appendix 1 - summary of written submissions

29S.NA0005 DART Underground Summary of Written Submissions to An Bord Pleanala 1

An Bord Pleanála

29S.NA0005 Dart Underground

Inspector’s Report - Appendix 1

Summary of Written Submissions to An Bord Pleanala


Introduction

This report is a summary of the written submissions received by An Bord Pleanala in August

2010 in relation to the railway order application. The submissions relate to the proposed

railway order and/or the likely effects on the environment of the proposed railway works

and/or objections to the proposed compulsory acquisition of lands relating to the order.

Including those from the Planning Authority and prescribed bodies, the Board received 245

submissions. This report has been compiled by Tom Rabbette, Senior Planning Inspector.

List of submissions received:

PLANNING AUTHORITY page 10

1. Dublin City Council

PRESCRIBED BODIES page 11

2. An Taisce

3. Department of Communications, Energy and Natural Resources

4. Waterways Ireland

5. Department of Agriculture, Fisheries and Food

6. Inland Fisheries Ireland

7. Health Service Executive

8. Dublin Docklands Development Authority

9. Office of Public Works, Head Office, Trim, County Meath.

10. Health and Safety Authority, the Metropolitan Building, James Joyce Street, Dublin 1

11. RPA, Parkgate Street, Dublin 8

12. Department of the Environment, Heritage and Local Government

PUBLIC REPRESENTATIVES page 21

13. Maureen O’Sullivan TD and Councillor Marie Metcalfe, c/o Dail Eireann, Leinster

House, Kildare Street, Dublin 2.

14. Lucinda Creighton TD, c/o Dail Eireann, Leinster House, Dublin 2.

15. Councillor Claire O’Regan, 66 Sea View Avenue, East Wall, Dublin 3.

16. Bertie Ahern TD, Dail Eireann, Leinster House, Kildare Street, Dublin 2.

17. Councillor Mary Fitzpatrick, Dublin City Council, Members Room, City Hall, Dublin 2.

18. Councillor Nial Ring, 70 Ballybough Road, Ballybough, Dublin 3.

19. Councillor Kevin Humphreys, Dublin City Council, Wood Quay, Dublin 8.


20. Senator Paschal Donohoe and Councillor Ray McAdam, Constituency Office, 6A

Phibsborough Plaza, Phibsborough, Dublin 7.

21. Patrick Martin, Chairman Ógra Fianna Fail Dublin Central, 37 Leinster Avenue, North

Strand, Dublin 3.

22. Mary Upton TD, Dail Eireann, Kildare Street, Dublin 2

23. Mary Lou McDonald and Councillor Seamus McGrattan, c/o Mary Lou McDonald, 58

Faussagh Avenue, Dublin 7

24. Joe Costelloe TD, Dail Office, Dail Eireann, Kildare Street, Dublin 2

25. Aengus O’Snodaigh TD, Teach Laighean, Sráid Chill Dara, Baile Átha Cliath

26. Catherine Byrne TD and Councillor Claire Byrne, 30 Bulfin Road, Inchicore, Dublin 8

27. Chris Andrews TD, Dail Eireann, Leinster House, Kildare Street, Dublin 2

28. Councillor Kieran Perry, Members Room, City Hall, Dublin 2

29. Oisin O’Halmhain, 18 Viking Harbour, Ushers Island, Dublin 8.

30. Kathleen Kelleher, 27 Rathdown Park, Greystones, Co. Wicklow.

31. Sean Ardagh TD, 168 Walkinstown Road D12.

32. Cyprian Brady TD, St. Lukes 161 Lower Drumcondra Road D9

33. Ruadhan Mac Aodhain BL, 29 Munster Street Phibsborough Dublin 7

GENERAL OBSERVER SUBMISSIONS page 40

34. Roger O’Connor, c/o Peter Sweetman & Associates, 184 Lower Rathmines Road,

Rathmines, Dublin 6

35. Centre for Independent Living, c/o David Egan, Carmichael House, North Brunswick

Street, Dublin 7.

36. Irish Wheelchair Association, c/o Aras Chúchulainn, Blackheath Drive, Clontarf, Dublin

3.

37. Rail Users Ireland, c/o Colm Moore 42 Kenilworth Square, Dublin 6

38. Donie O’Leary and Morgan McKnight, People With Disabilities in Ireland, 4th

Floor,

Jervis House, Jervis Street, Dublin 1

39. Luke Gardiner Ltd., 19 Mount Joy Square, Dublin 1

40. Gerard Ellis, 8 Wyattville Road, Ballybrack, County Dublin.

41. Dublin Chamber of Commerce, 7 Clare Street, Dublin 2

42. Cormac Rabbitt, Dargan Project, 8 Hy Brasail Court, Circular Road, Galway

43. National Disability Authority, c/o Siobhan Barron, 25 Clyde Road, Dublin 4

44. Warren Whitney, 31 The Avenue, Boden Park, Rathfarnham, Dublin 16

45. Dublin City Centre Business Association Ltd, c/o Tom Coffey, 21 Dawson Street, Dublin

2

AREA 101 - Inchicore to Memorial Park page 54

46. Patricia Corry, 4 St. Patrick’s Terrace, Inchicore, Dublin 8.

47. Joseph Anthony Currivan, 5 St. Patrick’s Terrace, Inchicore, Dublin 8

48. Jo Homewood & Ned McLoughlin, 1 St. George’s Villas, Inchicore, Dublin 8

49. Gerard McGeough and Louisa MacDonald, 1 St. Patrick’s Terrace, Inchicore, Dublin 8.

50. Conor Flood and others, c/o 6 Terrace, Inchicore, Dublin 8.

51. Alan Casey, 215 Kilmainham Square, Inchicore Road, Dublin 8.


52. John B. O’Connor and Kay White, 2 St. George’s Villas, Inchicore, Dublin 8

53. David Reynolds, Sky Property Management Limited, 32 Stepaside Park, Stepaside,

County Dublin for the residents of Wheaton Court, Inchicore Terrace North, Dublin 8.

54. Siobhan Martin, 118 Inchicore Road, Inchicore, Dublin 8

55. David Sherwin, 112 Inchicore Road, Dublin 8 and Cecilia Clifford 116 Inchicore Road,

Dublin 8

56. Ann O’Gorman, 4 Woodfield Place, Inchicore, Dublin 8.

57. Edel Quinn and Joe Kerrins, 2 North Terrace, CIE Works Dublin 8

58. Billy McCannon Resident of St. Patrick’s Terrace, Inchicore, Dublin 8

59. Daniel Keleher, 16 Abercorn Square, CIE Estate, Inchicore, Dublin 8.

60. Aifric Ni Chianáin, 12 Ontario Terrace, Rathmines, Dublin 6

61. Tessa Robinson and Robert Purcell, 8 St. Patrick’s Terrace, Inchicore, Dublin 8

62. Louise Carroll, 412 Le Fanu Road, Ballyfermot, Dublin 10

63. Gerard Green, Aoife Lawlor and others, c/o 12 Woodfield Avenue, Inchicore, Dublin 8

64. Jonathon Archer, OZO 24-7 Collect and Rescue Kylemore Business Park, Kylemore

Way, Dublin 10

65. Niamh Flood, David Lawless and May Flood Lawless, 3 St. George’s Villas, Inchicore

Parade, Dublin 8

66. Niamh Flood, Secretary, The Inchicore Sports and Social Club, Library Square,

Inchicore, Dublin 8

67. Sherling Group, Jamestown Rd. Inchicore, Dublin 8

68. Inchicore On Track, John Beck, Chairperson, 5 North Terrace, Inchicore Dublin 8

AREA 102 - Memorial Park to Heuston page 83

69. Susan Byrne, Parkgate Place Management Company Limited for Parkgate Place

Apartment Complex, Parkgate Street, Dublin 8

70. Mr. Pat McDonagh, Managing Director, Supermac Limited, Supermac Head Office,

Ballybrit Business Park, Ballybrit, Galway

AREA 103 - Heuston to Christchurch page 84

71. Flancrest Enterprise Limited, c/o Sudway and Company Limited, Chartered Surveyors,

Riversdale View, Ballyboden Road, Rathfarnham, Dublin 14.

72. Berndorf Limited, 16 Palmerston Park, Rathmines, Dublin 6.

73. Diocesan Property Manager, Archdiocese of Dublin, c/o Holy Cross Diocesan Centre,

Clonliffe Road, Dublin 3.

74. TASCQ, Temple Bar Traders, 27 Eustace Street, Temple Bar, Dublin 2

75. Temple Bar Cultural Trust 12 East Essex Street, Temple Bar, Dublin 2

76. Noel Leonard, 40 Wattling Street, Victoria Quay, Dublin 8

77. Diageo Ireland, St. James’s Gate, Dublin 8

78. The Atrium Management Company Limited, Island Street c/o Sudway and Company

Limited, Riverside House, Riverside View, Ballyboden Road, Rathfarnham, Dublin 14.

79. Michael Casey, 26 Fishamble Street, Dublin 8


80. Pat Carroll, ECW Limited, 14 Ushers Island, Dublin 8

81. Mary and David O’Flanagan, Car Upholstery Covers, 12 and 13 Ushers Island, D 8

82. Raymond Peers, Chief Executive Q Park Ireland Limited, Head Office, Marlborough

Street, Dublin 1

AREA 104 - Christchurch to Merrion Square page 92

83. Boston College Ireland Limited, 42-43 St. Stephen’s Green, Dublin 2.

84. Ciaran McGrath, 22 St. Stephen’s Green, Dublin 2.

85. Damien O’Regan, 1 Westfield, Sion Hill, Blackrock, County Dublin.

86. John Barron, c/o Lambe and Tyndall Architectural Practice, c/o Park Chambers, 13

St. Stephen’s Green, Dublin 2.

87. Fitzwilliam Land Securities, 57 Fitzwilliam Square, Dublin 2.

88. Joselyn Braddell and Others, 36 Highfield Road, Rathgar, Dublin 6.

89. Irish Georgian Society, 74 Merion Square, Dublin 2.

90. Salix Trust Limited, c/o RPS Planning and Environment Consultants, Dun Laoghaire,

County Dublin.

91. James Adam and Sons Limited, c/o Reed Associates, Sandycove, County Dublin.

92. Ciaran McGrath, c/o OLM Consultancy, 33 Fitzwilliam Place, Dublin 4.

93. Perlar Limited, c/o O’Connor Sutton Cronin & Associates, 9 Prussia Street, Dublin 7.

94. Corcia Acquisitions Limited, c/o O’Connor Sutton Cronin & Associates, 7 Prussia

Street, Dublin 7.

95. Suzanna Jackson, c/o Il Posto Restaurant, 10 St. Stephen’s Green, Dublin 2.

96. Thomas Barry and Company Solicitors, 11 St. Stephen’s Green, Dublin 2.

97. Bartral Limited, c/o O’Connor Sutton Cronin & Associates, 9 Prussia Street, D 7.

98. Alric Limited, c/o O’Connor Sutton Cronin & Associates, 9 Prussia Street, Dublin 7.

99. Sean and Madeleine Mulligan, 54 The Green, Woodbrook Glen, Bray, Co Dublin.

100. Pat and John Sexton, Michael Power, Acuman Facilities Management, Swords

Business Campus, Balheary Road, Swords, County Dublin.

101. Gerry Dempsey and others, Europlan Insurances Limited, 11 St. Stephen’s Green

North, Dublin 2.

102. Deks Limited, c/o Owen P. Clear Solicitors, 42 St. Stephen's Green, Dublin 2.

103. William Murray and Rory Fitzpatrick, 11 St. Stephen's Green North, Dublin 2.

104. Derek Flood, Bentleys Oyster Bar and Grill, 22 St. Stephen's Green, Dublin 2.

105. Anglo Irish Assurance Company Limited, c/o Arthur Cox Solicitors, Earlsfort Centre,

Earlsfort Terrace, Dublin 2.

106. Bank of Scotland (Ireland), 124-127 St. Stephen's Green West, Dublin 2.

107. Ampleforth Limited c/o John Spain Associates, Lower Mount Street, Dublin 2.

108. Peploes Restaurant, Basement of 16 St. Stephen’s Green North, Dublin 1 care of

Aidan McLernon, Cunnane Stratton Reynolds, 3 Molesworth Place, Dublin 2

109. Kildare Street and University Club of 17 St. Stephen’s Green, Dublin 2 care of

Eoghan P. Clear Solicitors, 42 St. Stephen’s Green, Dublin 2

110. Ray Mooney, General Manager, Stephen’s Green Hibernian Club, 9 St. Stephen’s

Green, Dublin 2.


AREA 105 - Merrion Square to the River Liffey page 132

111. Rory Dunne, 6 Pearse Square, Dublin 2.

112. Stefano Crescenzi, 8 Pearse Square, Dublin 2.

113. Federico Crescenzi, 26 Pearse Square, Dublin 2.

114. Eileen Dunne, 8 Pearse Square, Dublin 2.

115. Sean Crescenzi, 7 Pearse Square, Dublin 2.

116. Aislinn Crescenzi, 7 Pearse Square, Dublin 2.

117. Barbara Dawson, 44 Pearse Square, Dublin 2.

118. Timothy Lynch, 51 Pearse Square, Dublin 2.

119. Mark Kelly, 15 Pearse Square, Dublin 2.

120. Patrick Sherwin, 33 Pearse Square, Dublin 2.

121. David Hughes, 35 Upper Erne Street, Dublin 2.

122. Residents of Upper Erne Street, c/o David Hughes, 35 Upper Erne Street, Dublin 2.

123. Carmel McCormack, 35 Upper Erne Street, Dublin 2.

124. Marie Mackey, 32 Upper Erne Street, Pearse Street, Dublin 2.

125. Michael Keegan, 35 Upper Leeson Street, Dublin 4.

126. Edith MacGarry and Damien MacGarry, 196 Rathfarnham Road, Dublin 14.

127. Una O’Kane, 29 Boyne Street, Dublin 2.

128. Patricia Ford, Boyne Street Residents 26 Boyne Street, Off Westland Row, Dublin 2.

129. Brenda Reilly, Boyne Street Residents Group, 8B Boyne Street off Westland Road,

Dublin 2.

130. Joan Coburn, 31 Boyne Street, Dublin 2.

131. Geraldine Byrne, Sandwith Street Residents, 5 Sandwith Street Upper.

132. Melanie Woods, St. Andrews Court 1-16 Residents Group, 15 St. Andrews Court,

Fenian Street, Dublin 2.

133. Paul Mangan, Trinity College Dublin, Director of Buildings Office, West Chapel,

Trinity College, Dublin 2.

134. Petra McDonnell, 28 Pearse Square, Dublin 2.

135. Noel Ryan, Romara, White Cross, Bray Road, Foxrock, Dublin.

136. Tom Bailey and Caroline Bailey, Culcommon, Batterstown, County Meath.

137. Irish Prison Officers Association, c/o DBFL Consultant Engineers, Herbert House,

Harmony Row, Dublin 2.

138. Catherine Guy, ByrneWallace, 2 Grand Canal Square, Dublin 2

139. James Synott Cedar Cottage, Old Russian Village, Kilquade, County Wicklow.

140. O’Callaghan Hotels and Associated Companies care of John Spain Associates, 10

Lower Mount Street, Dublin 2.

141. Chartered Land Usher House, Main Street, Dundrum, Dublin 14, care of Stephen

Little & Associates, 6 Upper Mount Street, Dublin 2

142. Grand Canal Theatre Company Limited, Grand Canal Theatre, Grand Canal Square,

Docklands, Dublin 2, c/o John Spain Associates, Planning and Development Consultants,

10 Lower Mount Street, Dublin 2.


143. Tim Lynch, (E. Dunne, Barbara Dawson and Rory Dunne), Pearse Square Residents

Association, c/o 51 Pearse Square, Dublin 2

AREA 106 - River Liffey to East Wall page 171

144. Elizabeth Corrigan, 7 Abercorn Road, East Wall, Dublin 3.

145. Lawrence Redmond, 80 West Road, East Wall, Dublin 3

146. Phyllis Doyle & others, c/o 25 Crescent Gardens, East Wall, Dublin 3

147. James Duffin, 3 Abercorn Road, East Wall, Dublin 3

148. Carmel Kelly & others, c/o 8 Killane Court, East Wall, Dublin 3

149. Paul O’Brien, 171 Crosby’s Yard, Ossory Road, Dublin 3.

150. Aidan Foley and Master Labs Limited, 81 West Road East Wall, Dublin 3.

151. Angela Wigglesworth and others, 9 Abercorn Road, East Wall, Dublin 3.

152. Ian Hand, 40 Blythe Avenue, East Wall, Dublin 3.

153. Martina Kelly and Paul Corrigan, 38 Blythe Avenue, East Wall, Dublin 3.

154. Karl O’ Grady and Deirdre O’Reilly, 41 Blythe Avenue, East Wall, Dublin 3.

155. Lisa McQueen and Sandra McQueen 12 West Road, East Wall, Dublin 3.

156. Lisa Reade and Brian Reade, 23 Portside Court, West Road, East Wall, Dublin 3.

157. L. Hynes, 53 West Road, East Wall, Dublin 3.

158. Lynn Durie and Cormac O’Brien, 49 West Road, East Wall, Dublin 3.

159. Denise Wright 64 West Road, East Wall, Dublin 3.

160. Shalom Binchy and Niall Nolan, 15 Hawthorn Terrace, East Wall, Dublin 3.

161. Terrance Mehlhorne, 26 Hawthorn Terrace, East Wall, Dublin 3.

162. Maria Ronan, 22 Sea View Avenue, East Wall, Dublin 3.

163. Tommy Seery, 9 Sea View Avenue, East Wall, Dublin 3.

164. Margaret Ballot and others, c/o 40 Sea View Avenue, East Wall, Dublin 3.

165. Pavla Simdova and others, c/o 10 Fair Field Avenue, East Wall, Dublin 3.

166. Carmel Cosgrave and others, c/o 31 Fair Field Avenue, East Wall, Dublin 3.

167. Emma McDonnell, 73 West Road, East Wall, Dublin 3.

168. Protect East Wall Group, c/o BPS Planning Consultants, 23 Saville Park Road,

Dalkey, County Dublin.

169. Philip McGovern & others, c/o 29 Church Road, East Wall, Dublin 3

170. Leslie Maher, Zen Hair and Beauty, 32 Church Road, East Wall, Dublin 3.

171. Helen McCabe and others, c/o 11 Church Road, East Wall, Dublin 3.

172. Susie Lynam and others, c/o 133 Church Road, East Wall, Dublin 3.

173. Bernie Fleming and others, c/o 5 Church Road, East Wall, Dublin 3.

174. Ann Flanagan and others, c/o 48 Church Road East Wall, Dublin 3.

175. Eugene Gilsenan, 43 Church Road, East Wall, Dublin 3.

176. Steve O’Connor and others, c/o of 167 and 168 Church Road, East Wall, Dublin 3.

177. James Lee, 69 Church Road, East Wall, Dublin 3.

178. Christopher Kavanagh, 20 Strangford Road, East Wall, Dublin 3.

179. Adrienne Redmond and others, c/o 6 Strangford Gardens, East Wall, Dublin 3.

180. Patricia Mulhall, 126 Caledon Road, Drumcondra, Dublin 3.


181. Shane Roe, 18 Moy Elta Road, East Wall, Dublin 3.

182. Laura O’Connor, 130 Caledon Road, Drumcondra, Dublin 3.

183. Stephen O’Brien and others, c/o 9 Hawthorn Terrace, East Wall, Dublin 3.

184. Karen Broderick, Irvine Terrace, East Wall, Dublin 3.

185. Karen Greene and others, c/o 23 Shelmalier Road, East Wall, Dublin 3.

186. Michael Muldodney, 7 St. Barnabas Gardens, East Wall, Dublin 3.

187. Declan Rogers, 34A Kincora Avenue, Clontarf, Dublin 3.

188. Business Owners, Ossory Road Industrial Estate, Dublin 3. Michael Kennedy and

others

189. Declan Roche and others, c/o 75 St. Mary’s Road, East Wall, Dublin 3.

190. Eva Dillon, Daisy Days Community Childcare, Sean O’Casey Community

Centre, St. Mary’s Road, East Wall, Dublin 3.

191. Gerry Fay, Chairman, North Wall Community Association, 77 Seville Place,

Dublin 1.

192. The Crosby’s Yard Residents Committee, c/o Hannah O’Neill, 169 Crosby’s

Yard, Ossory Road, Dublin 3.

193. Declan Tuite and Anna Weiss, 114 Crosby’s Yard, Ossory Road, Dublin 3.

194. Residents of Nos. 61, 62, 63, 64, 65, 66, 67, 68, 69, 70, 71, 75 and 77 West

Road, East Wall, Dublin 3.

195. Sean, Mary and David O’Connor, 33 West Road, East Wall, Dublin 3.

196. Marie and Angela Broderick, 35 West Road, East Wall, Dublin 3.

197. Seamus Cummins and Delphine Guine, 40 West Road, East Wall, Dublin 3.

198. Marcella Shanley, No. 39 West Road, East Wall, Dublin 3.

199. Jody Toner and Anna Morgan, 37 West Road, East Wall, Dublin 3.

200. Patrick and Ann Lacombre, No. 36 West Road, East Wall, Dublin 3.

201. Andrew and Elizabeth Hulton, No. 34 West Road, East Wall, Dublin 3.

202. Margaret Roper, 82 West Road, Pat Ferry, 83 West Road, Michael and Ann

Kane of 14 Hawthorn Terrace and Oliver Martin of 20 Hawthorn Terrace, East

Wall, Dublin 3.

203. Doreen and Freda Caprani, No. 10 Strangford Gardens, East Wall, Dublin 3.

204. Thomas and Ita Hulton, No. 99 Caledon Road, East Wall, Dublin 3.

205. Mary Corcoran and Richard Hewer, 8 Abbercorn Road, East Wall, Dublin 3.

206. Marie, Matt & Jack O’Reilly, 2 Upper Mayor Street, North Wall, Dublin 1

207. Spencer Dock Owners Committee c/o Concierge Office, Spencer Dock

Apartments, Park Lane, North Wall Quay, Dublin 1.

208. Spencer Dock Development Company Limited, Connaught House, One

Burlington Road, Dublin 4.

209. Tony, Hilda & Derek McDonnell, 1 Mayor Street Upper Docklands, Dublin 1

210. North Port Dwellers’ Residents’ Association, c/o Tony McDonnell, 1 Mayor

Street Upper Docklands, Dublin 1

211. Price Waterhouse Coopers, 1 Spencer Dock, North Wall Quay, Dublin

212. Caren Gallagher, 16 Irvine Terrace, North Wall, Dublin 3

213. Emma and Sarah Donnelly, 124 Caledon Road, East Wall, Dublin 3


214. Edward Rainsford and others, c/o 41 West Road, East Wall, Dublin 3

215. Mr. Aiden Murray, Ross Spelman and Lillian Spelman, c/o 76 St. Lawrence

Road, Clontarf, Dublin 3

216. Phyllis Corcoran, Roger and Adrienne Gallihue and Jimi and Kay Alford, c/o Phyllis

Corcoran, 38 Church Road, East Wall, Dublin 3

217. Carmel Gormley and others, c/o Carmel Gormley, 4 Hawthorne Terrace, East Wall,

Dublin 3

218. Aidan Hurley, 4 Oxford Terrace, East Wall, Dublin 3

219. John Meade, 72 Russell Avenue, East Wall, Dublin 3

220. Jean Delaney, 29 Caledon Road, East Wall, Dublin 3

221. Angela Foley and others, c/o Angela Foley 22 West Road, East Wall, Dublin 3, (

222. Anne Fegan and others, c/o 122 Caledon Road, East Wall, Dublin 3

223. Joe Mooney, 34 Merchant Square, East Wall, Dublin 3

224. Michael Kennedy, Gore and Grimes, Cavendish House, Smithfield, Dublin 7

225. Margaret Mulhall, 58 Ravensdale Road, East Wall, Dublin 3

226. Christine and Martin Taylor, Ossory and District Residents Group, c/o 7 Ossory

Road, Dublin 3

227. Karim White and others, c/o 48 West Road, East Wall, Dublin 3,

228. Nascadh Community Development, 75 Teeling Way, East Road, East Wall, Dublin 3

229. Dolores Steele, Chairperson, Parkside North Strand Residents Group, 13 Hope

Avenue, Dublin 3

230. Amanda Ralph, Apartment 138, Crosbies Yard, Ossory Road, Dublin 3

231. Crosby Properties, Unit 24, Point Village, East Wall Road, Dublin 1

232. Diarmuid Reidy and others, c/o 5 St. Barnabas Gardens, East Wall, Dublin 3

233. East Wall Water Sports Group Ltd., c/o Paul Dolan PO BOX 11314, East Wall,

Dublin 3

234. East Wall Medical Centre, c/o Dr. Joseph Murphy, 145 Church Road, East Wall,

Dublin 3

235. Elaine and Paul Kenny, 35 Blythe Avenue, East Wall, Dublin 3

236. Ian Slacke and Emma Bradley, c/o 12 St. Mary’s Road, East Wall, Dublin 3

237. John Conway, 56 West Road, East Wall, Dublin 3

238. Sinead Courtney, 53 St. Mary’s Road, East Wall, Dublin 3

239. Anne Fegan, 122 Caledon Road, East Wall, Dublin 3

240. Brendan McManus, Ossory Properties, Unit 16, Ossory Court, 24 Ossory Road, North

Strand, Dublin 3

241. Anne Gahan, 3 Hawthorne Avenue, East Wall, Dublin 3

242. James Smith, 128 Caledon Road, East Wall, Dublin 3

243. Ruairi O’Meara, Coady’s Yard, West Road, Dublin 3

244. Vincent Keane, 201 Crosbies Yard, Ossory Road, Dublin 3

245. Patrick Tuite, 165 Church Road, East Wall, Dublin 3


Summary of Submissions:

PLANNING AUTHORITY

1. Dublin City Council

The contents of the submission from the above can be summarised as follows:

The Dart Underground (DU) supports the development strategy of the City

Development Plan 2005-2011

The development of DU is supported by a number of transport policies

Consultations have taken place with Irish Rail throughout the design process and the

PA is fully supportive of the provisions of this key piece of transport infrastructure

All of the heritage policies in the development plan require that extreme care is taken

when dealing with development in conservation areas and relating to protected

structures or National Monuments

The DU is considered to be a key element in the continuing economic development of

the city

The DU does not pass through any SAC, SPA or NHA.

The (then) draft Development Plan strongly supports the provision of all of the

Transport 21 projects

The DU, although not directly addressed in the Liberties LAP, does underpin a

number of elements of the overall vision of that LAP

The Dublin Docklands Masterplan 2008 supports the provision of the DU (referred to

as the Interconnector)

The North Lotts Planning Scheme 2002 as amended makes provision for the

Docklands Station

The DU is a critical economic asset to the city, the immediate environment, the wider

metropolitan area and the national economy

It is strongly recommended that the proposed development proceed because it will

deliver a wide range of economic, social and environmental benefits

The DU complies with the Vision Statement of the Regional Planning Guidelines for

the GDA 2010-2022

The Public Transport Programme of the ‘Infrastructure Investment Priorities 2010-

2016: A Financial Framework’ (DoF July 2010) prioritises the DU and Metro North

The DU will link the north and south city centres and will be a great boost to efforts to

deliver the planned investment in the Carlton and Arnotts developments.

