Thursday, September 02, 2010

Copy of Full Submission on Dart Interconnector to An Bord Pleanala

Dear Sir/Madam,

We accept the principle of linking the mainline railway with the DART and LUAS lines and the proposed METRO. While we do not oppose the Interconnector project we have serious concerns about aspects of the proposals as detailed in the Railway Order.
The Interconnector will cause major disruption at three points along its route – Inchicore, St. Stephen’s Green and East Wall.

It appears that no consultation has taken place locally regarding St. Stephen’s Green; that minimal consultation has taken place with the community of East Wall and that Iarnród Éireann engaged in full and frank consultation with the residents of Inchicore.

Indeed the original proposal for tunnelling along the route had been presented as tunnelling from both Inchicore and East Wall. Yet to the consternation of the residents of East Wall the public assertions of Iarnród Éireann were altered and the Railway Order applied for in July 2010 sought to tunnel only from East Wall.
Thus East Wall will become the hub of the Interconnector Project and bear the brunt of the works for the entire duration of the project.

The main tunnelling works will initiate in East Wall; the spoil will be excavated and transported from there; the operational Control Centre, Management Suite and traction sub-station and Intervention shaft will all be located there if the Draft Railway Order is approved in its present form.

The proposed development will take almost a decade to complete. East Wall will be visited with disruption from spoil removal, noise, dust and traffic congestion for the duration of this major development.
When complete it will create a visual intrusion on the landscape and an extra volume of noise from the increased activity along the new Interconnector and old mainline railway.

In return East Wall will receive absolutely no benefit – not even a DART station to improve public transport which is woefully inadequate in the East Wall area.
It is a bleak prospect, and no wonder the closely knit residential East Wall community is angry and feels discriminated against by Iarnród Éireann.
East Wall is a small, urban community of about 3,500 people. The original houses are almost entirely two storey, built on land reclaimed from the sea. East Wall lies within the curve of the railway line and is isolated from the rest of the City.
Due to its low-lying location it has been subjected to flooding, the most recent being last year, 2009. Householders find it difficult and expensive to get home insurance.

In 2004 wishing to be considered as a distinct community within the Dublin Docklands and impatient with the lack of community gain from the burgeoning Docklands development the East Wall Area Action Plan was drawn up with the Dublin Docklands Development Authority.

Most recently in the present Draft Dublin City Development Plan (2011 – 2017) East Wall succeeded in persuading the City Council that it should be granted a Local Area Plan (LAP). When complete the LAP will provide East Wall with a statutory framework for future development. This plan will enable East Wall to protect its amenities, heritage and character and establish appropriate height and density for future developments.

The Railway Order is silent on both plans for East Wall and Iarnród Éireann has not included them in any way in the Interconnector Project.
East Wall needs sensitive treatment from planners and community benefit from major projects that impact on the area.

In our submission today we appeal to An Bórd Pleanála for a fair hearing for the East Wall Community.

We wish to raise the following issues of concern to the residents of East Wall.

A project as large as the DART Underground Interconnector requires an oral hearing so that citizens, communities and businesses along the route can express their views and concerns.

The residents of East Wall have already incurred substantial costs in preparing their submission and will incur ongoing costs for the duration of the project. Iarnród Éireann should pay the bill for all reasonable costs incurred by communities along the route.

The Interconnector will benefit the people of Dublin. However, it will seriously discommode the people of East Wall and Inchicore during its construction. It is unreasonable that the benefit of a local station should accrue to Inchicore while East Wall will suffer a double whammy of not getting a local station but becoming the tunnelling hub of the entire project. East Wall should be provided with a local station and the tunnelling should be shared equally between both Inchicore and East Wall. Moreover, if four Tunnel Boring Machines (TBMs) were employed instead of two, the work could be carried out much more quickly and efficiently and with far less adverse impact on both communities.

A comprehensive survey of the health and homes of people in the vicinity of the tunnel should be carried out prior to tunnelling. Damage to health and property should be monitored throughout the duration of the project.

There are serious question marks about the entire alignment along West Road. It is unclear why the new proposed bridge needs to be taller and wider than the old bridge; why a cycle lane is part of the proposal; what purpose the so-called “emergency”/evacuation footbridge at West Road serves; and why a permanent retaining wall is necessary.

The proposed works at and behind Abercorn Road are substantial and would impact heavily on the local residents particularly in relation to truck movements. The backup travel route proposed to the rear of Abercorn Road and Irvine Terrace should not be permitted, as it would cause noise, dust and disturbance.
Likewise Blythe Avenue, Hawthorn Terrace and Church Road are likely to experience disruption and disturbance during the construction and tunnelling phase with residents’ enjoyment of their homes being severely curtailed.

An Independent Arbitrator should be appointed to resolve any dispute that might arise with the main contractor during the lifetime of the project.

The main contractor for the project must produce in consultation with Iarnród Éireann the following documents: The Construction Code of Practice, A Noise and Vibration Plan, An Environmental Management Plan, A TBM Mitigation Plan, A Traffic Management Plan, and a Dust Minimisation Plan. These documents should be supplied to the residents as soon as possible and included in an agreement with the contractor. This should be a condition of the Railway Order.

There should be a Charter of Rights drawn up between the residents of East Wall and Iarnród Éireann. It would be enforced by the Independent Arbitrator.

A liaison committee should be established between the East Wall Action Group and Iarnród Éireann for the duration of the project to monitor progress and to address potential crises or emergencies.

The East Wall community should benefit from a local employment clause of 20% of the workforce and apprenticeships and should also benefit from Community Gain funding for local community-based projects and scholarships during the construction period and the subsequent operation of the Interconnector.

The spoil from the tunnelling should be transported out of the area by means of the existing mainline railway so as to minimise pollution and road traffic disruption.

Car and truck parking for the large number of on site workers should be planned in such a way that the streets of East Wall and North Strand would not be clogged with vehicles for years to come.

Hours of working should be determined by An Bórd Pleanála and should be in accordance with the wishes of the residents.

The proposed Operational Control Centre, Management Suite and Eastern Intervention Shaft should be located outside of East Wall as they would be visually intrusive.

Flooding has taken place as recently as last year in East Wall. The Railway Order should include a comprehensive plan to deal with the low water table and the likely
flooding of the tunnel during construction and the eventuality of flooding in the tunnel and in East Wall in the future.

Finally, when the project is complete Iarnród Éireann should provide a thorough landscaping of all the areas affected with a view to reducing adverse visual impact and improving the environment. This should be a condition of the Railway Order, as on a previous occasion in 2002, Iarnród Éireann failed to carry out its commitment to landscape its property in the North Strand Area.

In conclusion, we support the submission made by the East Wall Community through the East Wall Action Group.

They have requested an oral hearing and we earnestly request that it be granted.
Should it be granted we would welcome the opportunity of making an oral submission.

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