recreational amenities’, with a view to providing ‘recreational and amenity resources for urban and rural populations subject to strict development controls. Only community facilities and other recreational uses will be considered and encouraged by the Planning Authority’.
The estates that will be affected by the proposed bridge are also located in a ‘highly sensitive landscape’ area, which means it is a site that is particularly vulnerable to change and, as a result, is associated with a series of natural heritage planning objectives.
Other options proposed by Irish Rail are more supportive of Fingal Development Plan.
Crime and Anti-Social Behaviour
A cul-de-sac at Coolmine train station will introduce a risk of antisocial behaviour as there will be a lack of passing vehicular traffic.
Key points
Irish Rail’s proposed bridge through Riverwood is not the right solution.
The public consultation process has been inadequate, and there are serious errors and omissions in the information Irish Rail have provided to the public. It is not even clear if the proposed bridge is really Irish Rail’s ’emerging preferred option’.
The proposed bridge will divide our community and have a devastating impact on the environment and existing residential amenity. It also puts cars before communities and will contribute to already significant traffic congestion in the area.
There are other, better, options for Coolmine Level Crossing.
The requirement for Irish Rail to deliver a public service does not outweigh the harm that the ’emerging preferred option’ will inflict on directly affected residents and the wider community.
Submissions
Some residents have given us permission to post their submissions on this site – we have added them to a Submissions page. These may help you when writing your own submission.
[RRA home page] [Proposed Bridge home page][Background and Documents][Submissions page][Useful downloads]