The DU will have a strong regeneration benefit most directly on Heuston Quarter, the

Guinness lands, the Liberties, the Digital Hub and Docklands

The opening of the Convention Centre at Spencer Dock will be a great boost to

business tourism, the DU will be a critical link

There are no significant planning histories relating to the proposed development with

the exception of the Docklands station

The PA highlights the following applications: Fenian St. ref: 3327/08, OPW site

Jamestown Rd. Inchicore ref: 1601/07 and Clayton Love Distribution, Inchicore, ref:

2274/09


The DU complies with the hierarchy of plans set out for Dublin including the NSS,

the NDP, Platform for Change, Transport 21 and the Regional Planning Guidelines

Part V is not applicable

Parts of public amenity lands will be unusable during construction at St. Stephen’s

Green, Christchurch/Civic Offices, Station Square Docklands and Inchicore Playing

pitch, provided the areas are properly reinstated following construction, this situation

is acceptable

The PA supports the DU and considers that the assessment provided by the applicant

is satisfactory in terms of the statutory and planning context and in terms of the

information provided in the EIS

The PA highlights the need for attention to be paid to four areas in relation to the

proposed development and consequently of the requirement for specific conditions

relating to these areas

The four areas are: public realm infrastructure, impacts on protected structures and

buildings of architectural merit, final urban design of the proposed station and

archaeological assessment and provisions

DCC request that the board apply 114 conditions relating to the following issues:

o Planning/architecture 20 no. conditions

o Archaeology 10 no. conditions

o Road Works & QBN 10 no. conditions

o Noise, Vibrations, Settlement, Air Quality 17 no. conditions

o Water Services 12 no. conditions

o Drainage Services 9 no. conditions

o Flora & Fauna 10 no. conditions

o Parks & Landscape Services 12 no. conditions

o Traffic 11 no. conditions

o CPO Issue 1 no. condition

o Supervision 1 no. condition

o Development Contributions 1 no. condition

PRESCRIBED BODIES

2. An Taisce


The DU is a key measure to integrate connectivity of the rail system in Dublin

There are significant environmental impacts and mitigation measures to be addressed

in further consideration of the scheme

In particular the mitigation of impacts on residential communities at Inchicore and

East Wall

Individual station particularly those at Christchurch and Stephen’s Green pose

significant urban design challenges

Further significant revisions are required to minimise the impact on Stephen’s Green

The effect of the proposal at St. Stephen’s Green is seriously problematic in impact

There are significant issues with regard to the interface and sequencing of this

proposal with the metro North project and LUAS BXD proposals

An Oral hearing is requested


3. Department of Communications, Energy & Natural Resources

No observations/comments to make on the RO application

4. Waterways Ireland


WI is the body responsible for the Royal and Grand Canals in Dublin

Any impact on the canal structures should be considered as part of the design process

Waterways Ireland wishes to be consulted as the design progresses in order to assess

any of the potential impacts

5. Department of Agriculture, Fisheries and Food

No observations/comments to make on the RO application

6. Inland Fisheries Ireland


The presence of salmonid and other fish populations in the watercourses described in

the EIS highlights the sensitivity of local urban watercourses

As with any development all measures necessary should be taken to ensure

comprehensive protection of local aquatic ecological integrity in the first place by

complete impact avoidance and only as a secondary approach through mitigation by

reduction and remedy

Only clean uncontaminated water should leave the development site and drain to the

river network

Any river manipulation works (bridging, culverting or otherwise) must first be

submitted to IFI Blackrock for assessment and approval

Comprehensive surface water management measures (GDSDS study

recommendations) must be implemented at the construction and operational stage to

prevent any pollution of local surface waters

The issue of DU storm-water drainage to surface waters in the area is seen as a

particularly high risk element which should be afforded due consideration at planning

in order that sensitive aquatic resources are comprehensively protected

A comprehensive and integrated approach for achieving estuary and river protection

during construction and operation should be implemented through environmental

construction management planning as described in the EIS

All mitigation measures as outlined in s.15.5 should be implemented in full

Any discharges to surface water waters should be licensed as appropriate by the

relevant Local Authority

EIS s.12.3.6.6 should mention the presence of Atlantic salmon in the River Dodder

Section 15.3.4.3 should acknowledge that the River Tolka has a significant fisheries

value both biologically and from an amenity perspective


7. Health Service Executive

Dr C. Hayes, Consultant in Public Health Medicine, Dept. of Public Health, Population

Health Directorate, HSE

The contents of the submission to the Board from the above can be summarised as follows:

The submission relates specifically to potential human health impacts

An extensive EIA has been carried out

An extensive literature review on the predicted health impacts of emissions of dust,

noise, vibration, increase in the rodent population with effects on water quality,

traffic, potential increase in violence and anti-social behaviour and suicide has been

carried out in the EIS

The number of people exposed, the duration of exposure and the vulnerability of

sensitive populations to the exposure have been identified as the most important

determinants of likely impact

The submission is only on those aspects which need to be made more explicit or

which may need further examination and/or mitigation

Safety concerns around unintentional injury (accidents) with respect to tunnelling and

blasting and is noted in the report

The excavated space at Docklands Station which will remain open for the duration of

construction is potentially hazardous with respect to unintentional injury

There is also potential for increased road traffic accidents due to diversions, traffic

delays, heavy machinery and trucks

In relation to noise, the likely duration of the early construction phase during which a

‘slight to moderate or slight to major exceedance of the criteria’ is predicted needs to

be specified

The negative impact on air quality arising from dust has been alluded to which may

give rise to a variety of respiratory illnesses depending on individual sensitivity which

need to be monitored. However the threshold limits for air quality are not likely to be

exceeded.

The quality of air with regard to its odour from impact of moulds such as aspergillus

and waste also needs monitoring

There may also be a further negative impact on air quality due to traffic disruption

and delays

The risk from contaminated ground, leaking sewers, accidental spillage of polluting

substances and flooding risk have been alluded to in the report and the public water

supply will be routinely monitored

The effect of land disturbance on the increase in the rodent population have been

alluded to and the increased potential risk of Leptospirosis

During the operational phase the health impacts are overwhelmingly positive as noted

promoting increased physical activity, decreased transit time for customers and

improved air quality

There is a risk of crushing injury both on trains and in accessing and alighting from

underground stations during peak hours

The potential for anti-social behaviour has been taken cognisance of in the design of

the DU


The location of a station adjacent to a sports ground where young people congregate

may also be a cause of concern

Recommendations include:

o demand management strategies needed to mitigate crushing/overcrowding

during peak traffic times

o access for people with impaired mobility to stations as well as alighting from

trains needs to be monitored

o specific travel needs of elderly people need to be monitored

o need for good lighting and increased security

o air quality data needs to be linked to available health datasets i.e. Health Atlas

Ireland on a geographical basis

o there should be a commitment to track the health impacts of the project and its

implementation where possible

Ms Michelle Convey, Environmental Health Officer, HSE


Submission is from the Environmental Health Service (EHS) relating to the

applicant’s EIS

The EIS does not discuss other transport options

The Environmental Health Service (EHS) was unable to identify in the EIS details of

contingency plans in the event of explosions, flooding or tunnel collapse during

construction

The traffic management plan should include specific details of how emergency access

can be maintained to construction sites, commercial premises and dwellings during

construction phase

The traffic management plan should include details of access to health care facilities

All food businesses and the EHS should be notified in advance of any utility diversion

or disconnection

The EHS recommends that food premises are considered within the dust minimisation

plan

It is important and necessary that local food premises are considered as a priority for

active pest control under the Environmental Management Plan

Waste generated should only be transferred to waste collection permit holders and

authorised waste facilities, this should be conditioned

Audits for all relevant hazardous materials such as asbestos are carried out prior to

demolition

EIS proposals (i.e. Waste Hierarchy Plan) governing tunnel spoil disposal should be

fully implemented

The EHS recommends that the Water Management Plan (Ch. 14, Ch25) pertaining to

groundwater quality standards and threshold values for compliance aim to be inline

with the criteria set out in the Water Framework Directive 2013 and not just Directive

80/68/EEC and Directive 2006/118/EC

8. Dublin Docklands Development Authority

DDDA Planning Team



The submission is restricted solely to observation on works proposed within the

DDDA master plan Area

However, the DDDA has made comment in relation to methodologies employed in

terms of architecture and design, soil removal and remediation and environmental

protection plans for residents in the surrounding area

The DU team have consulted with the DDDA

DDDA welcomes and supports the DU

It is a pivotal strategic public transport initiative for the Dublin Docklands Master

Plan Area, the City and its hinterland

Policy T15 of the Master Plan 2008 refers to the Interconnector

DU has the potential to remake the mental map of the city

The principal interchange for all trains north of the Liffey would be the Docklands

Station rather than the existing Connolly

The Dublin Docklands Master Plan 2008 is the statutory framework for articulating

the Authority’s policy in fulfilment of its remit

The impact of below ground works in the Grand Canal Dock Planning Scheme Area

will require strict regulation in order to ensure the protection of residential amenities

and in order to prevent disruption to the operation of the significant legal/financial

office cluster within this mixed-use development area

The provision of a new pedestrian bridge at Forbes Street as outlined in Master Plan

Policy T3 would further enhance accessibility from Grand Canal Square to Docklands

Station

The concentration of residential housing in the vicinity of the Sandwich Street

excavation and the proximity of that housing in particular on Erne Street Upper, Erne

Terrace and Boyne Street to the principal excavation would dictate the preparation of

an environmental management plan in consultation with the residents in order to

regulate the construction phase of the development

The potential community gain at the Sandwith Street / Boyne Street site although not

defined is welcomed

The North Lotts Planning Scheme 2002 sets out detailed policies and objectives for

the development of the Docklands North Lotts area

It is the policy of the DDDA to seek the development of the DU in the Planning

Scheme

The DDDA has engaged extensively with the DU project team in relation to its

proposals for lands within this area

The DU team presented alternative routes to the DDDA and its rationale for the

preferred route during consultation meetings is to the satisfaction of the Authority

The proposal to use the LMS building fully accords with the Planning Scheme and is

welcomed

The DDDA suggests a detailed landscape plan be submitted to ABP for Station

Square to form part of the application documentation

The Boards attention is drawn to a Section 25 Cert. DD313 issued by the DDDA in

Feb. 2005

The location of the Northern Shaft is considered acceptable to the Authority


The northern shaft should be designed to allow for future integration into a building

of up to 44 m in order to ensure the maximum potential development capacity of the

site is not inappropriately compromised

The Board is requested to satisfy itself that the potential construction impacts from the

‘bottom-up’ approach on surrounding land users is adequately weighted in the context

of the other overall benefits described in the EIS

It is requested that the method of storage of excavated material, removal of excavated

material and decontamination of excavated material is made transparent through the

planning process for the information of ABP, the DDDA and the public

Any works within the conservation area designation or within its environs would

require appropriate regulation

The alignment of DU is within the boundaries of the East Wall Area Action Plan 2004

The remodelling of West Road would effectively increase the journey distance from

Moy Elta Road to North Strand by 65 metres and would create a more circuitous route

from North Strand to East Wall than currently exists

Figure 5.1 of the Master Plan shows a proposed priority pedestrian route that could

provide, inter alia, a direct link from East Wall to Station Square

The East Wall Area Action Plan 2004 acknowledges the need for greater connectivity

between East Wall and North Lotts

It details environmental improvements at Church Road and West Road in order to

improve access and egress into east Wall

It is considered that the enhancement of connectivity between East Wall and the

North Lotts in particular pedestrian and cycle links to Station Square would be a

logical initiative in facilitating passenger demand in the absence of a dedicated station

at East Wall

The DU project affords the opportunity to implement the provisions of the East Wall

Action Area Plan and the Docklands Area Master Plan in respect of pedestrian links at

the completion of the construction phase of the project

The remodelling of West Road has the potential to depreciate access and egress

between East Wall and North Strand by extending the journey distance from North

Strand

The proposal to provide an off-road cycle lane and footpath on the realigned West

Road is welcomed

Recommendation E1W8 of the East Wall Area Action Plan 2004 may be achieved by

the design of the new bridge

The proposed ESB substation is unacceptable in urban design terms by reason of its

scale and massing, blank elevation and lack of animation

Environmental Management Plans should be prepared in consultation with the local

community and agreed with DDDA and DCC

There is potential for undiscovered marine archaeology within the environs of

Spencer Dock at the location of the ‘bottom-up’ excavation of the station box

There is a unique opportunity given the duration and ambitious nature of the DU

project to employ at both constructional and operational phases, local Docklands

residents

Jim O’Hagan, Senior Property Surveyor, DDDA



Submission made on behalf of DDDA and two subsidiaries: Grand Canal Harbour

Management Company Ltd. and Dublin Docklands Affordable Housing Ltd.

The response relates to their capacity as landowners/occupiers

Submission relates to property interests as per the Book of Reference

Submission refers to changes recommended to Book of Reference

DDDA own the industrial chimney situated within the Chimney View Park and

require that measures to ensure its protection from damage is established

Regard must be had to the location and depth of underground basements

Parcel of lands were subject to the Grand Canal Harbour Soil Remediation works

2003

9. Office of Public Works, Head Office, Trim, County Meath.

The contents of the observer submission from the above can be summarised as follows: -

The Commissioners of Public Works will act for the state properties involved in the

project. A definitive property schedule impacted by this project is being finalised with

CIE.

The Commissioners will facilitate the use of state property attached to this project

subject to agreement by CIE to the following: -

1. Manner of legal approach to land in question.

2. Scope of property survey work involved including adjoining property as

appropriate.

3. Agreement to timing of drilling works under properties.

4. Impact on functionality of buildings during construction operations.

5. Adherence to issues in respect of security requirements.

6. Other associated project issues as they arise.

The Commissioners are progressing the above issues with CIE.

10. Health and Safety Authority, The Metropolitan Building, James Joyce Street,

Dublin 1.

The contents of the submission from the above can be summarised as follows: -

The authority acting as a central competent authority under EC (Control of Major

Accident Hazards involving Dangerous Substances) Regulations 2006 gives technical

advice to the planning authority when requested under Regulation 27-1 in relation to

(a) the siting of new establishments, (b) modifications to an existing establishment to

which Article 10 of the Directive applies or, (c) proposed development in the vicinity

of an existing establishment.

The Health and Safety Authority is currently seeking more information from Iarnrod

Eireann in relation to the proposed development.

The Health and Safety Authority submit a copy of a letter to the Board sent to Iarnrod

Eireann outlining the information that is required.


The Authority will provide its advice to An Bord Pleanála within five weeks of the

receipt of the request for information.

The further information sought from Iarnrod Eireann relates to two issues.

1. The proximity of the terminus at Inchicore to the area and site where the

dangerous substances are stored, and

2. Relates to increasing the height of the bund wall as a means of reducing the

overtop fraction.

11. RPA, Parkgate Street, Dublin 8.

The contents of this submission from the above can be summarised as follows: -

RPA supports the Dart Underground Project and believes it will compliment the

existing rail based public transport network including the new lines under

development and in particular the Metro North Line as well as the proposed extension

of the Green Luas Line from St. Stephen’s Green to

It is likely that the construction of the Dart Underground and Metro North Projects

will overlap.

RPA notes that Iarnrod Eireann has assessed the cumulative impacts in both projects.

RPA notes that Iarnrod Eireann has agreed that the Dart Underground Contractor will

prior to commencement of its works at St. Stephen’s Green agree appropriate

mitigation measures with Metro North Contractor in order to avoid significant

impacts, taking the cumulative effect of both projects into account.

In relation to hydrogeology, the EIS appears to suggest that the Metro North

Contractor is required to undertake additional mitigation measures.

Iarnrod Eireann has now clarified that this is not the intent and has confirmed that no

additional mitigation measures by the Metro North Contractor are required.

The proposed relocation of a bus stop to the top of Dawson Street conflicts with the

Metro North requirement to use this as a temporary unloading bay for premises on St.

Stephen’s Green.

Iarnrod Eireann has confirmed that this bus stop is no longer required.

The proposed Dart Underground alignment crosses under the existing Red and Green

Luas Lines at Spencer Dock, St. Stephen’s Green and Heuston Station.

It will be necessary to put in place a regime for the continuous monitoring of ground

settlement in these areas in order to ensure the uninterrupted safe operation of the

Luas System and to avoid any possible degradation of the structural integrity of the

Luas Track Slab.

The ventilation shaft proposed for Dart Underground on St. Stephen’s Green North is

located directly beneath the section of the siding proposed in the Luas Broombridge

Scheme.

RPA has agreed with Iarnrod Eireann that should the construction of Luas

Broombridge precede Dart Underground works in this area, RPA will delay the

completion of the siding to the extent practicable until such time as Iarnrod Eireann

completes its works.

Iarnrod Eireann has agreed that the ventilation shaft will be designed and built so as

not to comprise the installation and operation of the siding at a later date.


Iarnrod Eireann acknowledge the opportunity for an interchange between Dart

Underground and the proposed Luas Line F1 (Lucan) at Inchicore and RPA is

supportive of this.

12. Department of the Environment, Heritage & Local Government (now DoECLG)


The Dart Underground Project is part of the Transport 21 Capital Investment

Framework set out under the National Development Plan Framework through which

the transport system in Ireland would be developed over the period 2006 – 2015.

As part of this capital investment programme, Dart Underground would be a key

element in integrated public transport system for Dublin.

This commitment was most recently underpinned in the Government’s Infrastructure

Investment Priorities 2010 – 2016 published in July 2010.

The aims of the project are fully supported by the Department.

It is considered that impact on architectural heritage has generally been taken into

account in the Environmental Impact Statement.

It is considered that there are some issues which require clarification in the EIS and

the railway works drawings in terms of the project being a reference design.

It is recommended that the various specific instances set out in the EIS relating to

significant impact on architectural heritage are taken into account in determining if

those impacts are outweighed by the wider benefits arising from the Dart

Underground proposals as a piece of transport infrastructure within Dublin City.

A Railway Order is in effect a grant of planning permission by An Bord Pleanála for

the specified railway works, thereafter such works effectively constitute exempted

development.

Where a Railway Order is granted notionally, the PPP contractor could erect new

structures of whatever appearance suited his purpose without further reference to

Dublin City Council as Planning Authority as long as the works generally complied

with the scheme approved in the Railway Order.

Similarly works affecting structures of architectural heritage merit could be

undertaken without either reference to the Planning Authority or prescribed bodies

including the Minister, again as long as the works generally complied with the scheme

approved in the Railway Order.

It will remain an anachronism of the process if for instance the Planning Authority for

the city does not have an input to the detailed appearance of prominent structures

which might be erected in the city.

A similar situation applies to the Minister’s role in relation to structures proposed to

be erected in St. Stephen’s Green and the role too of the Office of Public Works as

Executive Manager of the Park.

It is part of the reference design process that the final detail is left to another hand to

be designed and carried out on foot of a railway order.

In order to remove any doubt in the matter, it is recommended a condition is placed in

any Railway Order that CIE as Railway Undertaker and the PPP contractor both

consult and agree the final details and appearance of all above ground structures with

Dublin City Council as Planning Authority and the Minister/OPW as appropriate.


Government Policy and Architecture 2009 – 2015 is of particular relevance to the

overall Dart Underground Railway Project.

A number of the key statements as contained on Page 16 of this Government Policy

should be reflected in the architectural design standards that apply to the Dart

Underground Railway Project.

Notwithstanding the comments in relation to the architectural finishes proposed as

contained within the EIS, the railway works drawings typically indicate powder-

coated metal louvers, powder-coated cladding, sheet glass and stone cladding, all of

minimal appearance to be the typical detailing and finishes to new work, it is not clear

how any of these materials can be described as being “traditional” and as such are

being expressed in a modern way.

It appears that the intention is to provide minimalist structures with the least amount

of visual impact.

However it is not clear if even in the context of a reference design offering flat-roofed

structures of simple rectangular design, achieves a standard of architectural quality or

excellence as called for in the Government Policy and Architecture.

This applies, for instance, to the escape/ventilation shaft building proposed to be

placed inside St. Stephen’s Green across from the top of Kildare Street.

This structure will be some two storeys in height and is to be located immediately

inside the perimeter railings.

The flat-roof structure bears no relation to the shape and form of other prominent

structures in the Green, nor can it be said that “the materials used replicate those of

their surroundings”.

It is important that the standard of architectural design and the visual quality of those

elements of Dart Underground which will be in the public domain and which indeed

will shape and form the public domain within their own ambit to a high standard.

This includes both above ground and underground public spaces.

It is recognised that the content of the railway works drawings is a reference design, it

is recommended that a condition is placed in any railway order that CIE as undertaker

and the PPP contractor both consult and agree the final details for the external and

internal appearance of all structures with Dublin City Council’s Planning Authority

and the Minister/OPW where relevant.

The intention to return part of the LNW building on North Wall to use as part of the

Dockland Station presents an opportunity to give a new lease of life to the entire

LNW structure along the street.

The present proposal amounts to a corridor running through the building as part of the

Quayside Station entrance.

In effect, the existing building will be severed in two at ground floor level.

This ignores the integrity of the protected structure as a single entity and does not

equate with good conservation practice.

It would seem appropriate that the whole façade of the former railway building

becomes synonymous with being part of Dockland Station and is taken in as part of it.

The opportunity exists to use the new station entrance as a regenerator in bringing the

entire building back into viable use.

This might add additional vibrancy to this section of North Wall just to the east of the

National Conference Centre and some 400 metres to the west of the O2 Point Depot.


In relation to archaeological observations, Iarnrod Eireann contacted the National

Monument Service of the Department in January 2009, since then there has been on-

going consultation between Iarnrod Eireann and this Department.

It is the Department’s recommendation that the following measures be carried out and

be included as conditions in any grant of planning permission that may arise: general

mitigation, construction phase and operational phase. Site specific mitigation

measures are also recommended at the following locations: the Western Port

including Inchicore Station, Memorial Park Ventilation Shaft, Heuston Station, Island

Street Ventilation Shaft, Cook Street Ventilation Intervention Shaft, Christ Church

Station, the Wood Quay National Monument, St. Stephen’s Green Stop, Pearse Street

and Bass Place Shaft, Dockland Station and Ventilation/Intervention Shaft at the

Eastern Port.

In relation to nature conservation, having studied the EIS submitted in support of the

application for a Railway Order, the NPWS considers that overall the sections of the

EIS dealing with flora and fauna provides a generally accurate appraisal of the

proposed Dart Underground impact on both animals and plants, and that the various

measure suggested to mitigate the projects effects on fauna and flora should, if

implemented, reduce such impacts to the extent predicted.

However, Section 12.5.1.2 of the EIS dealing with habitat clearance contains some

misinformation which requires correction in order to avoid any subsequent

misunderstandings by personnel or contractors on the Dart Underground Project.

With reference to a number of sub-sections of the Wildlife Acts, it should be noted

that all occupied protected bird nests are protected everywhere all the time and may

only be destroyed under license from the National Parks and Wildlife Service.

For instance, if a nest of a Wood Pigeon or Mallard Duck was still active in

September of any year in St. Stephen’s Green, a license to interfere with such a nest

would have to be applied for to the NPWS.

This situation should be drawn to the attention of Iarnrod Eireann, their operatives and

contractors.

PUBLIC REPRESENTATIVES

13. Maureen O’Sullivan T.D. and Councillor Marie Metcalfe c/o Dail Eireann,

Leinster House, Kildare Street, Dublin 2.

The contents of the observer submission from the above can be summarised as follows:

The observers are requesting that an oral hearing be held.

This project will have a massive impact on the residents both during the construction

phase and when operational.

Communities in East Wall, North Port, North Wall have had to endure massive

developments in recent years causing untold disturbances and intrusions in their lives, the

most recent being the extension of the LUAS to the Point.


Despite promises from authorities and developers conditions have been breached,

extended working hours, noise, dirt, vibrations, damage to residential property, loss of

business and appalling traffic congestion.

Whatever permission is granted it must be watertight in relation to monitoring, mitigation

and protected measures.

Also vital as part of planning permission is a real and meaningful way for residents to

address difficulties and concerns as they arise, for example the 24 hour manned telephone

or designated liaison person.

The proposed working hours are excessive and unacceptable.

Equally unacceptable is the number of vehicle movements per day.

Many of the roads in the area are subject to HGV restrictions and the observers do not

wish to see a reversal of this strategy.

Monitoring data and equipment must be made available to community representatives and

residents in relation to noise, vibration and dust.

There is a need for independent arbitration in the event of difficulties with vibration and

noise levels.

In relation to dust there must be an agreed programme for window cleaning and car wash

allowances.

Conditions regarding street cleaning and sweeping have to be included.

The high density lighting being used must be positioned and operated in such a way as to

cause limited disruption to households affected.

East Wall and North Strand have experienced significant flooding in recent years and the

implications of this project on the water table has to be considered.

At the end of the construction phase the visual impact has to be acceptable to residents

and they must be consulted.

The observers wish to know on what basis was the decision made to move both boring

machines on the East Wall/North Port areas.

One of the observers (Maureen O’Sullivan) is concerned with access to her house.

There is going to be major difficulty getting in and out of East Wall for residents.

Future house insurance is also a concern.

The compensation scheme proposed is unfair and unacceptable.

CIE as a public body and a commissioning authority of this project should therefore offer

a scheme of unlimited liability.

The limitation of 12 months is also unacceptable.

Damage subsidence can occur years following the completion of the works.

The EIS does not consider the operation phase of the Dart and the observers feel this

needs addressing.

The observers question whether CIE is a prescribed organisation in relation to planning

applications and what is the legal status of any conditions?

The communities of East Wall, North Port, North Strand and North Wall are facing into

years of disruption, mayhem disturbance and impact on quality of life.

The matter of community gain has to be considered.

14. Lucinda Creighton TD, c/o Dail Eireann, Leinster House, Dublin 2.



While the observer has issues with the cost of the project she is broadly in favour of it.

Such a major infrastructure project will however have serious effects on the city and its

inhabitants.

All effort must be made to prevent the works from degrading the quality of life of

residents. It is imperative that the planning process involves residents and other interested

parties from the outset.

The observer is requesting an oral hearing for the project so that the voices of local

residents and businesses can be heard.

The issue of the potential for tunnelling to damage houses must be properly addressed to

the satisfaction of all residents.

The impact of ventilation shafts on the areas in which they are situated must be examined

to ensure that there is no adverse effect on people or property.

The St. Stephen’s Green area containing as it does the terminal of the LUAS green line as

well as a main business and shopping district does make sense for an underground station

but this station must respect the architectural and historical context in which it is being

built.

There should be no loss of overall amenity space in the park and no loss of vegetation.

Any felling of mature trees must be mitigated by sufficient planting of new trees.

The character of the park must be respected.

The observer has reservations how the existing Dart system at Pearse is to be connected

with the Dart underground.

The residents in the Boyne Street and Sandwith Street area face many years of disruption

and nuisance during the construction of a station here.

Everything possible must be done to minimise this disruption including re-examination of

the choice of site. If development goes ahead as planned in this area the least that CIE can

do would be to set up a fund of an adequate amount of money for the local community to

compensate them for the disruption.

The current proposal involves quite a distance between the Dart underground station and

the current Dart platforms. This will not encourage use of the station and should be

reconsidered to ensure that the station is a viable interchange point.

15. Councillor Claire O’Regan, 66 Sea View Avenue, East Wall, Dublin 3.


East Wall is physically cut off from the city and its amenities to the north, south and

west.

This is to a large extent due to various elements of the national transport infrastructure

including the port tunnel to the north and the elevated rail lines to the west and south

which form physical barriers to the environment.

While the importance of this infrastructure is acknowledged it brings no direct benefit

to the community of East Wall.

It is currently a source of noise, air and industrial pollution.

The railway order application will worsen pollution effects.

It will cause additional blockages to the already limited access routes during

construction and additional noise, air and visual pollution during construction and


later during operation when traffic on the railway line will be significantly increased

with no benefit to the community of East Wall.

This is another example of how East Wall has been ignored by the agents of Planning

in the city.

The observer requests that An Bord Pleanala ensure that access to the proposed

improved Dart network from East Wall is provided in one of two ways either by

provision of a station for East Wall/North Strand or by a pedestrian bridge from

Church Road to link the neighbourhood to the proposed Spencer Dock Station.

It would be appropriate and of benefit to the East Wall community to build a station at

the location of the proposed operation control centre.

A station and the operation control centre can be accommodated in the land between

the two elevated rail lines together with a new public open space connecting North

Strand and East Wall, this is an objective of the Dublin City Council Draft

Development Plan 2011 to 2017.

Should the provision of a DART station at East Wall/North Strand not be feasible

then a bridge for pedestrians and cyclists should be provided from the southern end of

Church Road and East Wall to the docklands station.

Such a pedestrian bridge was envisaged in an Area Action Plan for East Wall

prepared by Dublin City Council in 2004 and as also indicated in the Dublin

Docklands Development Master Plan 2008.

The Docklands Master Plan was reviewed by the Design Team for the railway order

application, however there is no proposal for the provision of such a bridge in the

application.

There is no mention of a mitigation strategy in the EIS for the East Wall area from

where it appears that there are now to be two boring machines starting simultaneously

and therefore a mitigation strategy at least is urgently required.

The observer suggests that this proposed boring should not be granted permission.

Access and egress for construction traffic for the proposed OCC building and West

Road will be from West Road with at peak 134 daily two way HGV movements. This

will cause significant noise and inconvenience.

The additional noise created by traffic and works will be unbearable for families who

wish to sleep.

The EIS states that the results of operational air borne rail assessment have indicated

that with a proposed acoustic barrier noise levels can be reduced at all assessed

properties along both sides of the track to within acceptable levels and the residual

impact is neutral to slight.

It is incomprehensible that this might mitigate against significant additional noise

where the noise is already significant even before the proposed works starts.

The observer requests that CIE provide a 24 hour telephone number for residents in

case of infringements of planning permission.

CIE should provide a weekly update to residents.

16. Bertie Ahern T.D., Dail Eireann, Leinster House, Kildare Street, Dublin 2.


The observer is writing on behalf of the residents of East Wall, Dublin 3.


The observer fully supports the submissions made by the East Wall residents.

The observer would greatly appreciate it if the Board could take the Residents

Association’s strong concerns into consideration when a decision is made.

17. Councillor Mary Fitzpatrick, Dublin City Council, Members Room, City Hall,

Dublin 2.


The observer requests an oral hearing.

The observer supports the submission by the Protect East Wall Group.

An Bord Pleanála should make every effort to ensure that this project of significant

national importance is executed in a manner that protects the existing residential

community in East Wall.

East Wall is a predominantly residential area close to historical industrial lands.

East Wall is one of Dublin’s oldest villages where in recent years there has been

significant new development.

An Bord Pleanála should consider this application in the context of a major

infrastructure project being undertaken in a primarily residential setting.

Specific mitigation measures need to be stipulated to ensure that the residential

community is protected and enhanced.

It should be a condition of any order that an independent third party be appointed to

monitor the project before, during and after construction and to ensure that all

conditions of the order are adhered to.

Strong consideration should be given to the health risks of the project of this size and

duration.

CIE should be required to provide dedicated medical support and services to the local

community.

As an area reclaimed from the sea East Wall has over many years had serious

flooding problems most recently in July, 2009.

This is a matter of legitimate and serious concern for many residents in the area who

live in fear of a flood reoccurrence and are extremely concerned that the proposed

project will compound the risk.

The observer requests that included in any permission are adequate flood mitigation

measures including the provision of insurance to home owners in the area.

With reference to the North Strand bombing of 1941 the observer requests that An

Bord Pleanála includes provisions and conditions which will require comprehensive

survey of the area to identify any unexploded devices and ensure steps are taken to

protect the residents or workers on the project from any risk.

An Bord Pleanála should consider whether or not the EIS is adequately prepared in

the context of the applicant’s proposal to commence boring of both tunnels

simultaneously in East Wall.

18. Councillor Nial Ring, 70 Ballybough Road, Ballybough, Dublin 3.



The observer supports the protect East Wall Campaign.

East Wall is a long established Dublin neighbourhood which has played a pivotal role

in the economic and social development of the city.

Although geographically somewhat isolated its defined boundaries give a strong sense

of community and a feeling that the area is essentially a village within the city.

The Board will appreciate that the demographics of the area is of a mainly elderly

population.

Health risks are an important consideration of this case due to the elderly population

of East Wall.

A condition requiring the provision of 24 hour contingent medical

facilities/availability in the East Wall area for the duration of the works would be

welcome and necessary.

As an area reclaimed from the sea East Wall has over many years had seriously

flooding problems particularly 1954, 2002 and more recently in July, 2009.

The Board should be made aware of the fact that CIE was directly implicated in the

major floods of 1954 and 2002.

Many residents live in constant fear of further flooding of their homes and are

concerned that the works involved in the Dart underground project by CIE will

increase the flood risk in the area once more.

With reference to the North Strand bombings of 1941 the Railway Order should

include provisions and conditions which will take into account the potential health

and safety risk of unexploded devices for construction workers and local residents.

It is now intended to commence both boreholes in East Wall and drill east/west only,

the submitted EIS would have examined and evaluated the noise, dust, vibration, air

quality, transport issues etc., based on one borehole in East Wall at any one time.

19. Councillor Kevin Humphreys, Dublin City Council, Wood Quay, Dublin 8.


Investment in public transport is generally welcomed and is necessary for the

development of Dublin.

In any such development residents’ quality of life should be protected during

construction and on-going operation of the Dart underground.

The observer is concerned that adequate consideration of the effects to local residents

in the Sandwith Street, Boyne Street, Erne Street, Fenian Street and Pearse Square has

been fully taken into consideration.

The construction of the station between Sandwith Street and Erne Street will in fact be

an open cast mine with dirt, noise and heavy vehicle traffic associated with it.

If permission is given for this development measures to protect local residents must

be put in place. Strict control and working hours and traffic movement needs to be

put in place and be forceful.

A local consultative committee independently chaired could be of assistance in this.

If permission is given this should be a manned station well-policed with controls put

in place to deal with crowd movements, noise and litter. Pearse Square has not been

adequately dealt with. There is a number of outstanding questions which need to be

addressed, vibrations during tunnelling and on-going operations, depth of tunnel

under the Square and whether it should be deeper.


Long term possible damage to residents’ homes and adequate insurance to cover such

damage.

20. Senator Paschal Donoghue and Councillor Ray McAdam, Constituency Office,

6A Phibsborough Plaza, Phibsborough, Dublin 7.


The railway order does not recognise the residential nature of communities.

Concern with respect to the decision to launch TBMs from the East Wall area.

It is essential that more precautionary measures and enhanced mitigation plans are put

in place.

Support for the Protect East Wall group.

Call for an oral hearing.

Recognise the importance the Dart Underground project will present to the city.

Contend that the working / construction phase must be shared more equally across the

entire city.

Dublin City Development Plan recognises East Wall as a residential area. Dart

Underground must do the same.

Request that TBMs are allocated across the entire city as opposed to just the East Wall

and North Wall district.

Concern with respect to impacted noise on the East Wall community.

Need for strengthened precautionary measures and more extensive mitigation plans.

Blasting is of particular concern.

Specific sources of noise will include the construction and operation of the control

centre, new bridge and use of bridge at West Road. Noise from North Wall yard,

construction of ESB station at Abercorn Road, work on Sheriff Street Bridge and

widened East Wall Bridge.

Query the role of mitigation outlined in the EIS.

Strongly propose strengthening of precautionary measures and need for mitigation

plans that are more substantial and capable of independent review.

Recommend the following precautionary measures.

Blasting should be confined to specific times of day.

Independent monitors should be appointed to ensure that the conditions of the

Railway Order are strictly adhered to.

Acoustic barriers must be increased in height.

The length of the acoustic barriers must be increased.

Acoustic barriers must be strengthened on the West Road area.

Concern with respect to vibration impact of Dart Underground due to amount of

above ground work and lower depth of tunnelling.

The impact of this project on the East Wall area during construction phase will be

unique.

Concern with respect to increase in train frequency and consequent higher level of

vibration.

The property protection scheme will be vital for residents to assess any damage

caused to their property by vibration and to enable the claiming of expenses for same.


An Bord Pleanála should request the publication of the noise and vibration

management plan in an additional information request. It is unclear why the

applicants need to specify a cap of €30,000 for expenses due to potential property

damage. Request that that the cap and the value of expenses in the property

protection scheme be removed.

That the area for which the scheme is applicable should be increased.

There is a need for independent monitors.

Concern with respect to impact of project on flooding risk for East Wall.

Consider that emergency plans should be published to outline what additional

resource would be made available to protect residents in the case of additional

flooding.

Concern with respect to increased traffic levels in East Wall.

Propose mitigation measures for traffic require further examination before a railway

order is granted.

There are a number of issues of concern with respect to traffic in the East Wall area

including movement work and what priority will be provided to the movement of

local vehicles in the area.

On-site parking for construction staff.

The EIS makes reference to the need for road possession in East Wall, however, there

is a lack of detail as to what roads will be taken into possession.

Recommend that An Bord Pleanála direct that an independent review of the Traffic

Impact Assessment take place.

Detailed Traffic Management Plans should be put in place and form part of any

approved railway order.

Limit the operation of commercial vehicles to between 7.00 a.m. and 7.00 p.m.

Monday to Friday and 7.00 a.m. to 3.00 p.m. Saturdays and Sundays in the East Wall

and North Wall area.

No commercial vehicles carrying spoilt should be allowed to pass through Sherriff

Street Lower as a route away from the site.

Concern with respect to the impact of the proposed Dart Underground on North Wall

area also.

In particular with respect to the area near Abercorn Road, Irvine Terrace and Church

Street East.

Concern with respect to the impact from vibrations, noise and water in these areas

Concern with respect to the proposal to construct an ESB sub-station at the junction of

Abercorn Road and Sheriff Street Upper. Concern in particular with respect to the

proposed height of the building compared with homes in the area, the location of the

sub-station particularly its proximity to a residential area and the visual intrusion this

facility will have.

Concern is also had to noise emanating from the centre, electromagnetic emissions as

well as the associated traffic problems both during construction and when in

operation.

More information is needed on the recharged well proposed at the rear of homes on

Abercorn Road.

Concern with respect to construction traffic in particular the access point at 1

Abercorn Road. Will HGVs be allowed to use this entrance?

Concern with respect to the proposed location of temporary two-storey office blocks

on Abercorn Road.


Consider that the location of these blocks in close proximity to an established

residential area is inappropriate.

These buildings would negatively impact homes through overshadowing and loss of

privacy as well as the visual intrusiveness of their construction.

Concern with respect to noise pollution from congregating construction workers and

parking of vehicles at these office blocks.

Query whether on-street parking will be lost from Abercorn Road, Church Road East

and

Supports the request of the local community that An Bord Pleanála relocate the sub-

station to Docklands Station.

Requests that An Bord Pleanála examine in detail what is the recharged well, why it is

needed and why it is located so close to a residential area?

Urge An Bord Pleanála to refuse permission for temporary office blocks too close to

this residential area.

Support the request of local residents that no on-street parking be removed on

Abercorn Road, Church Road East, Irvine Terrace.

Submit that any approved railway order needs to contain a detailed traffic

management plan for Sheriff Street Upper and Abercorn Road.

21. Patrick Martin, Chairman Ógra Fianna Fail, Dublin Central, 37 Leinster

Avenue, North Strand, Dublin 3.


Concern with respect to the impact that the proposed construction of the Dart

Underground will have on the wellbeing and lifestyle of the youth of the North Strand

area and also on the elderly population.

Based on the census of population 2006 East Wall, North Wall and North Strand are

home to 502 children aged 13 years or younger.

Taking into account births that have taken place since the census the number of

children increases to an estimated 678.

Concern with respect to health impacts in particular sleep for young children.

Concern with respect to the 24 hour day tunnelling excavating and transportation of

materials and consequential noise which will result every day of the week for months

if not years.

Concern with respect to dust and impact upon open spaces of children’s play areas.

Concern with respect to vermin, risk to children.

Due to the number of roads that are to be closed around the East Wall and North Wall

area this will impact upon the ability of children and families to physically interact

with one another.

The loss or reduction of the no. 53 bus will also hamper children’s ability to do a lot

of their activities.

The loss of the bus would mean many children have lost their transport links to the

rest of the city forcing them to have long walking distances to get to a bus route.

Many of the issues surrounding Dart Underground will impact on a child’s education

in particular children aged 13 years or younger or at an age where their development

is in full swing.


While the project is not due to begin until 2012 it will impact on these children

between 2012 and 2018.

Children getting little sleep each night due to noise impact will have a negative impact

on their ability to concentrate during class.

Encourage CIE to seek ways to minimise the impact their construction phase will

have on the area mentioned.

Seek the provision of transport for children in the way of a private bus service paid by

CIE.

Seek the provision of both vermin control and waste removal to keep the area

surrounding the site clean and safe at all times.

Fully support the East Wall community’s objectives as expressed in their submission.

Also the submission of the residents of the North Strand area.

Request that an oral hearing is granted.

22. Mary Upton TD, Dail Eireann, Kildare Street, Dublin 2.

The contents of this submission from the above can be summarised as follows:

Support in principle for the Dart Underground.

Concern that several of the proposed stations notably at the Inchicore works and

Christchurch would be located adjacent to established communities.

There is a need for consultation prior to construction regarding station development

and the long term impact of the line.

Welcome the decision not to locate a portal construction at the Inchicore playing field

in Inchicore Works.

Any tunnelling which occurs in the vicinity of Oliver Bond Housing Complex should

be at a minimum sub stratum level of 50 feet.

A full and comprehensive archaeological dig of both the Wood Quay Amphitheatre

and the Church of the Immaculate Conception, Cook Street must be undertaken in

advance of any construction or movement of the sub stratum.

The construction of Dart Underground in particular the Christchurch Station must not

damage the line of the city wall.

The achievement of greater density along the line should not be at the expense of

existing residents and communities.

The most stringent mitigation measures with regards to noise and vibration during

construction must be undertaken to ensure quality of life of households.

Households must be informed in advance of when the property is likely to experience

significant noise and vibration impacts.

A dedicated community liaison team including a person with engineering speciality

should be available to liaise with local communities during the project.

Mature trees lost during construction from St. Stephen’s Green and Memorial Park

should be replaced as soon as possible upon completion of the project.

The Dart Underground system must be designed with ability for trains to

accommodate bicycles.

A park and ride facility should be provided at the Inchicore Station.

Concern that the proposed Christchurch Station does not have an exit towards

Fishamble Street/Temple Bar.


The intervention shaft proposed for Christchurch Station must be designed and built

using similar materials to the church so as to minimise the visual impact.

Passenger permeability into stations is central to the development. At each station the

design structure should be re-evaluated to see if it is possible to create more above

ground entrances to the ticketing concourse. While this may be more costly it will

increase footfall and ease of use of passengers.

‘Travelators’ should be incorporated into the Pearse Street Station to minimise the

time distance between the station concourse and the entrance/exits.

The proposed Merrion Street entrance to the Pearse Street Station should be reinstated

in the interest of increasing passenger footfall and to increase the integration of the

system into the city.

Consideration of an underground pedestrian link between the Docklands Station and

Connolly Station should be taken.

In view of the project’s potential long term impact on the regeneration of the Heuston

Station area consideration should be given to locating the station entrance outside of

the main station so as to reduce congestion within the station.

23. Mary Lou McDonald and Councillor Seamus McGrattan, c/o Mary Lou

McDonald, 58 Faussagh Avenue, Dublin 7.


Request that an oral hearing be held in relation to the application.

Improvements to public transport infrastructure for Dublin are overdue and

welcomed.

Dart Underground is ambitious representing a huge investment for the state.

It is welcomed to improve the connectivity of the existing public transport system.

Submission focuses primarily on the eastern portal docklands sections of the project

and residential areas that will be impacted by the project.

Communities need independent expertise to enable them to make a sound reason

assessment in response to the Dart Underground proposal.

The RPA in the case of Metro North set a precedent for this type of support to the

community as an interested party in rail infrastructure development.

Ask that an independent arbitrator be appointed to ensure that all consent conditions

of the railway order be adhered to.

There is a lack of consideration in the EIS for residents of East/North Wall and North

Strand areas.

The working hours for construction as set out in the EIS 24/7 are totally unacceptable.

The 24/7 operation of the project is cost driven and unacceptable. The granting of a

railway order should be contingent and equal consideration given to all residential

communities and areas of amenity.

In the interest of fairness request that four TBM option and tunnelling from both ends

of the route be considered.

Iarnrod Eireann’s decision to opt for a two TBM strategy is unacceptable and

lengthens the duration of the proposed works.


Concern with respect to community health. There are no measures for vermin

control, no measures is made for health monitoring throughout the duration of the

construction phase.

The granting of a railway order should be contingent on proper health screening and

monitoring being made available to all residents within acceptable symmetry of the

construction and operation of works.

Concern with respect to traffic and road closures. There are no measures in place for

access for emergency services or other healthcare workers.

There are no alternatives offered to residents who will use on-street parking.

It is proposed there will be no access at all to Blythe Avenue. Residents will not be

able to access their homes and no mitigation is suggested.

Concern for traffic safety with regard to HGVs during construction.

There are no mitigation measures proposed to counteract the following:

1. Total road closure of proposed main access routes to East Wall, Sheriff Street,

Abercorn Road, West Road and Ossory Road to allow an estimated 350 HGVs

per day access the construction works in East Wall.

2. Construction workers accessing the construction sites and parking in the area.

3. Existing increases in traffic volume when there are performances in the Point

Theatre.

4. Concern that the decision to locate TBMs in East Wall will result in all hazardous

waste being taken through East/North Wall.

No consideration has been given to the residents of West Road and its environs.

Major construction is proposed for West Road - the closure of the existing bridge, the

opening of a new bridge, the construction of an emergency portal bridge and

operation of a controlled centre and a traction substation – it is submitted that the lack

of consideration for residents in this area is great.

Concern with respect to air pollution.

Concern with respect to noise and vibration. Levels resultant from increased road and

rail traffic post construction.

The proposed new 40 metre wide steel bridge on West Road will cause unacceptable

increased levels of noise.

There are many mental and cardiovascular illnesses directly affected by raised noise

and vibration levels.

The granting of a rail order should be contingent on clear and adequate mitigation

measures put in place for noise and vibration.

As structural damage is based on predictions there should not be a maximum limit for

compensatory damage.

A railway order should be contingent on the basis of realistic property protection

measures for residential homes.

The EIS largely portrays East/North Wall and North Strand as being industrial by

nature. This is not so. There are settled residential areas that will suffer a major

negative visual impact from the proposed Dart Underground.

No effort has been made to sensitivity integrate the new structures into the existing

settled residential area.

There is no community benefit whatsoever for the residents of East Wall and North

Strand.

Iarnrod Eireann refuse to consider a station in East Wall on the basis that Clontarf and

Connolly Stations are in close proximity.


The granting of a railway order should be contingent on a local labour clause

guaranteeing local jobs and including any opportunity to commence/complete

apprenticeships for local workers.

A precedent for this approach was set under the Dublin Docklands Area Master Plan

which included an agreement to which is 20% local labour.

A railway order should also be contingent upon the establishment of a Docklands East

Wall local employment form by Iarnrod Eireann’s/the contractor, in partnership with

local employment services.

The granting of the railway order should also be contingent on the establishment of a

community gain fund to support community facilities and services within the

catchment area of the project for the duration of the construction works. A

community liaison committee would administer the fund as has been practiced with

other large scale infrastructural projects.

24. Joe Costelloe TD, Dail Eireann, Kildare Street, Dublin 2.


Except the principle of linking the main line railway with the Dart and Luas lines and

the proposed Metro.

The inter-connectable will cause major disruption at three points along its route,

Inchicore, St. Stephen’s Green and East Wall.

Concern with respect to the level of consultation which has taken place.

Concern that East Wall would become the hub of the inter-connected project and bear

the brunt of the works for the entire duration of the project.

The main channelling works will initiate in East Wall. The excavated material is to

be transported from there. The operation of control centre, management suite and

traction sub-station and intervention shaft will be located there if the draft railway

order is proved in its present form.

Concern with respect to visual intrusion on the landscape, volume of noise and the

increase in activity along the new interconnector and the old railway line in the East

Wall area.

In return East Wall will receive absolutely no benefit.

The railway order is silent on both the East Wall Area Action Plan which was drawn

up by Dublin Docklands Development Authority and more recently the Draft Dublin

City Development Plan 2011-2017 proposal that an LAP be granted for the East Wall

area.

Request that an oral hearing take place to allow communities and businesses along the

route to express their views and concerns.

Iarnrod Eireann should pay the bill for all reasonable costs incurred by communities

along the route.

It is unreasonable that the benefit of a local station should be given to Inchicore while

East Wall will suffer by not getting a local station. It being the tunnelling hub of the

entire project.

East Wall should be provided with a local station and the tunnelling should be shared

equally between Inchicore and East Wall.


If four TBMs were employed instead of two the construction phase would be carried

out in a much quicker and efficient manner.

Damage to health and property should be monitored throughout the duration of the

project.

Concern with respect to the entire alignment along West Road. It is unclear why the

new proposed bridge needs to be taller and wider than the old bridge.

The proposed works at and behind Abercorn Road are substantial and would impact

heavily on 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.

Blythe Avenue, Hawthorn Terrace and Church Road are likely to experience

disruption and disturbance during construction and tunnelling phases.

An independent arbitrator should be appointed. The main contractor for the project

must produce in consultation with Iarnrod Eireann the following documents. The

construction code of practice and Noise and Vibration Plan, and Environmental

Management Plan, a TBM Mitigation Plan, a Traffic Management Plan and a Dust

Mitigation Plan and these documents must be supplied to the residents as soon as

possible.

A charter should be drawn up between the residents of East Wall and Iarnrod Eireann.

A liaison committee should be established.

The East Wall communities should benefit from local employment clause of 20% of

the work force and apprenticeships should also benefit from community game

funding. The spoil from the tunnelling should be transported out of the area by means

of existing main line railway so as to minimise pollution and road traffic disruption.

Car and truck parking should be planned in a way that the streets of East Wall and

North Strand are not clogged up with vehicles for years to come.

Hours of working should be determined by An Bord Pleanála and should be in

accordance with the wishes of the residents.

The proposed operation of controlled centre management suite and eastern

intervention shafts should be located outside of East Wall as they would be visually

intrusive.

Concern with respect to flooding, the railway order should include a comprehensive

plan to deal with a water table and likely flooding of the tunnel during construction

and eventually an eventuality of flooding in the tunnel and in the East Wall in the

future.

On completion of the project landscaping of all areas should be carried out by Iarnrod

Eireann.

Support the submission led by East Wall community through the East Wall Action

Group.

25. Aengus O’Snodaigh TD, Teach Laighean, Sráid Chill Dara, Baile Átha Cliath .


Support for the Dart Underground in principle.


Concern that the proposal for the interconnector is being put in isolation of other

major public transport improvements in the Ballyfermot Inchicore area namely the

Luas line linking Lucan to the existing network.

Concern with respect to the works as they pertain to the Inchicore/Ballyfermot area.

Lack of consultation in the East Wall area where the main construction work is

supposed to be concentrated.

Urge An Bord Pleanála to ensure the full public consultation with residents along the

route affected has been carried out.

Request that an oral hearing be held.

Consider that the whole picture of what has been planned for the Inchicore works has

not been revealed.

Believe that one of the reasons that the portal and station in the works is not moved

further west and further away from people’s homes is that the company is planning to

use this land as development land for future offices and residential development does

justifying building a Dart Station in the middle of nowhere.

The location of the station as proposed is ridiculous.

If the station was moved further west it would still allow for a link with the arrow

route on the main line rail with the proposed Luas which to come down Kylemore

Road with the bus route currently travelling on the road and would link many of the

industrial estates nearby, Kylemore Road, Robin Hood, Bluebell Park West quite

easily.

Concern with proposals to locate a construction site in the Inchicore Railway Estate

which consists of approximately 150 homes.

There needs to be a full traffic management plan drawn up for the Kylemore Road.

Consider proper attention has not been given to the uniqueness of the Inchicore estates

and the amenity contained with them.

Concern with respect to the effects of such a long phase of construction on the

residents of Seven Oaks, Landen Road, Tyrconnell Road/Railway Avenue in relation

to dirt, dust, noise, pollution which have been highlighted by the Inchicore on Track’s

submission and will affect the residents of Inchicore railway estate.

Believe the EIS is flawed.

Serious consideration should be given to the proposed route of the line as it interferes

with Sarsfield Road.

No attempt has been made to take into account the Dublin City Development Plan by

Iarnrod Eireann.

Concern with respect to working hours proposed.

26. Catherine Byrne TD and Councillor Claire Byrne, 30 Bulfin Road, Inchicore,

Dublin 8.


Support for the integrated transport system.

Primarily concerned with the effects that tunnelling and construction will have on the

Inchicore and Christchurch areas and the people who reside there.


Do not agree that the playing field is the most suitable location for the intervention

shaft at the sports ground in the CIE estate. The height of the shaft is excessive for

this low rise residential area and will have a negative visual impact on the area.

Welcome the decision to relocate the cut and cover western portal from George’s

Villas to the CIE works.

It is important that buildings of historical significance are retained where possible.

It is vital that disruption and noise during the demolition work is kept to a minimum.

Concern with respect to noise and vibration from tunnelling and infringement on the

quality of life of local residents.

The property protection scheme must be transparent and accessible to residents and

any damage caused must be repaired to the highest standard.

Fully support the construction of a new Dart Station in Inchicore which would be

located in the CIE works.

Concern that 24 hour working will cause convenience for residents.

Any change to the working hours must be notified in advance to local residents.

Access to the new Dart Station in Inchicore needs to be clarified.

Will there be separate access for cars, pedestrians and cyclists?

Support maintaining the current pedestrian access route via the main entrance to the

CIE works however proposed to opening up pedestrian access to the rear of Abercorn

Terrace.

A park and ride should be considered in Inchicore.

Support a link of the Dart with Luas as long as residents are carefully consulted on the

route and associated works.

Consider that compensation should be forthcoming for four years of dust, noise and

construction.

Iarnrod Eireann must give back to the community in the following areas.

1. Upgrade street lighting in and around CIE estate.

2. Upgrade pavements, footpaths, road servicing.

3. Upgrade boundary wall of CIE sports and social club by installing new

railings.

4. Development of a new community centre. Refurbished / replace the old CIE

sports and social club which is in a poor state of repair.

5. Recede green areas where necessary and replant flowers, trees.

6. Upgrade and restore the boundary wall at the CIE estate.

It is important that both the CIE site Master Plan 2003 and the Draft Urban Design

Framework for CIE are taken into account throughout the construction phase.

Concern with respect to loss of civic space.

Do not believe that Cook Street is an appropriate location for a ventilation shaft.

All excavation and tunnelling works must respect the archaeological heritage of the

area notably around Wood Quay.

On-going communication with residents is necessary.

All queries and problems should be dealt with swiftly.


27. Chris Andrews TD, Dail Eireann, Leinster House, Kildare Street, Dublin 2.



Support in principle for the project.

Concern in particular with residents and businesses in the Dublin 2 and Dublin 8

areas.

Concern with respect to noise pollution and general inconvenience to residences and

businesses during the construction phase and the operational phase.

Concern with respect to damage to property. It is critical that correct procedures and

processes are put in place to ensure a speedy resolution of any problems that may

arise.

In the event that serious damage was to incur to a property the limit of €30,000 is not

sufficient.

Concern that the process that should damage in excess of €30,000 occur,

responsibility will refer to the contractor, thus leading to protracted disputes.

Submit that given the level of disruption to the Dublin 2 and Dublin 8 areas that an

audit of the social and community infrastructure be carried out and that a community

game fund be established.

There is a need for more services for young people, more playgrounds, better

community services for the elderly.

28. Councillor Kieran Perry, Members Room, City Hall, Dublin 2.

The contents of the above submission can be summarised as follows:

Concerns expressed with respect to the north inner city constituency and elsewhere.

Residents in East Wall, North Wall and North Strand and Ossory Road areas will

suffer enormous difficulties during the construction phase of the project and to a

lesser extent during the operation phase.

It is essential that the level of disruption is kept to the absolute minimum and

measures to provide protection for residents conditioned into the Board’s decision.

Residents must be provided with protection to minimise the impact from noise, dirt,

dust, vibration and light pollution.

It is essential that mitigation measures are coupled with clear monitoring procedures.

A clearly defined procedure for reporting and addressing all features of conditions

must be provided.

A Traffic Management Plan is of extreme importance.

A parking plan for construction phase workers is necessary.

Sound barriers erected throughout East Wall have proven effective but they need to be

increased to provide extra reduction in the operational phase.

Sound barriers should be extended to the North Strand side of the track and also to

other areas, North Wall, Ossory Road etc.

The quality of landscaping and railing should be of quality and as agreed with existing

residents.

Concern with respect to the level of consultation that has taken place, transparency

issues and at the commitment of Iarnród Eireann to a genuine engagement.

There is a need for a liaison committee with representatives from the effected

communities, Iarnród Eireann and the contractors to be established to address the on-

going construction issues that will affect residents.


Residents of East Wall would suffer a major impact due to the relocation of the bridge

on West Road.

The possibility of an alternative realignment should be assessed.

Requested an oral hearing be heard.

29. Oisin O’Halmhain, Sec. Green Party Dublin South Central Branch, 18 Viking

Harbour, Ushers Island, Dublin 8.


The proposed location of the railway station serving Inchicore should not be located

in the Inchicore Railway Works site. It should be located underground within 100

metres of the centre of the existing Inchicore village.

The project should be extended to Kylemore Road or Le Fanu Road, Ballyfermot

where a further station should be built to serve Ballyfermot.

If a station were built in Inchicore Village then

(a) Businesses in the village would benefit from more footfall

(b) It would improve viability and ambiance of the village

(c) Create jobs in the village and surrounding area

(d) It would encourage attendance of the local football club

(e) It would provide a way to get crowds into Richmond Park

(f) it might be possible to incorporate an underground car park which would make

Inchicore Village more accessible to everyone.

(g) Would encourage integration with bus services

(h) Tourism would be facilitated at Kilmainham Jail the War Memorial Gardens

and the Grand Canal would be more accessible from the City Centre and beyond

The proposed location for the DART station in the Inchicore Railway Works is

unsuitable for the following reasons:-

(a) The proposed site is more than 500 metres from the natural centre of the village.

(b) The location is more than a 50 minute walk away from Bulfin Estate where a

large number of residents live.

(c) The proposed site is enclosed in a location that is presently not very accessible.

(d) Narrow residential roads would have to be used by pedestrians and motorists

wishing to access the station.

(e) Development of the station in the works would appear to be contingent on

rezoning of the land currently light industrial to residential but is not desirable

in terms of Dublin City Development Plan.

A station at either Kylemore Road or Le Fanu Road would have the following

benefits:-

(a) It would serve the large population of Ballyfermot

(b) It would allow an interface with the LUAS line F to Lucan

(c) It would allow for better interface between DART and bus services including

the Cross City Route 18.

Overall support for the project however the location of railway stations are important

given that they determine the success of the project.

30. Cllr. Kathleen Kelleher (Greystones TC), 27 Rathdown Park, Greystones, Co.

Wicklow.



Focused on the Inchicore Area

Recognise many of the points raised in the Inchicore debate as the same points which

were raised in the DART extension to Greystones

There was much negativity – however it has been hugely advantageous

Financial gain has also attributed

The Inchicore Dart Station will provide a community gain to the residents of

Inchicore and Lower Ballyfermot

Improved sustainable transportation

Regeneration of the disused and underutilised CIE lands

Local job employment opportunities

The existing housing stock in the area incl. Abercorn Sq. Wheaton Court apartment

complex, Grattan Court terraced town houses, The Works terraced houses,

development at Floraville and Sevenoaks apartments has set a precedent for

development.

All of the aforementioned modern builds provide an encouraging and welcome

precedent for future housing provision on the disused and underutilised site.

There is widespread enthusiasm from the residents of the Inchicore Railway Estate

Is hopeful that the application is successful.

31. Sean Ardagh TD, 168 Walkinstown Road, D12.

The contents of the observer submission from the above can be summarised as follows:-

Requests that the representation on behalf of Celia Clifford be taken into account.

32. Cyprian Brady TD, St. Luke’s, 161 Lower Drumcondra Road D9.


Submission on behalf of the residents of East Wall

Fully supports the submission made by the residents of East Wall and particularly the

residents association

Enclosed is a Draft Charter which the residents would like to see implemented.

Concern with respect to noise levels, disruption to residents, programme of works

Consultation is required at each stage of works

Request that the views of the residents as per their submission be taken into account.

33. Ruadhan Mac Aodhain BL, Sinn Fein Public Representative, 29 Munster Street,

Phibsboro, Dublin 7.


Inadequate consideration in the EIS on health implications for residents of East Wall

Proposed 24/7 construction working hours unacceptable

No adequate assessment of noise pollution


Location of the tunnel boring machines in close proximity to residents places them at

risk of exposure to hazardous materials and air pollution.

EIS fails to provide alternative routes in instances where road closures are proposed.

No consideration of traffic disruption

The draft order fails to assess alternative forms of transport e.g. rail

No proposal for social dividend for East Wall community

GENERAL OBSERVER SUBMISSIONS

34. Roger O’Connor, c/o Peter Sweetman & Associates, 184 Lower Rathmines

Road, Rathmines, Dublin 6.


Application NA0005, Application NA0004 and Application NA 0003 are

interconnected.

There is a requirement in EU Law that they should be assessed together.

The applications should have been assessed in their entirety.

It is submitted that a Strategic Environmental Assessment (SEA) would have been

appropriate.

It could not possibly be considered sustainable development to build two stations at

St. Stephen’s Green.

The procedure adopted is contrary to the law.

35. Centre for Independent Living, c/o David Egan, Carmichael House, North

Brunswick Street, Dublin 7.


Issues concerning accessibility for people with reduced mobility on Dart underground.

The observers welcome this vital new piece of transport infrastructure which will link

all of Dublin’s transport systems.

The observers understand that all new stations on the proposed Dart underground will

accommodate wheelchair users in line with relevant legislation and best practice

guidelines both nationally and internationally.

The observers wish An Bord Pleanála to take a view on the accessibility of the entire

system including the platform/carriage interface.

The observers are mindful that the rolling stock which Iarnrod Eireann proposes to

use in operations on the Dart underground may not form part of the planning process.

It is not possible to view rolling stock on platforms as separate entities in the context

of wheelchair access and it is the interlocking nature of the relationship which will

determine the accessibility of the system.

The European Community Directive 2008/164/EC which came into effect on 1st July,

2008 applies to all rail systems in Ireland.

The observers define wheelchair access as the ability of the users of both manual and

electric wheelchairs to have unassisted access to every aspect of Dart underground.


The stepping distance target will require that some wheelchair using passengers would

have to request assistance from Iarnrod Eireann staff to deploy a manual ramp for the

purpose of boarding and disembarking rolling stock.

Such a deployment would render the Dart underground ineffective, inefficient and a

deterrent to potential passengers with disabilities.

Deploying manual ramps in a busy underground station would be impractical.

This single piece of infrastructure which is intended to link all of the unassisted

accessible public transport systems will require that wheelchair users seek manual

assistance, the observers believe that such a proposition is both unthinkable and

untenable.

An Bord Pleanála should set as a condition for its approval of the CIE Railway Order

Application that the applicant demonstrates how they intend to achieve unassisted

wheelchair access on the Dart Underground using platform based solutions or with

carriage integrated automatic ramps.

Iarnrod Eireann should be required to state the stepping distance they intend to

achieve between the carriage and platforms.

The observers refer to Article 9 of the United Nations Convention on the Rights of

Persons with Disabilities.

The Irish Government has signed this Convention and signalled its intention to ratify

the Convention in 2010.

It is the view of the observers that requesting assistance to deploy a manual ramp falls

outside of Article 9 of the said Convention.

Platform based ramps are commonplace on heavy rail systems in Europe and have the

advantage of being a relatively cheap way of eliminating any vertical gap.

Integrated electric or electro-hydraulic ramps offer a more complete solution

responding to the problems of vertical gap, horizontal gap and platform variance.

None of the existing Dart carriages are fitted with electronic ramps and the operating

company intends providing assistance to deploy manual ramps for use on existing

rolling stock and Dart Underground.

It is technically feasible to retrofit existing carriages with vertically mounted

electronic ramps.

The observers are of the view that as a condition of planning all Dart rolling stock

including existing rolling stock which will use the Dart Underground system will have

at least one carriage per train set fitted with electronic hydraulic ramp for use by

wheelchair users if required.

36. Irish Wheelchair Association, c/o Aras Chúchulainn, Blackheath Drive,

Clontarf, Dublin 3.


The observers very much welcome this vital new piece of transport infrastructure.

However they are extremely anxious to ensure that everybody will have access to all

modes of transport.

They understand that all new stations on the proposed Dart Underground will

accommodate wheelchair users in line with relevant legislation and best practice

guidelines both national and international.


The observers wish An Bord Pleanála to take a view on the accessibility of the entire

system including the platform/carriageway interface in respect of wheelchair access.

The observers are mindful that the rolling stock which Iarnrod Eireann proposes to

use in operations and Dart Underground may not form part of the planning process.

The carriages interface with the station platforms which do not form part of the

planning application will be critical to wheelchair access. The observers refer to the

European Community Directive 2008/164/EC which came into effect on 1st July,

2008.

It is the opinion of the observers that the question of “most viable overall solution”

should form part of any decision by An Bord Pleanála.

The observers define wheelchair access in the context of this submission as the ability

of the users of both manual and electric wheelchairs to have unassisted access to every

aspect of the Dart underground.

The inspirational stepping distance of some 56 millimetres in total will require that

some wheelchair using passengers would have to request assistance from Iarnrod

Eireann staff to deploy manual ramps for the purposes of boarding and disembarking

rolling stock.

Such development would render the Dart underground ineffective, inefficient and a

deterrent to potential passengers with disabilities.


The indirect cost of slowing the entire network to accommodate wheelchair

passengers boarding and disembarking with use of manual ramps and assistance

would bring Dart underground into disrepute.

This single piece of infrastructure which is intended to link all unassisted accessible

public transport systems will require that wheelchair users seek manual assistance.

It is the observers’ position that An Bord Pleanála should set as a condition for its

approval all of the CIE Railway Order application that the applicant demonstrates

how they intend to achieve unassisted wheelchair access on the Dart underground

using platform based solutions or with carriage integrated automatic ramps.

Iarnrod Eireann should be required to state the stepping distance they intend to

achieve between the carriage and platforms.

The observers refer to Article 9 of the United Nations Convention on the Rights of

Persons with Disabilities.

The Irish Government has signed up to the convention and has signalled its intention

to ratify the Convention in 2010.

It is the view of the observers that requesting assistance to deploy a manual ramp falls

outside of the said Article 9.

There are other more cost effective solutions available.

Platform based ramps are commonplace and heavy rail systems in Europe and have

the advantage of being a relatively cheap way of eliminating any vertical gap.

Integrated electric or electro-hydraulic ramps offer a more complete solution


None of the existing carriages are fitted with electronic ramps and the operating

company intends providing assistance to deploy manual ramps for use in existing

rolling stock in Dart underground.


electronic ramps.


A number of the existing train sets do not meet the specifications for operating a Dart

underground.

It is the view of the observer that as a condition of planning permission all Dart

rolling stock including existing rolling stock which will use the Dart underground

system will have at least one carriage per train set fitted with electro-hydraulic ramp

for use by wheelchair users if required.

37. Rail Users Ireland, c/o Colm Moore, 42 Kenilworth Square, Dublin 6.


Full support for the project and welcome the decision to extend it to Inchicore.

Main concerns relate to passenger experience, accessibility and operational efficiency

of the proposed project.

A level platform to train interface should be provided within the tunnels for improved

accessibility and reduced passenger risk and convenience of wheelchair passengers.

It should be possible for Docklands Station to operate as a terminus in the following

scenarios.

(a) Line north of East Wall Junction blocked / closed. Between Church Road

junction and Westwood junction is straight, level and of sufficient length to

provide a twin track turn back facility and would resolve this situation and

(b) Line south of Spenser Dock blocked closed. A simple crossover north of

Spenser Dock Station would resolve this situation.

This ensures service can be maintained under failure conditions.

It would also be useful if the ability to operate trains from the DART Underground

onto the Maynooth line and vice versa with double track be maintained. This would

involve some adjustment in the vicinity of Church Road Junction.

The current concourse within Heuston is constrained and is unlikely to be able to cope

with the large flows of interchange passengers at peak hours. Effective interchange

between intercity/community services to the DART service with a minimum of turns

and ticket gates is essential.

The walk from the secondary concourse of platforms 6, 7 and 8 to the main concourse

is excessive, potential to use the now unused fast track building and ticket desk as an

access to a pedestrian tunnel connecting the secondary concourse directly to the

platforms below.

Clarity is required as to the pedestrian access to Inchicore Station.

The fact this station, while a separate planning issue is an integral part of the project

should be clearly stated.

The current fast/slow, slow/fast arrangement for the Kildare Route Project KRP

makes efficient use of track capacity, best use of the turn backs at Adamstown and

Hazelhatch and allows other non-electric passenger and freight services to use the

DART tracks, should the fast tracks be blocked for some reason. Would also

minimise disruption while the tunnel section is added in, as the existing signalling

would not require alteration.

Given the difficulties which are becoming clear with the TBM cut and cover interface

in Inchicore an option may be for the Inchicore Station to be sub-surfaced at 5-6

metre depth with the station in an open box as per stations on the UK high speed line


in London thus moving the TBM cut and cover interface away from residential

property.

This would allow for easier pedestrian access, saving a set of stairs and would

facilitate an underpass arrangement for the connection to the centre two tracks of the

4-track section.

The traditional hump and valley model should be followed that stations would be

slightly closer to the surface than the normal tunnel. This would give trains leaving a

station a downhill gradient assisting acceleration and a uphill gradient when

approaching stations assisting breaking. This reduces running costs and gives a

fractional performance improvement.

The previous option with the Merrion Square entrance is preferable as it offers a

direct passenger route where a large portion of passengers are destined. This offers

also good integration with bus services on the Ballsbridge Blackrock QBC.

Previous public consultation referenced a possible grade separated junction at East

Wall in light of the fact that Northern Ireland would be pushing the limits of its new

signalling system all conflicts should be removed to maximise capacity and minimise

delays.

Despite a number of railway orders having been made in the last few years there

appears to persist some lack of standardisation, minor errors and spurious

information. The railway order will need to be reviewed in detail to remove such

items.

Generally happy with the design given the constraints placed on the project however

there are a number of comments and would request that the Board condition the

Railway Order accordingly:

1. Some internal routes are excessively winding for example the Docklands.

2. The absence of ticket offices or other fixed contact point is concerning.

3. Do smoke vents need to be taller than adjacent buildings?

4. Should cross passages have smoke lobbies?

5. Spenser Dock vs. Docklands. What is this station to be called?

6. New bridge over West Road must be of adequate height to avoid bridge

strikes. The current design is likely to be prone to bridge strikes.

7. West Road diversion is excessively winding. Details of cycle route are needed.

8. West Road must be kept open during construction.

9. Cycle parking provision at stations is derisory.

10. Drawing DU-IS-101-C-D-12.PDF, no fire lobby between low voltage Room 1

and escape route.

11. Fire escape stairs should be designed such that escapes can’t normally go

down from the track level.

12. Drawing DU-ST-101-A-C-01.PDF, moving bike lane from path-road-path is a

recipe for trouble.

13. DU-ST-101-A-C-02.PDF, why is bicycle parking provided in two separate but

close locations.

14. Drawing DU-IS-102-0-A-04.PDF, should the air extractor supply be separated

more.

15. Drawing DU-RO-102-C-PO.PDF, no details provided of advisory cycle lane.

16. Drawing DU-RO-103-A-B.PDF, placing of intervention shaft prevents the

building line of Bridgefoot Street being improved.

17. Drawing DU-ST-103-C-0-03.PDF, no fire lobby between waste storage room

and escape route.


18. Christchurch - pedestrian’s access to Essex Street West required.

19. Christchurch - PRM access to top of Christ Church Hill required.

20. Drawing DU-ST-103-C-0-02.PDF, amphitheatre needs to be circular.

21. Drawing DU-ST-103-C-0-02.PDF, can direct access be provided from ground

level to concourse level without the intermediate landing between the

escalators? Landing is relatively small and risks congestion.

22. Drawing DU-LW-104-0-0.PDF, River Poddle missing.

23. Drawing DU-ST-104-A-0-06.PDF, PRM refuge marked in UPS room.

24. Drawing DU-ST-104-A-0-06.PDF, no ticket machines at gate line at

interchange with Metro North.

25. Drawing DU-ST-104-A-0-08.PDF, no lobby between cross passage and

escape stairs.

26. Drawing DU-FB-106-B-C-01.PDF, why no lift to bridge for emergency

access?

27. Drawing DU-MC-106-A-B-12.PDF, wheal breaker type bicycle stands should

not be used. Why is the bicycle stand outside gate but car parking inside?

28. Drawing DU-ST-106-0-A-01.PDF, concealed unsupervised location for cycle

parking is unacceptable.

29. Drawing DU-ST-106-0-A-02.PDF, it would be useful to omit the landing and

have direct escalator access from the concourse to platform level.

30. Drawing DU-ST-106-0-A-06.PDF, if possible provide straight route from

LMS building to concourse, reduce distance from entrance to platforms.

Full support for the project and welcomes the opportunities it would provide to the

City and eastern region, requested an oral hearing be heard.

38. Donie O’Leary and Morgan McKnight, People With Disabilities in Ireland, 4th

Floor, Jervis House, Jervis Street, Dublin 1


People with Disability Ireland (PWDI) welcome the new DART Underground.

PWDI wishes An Bord Pleánala to take a view on the accessibility of the entire

system including the platform/carriage interface in respect of future access.

Ask that An Bord Pleánala are cognisant of all other people with other ambulatory

disabilities, visually impaired, temporary disabilities such as broken limbs, older

people, people pushing prams etc.

Mindful that while the rolling stock which Iarnród Eireann propose to use in

operations on DART Underground may not form part of the planning process

however the carriages interfaces with the platform stations do form part of the

planning application.

It is not possible to view rolling stock and platforms as separate entities.

The European Community Directive 2008-164-EC came into effect on July 1st 2008

and it applies to all rail systems in Ireland.

TSI Technical Specifications for Interoperability states that a boarding aid shall be

provided and the Infrastructure Manager and the Railway Undertaking shall decide

who is responsible for provision of boarding aids and to ensure that the division of

responsibility they agreed is the most viable solution.

The Infrastructure Manager and the Railway Undertaking in this case are a single

entity.


It submitted that the most viable overall solution should form part of any decision by

An Bord Pleánala.

Should there be a stepping distance of 56mm it will require that some wheelchair

users would have to require assistance from Iarnród Eireann staff for the purpose of

boarding and disembarking.

A stepping distance would render the DART Underground ineffective, inefficient and

a deterrent to potential passengers with disabilities, making it prohibited for people

with disabilities for independent and dignified boarding and disembarking.

The CSO Disability Survey 2006 found that the difficulty getting on and off public

transport was the reason 16% of disabled people did not use it.


The indirect cost of slowing down the entire network to accommodate wheelchair

users would be unacceptable

It is proposed that Metro North have access similar to the current LUAS system

unassisted.

It is submitted that An Bord Pleánala should set out a condition, in its approval of the

Railway Order application, that the applicant demonstrate how they intend to achieve

unassisted wheelchair access on the DART Underground using platform based

solutions or with carriage integrated automatic ramps.

Iarnród Eireann should be required to state the stepping distance they intend to

achieve between the carriageway and platforms. In the absence of such a clear

statement, planning permission would be based on an aspiration.

Platform based ramps will require the trains stop in designated positions as set out in

TSI.

Integrated electric or electrohydraulic ramps offer a more complete solution



electronic ramps, sub floor ramps may not be technically feasible or cost effective.

A number of the existing DART rolling stock do not meet the specifications for

operating in DART Underground.

Given the requirement to fit only one electronic ramp per train, the cost of retrofitting

the existing fleet prior to DART Underground becoming operational in 2018 would be

technically feasible and a cost effective solution.

PWDI submit that it should be a condition of planning that all DART rolling stock

including existing rolling stock which will use the DART Underground system will

have at least one carriage per train set fitted with an electronic hydraulic ramp for use

by wheelchair users if and when required.

Also requested all information systems such as booking tickets, ticket vending

machines, timetables and websites etc. should be accessible.

39. Luke Gardiner Ltd., 19 Mount Joy Square, Dublin 1.


Submission on behalf of Luke Gardiner Ltd. as a company involved with property

management, development and urban regeneration in the north City Centre area.

Public transport is a priority within the Dublin region.


It is submitted that as the applicant has not furnished a strategic Environmental

Impact Assessment the Plan is failing to comply with EU law.

An SEA evaluates how the proposed project knits in with other infrastructure and

plans.

As set out in the 2005 Directive an SEA should be conducted where there is a

programme likely to set a Framework for development consents – as a high quality

new public transport corridor will do as it will be cited when applications will be

made by Developers for schemes such as possible high density department schemes

along the route.

An SEA is of crucial importance and should be provided for in order for the scheme

to be properly evaluated particularly as this project is only one element of a much

larger transport scheme for the Dublin area known as Transport 21.

In the absence of an SEA being furnished this application appears premature.

The scheme conveniently ignores that there is already a line with Spenser Dock and

Heuston that goes by the north side which Irish Rail are not using nor do they plan to

use.

This project proposes to build the bottom half of a loop while leaving the top half

unused.

Criticise that this Plan effectively bypasses the north City Centre.

The proposal benefits Developer interests and the south-east Docklands area of the

City at a major unnecessary cost.

This project would effectively disconnect Connolly station – the de facto station for

the north centre commercial core – from its natural hinterland.

If adopted as proposed then future shoppers coming from Raheny, Howth or Malahide

who wish to go to the O’Connell Street area are not to be brought into Connolly as

currently happens but instead via Docklands under the Liffey where they will have to

change at Pearse in order to go back across the Liffey so as to get off at Connolly.

Realistically passengers would be much more likely to simply alight at Stephen’s

Green instead.

It would be far better if an SEA was provided to demonstrate all of the impacts of the

proposed scheme as presently the EIA treats the projects as if it were a standalone

scheme.

It is questionable as to who really benefits from the proposed scheme.

Request that the Board consider asking the applicant to withdraw the Plan and instead

resubmit a complete application that would contain an SEA.

40. Gerard Ellis, 8 Wyattville Road, Ballybrack, County Dublin.


Supports the interconnector in principle.

Concerned with respect to the vertical and horizontal gap between carriages and

platforms.

Understand that there is no defined stepping distance between the proposed new

platform and the DART rolling stock but there is an aspiration on the part of the

operating company to have a stepping distance target of 20mm vertical and 15mm

horizontal. These targets have not been verified as feasible.


Even if the aspirational figures are met, these distances are enough to cause regular

problems for many people who will trip over them. It would cause considerable

problems for wheelchair users and commuters with other ambulatory disabilities and

who would require assistance from staff members and thus could not travel

independently.

It is often thought that issues such as accessibility of the interconnector only effect

wheelchair users however a wider cross-section of society would be affected.

It is clear from all regulatory instruments in particular the UN Convention that it is a

clear aim of national and international legislatures that accessibility be the norm, not

the exception.

If the interconnector is built in an inaccessible fashion it would be legally challenged.

Using a transport system is not just about boarding and alighting, it involves a

complete chain of actions including investigating timetables, purchasing tickets, car

parking, using information, using facilities in stations and on trains such as toilets etc.

An organisation called direct inquiries carried out audits and produced information

about the underground stations. An example of this information is contained at

http;//www.directinquiries.com/information/ealing percentage 20

Broadway/74262/Station Plan route/inforamtion.aspx

Inaccessibility is an avoidable danger to the elderly.

Given the percentage of people with reduced mobility there is a requirement for any

transport system to be accessible.

Young children, parents with infants and prams, people with temporary disabilities

such as broken limbs, people burdened down by shopping or luggage, people wearing

high heels and people rushing for a train are just some examples of others who could

be affected.

Manual ramps could possibly delay trains, require sufficient staff members to be

present, would be costly to the train operators and would cause disruption to other

commuters.

A fixed platform based solution requires that every train stop very precisely so that

the carriageway doors are aligned with the lifting service. This is highly unlikely to

happen in reality.

Fixed platform based solution limits affected commuters in the carriages they can use,

excludes effected commuters if the carriage close to the lifting devise is full even if

there is space elsewhere on the train and can cause blockages on the platform for

every commuter.

Automated ramp on one carriage allows the train to stop anywhere along the platform,

still limits effected commuters to only one usable carriage, forces effected commuters

to know precisely where to wait on every platform, results in one carriage per train

being designed differently from the rest. This would add an extra cost when

manufacturing and maintaining the carriage.

Automated ramp on one carriage is better than fixed platform based solution or

manual ramps.

Automated ramp on every carriage allows every commuter to use every carriage thus

minimising delays, allows every carriage to be built to the same specification thus

avoiding extra capital for on-going maintenance costs as compared to having some

accessible and other inaccessible carriages.


Eliminate all gaps. This would involve no horizontal or vertical gaps between the

carriages and the platform. This solution is an ideal solution. It requires comparison

with similar European systems to test its feasibility.

If the interconnector is developed as proposed is likely to lead to a large number of

compensation claims.

An accessible transport system is required to help reduce the high unemployment rate

amongst people with disabilities.

For internationally recognised standards on the development of accessible websites

see the Web Content Accessibility Guidelines from the World Wide Web consortium

at www.w3.org/wai.

Request that the Board set the following conditions of its approval of the

interconnector:

1. Ensure that the entire transport chain is accessible. This includes websites for

timetables, ticketing mechanisms, car parking, toilets and all other facilities as

well as the interface between carriages and platforms.

2. Undertake a study of similar systems in Europe to ascertain if it would be

possible to eliminate gaps between the carriages and the platforms and

implement the solution if possible.

3. Failing this install automatic ramps in every carriage which would allow those

who need them to Board and alight safely and quickly.

4. Specify a maximum vertical and horizontal gap that may be present between

the carriages and the platforms.

5. Do not allow the operators to force commuters to rely on assistance from staff

members.

6. Insist on internationally recognised best practice in designing and developing

all aspects of the interconnector such as universal design and the W3CWCAG

Guidelines.

An observation accompanied the submission with a list of:-

o Legislation and the UN Convention on the Rights of Persons with Disabilities,

Article 9 Accessibility and Article 20 Personal Mobility.

o Central Statistics Office age projections.

o European Disability Form information.

41. Dublin Chamber of Commerce, 7 Clare Street, Dublin 2.


Dublin Chamber supports the Transport 21 programme for the Dublin City region.

Dublin Chamber supports the granting of a railway order for the DART Underground

project subject to certain conditions being attached so that it is business as usual for

all businesses during enabling works, main construction works and when DART

Underground is fully operational. Successful delivery of DART Underground will

depend on mitigating the adverse effects during construction.

Consider that special attention on the part of the responsible transport agencies, public

authorities, An Garda Siochána and An Bord Pleánala is warranted on:

1. The construction period for the three rail projects in the City Centre

2. Traffic management, access to premises and the rerouting of traffic in both

short and longer term and

http://www.w3.org/wai


3. Communicating the plans for addressing disruption to all users of the City in a

positive way and marketing the City as fully open for business.

DART Underground will reduce urban sprawl and help concentrate the location of

businesses which would improve Dublin’s international competitiveness.

Concur with Iarnród Eireann that DART Underground will provide a major economic

impetus and play a central role in economic growth when supported by height and

density along the key transport corridors into Dublin and the central business district.

The marked downturn in economic activity over the past few years has depleted the

reserves of businesses. There is genuine concern about ability to remain trading

through a protracted period of disruption due to the combined construction works of

DART Underground, Metro North and LUAS Broombridge.

Dublin Chamber is disappointed that a detailed Impact Assessment of the cumulative

impacts of delivering these three projects has never been completed by the RPA and

Irish Rail.

Construction works should be conducted in as short period as possible and be

completed in a period of no more than 5 years.

Request that a condition be attached requiring the main works at Stephen’s Green on

Metro North and the DART Underground to be constructed at the same time.

Concerned that the DART Underground, Metro North and LUAS Broombridge

projects are each being treated and managed as separate projects by separate teams.

Call on Iarnród Eireann to:

1. Ensure that the winning bidder will work closely with the Railway Procurement

Agency and its contractors for Metro North and LUAS Broombridge so that

appropriate and comprehensive planning takes place.

2. Engage openly and extensively with businesses operating in the affected area and

3. Take full responsibility for the impact on Dublin City Centre environment when

delivering their project.

The proposed tunnel and station box alignment at Stephen’s Green should be moved

to an alignment under the Green, an option which Irish Rail has previously considered

and one which is possible from an engineering point-of-view.

Of particular concern is that rock breaking by blasting and/or propellants are likely to

be used by the contractor.

Welcomes the decision to put in place a Property Protection Scheme.

Concern that specific details of the Property Protection Scheme have not yet been

disclosed. No ceiling on the maximum amount of available funding for remedial

works should be set.

Concern with respect to noise and dust, mitigation measures. Remediation measures

should be put in place including periodic cleaning of the outside of buildings in close

proximity to the works including the facade windows, entrance areas and doors at

intervals to be agreed between parties.

Where possible all construction should proceed 24/7 and at a minimum the proposal

in the EIS to proceed with construction weekdays 7am – 11pm and weekends 7am –

3pm be included in the Railway Order. Firmly believe that any reviews to the 24/7

construction must be location and building specific.

Concern with respect to management of construction traffic and lack of car parking to

facilitate construction workers.

Effective traffic management will be required to ensure the businesses continue

trading successfully.


Request that all traffic and pedestrian plans are drawn up in conjunction with the

business community.

Submit that the contractor should not be responsible for traffic management at each

site. An Garda Siochána in association with Dublin City Council must be fully

responsible for traffic management to each site including the making of contingency

plans when emergency vehicles need access or when routes surrounding the site are

closed off due to unforeseen circumstances.

A 24/7 contact number must be made available to businesses in the area to ring if

there is a problem with traffic in the vicinity.

Public and private bus operators and taxis should be able to continue to offer high

levels of frequency in quality services.

Unimpeded pedestrian access is essential for all businesses.

There is a need for park and ride facilities to be put in place and to be fully

operational before enabling works for DART Underground and Metro North get

underway.

There is a need for a Comprehensive Marketing Plan that clearly informs all investors,

workers, shoppers and tourists planning on travelling into Dublin City that the City

remains fully accessible and open for business.

A programme of utility works must be created in consultation with businesses which

includes a Risk Management Plan.

Request that an oral hearing be undertaken.

The observation is appended by the Dublin Chamber of Commerce submission to An

Bord Pleánala for the RPA Railway Order for Metro North dated 29th

October 2008.

The submission is also appended with Dublin Chamber of Commerce submission to

An Bord Pleánala with the RPA Railway Order for LUAS Broombridge (Line BXD)

dated 13th

August 2010.

42. Cormac Rabbitt, Dargan Project, 8 Hy Brasail Court, Circular Road, Galway.

The contents of the observer’s submission from the above can be summarised as follows:

Contend that the DART Underground scheme should and could be modified so as to

encompass

1. A circular line metro and

2. A single large tunnel.

The benefits of such amendments are significant and would include

(a) Public transport and its interconnectivity

(b) Patron safety

(c) The quality of the metro operation

(d) Construction safety

(e) Reduce construction disturbance and

(f) Reduce capital cost and reduce operation cost.

Believe that the alternative could be implemented by state agencies or it could be

implemented by Dargan themselves who are prepared to make a direct application for

a Railway Order with a view to state agencies and/or the private sector building and

operating it.

Since 2000 it was believed and expected that Metro procurement process was to

include route selection.


Request that an oral hearing be held and that Dargan could submit alternatives at the

oral hearing.

43. National Disability Authority, c/o Siobhan Barron, 25 Clyde Road, Dublin 4.


The National Disability Authority (NDA) is the independent statutory advisory body

to government and issues of disability policy in practice.

Accessibility for people with disabilities, elderly people and others with reduced

mobility should be a key criteria in the design and operation of this infrastructure and

associated rolling stock.

This is in line with

1. The obligations under the Disability Act for public bodies to provide services

that are accessible to people with disabilities – related statutory Code of

Practice and accessibility of public services and information provided by

public bodies.

2. The commitments in Transport 21

3. The obligations of the Equal Status Acts

4. The EU technical specifications on interoperability with regard to accessibility

for persons with reduced mobility

5. The provisions on mobility and accessibility set out in the UN Convention

There is a substantial estimated number of people living within the Greater Dublin

Area with specific long-term disabilities.

The CSO forecast that the number of elderly people in the Greater Dublin Area is on

an increase.

The detailed design of DART Underground and of the proposed transport interchange

should carefully address the needs of different types of users.

It is important to build in the accessibility features at the design stage.

Priorities for accessibility include station access, facilities to aid step-free passenger

movement, ticket offices with split level counters, non-reflective glass, significant

colour contrasting, induction leaps, improved lighting and security, customer

information and customer facilities including accessible toilets and improved waiting

areas.

The design of DART Underground should enable people with disabilities to make

seamless journeys.

There is a need to consider for example carriageway and platform alignment (and

gaps), footpath slopes, surface edge garden, railings, signage, door sizes and operation

specifications.

Part A of the Building Regulations (on disabled access) is currently being revised and

expected to be issued in late 2010.

The optimum design of the platform train interface with DART Underground would

be a level floor access system similar to the LUAS.

Stations with platforms that are used by both mainline trains and the DART need to

allow for the differences in rolling stock, running height for DART and for diesel

commuter trains.

A stepping distance target of 20mm vertical (about 0.8 of an inch) and 15mm

horizontal (about 2 inches) which it is understood to be considered by Iarnród Eireann


can pose a risk of traffic crutches or other walking aids and compose a risk also for

wheelchair users, people with vision impairments, elderly people and others with

reduced mobility.

The feasibility of mobile ramps at stations is difficult to see.

Mobile ramps would diminish the independence of people with disabilities to

undertake spontaneous journeys that would be characteristic and urban pasture

transport service.

Automatic bridging plates (with manual backup) are preferable to bridging plates that

need to be moved into place by staff.

There is a need to engage with stakeholders around details accessibility design.

44. Warren Whitney, 31 The Avenue, Bolden Park, Rathfarnham, Dublin 16.


Support for the project in principle.

Endorsement of the general thrust of the plans for St. Stephen’s Green.

The Phoenix Park tunnel is not an alternative to DART Underground.

With respect to the fact that the existing Howth-Bray route would be broken as a

result of the development of DART Underground with the north side section being

diverted into the tunnel and the south side section joined into the Maynooth line it is

submitted that on balance journey opportunities created for the proposed changes

counterbalance the opportunities lost.

Albeit that north side DART stations would lose direct access to Connolly they would

gain direct access to Heuston.

Conditions concerning routing and timetabling are appropriate for the railway order.

Consider that the site at Inchicore is a good location for the Inchicore station.

The station site within the works is accessible to the lower Ballyfermott area which

will not be served by the Lucan LUAS.

Concern with respect to the station at Christchurch as it relates to the management of

the proposed hard landscape square replacing the present amphitheatre.

Concern that the area labelled as public square in plan DU-ST-103-C-02 to the east of

the bench seating/planting box would attract loitering during opening hours and how

it might be managed in order to avoid such problems.

Puzzled with respect to the presence of ticket barriers in the route between Metro and

the DART Underground platforms.

Concern at the potential obstacle of ticket barriers to easy interchange.

Welcome the cooperation between Iarnród Eireann and the Railway Procurement

Agency regarding the construction and management of the St. Stephen’s Green

station.

Concern with regard to access to the surface Docklands Station.

Serious consideration should be given to a more effective connection with the

underground station involving a possible northern entrance.

Consideration should be given to at least safeguarding the potential connection

between the two stations.

There is a need for security and policing strategy.

Ticket barriers should not be left open at any time during normal operating hours.


45. Dublin City Centre Business Association Ltd, c/o Tom Coffey, 21 Dawson Street,

Dublin 2.


The DCBA supports this application subject to the following:

1. That all restoration costs are funded from T21 budgets and not from business

rates in Dublin City.

2. All spoil be removed from CBD via the Bored tunnels not on CBD roads

which are needed for mobility to sustain the CBD economy.

3. All the work at St. Stephen’s Green should take place inside the railings at St.

Stephen’s Green park and not on the street between Dawson Street and

Merrion Row.

4. That all buildings including 18th

century buildings be protected from risk

caused by drilling and/or blasting in the section from Grafton Street to Merion

Row.

5. That all risk assessment to all buildings in this section of St. Stephen’s Green

north be published and taken into account by An Bord Pleánala.

6. That during construction access to CBD be maintained for shoppers, cars,

delivery of goods, staff, customers, rail and bus.

7. That all historic buildings near the construction works be safeguarded and not

damaged.

8. That all tourist tours of Dublin be able to continue to run their businesses

during construction works.

9. That the public demesne be reinstated respecting the historic core as a valuable

asset for tourism, an attracter of foreign currency spend into our economy

10. That streets and footpaths be kept clean with continuous access to shops,

hotels, bars and restaurants for pedestrians.

Submission accompanied by a disc containing information on defining Dublin’s

historic core a report by Dublin Civic Trust and Dublin City Business Association.

Also a printout of the report on the disc submitted.

The report entitled Defining Dublin’s Historic Core includes information on history

and attributes of the City, connectivity in the centre, ceremonial and civic space, the

public realm, getting about, revitalising the squares, commercial and civic life.

AREA 101 - Inchicore to Memorial Park

46. Patricia Corry, 4 St. Patrick’s Terrace, Inchicore, Dublin 8.


The observer objects to the granting of the railway order.

The objection relates to the observer’s personal health and wellbeing.

The impact on the observer’s health by the tunnelling and associated disruption is of a

major concern.

The proposed development will be detrimental to her health.

47. Joseph Anthony Currivan, 5 St. Patrick’s Terrace, Inchicore, Dublin 8



The CIE proposed development is a recipe for disaster to the community’s health and

safety.

The roads in the estate which are 150 years old are just adequate for the current level

of traffic.

Any increase will entail serious traffic management, will emergency services have

access to the estate in time of need?

The access road is a narrow road and cannot handle traffic in both directions for half

of its length.

The lane (rear entrance) and St. Patrick’s Terrace are to become access points to the

public to gain entry to the proposed station. These laneways have no proper footpaths

and are used by residents, driving/parking and service vehicles.

The proposed development raises a new range of problems relating to security and

safety for pedestrians and access for emergency services.

The CIE boundary wall at the rear of St. Patrick’s Terrace is old and starting to

crumble.

Five years ago a section of the wall fell out into the back lane and it took CIE five

years to get it repaired.

This wall will collapse into the laneway when they start working on the CIE site to

demolish the stores and construct electricity station.

The observer feels that CIE has been negligent in their consideration of their area of

influence with regard to the possible damage to homes in the estate. This needs to be

addressed in great detail with the residents as the current proposal is not acceptable.

The observer fears that CIE will sell off the remaining land for development when

they have completed the station.

The area inside the works would be ideal for training the next generation of

craftsmen.

The observer is concerned that CIE will be doing crisis management for the duration

of the construction.

CIE have not given the total plan serious consideration.

The proposed station is in the middle of nowhere.

The observer asks that the current application be refused and that CIE be ordered to

consult with the residents of the estate and address all the concerns brought before

them.

If the Board grant CIE the Order, the observer feels they could hand over the

responsibility to an agent and make themselves invisible and unavailable.

The observer wants to see progress but not at the cost of the community’s health and

safety.

48. Joe Homewood & Ned McLoughlin, 1 St. George’s Villas, Inchicore, Dublin 8



The observers’ house is part of the Inchicore Railway Estate and residential

conservation area with a deeply felt sense of history and a strong and vibrant

community.

The observers object to the EIS that accompanies the Railway Order.

The observers are unhappy with the manner and quality of consultation information

they have received from the first day they heard about the revised plan to tunnel to

Inchicore.

The observers work from home, not only their living space, but their working space is

to be invaded.

It is not possible from the EIS to get a sense of the cumulative impacts of the scheme.

There will be noise from the construction compounds, both immediately behind and

in front of their house from 0700 hours to 2300 hours, Monday to Friday and from

0700 hours to 1500 hours on Saturday and Sunday and bank holidays.

According to the proposals in the EIS, the observers will have no day when they do

not have heavy construction work going on.

The observers request An Bord Pleanála to restrict the hours of working to more

normal construction hours and to ensure that one day a week there is no construction

work.

The EIS should be clear and consistent on how long construction will take place.

The observers will be affected by dust and vibrations.

The environment around the observers will be utterly changed, as they will be

sandwiched by two construction sites.

It is imperative that there is proper monitoring in place and that there is a 24-hour

phone line that will be guaranteed to be answered by a person at a sufficiently high

level of management to deal immediately with issues as they arise.

There should be a representative of residents on a monitoring liaison group.

The preparation of an Environmental Management Plan as prepared by the CIE

should form part of Railway Order, this must not be left to the contractor.

CIE anticipate the observers’ house will experience “significant soiling”, this is not

quantified in any way.

The observers question the implications of this significant soiling.

A programme of mitigation must be developed and agreed with the observers as

residents.

The observers requested An Bord Pleanála insist on such a programme as a condition

of any Railway Order.

The observers raise a number of concerns relating to noise and traffic generated by

construction workers at the site.

An Bord Pleanála must insist that CIE prepare a proper plan to cater for workers

vehicles and ensure that no workers vehicles are parked on the estate.

An Bord Pleanála must make it a condition of the granting of any Railway Order that

CIE have proper mechanism to deal with all litter that is generated by the workers and

those working on site.

It is anticipated that there will be 88 two-way movements of traffic each day outside

the observers’ home.

The observers requested An Bord Pleanála lay down strict guidelines as to the volume

of construction traffic and the hours of which it is allowed to operate.

It is stated in the EIS that in Inchicore Parade, no significant impact is anticipated, this

is completely not the case, there will be enormous impact.


The EIS in fact contradicts itself when in the socio-economic chapter it admits that the

observers will suffer a major negative impact due to the social severance.

The EIS should be rewritten to be consistent.

It should be noted that the level of detail in the description of the visual impact of the

Inchicore Shaft is much less than for other intervention shafts.

The site of the Inchicore Shaft is not industrial land, this is in the middle of quiet

residential estate of some 240 houses.

There are no visualisation looking east from St. George’s Villas or looking west from

Wheaten Court or North Terrace. Both places where the visual impact would be more

significant.

The design of any building in the estate, i.e. the intervention shaft and the wall

surrounding it should complement the heritage buildings of the estate.

The operational/post-construction stage has a long-term significant impact for the

residents of the area.

The construction work will surround the observers’ home to the rear in the Inchicore

railway works and to the front by the shaft construction site. The observers are

concerned in relation to noise and vibration and the duration of same.

CIE indicate that there would be 24-hour working during the removal of the tunnel

boring machine and during the fit-out of the tunnel.

The observers are concerned about the noise that would come from the substation that

is going to be placed close to their house.

The observers will suffer from a very high impact as the tunnel boring machines pass

alongside their property.

The observers request An Bord Pleanála place stringent conditions on the granting of

any Railway Order in relation to frequent and proactive dust monitoring.

The observers will suffer light pollution from both of the construction sites around

their house.

There is a history of flooding of the east end of the Inchicore Parade, it appears that

the drains already have a great deal of difficulty with dealing with the flow from the

works.

There is a local history of the sports ground being flooded from time to time.

In relation to settlement, the observers request that An Bord Pleanála ensure that their

home is given a Phase 3 assessment and that their estate given the proper protection.

The observers request that An Bord Pleanála fully scrutinise the tunnel boring

machines chosen by CIE.

In Chapter 19 of the EIS no mention is made of the Inchicore Railway Estate, a site of

regional national importance.

The architectural heritage chapter of the EIS has again ignored the entity of the

Railway Estate, its unique character and vernacular architecture.

It is shocking that nowhere in the EIS is the historic railway estate referred to.

Along with the six years of disruption that the construction of the Dart Underground

will bring, the proposal for the station will also have profound changes for the area, it

would open up this quiet historic estate and has the potential to utterly change it.

The observers request that An Bord Pleanála hold an oral hearing into the application.

The observers look to An Bord Pleanála to ensure that they have legal guarantees that

a contractor cannot walk away from their responsibility.


The observers look to An Bord Pleanála to recognise the unique architectural and

cultural heritage of the Inchicore Railway Estate and to ensure that CIE recognises

and respects this heritage.

49. Gerard McGeough and Louisa MacDonald, 1 St. Patrick’s Terrace, Inchicore,

Dublin 8.


This application for a Railway Order by CIE will have a very marked effect on the

character of the Inchicore Railway Estate and the lives of those who enjoy living in it.

As the observers is the first house on the terrace and faces Inchicore Parade to the

front they inescapably are in the jaws of the project.

The observers wish to see the project built for the betterment of the area and the city

as whole.

The EIS Report is difficult to read and the six week window to digest it is impractical.

The consultation throughout this process has been scant.

The input from Irish Rail was presented as a fait accompli and did little to add to the

feeling of a consultation process.

There will be a clear danger to the observers’ children in many of the aspects of the

project.

Traffic movement particularly HGV movement to the front, side and rear of their

house will hamper their day to day functionality.

There will be large scale HGV movements on the parade in an area that cannot let two

trucks pass on the same width of road at present.

These traffic movements will be within 3 metres of the observers’ kitchen table.

Traffic movement will be a considerable worry in general.

Parking for working crews during construction will put immediate pressure on car

spaces in the area.

Prevailing winds will see all of the dust blown into the observers’ house during

construction in the 74 acre work site.

Noise and light from the site will be a challenge for the observers to live with.

With excavations as deep as proposed the observers expect to have a serious vermin

problem.

The tunnelling will bring its own set of challenges to live through.

The tunnel is climbing almost at its peak directly beneath the observers’ house, engine

noise will be at its greatest at this point as the Dart makes its way upwards to the

station west of the observer.

The ESB substation is of further concern as the observers are aware of the

electromagnetic consequences that arise.

The substation should be moved further to the west.

Access and egress will be a further challenge for the observers during construction as

Inchicore Parade will be the main conduit for HGV movement to the intervention

shaft construction site.

Cuts in supply of utilities are also a concern.

The observers have concerns relating to noise and light vibration.


During construction at Inchicore all aspects of the project have a detrimental effect on

the observers.

The observers remain unconvinced as to how they can be expected to live so close to

this project as it confronts them on three sides.

Health and safety concerns are linked to the observers’ concerns with environmental

impacts.

Dust is high on the list of the observers’ concerns.

The observers will be unable to make use of the green during construction, this will

have a negative impact on their children.

The length of disruption will add to the stress of living alongside the largest

infrastructure project in the State.

The observers are particularly worried at the ability of their house to keep standing

during the heaviest of the construction.

The foundations of these houses are slight and attendant risks as a consequence are

very high.

In a worst case scenario a domino effect could come into play along the terrace.

The nature of the cap of €30,000 per household should damage occur seems

inappropriate in the context of what these four walls are facing.

The opening of the Dart station will bring a set of circumstances about that will

change forever the dynamic of the area.

The increased footfall will bring security issues to bear on the residents.

The increased footfall will most likely be accompanied by an increase in traffic as

commuters use the parade as a drop of point to enter the station.

The station should in the first instance be located in the village.

Irish Rail has not put forward any policing measures for the station.

In all aspects of the project the observers’ privacy is compromised.

In the absence of provisions being made by Irish Rail to ensure the privacy of the

observer, the observer must object to the order in its current form.

Anti-social behaviour will come as a matter of course.

Litter will become an issue.

Low level crime will become a daily occurrence.

The cul-de-sac nature of this estate will forever be lost.

Parking will become an issue that will have to be battled on a daily basis.

The future of the estate is under threat from the future development of the 74 acre site.

The Railway Order has been rushed through and there are far too many areas that

have not been addressed.

Irish Rail has not entered a process of meaningful consultation.

There is a clear lack of vision as to the future development in the CIE works

compound.

50. Conor Flood and others, 6 Abercorn Terrace, Inchicore, Dublin 8.


The application for a Railway Order by CIE will have a very marked effect on the

character of the Inchicore Railway Estate and the lives of those who enjoy living in it.


Since first notified of the proposal the residents of this vibrant community working

together as “Inchicore on Track” has sought to protect all that is best in this estate

whilst embracing progress and acknowledging that which is best for public transport

in Dublin.

The observers wish to object to a key aspect of CIE’s plan to allow the back lane at

the rear of Abercorn Terrace bordering on Square to be used as the main pedestrian

and cycle access for the proposed Inchicore Dart underground station.

The observers’ objection relates to security, privacy, anti-social behaviour,

environmental impact, health and safety and the availability of an obvious and better

alternative.

The proposal poses a real threat to the security of their houses.

Terrace residents’ back gates would be immediately accessible to the hundreds of

estimated passengers using the lane daily.

Backdoors would, in most cases, be less than 15 metres from pedestrian traffic.

The observers are hugely worried about their own safety and the safety of their

houses.

This lane has always been a meeting point for neighbours. A place of social

interaction and a play area for children.

The plan would result in the lane becoming a haven for anti-social behaviour.

The potential for disruption would be particularly high when the station is serving the

nearby ground of St. Patrick’s Athletic Football Club.

The lane is currently used by residents for wheelie bin storage.

Any additional lighting installed to mitigate security and safety concerns would

destroy the living conditions of residents whose houses back onto the lane.

There would be considerable increase in the level of noise and litter as a result of the

traffic, pedestrian, cycle and vehicular through the lane not to mention its use as an

unofficial toilet for many.

A pedestrian entrance at this point would encourage the use of the immediate area as

an unofficial park and ride facility.

The existing entrance along Inchicore Parade is a better alternative.

The observer submission is accompanied by a petition signed by some 45 persons plus

photographs and a map.

51. Alan Casey, 215 Kilmainham Square, Inchicore Road, Dublin 8.


The plans by Irish Rail to provide a station in the Inchicore Works 1.1 kilometres

from Inchicore Village and another station at Heuston will have a detrimental impact

on the Inchicore/Kilmainham area.

This plan is in conflict with the current Inchicore Urban Framework Plan as published

and adopted by Dublin City Council.

A Framework Area Plan for the railway works site accompanies this railway order

and shows how this project will result in future development being attracted away

from the village core.

The result of this will be to hamper the natural regeneration of the village core and

will also alter the status of the village core.


The Inchicore Framework Plan will as a result become unachievable and will fail.

The extension to Inchicore Works was done after the Stage 1 Alignment Assessment

in the EIS and added 40% more tunnel to the plan.

The best solution west of Heuston would be to have two stations, one at the Inchicore

Works and another midway between Inchicore Works and Heuston in the vicinity of

Inchicore Village or Kilmainham Jail.

This would facilitate the urban regeneration of Inchicore Village and result in an

enhancement of the area.

The name given to the surface station in the Inchicore Works is Inchicore, this is

inappropriate as it is misleading. It is 1.1 kilometres from Inchicore Village.

There is only one entrance/exit to the underground station at Heuston Station and this

is located right in the centre of the station.

Every passenger of every train must pass through this small area.

Inadequate number of bike stands and lack of integration with the Grand Canal way

cycle route.

The Framework Area Plan for the Inchicore Works which accompanies this railway

order is an inappropriate plan for this land.

It is completely dependent on having a LUAS line running through it as there is no

vehicular road access to the site.

This framework plan for the Inchicore Works site fails to integrate with the

surrounding area and is in conflict with the Inchicore Urban Framework Plan.

52. John B. O’Connor and Kay White, 2 St. George’s Villas, Inchicore, Dublin 8


Concern with respect to the construction of the intervention shaft and its future

operation.

The Inchicore intervention shaft appears to be constructed to at least three times what

is normally considered necessary

The intervention shaft cuts off the right-of-way between Inchicore Parade and North

Terrace and access to public transport.

Concern with respect to noise from construction activities.

Concern with respect to dust mitigation measures.

Mitigation measures identified in the EIS are inadequate.

If there is a dust problem work should cease until proper preventative measures

agreed with residents are put in place.

Concern with respect to site lighting and disturbance for residents.

Site construction should be limited to daytime only to negate the need for such

lighting.

Concern that site staff traffic may use Inchicore Terrace South as a shortcut to the site

increasing traffic down this residential road.

Concern with respect to traffic and parking within residential estates in close

proximity to St. Patricks Church.

Concern with respect to traffic hazard to children playing in the area.

Concern with respect to loss of amenity in the area with the on-going operation of the

shaft.


As proposed the intervention shaft compound would permanently reduce the area

within the sports ground currently used for training during winter months.

The oblique orientation of the intervention shaft compound would render the sports

ground unusable.

No. 2 St. George’s Villa residence also have concern with respect to noise, dust,

lighting, traffic and the construction time for portal and cut and cover tunnel to

Inchicore Station similar to the above mentioned noise, dust, lighting and traffic

concerns for the intervention shaft at Inchicore.

Concerns with respect to vermin given the opening up of a construction site within an

industrial area which is going to displace wildlife including a large number of rats.

It is considered that the EIS is inadequate to address the problem of vermin.

Concern with respect to house value and saleability. The owners of no. 2 St. George’s

Villas tried to sell their house already in August 2009 and they were advised not to

put the house on the market as it would be virtually unsellable.

In drawing DU-P-101-C-D several areas are shaded with a green cross hatching and

surrounded by a blue line. This indicates the land in which temporary possession may

be taken. It is considered that the reasons behind this designation are unclear, it is

unclear under what conditions these lands could be temporarily acquired, for what

purpose and for how long

Concern with respect to integrity of and support to property during the construction

phase and on-going running of the trains.

Concern with respect to vibration during construction. The EIS states that there will

be a very high impact to homes in the Inchicore area that will last for eight days for

each tunnel.

The EIS states that there will be a significant effect of noise from tunnels supply

trains for a period of up to 20 months during construction. Potentially making

people’s homes uninhabitable for nearly two years.

Submit that the noise measures for mitigation identified in the EIS are inadequate.

There should be no night time working in the Inchicore area.

Note that there has been no tunnelling works in Ireland let alone Dublin where 24

working has occurred.

Metro North tunnelling through very similar ground conditions does not proposed 24

hour working and the issue of safety has not been raised.

Tunnel supply trains should not be allowed to operate at night time under homes.

If it can be proven that the measures such as using rubber sleepers for the temporary

track will make the resultant noise and vibration imperceptible then no objection.

Concern with respect to electromagnetic impact.

The EIS states that only once the railway is operational will the EMI be measured and

only then will any remedial measures be implemented.

Insist that all available measures are taken prior to trains running to prevent EMI

reaching houses.

Concern with respect to operation of the proposed station. Station noise will be

incessant throughout operating hours which are from early morning to late at night -

putting a cover on the station would resolved this problem.

Residences in Inchicore Parade are concerned with respect to two pedestrian access

ways proposed through their estate. They are concerned that these access routes could

lead to parking, litter and unsociable behavioural problems within the estate.


It is submitted that the EIS does not adequately deal with traffic and transportation

issues.

Concern that there is no provision for people with impaired mobility to easily access

the station.

Concern with respect to parking within Inchicore Parade estate.

Does the railway order proposal include any parking provision in the station area?

There is the best part of half a kilometre walk within the railway works to get to the

station building. There is at least a further half a kilometre walk to get to the works

from Inchicore Village.

Note that the EIS states that parking restrictions will be considered after a period of

monitoring. This is vague and does not say how such restrictions will be regulated.

The report prepared by Murry O’Leary Architects - Inchicore Works Framework Plan

Report - makes scant reference to the Inchicore Railway Estate and the report is

therefore meaningless with such a glaring omission.

Support the proposal that has been submitted by Inchicore on Track, the

subcommittee of the Inchicore Railway Estate Residents Association.

The operation of the proposed electricity sub-station is of great concern given its

proximity to property in particular no. 2 St. George’s Villas.

Concern with respect to danger or fire and explosion from equipment or malfunction

Submit that the risk of permanent noise to all residents from positioning the sub-

station in its current location has not been fully evaluated.

53. David Reynolds, Sky Property Management Limited, 32 Stepaside Park,

Stepaside, Co. Dublin on behalf of the residents of Wheaton Court apartment

complex Inchicore Terrace North, Dublin 8.


Concern regarding the construction and operation of Dart Underground.

Boring works will be for approximately 20 days, under Wheaton Court apartment

complex, and will be carried out over a 24 hour cycle.

Should noise prove intolerable to residents and they have to move to temporary

accommodation that all costs should be borne by CIE.

Submit that there should be no night time working in the Wheaton Court environs in

Inchicore area or generally.

Tunnel supply trains should not be allowed to operate at night time

Should the project proceed request that all apartments including common area

windows are replaced with triple glazing that the roof space and exterior walls

underneath the buildings are all insulated and soundproofed to lessen the impact of

the constant noise during and after the construction phase.

The EIS indicates that the rail service underneath Wheaton Court will have a

continuous dB level of 35 post construction phase with 20 trains per hour i.e. a train

every 3 minutes. This high level of noise is unacceptable

Concern with respect to the strengthening works which are proposed to take place to

the estate wall at Sarsfield Road (bordering Inchicore Terrace North)

Note that Sarsfield Road Railway Bridge is to be dismantled. Concern with respect to

health and safety.


Request that the thinking behind the remedial works to the Sarsfield Road wall be

clarified and strengthened and a strong monitoring plan be put in place.

Concern with respect to temporary possession of Wheaton Court car park and garden.

CIE have indicated that this would be for a matter of weeks. However would be

grateful if the timeframe involved could be clarified or confirmed.

Requests that formal confirmation be given that temporary secure car parking would

be provided close to Wheaton Court apartments for the period involved and that CIE

will make good any damage caused to the car park and garden whether by drilling

vibration or any other works carried out.

Concern with respect to health impact of dust from excavation, vermin, light

pollution, glare and intrusiveness.

All damage caused to the Wheaton Court development as a result of works should be

borne by CIE.

There should be no limit or maximum compensation per resident and there should be

no restriction on a warranty period for a year.

Concern with respect to block policy insurance. Any adverse restrictions should be

borne by the CIE.

Concern with respect to the future value of the Wheaton Court apartments.

Residents should be entitled to seek financial redress from CIE in the event of a fall in

property price as a result of the Dart Underground works.

54. Siobhan Martin, 118 Inchicore Road, Inchicore, Dublin 8.


Concern with respect to possible structural damage to property. Is CIE intending to

offer pre construction condition surveys?

In the event of damage will there be a compensation fund available?

Concern with respect to settlement post tunnelling.

55. David Sherwin, 112 Inchicore Road, Dublin 8 and Cecilia Clifford, 116

Inchicore Road, Dublin 8.


It is important that the project comply with the best principles of good planning and

also that the rights of individual citizens are not trampled in the process.

Inchicore Road comprises a terrace of late Victorian houses that have little or no

foundations therefore concern is expressed that these houses are within the zone of

influence of the tunnel line.

At initial stages of public consultation the residents of Inchicore formed the opinion

that the extension of the line to Inchicore had been rushed, lacked proper planning and

real consultation and give little or no consideration to the effect on the lives of people

along the alignment.

Concern that some homes are to be compulsory purchased and possibly demolished.

Very scant information was available regarding what impact the emergency


intervention shaft would have on the homes nearby either during construction or

during operation.

Concern with respect to effects of combustion gases so close to people’s homes in the

event of a tunnel fire.

Residents in Inchicore believe that they are being misled and deliberately drip fed

information.

It was put to the residents that if the extension to Inchicore did not go ahead that it

would cause more land acquisition to enable the completion of the Kildare four track

project. Residents feel that this was a scare tactic.

Following the initial consultation period the preferred position for the shaft was

moved to Memorial Park and the alignment changed. This was welcomed, however, it

confirmed the belief that the initial alignment was fatally flawed, poorly planned and

that the extension of the line to Inchicore has still not been given due consideration.

Concern that there were alternatives to the proposed alignment.

Request that Irish Rail demonstrate that they have fully investigated the alternatives.

Where possible Dart Underground should be built away from residential properties

and affecting as few people as possible.

While the EIS makes reference to buildings and damaged buildings it makes no

reference to homes.

Concern with respect to noise and vibration. The number of supply train movements.

Concern that the construction activities will have the potential to generate noise

vibration, to affect water quality, cause settlement of structures and have heritage,

visual and traffic impacts.

24 hour, seven day construction working is totally unacceptable.

Special consideration is to be given to the Gaiety Theatre and the Grand Canal

Theatre and to the premises of Today FM. No such consideration is given to houses a

mere 10 metres above the tunnel drives, enclosed cross passages, which may be

blasted.

Submit that the EIS in its current form does not meet the requirements of Section 39

2(b).

A lot is left to the contractor after the railway order is granted and this also puts fear

into residents.

Who will monitor the contractor and who decides what levels of disturbance are

unacceptable.

Urge An Bord Pleanála to set limits for noise and disturbance to residents during

construction and operation of Dart Underground and to put in place realistic regime

for monitoring and timely enforcement with easy access for residents and real

enforcement power.

The residents of Inchicore Road are not opposed to Dart Underground.

Concern that properties will be damaged and devalued and lives blighted with

persistent noise and vibration during construction and operation.

56. Ann O’Gorman, 4 Woodfield Place, Inchicore, Dublin 8.



The initial public consultation with residents was inadequate. Information was scant

and people got different answers to the same questions depending on what Irish Rail

employee the questions were put to.

The lack of consultation in which this extension was planned does not adhere to good

planning practice. The information deficit regarding this project is immense.

The proposed alignment runs directly under many houses in Woodfield. Sufficient

information is not included to the affects of this.

Homes are likely to suffer from settlement, noise, vibration and electromagnetic

interference.

The EIS fails to adequately address the geology under homes in the Inchicore area.

Concern with respect to vibration from tunnelling and ground borne noise.

Concern with respect to 24 hour construction working.

Concern that residents will spend the rest of their lives living in fear of damage to

their homes. This can be avoided by just moving the alignment.

The EIS is grossly inadequate in its assessment of electromagnetic interference.

The EIS fails to address impacts on people’s lives during construction and the

operation of the Dart Underground.

Do not oppose Dart Underground per se but there are alternative alignments.

There is scope to move the alignment north and run it beneath the existing CIE

railway line.

Already suffer from noise and vibration from the southern main line track which runs

by their homes

The mitigation measures proposed in the EIS are very open and leave too much for

the contractor to put in place.

Call on An Bord Pleanála to reject this proposed extension to Dart Underground in its

present alignment in order that CIE get into meaningful dialogue.

57. Edel Quinn and Joe Kerrins, 2 North Terrace, CIE Works, Dublin 8


Concern with respect to noise and vibration

Concern with respect to 24 hour construction working, 7 days a week

Submit that there should be no night time working in the North Terrace environs and

that tunnels that supply trains should not be allowed to operate at night time under

homes.

Submit that due consideration should be given to what constitutes acceptable

thresholds of noise and vibration values from construction activities.

Submit that measures necessary to mitigate noise and vibration values post-

construction are adopted.

No. 2 North Terrace has been identified as being within the zone of influence relating

to ground movement, noise and vibration. This is an area of concern.

Concern with respect to subsidence and settlement directly under the property

Submit that once the railway is operational regular checks and balances should be put

in place to ensure on-going damage to the foundations of the property are assessed.

Concern with respect to health impacts of the project, pollution and vermin


Request that the EIS address in more detail issues of contaminated dust, vermin,

noise, pollution and the general impact of such a large scale development on a small

residential community

Concern with respect to increase in policy insurance.

Fully endorse and support the submission on behalf of the residents association to the

Inchicore on Track (IOT) Committee.

58. Billy McCannon, Resident of St. Patrick’s Terrace, Inchicore, Dublin 8.


The residents of St. Patrick’s Terrace object to the granting of the railway order under

the current plan.

Specific concern with respect to protection of public space specifically the green in

front of the terrace. The proximity of the ESB sub-station and the change of use of

the back lane.

Planning must be sensitive to the social fabric into which it is being installed.

St. Patrick’s Terrace comprise of 14 houses running south from the main works

entrance to the north in Abercorn Terrace.

There will be four separate construction sites within 100 metres radius of St. Patrick’s

Terrace including the intervention shaft, the ESB sub-station, cut and cover TBM

reception chamber

Taken the accumulation of construction sites it is expected that the whole terrace

would be severely impacted during the construction phase.

There is inadequate information as to the true impact of the operational phase.

It is considered that the application for the Railway Order is rushed and ill-considered.

Consultation between Irish Rail and St. Patrick’s Terrace has been devoid of

productive consultation where it needed to be informative.

Poor planning will invite a raft of litigation with attendant delays and cost overruns all

of which will leave the community in a state of protracted suspension.

CIE does not seem to understand that the whole area of pedestrian access is more than

a casual concern.

Impact of the project on St. Patrick’s Terrace and on Abercorn Terrace does not seem

to have been given due consideration.

Express concern with regard to traffic from the proposed station. The proximity of

the ESB sub-station, privacy and the safety of their children at play, and the welfare

of their elderly neighbours is of concern.

The greatest concern expressed is for the maintenance of the green in front of St.

Patrick’s and Abercorn Terraces.

The character of this area is a function of its design and vital to the health of the

community.

Concern for the green and all of the public spaces is immense. Regret to say that 18

months later countless meetings and in-estimateable number of e-mails CIE have not

managed to factor this into their plans.

Concern with respect to the level of construction traffic envisaged.

There has been no indication of the actual traffic levels during the operational stage.


There is a need for a meaningful study of how this will affect the social character of

the green. With a constant stream of pedestrians the green may serve new social

functions which will negatively impact on the privacy of the residents.

Concern with respect to noise, dust, exhaust fumes increase in levels of night lighting,

construction traffic, noise at night, necessity of intrusive undesirable security

measures, disruption of wildlife and vermin.

Concern with respect to anti-social behaviour for those living in close proximity to the

Dart Station.

The green will become part of the pedestrian thoroughfare. It will be a magnet for

late night drinkers with all the attendant anti-social behaviour. The EIS does not

properly address this matter.

In the absence of a policing strategy drawn up by CIE in conjunction with An Garda

Siochana and Dublin City Council the observer strongly objects to the granting of a

railway order.

CIE had made no proposals for mitigation of long term negative impacts.

The back lane is currently the property of CIE but maintained by Dublin City Council.

Object to the back lane becoming a public thoroughfare. No adequate provision has

been made for the change and no proper planning has been put in place.

The change of use of the back lane is a threat to welfare security and privacy.

Is pedestrian and vehicular traffic to be permitted along the back lane.

If so does it mean a redesign of the laneway, what is the nature of the redesign, where

will public lighting be installed, will CCTV cameras be installed. Do CIE intend to

restrict public access, who will be consulted?

Without complete redesign the back lane could become a haven for all kinds of anti-

social behaviour.

There is a need for higher security in the area.

The need for heightened security awareness will reduce opportunity for social

interaction between children and the elderly. The EIS has made no proposals

whatsoever for mitigation.

Possible alleviation measures must be explored during construction phase and

operational phase:

No construction traffic on the back lane.

Back lane is temporarily modified to provide a recreation area for the residents

and a playing area for children.

Residents must be resourced to sound and dustproof their homes.

Possible alleviation during operational phase.

Close the works entrance at night.

Redesign the back lane to discourage loitering.

Redesign the back lane to preserve current use.

Redesign access to channel passengers away from residential houses.

Abandon entrance at the back of Abercorn Terrace.

Close the lane to passenger traffic.

Residents must be resourced to upgrade security of their homes.

Meaningful consultation with residents, experts and An Garda Siochana and

Dublin City Council.

Concern with respect to the ESB sub-station:


It should be possible to move the ESB sub-station away from residents and

further into the works.

This would go some way towards ameliorating the extreme impacts of the full

project.

Strongly object to the location of the ESB sub-station in close proximity to St.

Patrick’s Terrace.

There is an alternative location for the ESB sub-station in the EIS, ask that the

ESB sub-station be moved there or somewhere else that is away from

residences. Health and safety concerns:

Health and safety are linked to other concerns with environmental impacts.

Airborne dust, dirt and toxins. Aggravation of respiratory ailments, stress,

sleep disturbance, increased traffic posed to children at play.

Living conditions will be impacted upon during construction such as drying

and airing of clothes, produce from herb gardens and vegetable patches will be

unfit for consumption, traffic movements are a real threat to the green

currently a haven for children.

Submission attached by signatures from residents of the terrace.

Submission attached by minutes of meetings between Irish Rail and residents of St.

Patrick’s Terrace dated September 22nd

9.30a.m.

Submission accompanied with questions for Dart Underground team from St.

Patrick’s Terrace owners/residents.

Submission accompanied with copy of minutes of the meeting dated Tuesday 22nd

September 9.30 a.m. to 12.00 p.m. between Iarnrod Eireann and St. Patrick’s Terrace

residents as minuted by Iarnrod Eireann.

Submission accompanied with answers to the resident’s questions from St. Patrick’s

Terrace owners/residents, dated 30th

October 2009, by Dart Underground Team.

59. Daniel Keleher, 16 Abercorn Square, CIE Estate, Inchicore, Dublin 8.


Strong support for the Dart Underground railway order application and in particular

for the Inchicore route and the promised Inchicore Dart Station.

Inclusion of the Dart Station at Inchicore is widely welcomed by local residents.

There are currently several thousand residents in Inchicore and lower Ballyfermot

who reside within a 15 minute walk of the proposed Inchicore Dart Station.

It would be a major advantage to have access to a rapid and frequent electrified rail

service.

There are numerous advantages for the Inchicore area of the Inchicore Dart Station.

The Inchicore Dart Station will facilitate regeneration of the CIE works which is a

disused and underutilised site.

There is strong on-going support from residents of the Inchicore Railway Estate for

the Inchicore Dart Station.

A flaw in the submission of the Inchicore Railway Estate Residents Association

Limited submission is that it fails to sufficiently express the support of residents of the

Inchicore Railway Estate for the planned Inchicore Dart Station in the CIE Works.


Inchicore on Track have achieved two major concessions by Irish Rail. It is submitted

that Irish Rail should be looked upon favourably by An Bord Pleanála in relation to

these compromises:

(a) Removal of the cut and cover construction plans from the Railway Estate and

removal of the TBM launch pit plans from the sports field.

(b) Inchicore on Track actively campaigned for the removal of the intervention shaft

from Inchicore Road when the relocation to the Inchicore Railway Estate was

announced it was enthusiastically welcomed.

Rather than being allowed to gain dereliction there had been numerous new building

developments in the Inchicore Railway Estate that have added vibrancy and new life

and have complimented the older houses.

It is submitted that the Irish Rail’s proposed Dart Station in the Inchicore Works is in

a more favourable location than the DTO plan as it is more readily accessible to

south-western Inchicore and it better facilitates regeneration of the CIE Works.

There are numerous examples which set a strong precedent in the Inchicore Railway

estate for new development and regeneration in the area. Examples include Flora

Villa apartments, Abercorn Square, Beech and Court, Gratton Court, the Works

townhouse, the apartments at the eastern end of Inchicore Terrace South, Inchicore

Terrace South, Inchicore Terrace, Abercorn Terrace, St. Patrick’s Terrace, Inchicore

Terrace North and numerous ad hoc developments in the estate.

Developments in the estate provide a compelling precedent for further future

development of lands in the Inchicore Railway Estate and the CIE Works.

The Inchicore Railway Estate in the Inchicore Works was originally designed to be

accessible and permeable.

The historical maps appended to the railway order application show that Inchicore

Railway Estate was originally designed with numerous access routes. Over the years

new access routes were opened up as needed.

It appears from the historical maps and photographs appended to the railway order

application that the old right of way through the laneway to the rear of Abercorn

Terrace (proposed access route) has been abandoned for many years and perhaps as

far back as the late 19th

century.

A station access route through the Inchicore Parade might be more appropriate.

The ranch and Sarsfield Road together with much of the surrounding area are

traditionally and culturally part of Inchicore. The proposed public access route over

the existing footbridge at Sarsfield Road will further reconnect these areas with

Inchicore.

There are many advantages of the tunnel extension to Inchicore.

A Dart station can be provided in its central location in the CIE Works which readily

facilitates the regeneration of the CIE Works.

It is no longer necessary to excavate the railway embankment between Heuston and

Inchicore or to reconfigure the SCR bridge so as to lay the two additional rail tracks.

It is no longer necessary to carry out major works at Heuston Station. Putting the

tracks underground in the Inchicore Railway Estate eliminates problems of noise.

There is a significant community gain as part of and resulting from the Dart

Underground project in Inchicore and Lower Ballyfermot.

In conjunction with connectivity and regeneration of disused areas the replacement of

the ugly wall around the railway estates sports field plus the replacement of the inner


track to an even gravelled surface of the staff car park beside St. Georges Villas and

the demolition of ugly central stores building which is visible from the railway estate.

An Bord Pleanála is urged to grant the railway order.

Submission is accompanied with a petition for the Inchicore Dart Station.

Submission accompanied with photographs taken in the general area of Inchicore.

60. Aifric Ni Chianáin, 12 Ontario Terrace, Rathmines, Dublin 6.


Owner of the property at 12 Woodfield Place, Inchicore.

Object to the tunnelling under Woodfield Place due to anticipated negative impact, 12

Woodfield Place.

Concern with respect to structural damage to property from construction and

operation of the Dart Underground.

Concern with respect to significant impact of ground borne noise from tunnelling

supply trains for a period of up to 20 months during construction.

Tunnelling impact such as noise, vibrations, pollutions, flow of construction traffic

could render property uninhabitable and unrentable resulting in a loss of income.

Impacts from the development could render the property potentially unsellable and/or

inhabitable.

Concern with respect to health impacts of dust generation from excavation of vermin,

light pollution, glare and intrusiveness.

Concern with respect to high current voltage.

Concern with respect to acquisition of sub stratum land and impacts upon desired

renovations such as lowering of ground level.

Concern that increases to policy insurance may occur.

Support for the submission made by Inchicore on Track and request that tunnel

construction be moved north towards Con Colbert Road where there is no housing.

61. Tessa Robinson and Robert Purcell, 8 St. Patrick’s Terrace, Inchicore,

Dublin 8.

The contents of this submission from the above are summarised as follows:

Concern with respect to the estimated time line of the project with consequent impact

in terms of noise, dust, vibration and other inevitable consequences of a major

construction project.

Request that conditions be attached to the order to ensure the project is completed

within the minimum time necessary.

Observers live within a matter of metres from the western portal and intervention

shaft sites.

Concern with respect to the 24 hour continuous nature of the construction proposed.

Request that the conditions be imposed in any order granted to limit working hours on

the project so that there will be no significant noise or vibration outside normal

working hours.


Concern with respect to mitigation from noise, tunnel boring will involve rock

breaking.

As with traffic management mitigation it would appear that it is left to the contractor

to decide on mitigation measures. This is unacceptable.

Concern that there is no provision for park and ride facilities.

Removal of spoil by rail in Inchicore will result in noise pollution for which there is

no specific noise reduction measures envisaged in the EIS. Concern with respect to

dust as a result of the construction work.

Concern with respect to road possession and closure of lanes.

There appears to be no provision for emergency vehicles to gain access to the

properties at St. Patrick’s Terrace in the event of a part of the laneway being closed

off.

Provision must be made for the laneway to be fully open for a number of hours each

day.

Request that the order if granted shall be conditional upon the ESB sub-station being

constructed in a location which is not a residential area.

A new road is to be opened up at the rear of property at St. Patrick’s Terrace. This

road will be less than 10 metres from the rear of dwelling houses. Propose that heavy

traffic movement can only take place during business hours.

There is a need to carry out at risk surveys to identify the potential impact of the

projected ground movements on various properties.

Concern with respect to green area immediately in front of house. Dust monitoring on

a monthly basis is inadequate.

Appropriate conditions need to be imposed on any order granted to provide for

adequate mitigation measures to deal with negative impacts.

Provision should be made for setting up of a dedicated phone line to receive alerts

from residents when dust levels become intolerable and provision of window cleaning

and other cleaning services.

Request that conditions be imposed that testing of buildings to be demolished be

carried out in accordance with best international practice prior to any demolition taken

place.

Request that a condition be imposed in any order granted to provide for litter

measures to be put in place.

Request that an oral hearing be held in relation to the application.

62. Louise Carroll, 412 Le Fanu Road, Ballyfermot, Dublin 10


Concern with respect to where the line is intended to connect up with over-ground

between the Inchicore Works station and Kylemore Road.

Concern that a further station would be put in at Kylemore further along the existing

line and the impact that this would have on traffic flows and parking.

Concern that extra pylons and sub-stations would be required for electrification of

additional tracks and the impact this will have on residential estates to subsequent

health and safety of the area.


Increase in frequency of trains would result in a deterioration of quiet and peaceful

enjoyment of property.

Concern that there would be no provisions or measures to minimise the disruption for

the local residents.

Concern with respect to parking and proposals for increased demand has not been

considered.

Upgrades of the bridges over the existing lines will be necessary and concern about

how this will impact on local residents and traffic flows within the area.

Concern with respect to 24 hour construction work proposals.

63. Gerard Green, Aoife Lawlor and others, 12 Woodfield Avenue, Inchicore,

Dublin 8.


Submission made on behalf of a number of residents of the Woodfield area Inchicore.

Woodfield Residents are concerned with respect to the impact of the project on their

homes. There has been a lack of consultation with CIE.

Acknowledge the benefits that the Dart Underground will bring to the Greater Dublin

Area however they simply want to be consulted and provided with evidence that

should the project go ahead their homes will not be impacted in a negative way.

Concern with respect to the depth of the tunnel below houses, approximate depth of

19 metres is considered unacceptable and dangerously close to homes.

Woodfield houses are older dwellings. These houses were built on reclaimed land

using rubble concrete and were not reinforced. These houses do not have

foundations.

Concern with respect to the impact of the vibrations once the underground is up and

running. Disagree that a full assessment has taken place.

Many properties in Woodfield already have an existing rail line located at the rear of

their gardens, the main Dublin, Cork, Galway, Limerick line. Currently vibrations are

felt from the main above ground line.

Major concern over the stability of houses as a result of tunnelling and on-going

vibrations from underground Dart.

Mirror the concern that Marino residents experienced following the construction of

Dublin Port tunnel whereby residents experienced cracks in the structures of their

homes.

Impact on the resale value of houses.

Ability to obtain insurance.

Woodfield Residents are frustrated at the lack of consultation from CIE.

There was no opportunity as a community to be involved in the designing of the plan

or to influence it in any way.

The lack of knowledge regarding Inchicore from the experts representing CIE was a

cause for concern.

The EIS is lacking in terms of minimisation and remedial measures for disruption to

residents.


The proposal to construct a Dart Station within the grounds of the CIE works is weak

in that most Inchicore residents live substantially closer to a bus stop or a Luas line

than they will to the proposed Dart Station.

Residents will be reluctant to use the proposed station at night due to the isolated

location of the proposed station.

The tunnel boring works are substantially closer to the ground level of properties in

Inchicore than is the case in any other part of the city.

Reference made to other European cities is not relevant as each case is unique.

Ground condition, age of buildings and foundation types differ depending on location.

It has not been evidenced that CIE have considered any alternative routes through

Inchicore to avoid potential risks.

Concerns with respect to working hours spanning seven days per week, 24 hours per

day, noise and dust pollution experiencing vibrations possibility of deteriorating water

quality, possibility of settlement of structures, heritage, visual and traffic impacts.

Possibility of negative impact on air quality.

Note the location of the model school (primary school) on Sarsfield Road and the

potential impact of traffic congestion on this road as a result of road closures and

construction traffic.

Safety implications for children in school.

Traffic congestion by means of the quantity of traffic which currently passes through

Inchicore village and the potential impact of further traffic congestion as a result of

full closures and construction traffic.

Woodfield Residents do not object to the introduction of a Dart Underground system.

Recognise the importance and value that a fully integrated rail network will bring to

the Greater Dublin Area.

Object to the current format on the following grounds.

No assessment has taken place to ascertain what the outcome would be of

running two tunnels 19 metres under houses that are nearly 130 years old in

the Woodfield area.

Level of consultation with the Inchicore community.

The location of the proposed Dart Station will not service the needs of the

community.

CIE have not provided the residents of Inchicore with any details of how they

will minimise the impact that this project will have on their community

environment and heritage.

Request An Bord Pleanála to refuse this rail order in its current format, encourage CIE

to resubmit a railway order which takes into consideration an alternative route that

will not pass beneath the residential properties in the Inchicore area, prior to the

railway order approval.

64. Jonathon Archer, OZO 24-7 Collect and Rescue, Kylemore Business Park,

Kylemore Way, Dublin 10.

(Jason Tyler, Agent Laughton Tyler Owens Architects, The Mash House, Off Distillery

Road, Dublin 3)

The content of the submission from the above can be summarised as follows:


The observer currently operates a waste management company on grounds affected by

the proposed works.

Requests that access to the site on a daily basis for numerous waste disposal vehicles

some of which are quite large, is not restricted.

Loading and unloading to the observer’s business necessitates articulated trucks pull

into the access road facing the steel works and make a right hand turn. This facilitates

the trucks to reverse the entire length of the industrial road down to his site which is at

the far end of the industrial road. This is the only way the client can load and unload

deliveries.

The business has been operating this way for the last eight years and has had no

difficulties to date.

From the documents attached to the railway order it is understood that the access road

will now become part of CIE access to the new railway station and that a new

proposed access road will be provided to the existing industrial units.

It is imperative that in providing this new access road the turning circle and the radius

of the bend in the inner most right hand side is wide enough to facilitate the observer

being able to make a right hand turn once they access this road to allow the truck to

reverse down the back of the road back to their premises.

Failure to provide this would be detrimental to the business.

Request that a condition is included in resolution to this concern.

It is proposed that the area between the new proposed access to the industrial units

and the new proposed access road to serve the station will be out of bounds from

general use.

The observer’s employees use this space every day to park.

Confirmation is required that alternative parking arrangements for staff will be put in

place.

Query whether it is possible for CIE to provide a car park adjoining the proposed

access road to facilitate users of the industrial park long term.

Not opposed to the works in general being carried out, merely wish to protect business

interests at this point.

65. Niamh Flood, David Lawless and May Flood Lawless, 3 St. George’s Villas,

Inchicore Parade, Dublin 8.

The contents of the submission on the above can be summarised as follows:

Impact on property, residential amenity and community.

Concern with respect to structural damage to property.

Lack of consultation with CIE, Iarnrod Eireann.

Request that An Bord Pleanála ensure that property is properly assessed for all

potential risks.

Conclude that the EIS contents are vague and ambiguous with no real assessment of

consideration of the problems that can and will inevitably arise and impact upon

residents.

Nowhere in the EIS documentation is the Inchicore Railway Estate mentioned as a

residential neighbourhood of significant historical importance.


Fully support the work of Inchicore on Track and endorse their submission to An

Bord Pleanála.

Main concerns in relation to the proposed works include:

o Location of the four homes in St. George’s Villas, a lane measuring only 45

metres which will be surrounded by a tunnel on one side, the TBM portal and

station construction site directly behind. The exiting railway track on the

other side and the construction of an intervention shaft in front.

Somehow according to CIE – Iarnrod Eireann only two of these four homes will have

direct effects from the construction process. It seems unbelievable.

Insist that An Bord Pleanála investigate how very near neighbours will have

significant impacts on their homes whereas the observers will have none.

CIE – Iarnrod Eireann is playing a political game by trying to minimise the perceived

number of people and properties impacted during this process.

Request that CIE – Iarnrod Eireann change the terms of reference to include the

observer’s home in the property protection scheme and assess the home prior to any

work being carried out.

Concern with respect to proposed working hours.

Concern with respect to light pollution and impact of light pollution. How many

lights will be used and what will be the light output, what will be the location of light

stands and what are the noise level numbers and location of generators, how has this

been factored into the existing EIS?

Concern with respect to dust and air borne pollution.

Concern with respect to mitigation measures of dust.

Concern with respect to noise pollution.

The noise levels expressed in the EIS are in average terms and is not clear if there are

limits.

Concern with respect to demolition of buildings to the rear of their property and

associated noise.

What kind of blasting will occur, will we be given prior notice of such blasts.

A defined car parking area within the railway works should be put forward for

agreement with the residents and An Bord Pleanála so as to

1. Minimise risk to safety for residents within the estate.

2. Allow residents, visitors to enjoy existing parking areas and

3. Minimise noise and litter associated for construction traffic.

Demand that An Bord Pleanála investigate the many issues with regard to noise.

The four homes that comprise St. George’s Villas will be on the wrong side of all the

tunnelling in construction traffic and will be isolated from the rest of the community.

Demand An Bord Pleanála require CIE – Iarnrod Eireann to fully protect homes and

adopt real and meaningful measures to alleviate the impact of this poor planning.

Concern with respect to traffic.

Sociological implications being isolated from the rest of the community in particular

for children – the residents of No. 3 St. George’s Villas have a small child.

Employed the services of a child psychologist to visit their home to better understand

their daughter’s unique situation. Attached report by Dr. Kelly clinical psychologist.

Fully supports the request to investigate and plan for alternative arrangements

to the proposed route of the construction of the railway works in Inchicore

Parade.


It is the professional opinion of the clinical psychologist that the impact of a

lengthy construction project will have an extremely negative impact on the

young child of no. 3 St. George’s Villas

Request An Bord Pleanála to put in place stringent procedures to enable all residents

of the Inchicore Railway Estate to promptly complain and expect a quick resolution

when things go wrong.

What recourse do they have when things go wrong?

Who will be on their side to help get things rectified quickly?

If they are forced to take legal action who would cover the costs?

Request that CIE clearly set out how they propose to deal with the various issues and

the reasoning behind the decision to locate an above ground station in such an

inaccessible area.

Request that An Bord Pleanála help to protect basic human rights to homes.

Request a more detailed clear description of the impacts on their home.

Urge An Bord Pleanála to come and visit their home and Inchicore Railway Estate as

they feel this would be the only real way to get a sense of how badly their lives would

be affected by this proposed plan. Reserve the right to further submissions in light of

any revised EIS.

Request the right to present at an oral hearing.

66. Niamh Flood, Secretary, The Inchicore Sports and Social Club, Library Square,

Inchicore, Dublin 8.


The premises are currently leased from CIE by the Inchicore Sports and Social Club.

It is proposed that Dart Underground construct a tunnel from Heuston Station to

Inchicore works passing under the works estate including part of the club at a depth of

approximately 12.5 metres.

Concern with respect to noise and vibration levels in respect of tunnelling in deep

excavation and construction of the intervention shaft and its associated compound.

Concern with respect to hours of construction work.

Concern with respect to ground borne noise and vibration.

Concern with respect to impact on air quality dust, dirt and soiling of environs.

Concern with respect to impediment of emergency exits.

Concern that natural light is not blocked off from the club by construction site

hoarding especially into the main hall of the club.

Concern that access be maintained to the club at all times at the front, side and rear.

Concern how emergency incidents and procedures might affect Inchicore Sports and

Social Club in view of the proposed location of the emergency intervention shaft.

Concern that members are exposed to risk of accident and injury should an incident

occur in the tunnel which might lead to the escape of noxious fumes.

Concern that the emergency intervention shaft will be converted into a ventilation

shaft after the works are completed.

Concern with respect to construction activity and structural damage to the Inchicore

Sports and Social Club and the buildings of which it is a part.


Concern with respect to loss of enjoyment and benefit of the property which is held

under lease from CIE.

Reserve the right to make further submissions in light of any revised EIS being

published.

Reserve the right to present oral hearing submissions at any oral hearing.

67. Sherling Group, Jamestown Road, Inchicore Dublin 8


The minimum 6 week period for consultation is insufficient

Request that an Oral Hearing be held

Sherling Group (Steel stock holding Co.) have an interest in the following properties:

D1A A02, D1AA03(1) & D1AA03(2), D1AA06(1) & D1AA06(2) – maps attached

Refers to lands from Kylemore Way to the proposed DART underground station

within the CIE works at Inchicore

Also concern with respect to lands, which Sherling have an interest in, of which

temporary possession may be taken

Concern that private rights may be extinguished

Interruption to business

The type of premises required by Sherling Group are difficult to come by.

The Sherling Group have two IPC licences for activities : shotblasting and priming

process and a lead mill and distribution business

The temporary and/or permanent acquisition by CIE of the lands referred to above (at

Kylemore Way) will destroy Sherling’s business.

The access to the train route alignment is through Sherling’s premises

Acquisition of the Sherling car park is of concern – impact on employee car parking.

Restriction of movement will result in closure of the business

Reserve the right to make further submissions / observations to the Board with respect

to construction traffic mitigation and proposed traffic management plan.

Pedestrian traffic is not compatible with the continued operation of the Sherling

facility site.

Health and safety concerns if Sherling Group facility continue to operate during

construction works.

Concern with respect to the length of the construction period – blighting of the site for

up to 10 years.

Concern with respect to noise, vibration, blasting, dust, fumes, damage to surrounding

roads

Concern with respect to structural damage to the Sherling site.

If CIE acquires the lands / rights, it will become impossible to operate the Sherling

business.

Attached with copy of letter from CIE to Sherling & Sons Ltd and a map indicating

affected lands.

68. Inchicore On Track, c/o John Beck, Chairperson, 5 North Terrace, Inchicore,

Dublin 8.



Inchicore Railway Estate Residents Association applauds and supports the delivery of

new public transport infrastructure

It would be a shame if public interests were to be destroyed by failing to address and

find solutions for the well-considered, measured but absolutely key issues set out in

the submission.

Concern with respect to impact of the project on the Inchicore Railway Estate and

environs

The Inchicore Railway Estate and Inchicore Railway Works (approx. 70 acres) both

1846, form a remarkable set piece of C19th urban socio industrial planning and

architecture.

The estate has survived largely intact – there is a strong sense of community and

identification within the residents of the area.

Community participation in the project is fundamental for IOT

Ask that a high level of scrutiny be applied to the implications of any possible

material contravention of the Development Plan. Since the process of the Railway

Order permits bypass of the democratic process involved in the drafting and

approving of the Development Plan (DP).

Have regard to the Dublin City DP 2011 – 2017. The IOT residents request that ACA

status be given to the Railway Estate

In favour of a properly planned and integrated transportation system

Tangible concrete, implementable conditions should be set to ensure that the project is

designed to protect communities

The EIS fails to refer to the Estate and Works – this is a major flaw in the railway

order application.

Within the estate the construction site would occupy the green field football pitch, a

surface car park, a historic field (formerly GS&WR allotments) and an open space

with a ROW. The proposed construction site is bounded on the east side by important

historic building stock, the former great Southern and Western Railway Reading

Rooms and Dispensary (1889), now the Inchicore Sports and Social Club

The proposed site is overlooked by original terraces of Estate houses and the newer

apartments of Wheaton Court, to the south, west and east. The proposed site is

bounded on its northern side by the main southbound railway line.

Construction activity in this area is proposed to consist of (a) below ground bored

twin tunnels (b) the construction of a combined intervention and ventilation shaft at

the northern end of the football pitch and (c) above ground site compounds, traffic,

stockpiling and associated activities.

The residents of St. Patricks Terrace and St. George’s Villas would be doubly affected

by the project – operating to the front and rear of their houses – effectively isolating

these homes

Concern with respect to loss of green space for 5 years

Concern with respect to the proposal to locate an emergency intervention shaft on the

green amenity space

It is unclear what reinstatement of the green area is proposed


Significant negative construction impacts – noise and vibration, light, dust, dirt, threat

of loss to historic built fabric, impacts on human health, loss of amenity space, visual

impacts, settlement and damage to buildings, traffic, nuisance and safety.

Potential negative impacts from operation of the Dart Underground under the estate

Noise and vibration during operation

Concern with respect to the proposed railway station – safety for users through the

large and under-occupied Works site.

Guarantees given by CIE to ensure standards both during and after construction are

unsatisfactory

Mitigation has not been adequately addressed in many cases the detail is left to a sub-

contractor after the railway order is granted

The development potential for the Works site is inadequately dealt with by an

appended master plan to the EIS.

Two key facts, namely, that the proposed Dart Underground relies on the

redevelopment of the Works site and that its possible development according to the

master plan has neither firm basis nor certainty are at odds with each other. This is a

major issue which goes to the root of the proposal to locate a station at Inchicore

Works.

The scale of the site proposed for development is immense – some 74 acres

The extent of the immediate and cumulative impacts on the area aligned to the long

term implications of a new railway station and related developments requires that

there be a strategy to include the concept of community gain.

Ask ABP to refuse to grant a Railway Order in the terms as currently proposed by

CIE

Formally request that an Oral Hearing be held.

Request that IOT representatives meet with ABP prior to the hearing being held.

The submission details the Dart Underground scheme and how it has changed since

2001

Stress felt by residents was exacerbated by the lack of recognition and consultation,

the EIS assessment and its recommendations are flawed with respect to architectural

heritage along the whole proposed Dart Line

Failure of the EIS to recognise Inchicore Railway Estate and Inchicore Works –

request that ABP request / direct CIE to amend their scheme

Concern with respect to length of construction phase

The EIS acknowledges that there will be a significant effect of ground borne noise

from tunnel supply trains for a period of up to 20 months during construction – 24/7

construction hour working is unacceptable. Such working would make homes

uninhabitable for almost 2 years. Mitigation measures to counteract this, as per the

EIS, are unsatisfactory.

There should be no night time working –

Ground borne noise and vibration should have a maximum of 35db and 0.1 m/s-1.76

VDV

Request that floating track slab be used throughout the Inchicore area

Health and safety concern with respect to Sarsfield Road retaining walls

EMI concern,

Major concern regarding noise and ground borne vibrations from the piling, crane and

plant movements, dust generation from excavation, plant and traffic movements, with

effect on health particularly children,


Excessive light pollution, glare and intrusiveness

The EIS does not state what the noise thresholds are for homes in the Railway Estate.

Insist that following should be adhered to: Night time 45 db, evening 55 db, day time

65 db

The intervention shaft compound would permanently reduce the area within the sports

ground currently used for training during winter months, rendering it unusable.

Insist on guarantees that the haul route for construction traffic to the rear of St.

Patricks Terrace will not be used in the construction of the portal or cut and cover

works.

The EIS should address the concern of vermin more fully

Concern with respect to proposal for emergency access through the Estate and the

existing Works entrance at Inchicore Parade, concern that in time this may become a

general access thereby increasing traffic through the estate.

Parking restrictions and regulation needs to be taken account of

Concern with respect to litter and anti-social behaviour

If the tunnel alignment were moved then so would the position of the intervention

shaft, thus negating the long list of mitigations

The little used ‘Horse Field’ off Sarsfield Road could be a suitable location for a

ventilation shaft

Question the purpose the station serves in its current / present proposed location

The name of the station should be Inchicore Works Dart Station

Urge ABP to consider any future development at Inchicore during the railway order

Grave concern with respect to the Master Plan – the document has no statutory basis,

contains no proposals for control of development on the site, concern with respect to

future CIE development proposals for the site`

The master plan is sparsely researched. It contains no proposal as to how its

implementation might be controlled, governed or procured in detail, in social,

economic, planning or architectural terms

The proposed Dart Underground relies on the re-development of the Railway Works

site and that its possible redevelopment has neither firm basis nor certainty are at odds

with each other.

Request that a feasibility study be commissioned under agreed terms with CIE,

Dublin City Council and the Inchicore Railway Estate Residents Association – to

scope out the idea of a sensitively developed Railway Heritage Site for the Estate and

the Works

Request that ABP request other transportation initiatives intended for the site such as

proposed Luas Stop, a transport hub and the status of Kildare route tie in

During construction phase and operation: Independent monitoring (on a daily / as

requires / live basis) should be carried out with respect to noise, vibration, dust, light,

ground movements, building movements, tunnelling parameters, traffic parameters

and parking.

There should be a forum through which people could easily make a complaint

More detail is required on how the property protection scheme will work.

There should be a shared and coherent concept of community gain

ABP has the power in respect of protection of local communities and persons affected

by the order

Make a clear requirement that the amenity development proposals such as: physical

renewal of Club buildings, renovate / rejuvenate playing fields / tennis courts


adjoining the social club, secure a playing field, maintain poorly kept public open

spaces be made a condition of the Railway Order.

ABP needs to be particularly sensitive to likely loss of amenity and damage to

community infrastructure

There is necessity for an area master plan and effective monitoring

CIE / IE should be required to fund a feasibility study to sensitively develop the area

as a Railway Heritage Museum Site

The EIS is deficient with respect to mitigation measures – no proposals are put

forward to address the protection of architectural and industrial heritage of the

Inchicore Works Site. Mitigation left up to the contractor is unacceptable.

Further information is required with respect to:

o an accurate description of Inchicore Railway Estate,

o a holistic assessment of affected architectural heritage, likely significant effects,

o a set of standards and technical specification should be prepared,

o a detailed examination of options of substantial reinstatement and of positioning and

of running the proposed Dart Underground.

o Clarification of the PPP process

o Details of tunnelling and demolition intended for Sarsfield Road and impact upon

curtilage wall

o Comprehensive booklet of drawings

o Details of resettlement – settlement calculations in EIS inadequate

o EMI must be adequately assessed

o A full assessment of the potential for contaminated dust

o Mitigation measures proposed for the Estate

o Examination of less intrusive alignment

o Assessment of the likely impacts on the Kildare route tie in / Luas Stop

o Re- examination of the master plan

o Proposals for monitoring – incl. independent monitoring

The size of the proposed construction site for the intervention shaft should be reduced

to the minimum required

Interference to ROW between North Terrace and Inchicore Parade should be

restricted to the minimum required

A cover should be put on the proposed station

The submission is accompanied with:

o Inchicore Railway Estate Residents Association Ltd. (formerly CIE Residents

Association) – Memorandum and Articles of Interest

o Inchicore Works Submission on the Dublin Development Plan 2005 – 2011 from CIE

residents Committee, Inchicore Dublin 8 regarding proposed rezoning of land at the

CIE Works, Inchicore Dublin 8

o Submissions to the Draft Dublin City Development plan 2011 – 2017

o IOT Materials

o Table of Key Events

o Correspondence (IOT and CIE/IE/Dart Underground)

o Record of facilitated process (Cormac Russell, Independent Facilitator)

o Swindon Conservation Area (Swindon Railway Village: Conservation Area Appraisal

May 2006 & Swindon Railway Works Conservation Area Appraisal May 2006)

o OTB Engineering Reports.


AREA 102 - Memorial Park to Heuston

69. Susan Byrne, Parkgate Place Management Company Limited for Parkgate

Place Apartment Complex, Parkgate Street, Dublin 8.


No objection in principle to the completed scheme and recognises its benefits to the

local area as well as the Dublin travelling public.

Concern with respect to residential amenity seek clarity that 24 hour amenity will not

be inhibited.

Seek clarity on the fact that it was considered necessary for noise air monitoring to be

carried out at Parkgate Place Apartment Complex when the property is apparently

outside the predicted noise/air impact zone and to consider noise/air impacts from

construction impacts other than tunnelling.

The EIS concentrates on the impact of the tunnelling phase but it is unclear as to the

timing and impact of other construction phases.

Concern with respect to movement of materials and construction site noise pollution.

Request clarity of the extent of each of these phases and its impact on the amenity of

Parkgate Place and other residential neighbourhoods in the vicinity of Heuston

Station.

Request that the Board restricts construction hours to Dublin City Council’s standards

at maximum.

What requirements will be placed on the contractor as part of the PPP with regard to

maintaining healthy community relations?

70. Mr Pat McDonagh, Managing Director, Supermac Limited, Supermac Head

Office, Ballybrit Business Park, Ballybrit, Galway.


Supermac operates from Heuston Station.

The proposed development will involve major development works to a protected

structure, Heuston Station.

Impact on Heuston Station ACA. Access/ventilation points are prime concerns. It

would appear that the final preferred proposed option for the Heuston Dart

Underground Station was chosen mainly on the basis that it is located entirely within

lands owned by Iarnrod Road Eireann.

It is accepted that this would appear to represent the most cost effective option.

However alternative options or locations within the station itself have not been

adequately assessed.

The destruction of the original elements of parts of the built fabric of Heuston Station

and the replacement with facsimiles is contrary to the proper planning and

development of the area.

It is submitted that the building is of national importance being of architectural,

social, historical and scientific interest.

The protection of the original protected structure and the Heuston Station ACA must

be properly assessed alongside the need to reduce passenger disruption.


It is considered that the chosen location within Heuston Station has not been

adequately justified.

The current proposal intends to locate the access to the dart contrary to the pedestrian

desirability line introducing pedestrian conflict.

It is submitted that any logical location for an underground station within the existing

concourse of Heuston Station should maintain and compliment the established flow of

pedestrian traffic between the railway platforms to the west and the Luas and bus

stops to the east.

Ventilation shafts could be incorporated into the concourse canopy and could be used

as ticket machine locations.

The proposed development will result in the closure of Supermac’s (Heuston Station)

with no alternative provided. Supermac has operated from a retail unit within

Heuston Station for the past seven years.

The proposed development does not include proposals to accommodate the

Supermac’s restaurant elsewhere.

The EIS does not assess the impact the proposed development will have on the

Supermac restaurant when the development becomes operational.

The proposed development will result in the removal of 6 no. retail units. All of these

outlets cannot be accommodated in the area identified as indicative retail area and

indeed they may not even be offered at this location.

The EIS does not address the proposed closure of the Supermac’s outlet.

The proposed development could be altered, relocated or redesigned at the Heuston

Station location to reduce the impact on existing businesses.

The current proposal includes a great deal of works to the south side of the concourse

area of Heuston Station without any major works to the open areas to the centre and

north of the concourse. The majority of the proposed works are located where they

will cause the most disruption to both existing businesses and to the built fabric and

character of the protected structure. An alternative solution could be to locate the

stairs, lifts and associated infrastructure in the centre of the concourse where there are

very little elements of the protected structure to be altered apart from the floor.

The impact on the existing Supermac’s outlet is unquestionable and severe.

Request that the proposed development at Heuston Station be revisited with a view to

accommodating the existing Supermac outlet in the new scheme.

AREA 103 - Heuston to Christchurch

71. Flancrest Enterprise Limited, c/o Sudway and Company Limited, Chartered

Surveyors, Riversdale View, Ballyboden Road, Rathfarnham, Dublin 14.

The contents of the observer submission on behalf of the above can be summarised as

follows:

The observers are the beneficial owners of a site on Bridgefoot Street which has the

benefit of planning permission for 33 apartments and 10,000 square foot of commercial

development.

This planning permission was granted by An Bord Pleanála with reference to planning

application no. PL223337 on 27th

November, 2007.


As part of this planning application agreement was reached with Dublin City Council

for the inclusion of lands in their ownership in the planning application. These lands form

the majority but not all of reference no. D3A/A19 which are now to be permanently

acquired under the Railway Order. In addition to the permanent acquisition of parts of the

remaining site namely reference D3A/A18 and D3A/A22 it is also proposed that the

entire of the remaining site would be required on a temporary basis which according to

Part 3 Article 16, sub-section 1 of the order grants this temporary acquisition right for a

period of 10 years from the date that the order comes into force.

While it is accepted that in the event of the order being confirmed that compensation

will be payable to the affected landowners, it is the observer’s contention that the

acquisition of reference D3A/A19 renders the current planning permission unusable and

the loss to the other permanent acquisitions and in particular the temporary acquisition of

all of the remaining site constitutes an excessive infringement on the observer’s right to

the quiet enjoyment of their property and will in effect prohibit them from carrying out

any works on the site for the duration of the temporary acquisition.

While compensation will be payable it will not take into consideration the current

financial commitment which the observer has in respect of the said lands.

The granting of this order would constitute an excessive infringement on the

observer’s constitutional right to the quiet enjoyment and use of their own property which

cannot be dealt with by the normal method of compensation.

The Board is requested to refuse to confirm the order as currently proposed.

The observer reserves the right to attend any public hearing which may be held into

the matter.

72. Berndorf Limited, 16 Palmerston Park, Rathmines, Dublin 6.

The contents of the observer submission as prepared by Hamilton Young Architects on behalf

of the above can be summarised as follows:

The observer owns a premises at 9 Bridge Street, City Gate, Dublin 8 also referenced

as Unit 9, Bridgecourt Lower, Bridge Street, Dublin 8.

This building is constructed on a deep pile foundation which will be adversely

affected and destabilised by the proposed tunnel.

The piles are laid out in an irregular pattern to avoid the old city wall under their

building complex.

It is essential that agreement be reached with the observer’s consultants so that their

property is not affected by the civil engineering works being undertaken or by the

eventual use of the tunnel for the transport system.

The area is of high archaeological importance containing medieval substrata and the

old city wall.

Details are requested as to how these valuable historical items will be protected and

agreement reached on this matter prior to the commencement of the underground works.

The observers are concerned with the effect the proposed construction work will have

on their business and on their tenants.

There is concern regarding the noise and vibration that will occur and its effects on

the structural stability of their building in the short term during construction and during

the longer term use of the tunnel.


Details are requested regarding the temporary access to the tunnelling work through

Augustine Street so that the observers can be assured that their business will in no way be

affected by this work.

The cost to the observer in retaining consultants should have to be borne by CIE.

73. Diocesan Property Manager, Archdiocese of Dublin, c/o Holy Cross Diocesan

Centre, Clonliffe Road, Dublin 3.

The observer submission from the above can be summarised as follows:

This project will affect the properties of the Archdiocese of Dublin.

The submissions include a technical submission carried out by Barrett Mahony

Consultant Engineers.

St. Audoen’s Church, High Street, Dublin 8 is a protected structure and is a fine

example of the Greek revival architectural movement in Dublin.

The church was built between 1841 and 1847 to the design of Patrick Byrne.

It is the opinion of the observers that the church may have been built on made up

ground in what is a very old and historic area of the city.

St. Audoen’s Church has suffered a major subsidence event in recent years which has

been made good at considerable cost.

The Archdiocese of Dublin wishes to submit an objection to the route the proposed

Dart underground because of the possible adverse effects on St. Audoen’s Church.

There are other properties along the proposed route and which the observers believe

are within the zone of influence of the proposed works.

The Barrett Mahoney Report states that additional properties in the ownership of the

dioceses may also be affected. These properties are St. Audoen’s Church, High Street,

Dublin 8 and the parochial house, St. Audoen’s Church, High Street, Dublin 8.

It is requested that the scope of the Dart underground protected scheme should be

extended to include the additional buildings identified. This is particularly important in

the case of St. Audoen’s Catholic Church which is of significant age and importance.

74. TASCQ, Temple Bar Traders, 27 Eustace Street, Temple Bar, Dublin 2.


TASCQ is an organisation which represents over 95 businesses from the Temple Bar

area in Dublin.

The observer acts as a promotional organisation for Temple Bar and undertakes to do

all within its remit to ensure that Temple Bar remains the premier tourism and cultural

quarter within the state.

It is estimated that 60,000 persons pass through Temple Bar on a daily basis therefore

making it one of the heaviest trafficked areas in the city.

The observers believe that the location of the station for the Dart Underground at the

Civic Offices is a welcome proposal and one which will enhance access into Temple

Bar, therefore assisting in sustaining existing businesses and helping with growing

new businesses within the area.


The western section of temple bar has long suffered for poor footfall therefore

creating difficulties for existing traders.

The proposed station at Christchurch will assist in driving traffic into western section

of Temple Bar.

The observers welcome the location and fully support the plans.

The observers request the station be renamed Christchurch and Temple Bar to reflect

the fact that Temple Bar is the leading tourism location within the country and an

important economic engine.

The legal boundaries of Temple Bar extend to the station and the observers

respectfully ask to rename this important station Christchurch and Temple Bar.

75. Temple Bar Cultural Trust, 12 East Essex Street, Temple Bar, Dublin 2.


Temple Bar Cultural Trust is the entity charged with the redevelopment of Temple

Bar area under the 1991 Temple Bar Renewal and Development Act.

Temple Bar Cultural Trust owns significant freeholds and properties throughout

Temple Bar and the company has particular interest in the old city area of Temple

Bar.

Some of these areas will be affected significantly by the proposed works.

The observers welcomed the development of the DART underground.

The observers submit that the new DART station be named Temple Bar Christchurch.

This will be of strategic value to the tourism industry and to the social and economic

interest of all stakeholders in Temple Bar.

The Theatre at Civic Offices is a precious civic and cultural resource that should not

be damaged or have its utility in any way limited or reduced by the proposed works.

An Bord Pleanala should stipulate that the method statements and all other practical

arrangements regarding the proposed works are planned as scheduled and managed in

a way that minimises nuisance and inconvenience to residents, businesses and

tourists.

An Bord Pleanala should insist that there is co-ordinated consultation liaison and

information flows about the proposed works to ensure that the best interests of all

traders and residents in the area are respected and protected to the maximum degree

that is feasible.

Dublin City Council is best placed to managed this essential process through its

south-east area manager and the Temple Bar forum which is managed by Dublin City

Council.

76. Noel Leonard, 40 Watling Street, Victoria Quay, Dublin 8.

Contents of the observer submission from the above can be summarised as follows:

The proposed Dart underground would be running underneath the observer’s

property.

The proposed Dart underground should not cause any damage to the observer’s

property.


There is a cellar that spans the entire floorspace of the observer’s property. The

height of this cellar is about 4 metres.

The observer’s property was built in the 1800’s. The area of the observer’s ground

floor is 131 square metres approximately and not 114 square metres approximately as

stated in the railway order.

There are three floors to the observer’s property, the cellar, ground floor and the first

floor.

The proposed Dart line should in no way interfere with any future development

proposals the observer has for his property.

77. Diageo, Ireland, St. James’s Gate.


Impact on the established use and future development of the Diageo lands at St. James

Gate, Brewery, Steevens Lane, Victoria Quay, Dublin 8.

There is insufficient detail set out in the EIS as to whether or not Dart Underground

will place a limitation on potential future development.

Requires a commitment from CIE that Dart Underground will not impact on any

potential future development of Diageo lands.

Concern as to how the timing and construction of Dart Underground might affect the

delivery of the statutory development policy as set out in the City Development Plan

and the Liberties Local Area Plan.

It is unclear from the EIS whether Diageo could currently develop their lands subject

to planning permission.

Concern with respect to further design changes which may happen beyond the

securing of consent.

Accurate detail design of the project is mandatory to ensure the efficiency of the EIS.

Full details of the construction programme and phasing should be fully set out as part

of the railway order application.

Mitigation measures should be put in place to maintain satisfactory vehicular access

to the public road network during construction phase.

All mitigation measures with respect to noise and vibration should be agreed with

Diageo.

Potential structural damage to Diageo’s property should be fully assessed.

Assessment & monitoring to address any implications for existing operating licences

such as EPA licence at the brewery lands.

Compliance with mitigation measures should be specifically included as a condition

of any final railway order consent.

Need to secure from CIE a dedicated environmental report directly describing the

consequences of the proposed scheme in terms of construction and operation and

impact to the on-going and future uses at the Diageo lands.

Specific concern with respect to acquisition of the substratum land below Diageo

lands - broadly along the Victoria Quay portion of these lands. Impact upon viability

of the future redevelopment of these lands. No specific comment is made in the EIS

as to whether the substratum land take from below Diageo lands places any

limitations on future structural development and associated uses on the ground above.


Diageo lands are identified for significant redevelopment in the Liberties Local Area

Plan.

Albeit that Section 4.4.5.3 of the EIS identifies Diageo lands under significant

development sites. It is further stated at Section 4.4.5.3 of the EIS that the Dart

Underground does not physically affect any of these sites.

Dispute this assertion as Dart Underground will run directly under a substantial part of

the Diageo lands and will incorporate a permanent sub-stratum land take.

Ask An Bord Pleanala to confirm the discernible difference which applies to the

Diageo lands compared to the other significant development sites outlined in the EIS

and to require from CIE a specific development report for the Diageo lands.

Greater certainty is required as to the final design of the project.

Ask An Bord Pleanala to seek greater clarity from CIE with regard to the precise final

design now proposed for Dart Underground and to confirm or otherwise whether the

detail set out in the railway order within the EIS constitutes the final design.

Greater detail of the construction programme and phasing is required within the scope

of the railway order and the EIS documentation. It is unclear from the EIS when the

tunnelling activities are expected to take place under Diageo lands or how long each

tunnel drive will last.

Diageo Ireland respectively suggests that more precise timings for the start and the

finish of the main construction activities in this area are required. It is reasonable that

these should be formally contained within the railway order documentation.

An informal conversation with CIE indicated that tunnelling works under Diageo

lands are expected to take approximately 6-8 months from mid-2014 to early 2015 at

a rate of 90 metres per week per tunnel drive. However this information is not

contained in the EIS. The estimates of timing for the Diageo land do not seem to

match the average tunnel boring speed. A more detailed construction plan should be

included in the EIS.

While no ‘at ground’ construction works are imposed on Diageo lands, there is a

proposed underground station located in close proximity to the subject site at Heuston

Station within 200 metres to the west. There is clear potential for disruption to

Diageo Brewing Operations during large scale urban infrastructure projects such as

the Dart Underground project.

Diageo is anxious that access arrangements to its brewing operations at St. James

Gate are maintained during the construction phase of the proposed scheme.

Ask An Bord Pleanala to secure from CIE a more detailed statement of specific local

changes to the road network and associated traffic movements in this area. Happy to

engage with CIE on such matters of detail.

Potential impacts on Diageo property and stock. There is no specific criteria set out in

the EIS which relates to the brewing operations or other specific functions on Diageo

lands.

Development Plan policy supports the protection and consolidation of the established

brewing operation on the Diageo lands.

Diageo Ireland cannot be expected to put all its operational review and development

requirements on hold for an undetermined time. Ranging from of 5-6 years.

The railway order and the EIS must present a more detailed and proactive

commentary on the possible consequences of the construction exercise on the existing

operations on the Diageo lands and also on the potential future brewery and other non

brewing development changes thereon.


Concern that the integrity of existing working areas and buildings directly above the

running tunnels could be significantly impacted upon.

There is no specific criteria which relates to compensation for the loss of stock as a

result of direct impacts associated with the construction operation of Dart

Underground.

Diageo needs further reassurance on the specific monitoring mitigation or remediation

plans specifically for the protection of their stock or how the risk would be insured,

costs reimbursed etc.

Concern with respect to potential noise and vibration impacts.

The proposed tunnel below the Diageo lands is at a depth of approximately 24 metres

to track level.

It is important that any works causing vibration must be planned and take account of

the recommendations for the safety, health and welfare at work.

There may be implications for existing operating licenses such as EPA licences at the

brewery lands.

It is considered that the potential noise and vibration impacts identified in the EIS are

not sufficiently linked to functions within Diageo lands.

Impacts on existing groundwater source.

The EIS recognises the possibility that Dart Underground could impact detrimentally

on the Diageo well or wells if they are used again in the future.

Diageo needs further reassurance on the specific monitoring mitigation and

remediation plans for the protection of this groundwater source and the potential

limitations on its future use.

Ask An Bord Pleanala to request detailed proposals from CIE in relation to the

protection and mitigation measures to enable this long established asset on the Diageo

lands to remain in use.

Request that compliance with proposed mitigation measures should be specifically

included as a condition of any final railway order consent.

Submission appended with relevant excerpts from statutory policy context for the

Diageo lands and environs including Dublin City Development Plan 2005-2011.

Draft Dublin City Development Plan 2011-2017 & The Liberties Local Area Plan

2009

78. The Atrium Management Company Limited, Island Street, c/o Sudway and

Company Limited, Riverside House, Riverside View, Ballyboden Road,

Rathfarnham, Dublin 14.


Effect the proposed construction might have on the integrity of building foundations

at 29-30 Island Street, Dublin 8.

The basement car park is already in close proximity to the water table.

Potential risk of flooding. Prospects for long-term damage to the structure of the

property both during construction and subsequent

Leakage of radon or other gases from the subsoil into the apartment block.

Construction hours should be limited to a period of 8.00a.m. to 8.00p.m.

Concern with respect to increase in higher insurance premiums and also building

insurance.


Concern with respect to archaeological interest and preservation of same once the

works commence.

Had the railway line been left where it was originally intended it may not have had

such a significant impact on the observer’s property.

Granting of this order would constitute an excess infringement of the observer’s

constitutional right to the quiet enjoyment of use of their own property.

Request that the Board refused to confirm the order as currently proposed. Request

the right to attend any oral hearing which may be held.

Request the right to raise issues that they feel are relevant in respect of the order or

the environmental impact statement at any hearing.

79. Michael Casey, 26 Fishamble Street, Dublin 8


Concern regarding the intersection of Fishamble Street and Essex Street West where it

is proposed to raise the present street surface level.

Concern with respect to structural impact on the fabric of the building and the ground

floor levels within the building and the basement.

No. 26 dates to the early - mid 16th

century and is listed in the current Draft City Plan.

Concern that the proposed work relating to the Dart Underground should have no

adverse impact on the historic fabric of the building.

Having met with a representative of CIE and the engineer concerned with respect of

the proposed works it was felt unnecessary to lodge a formal objection to the plan. It

is felt that with consultation and careful consideration, all of the concerns can be

addressed.

80. Pat Carroll, ECW Limited, 14 Ushers Island, Dublin 8.


The property is of historical importance.

Serious concerns for the building fabric/structure to withstand the tunnelling required

for this project as well as on-going concerns for the potential vibration impact on the

building once Dart Underground is operational.

Proposals to develop this land at some stage in the future may be compromised by the

existence of a tunnel below.

Have not received a satisfactory response with respect to question of piling for

foundations above the tunnel area.

The existence of this tunnel underground will result in a substantial additional cost

over and above the cost of standard ground works (building programme) which

should be compensated for.

81. Mary & David O’Flanagan, Car Upholstery Covers, 12 and 13 Ushers Island,

Dublin 8.



Both houses 12 and 13 Users Island were built in 1759. They are now protected

structures of historical interest.

Concern with respect to structural damage to the buildings and to land at the rear of

the property.

A series of tunnels run below 12 and 13 which originally linked the Guinness

Brewery on James Street to the quay side for the transfer of barrels. Concern that any

tunnelling work carried out would cause damage to the property by vibration impact.

Request that the contractor be compelled to use all mitigation measures available to

prevent the tunnel works beneath the property having a damaging impact.

Location of Dart Underground beneath the property should not restrict any future

development of the property.

Concern that during operational phase the tunnel and track system would cause

disturbance on an on-going basis by way of vibration, noise or by any other means.

82. Raymond Peers, Chief Executive Q Park Ireland Limited, Head Office,

Marlborough Street, Dublin 1.


Q Park Ireland Limited is the owner or long term lessee of the car parks at

Marlborough Street, Clerys Car Park, Ushers Quay, The Forecourts Car Park, Setanta

Car Park, Royal College of Surgeons Ireland Car Park.

Welcome and support the proposed Dart Underground.

Concern in relation to the proposed acquisition of substrata ground beneath the multi-

storey car park at Ushers Quay at the rear of 15-21 Ushers Quay, Dublin 8.

Concern with respect to the inclusion of ground beneath Usher’s Quay car park in the

route for the Dart underground

Q Park has been in the process of preparing proposals for a mixed-use development of

significant scale at Ushers Quay.

The proposals involve the demolition of the existing multi-storey car park and the

construction of a multi-level mixed use development incorporating residential and

commercial premises over a basement car park.

Consider that the land lying 10 metres and below the property has a significant value.

Invite CIE to engage in dialog regarding concerns with a view to agreeing a mutually

acceptable level of compensation.

Express concern in relation to the traffic management plans that relate to the proposed

Dart Underground. Q Park should be included in any consultation regarding the final

traffic management plan for the construction and operational phase of the proposed

scheme.

Welcome an opportunity to meet with CIE.

AREA 104 - Christchurch to Merrion Square

83. Boston College Ireland Limited, 42-43 St. Stephen’s Green, Dublin 2.

The submission as prepared by Owen P. Clear Solicitors on behalf of the above can be

summarised as follows:


The observer concurs with the contents of the Kildare Street and University Club

submission as prepared by John Spain and Associates in relation to the impact of the

proposed project.

The deadline for submissions in relation to this project should have been extended for

the following reasons:

1. Difficulty of obtaining access to appropriate advisers due to constraints imposed by

the traditional holiday period.

2. Lack of availability and access to the report of the planning inspector in relation to the

Metro North which has yet to be delivered.

The observer is concerned that the execution of the works currently envisaged by the

applicant will have the effect of undermining the operation of its business and further

damaging its interest in its property at St. Stephen’s Green.

Of grave concern is the duration and extent of the works.

The injury that would be caused by the cumulative effect of the execution of the

works of three projects namely Metro North, LUAS BXD and Dart underground and the

extended duration of same are matters that the observer wishes to have taken into account

by the Board when considering the adequacy of the procedures and remediation measures

to be adopted in the execution of the works in question.

The observer reserves the entitlement to adduce further and other professional reports

and oral evidence at the public oral hearing.

The observer would welcome the opportunity to submit further detailed information

to An Bord Pleanála under Section 47(d)(i) of the Transport (Railway Infrastructure) Act

2001 as amended by the Planning and Development (Strategic Infrastructure) Act 2006.

The Railway Order should safeguard the quiet enjoyment of the observer’s property

and ensure that no nuisance is occasioned during the execution of the works and the

subsequent operation of the railway.

There is currently no evidence before the Board of the financial losses that will be

occasioned to the property interest and business activities of the owners and occupiers of

businesses on St. Stephen’s Green resulting from the execution of the works.

The Inspector should condition the applicant authority to conduct a full and proper

evaluation of the economic impact of the project on all affected businesses in St.

Stephen’s Green.

The observer reserves all rights and entitlements both at law and under the

Constitution and the European Convention on Human Rights regarding his undertaking at

42-43 St. Stephen’s Green.

The Inspector should condition the applicant authority to discharge all costs incurred

by the observer associated with the submissions therein, any representation at the public

oral hearing and all costs associated with any further action advised on foot of the works

or operation of the railway.

84. Ciaran McGrath, 22 St. Stephen’s Green, Dublin 2.

The observer submission as prepared by Owen P. Clear Solicitors on behalf of the above can

be summarised as follows:


The observer concurs with the contents of the submission of Kildare Street University

Club as prepared by John Spain and Associates in relation to the impact of the proposed

project on his property.

The deadline for submissions in relation to this project should have been extended for

the following reasons.

1. Difficulty of obtaining access to appropriate advisers due to constraints imposed by

the traditional holiday period.

2. Lack of availability and access to the report of the planning inspector in relation to the

Metro North.

The observer is concerned that the execution of the works currently envisaged by the

applicant will have the effect of undermining the operation of his business and further

damaging his interest in his property at 22 St. Stephen’s Green.

Of great concern is the duration and extent of the works.

The injury that will be caused by the cumulative effect of the execution of the works

for the three projects namely Metro North, LUAS BXD and Dart underground and the

extended duration of same are matters that the observer wishes to have taken into account

by the Board when considering the adequacy of the procedures and remediation measures

to be adopted in the execution of the works in question.

The observer reserves the entitlement to adduce further and other professional reports

and oral evidence at the public oral hearing.

The observer welcomes the opportunity to submit further detailed information to An

Bord Pleanála under Section 47(d)(i) of the Transport (Railway Infrastructure) Act 2001,

as amended by the Planning and Development (Strategic Infrastructure) Act 2006.

The observer also requires the opportunity to make representations to An Bord

Pleanála at the oral hearing.

The observer is anxious to ensure that any railway order granted will safeguard the

quiet enjoyment of their property and ensure that no nuisance is occasioned during the

execution of the works and the subsequent operation of the railway.

There is currently no evidence before the Board of the financial losses that will be

occasioned to the property interest and business activities of the owners and occupiers of

businesses on St. Stephen’s Green resulting from the execution of the works.

The Inspector should condition the applicant authority to conduct a full and proper

evaluation of the economic impact of the project on all affected businesses in St.

Stephen’s Green.

The observer reserves all rights and entitlements both at law and under the

Constitution and the European Convention on Human Rights regarding his undertaking at

22 St. Stephen’s Green in relation to the process leading to the consideration of the

granting of the Rail Order.


by the observer associated with the submissions therein, any representation at the public

oral hearing and all costs associated with any further action advised on foot of the works

or operation of the rail.

85. Damien O’Regan, 1 Westfield, Sion Hill, Blackrock, County Dublin.



The illegal and fraudulent and non-valid procurement by CIE of both the ground

substrata and the use of St. Stephen’s Green, Dublin.

Since the 1600s St. Stephen’s Green has been used as a park by the people of Dublin.

In 1877 Sir Arthur Guinness was instrumental in building the current layout of the

park as we know it today.

The St. Stephen’s Green Act of 1877 granted the park for the citizens of Dublin.

Section 15 of St. Stephen’s Green Act gives State protection to the park “to be used

and enjoyed as a public park for the recreation and enjoyment of the public and not for

any other purpose”.

The park was then put in the trust of the Public Works Commissioners.

All kinds of prohibitions were included in that Act including railway transportation to

protect the park from exploitation.

However the Dublin Transport Authority Act 2008 has bulldozed away at this

legislative protection.

This Dublin Transport Authority Act 2008 has a section in it that states Section 15 of

St. Stephen’s Green Act does not apply to inspections, surveys or railway works or the

operation of a railway, light railway or Metro on or under St. Stephen’s Green.

This legislative malfeasance has given the green light for the destruction of one of the

most treasured parks in Europe.

St. Stephen’s Green is also a National Monument.

The observer believes that the Dublin Transportation Act is not a legal and valid

document to change Section 15 of the St. Stephen’s Green Act of 1877, the observer

encloses a copy of both the St. Stephen’s Green Act of 1877 and also the Dublin

Transportation Act 2008.

CIE do not have a legal right to develop St. Stephen’s Green for the use of operating a

railway.

St. Stephen’s Green does not belong to CIE. It is not theirs to destroy, wreck and ruin.

The proposed development is not compatible with the land use zoning applying to St.

Stephen’s Green.

Thousands of people will be using the park as an entrance and exit zone for a railway

station. The very integrity of the park will be destroyed.

The station is within the boundaries of a National Monument and An Bord Pleanála

should refuse the Rail Order for that reason.

The way that this process has proceeded has not been done in a professional,

transparent and democratic manner.

CIE has undertaken a process with the Dart Underground that is the most expensive to

the taxpayer, that is economically destructive to the businesses of Dublin and that is

environmental foolhardy and hostile.

An Bord Pleanála is reliant on its own resources and in a project as big as the Dart

Underground, the observer does not believe that this is sufficient to make a wise

judgement.

The observer does not believe that An Bord Pleanála has all the relevant

environmental information from non CIE sources of the effects on the environment of the

building of the Dart underground.

An Bord Pleanála is not equipped to deal with this Dart Underground application on

its own and the observer believes considering the size and scope of the Dart Underground

project that An Bord Pleanála should commission their own Environmental Impact

Statement to help ascertain the true unbiased effects of such a massive construction


project on the residents who live close by and the buildings that are impacted by the

works.

The problems that the Dart Underground would have caused TCD have been

displaced and relocated to other neighbouring areas.

It is obvious that An Bord Pleanála should investigate this matter as it has serious

implications to the destructive nature of the construction of the Dart Underground in this

part of Dublin.

CIE have not researched the hydrology concerns in a professional manner.

This part of Dublin has numerous underground streams and rivers and ground waters.

The impact as such a massive construction project could well cause flooding,

damaging the foundations of buildings.

CIE are a dysfunctional organisation as regard passenger safety.

86. John Barron, c/o Lambe and Tyndall Architectural Practice, c/o Park

Chambers, 13 St. Stephen’s Green, Dublin 2.


The observer is owner of the Richard Allen Retail Brand and tenant at 58 Grafton

Street, Dublin 2.

The observer feels that due to the cumulative impacts of the proposed Dart

Underground along with Metro North and the LUAS BXD projects, careful consideration

needs to be given to the impact of these major works on the viability of his business.

The application does not address the viability of any business impacted significantly

by the proposed works and there is also lack of clarity in relation to the positioning and

indeed the very availability of a permanent loading bay and drop-off point for the top of

Grafton Street.

Having reviewed the cumulative impacts of the Dart Underground, Metro North and

LUAS BXD line planning applications the observer believes his business will become

unviable as a commercial entity once the main construction works commence.

As a consequence of these works the observer’s shop will be forced to close.

87. Fitzwilliam Land Securities, 57 Fitzwilliam Square, Dublin 2.


The observer’s submission refers to the following properties 22, 24, 25 and 26 St.

Stephen’s Green, Dublin 2.

The observer holds the freehold title to the above properties.

The observer believes that An Bord Pleanála would require their consent before any

developments are undertaken.

88. Joselyn Braddell and others, 36 Highfield Road, Rathgar, Dublin 6.



The observers believe that the time for which submissions can be made to the Board

should be extended.

There are too many new financial complexities of this project.

The proposed development will result in the possible destruction of one of the most

treasured parks of central Dublin - St. Stephen’s Green.

It will result in a stay of profitable trading for at least five years.

The main worries that construction work will badly affect the character of Dublin city.

Dublin streets are narrow and might have to be totally blocked.

The use of green park area for construction in St. Stephen’s Green is certainly going

to change the unique cityscape, making many areas a building site for a whole decade.

The proposed development will facilitate a creeping modernisation of a historic city

centre.

The social aspect of the destruction of mature trees and the pools and bird life in

Stephen’s Green is quite devastating.

The Dublin Chamber of Commerce has warned that the construction will cause

widespread inconvenience which may even last as long as 8 years.

The main argument against the Metro is economic.

The cost of this underground will be largely met by more debt.

It is not clear how Ireland will continue to finance these large capital projects and

many of them will probably be left half done as Ireland will possibly default in 2012.

No economic cost benefit analysis has been carried out by the current administration

which should be mandatory for all large public sector projects which will allocate a

larger amount of taxpayers’ funds to projects with little economic benefit.

There is a significant risk that this project will be left half done, a dangerous eye sore.

In this current climate it does not make sense to invest nearly 7.5 billion euros on

Dublin’s public transport infrastructure.

The argument is that the Metro North and Dart Project will create jobs in the

construction sector but how many jobs will be lost in the public service and other

sectors that rely on public funding.

Tourists will be bereft of the city centre several years if this expensive underground

line is allowed.

There may also be drainage problems in the St. Stephen’s Green area that was built on

boggy ground with substantial amounts of rising groundwater.

Does Ireland really need an underground system anyway?

The success of the Luas system is surely an indication and investment should be used

to create a good over ground network of Trams.

An Bord Pleanala should reject this proposal.

The observer submission includes appendices relating to problems encountered with

the new Düsseldorf underground system and also with proposals for a new station at

Stuttgart.

89. Irish Georgian Society, 74 Merion Square, Dublin 2.


The society wishes to express particular concerns about the impact of this new

railway line on St. Stephens Green.


With the necessity to remove the extensive areas of planting and excavate in such an

architecturally sensitive area the proposed development will have a dramatic effect on

the character of the green for years to come.

The society is of the opinion that this form of development would under other

circumstances be considered unacceptable in terms of its impact upon the preservation

of the city’s built fabric and historic character and would be entirely contrary to good

conservation practice.

However the society is willing to accept that the development has the potential to

improve the transportation system in the city.

The applicant should be required to make every effort to minimise the impact of the

development works both during construction and the design and siting of above

ground structure and in the screening of these.

The clearance of any vegetation must be done in accordance with a replanting scheme

devised by suitable experts that is sympathetic to the existing gardens and works to

mitigate the visual impact of the development.

The observers have particular concerns about the visual impact of the proposed

ventilation/intervention shafts on the streetscape or on St. Stephens Green.

The eastern ventilation/intervention shaft would be highly visible from the street.

The Irish Georgian Society’s is concerned that this new structure would have a

considerable detrimental impact on the character of the street and on one of the city’s

most historic parks.

Given the architectural significance of the area the observers urge the every effort be

made to address these concerns.

90. Salix Trust Limited, c/o RPS Planning and Environment Consultants, Dun

Laoghaire, County Dublin.


follows:

The enclosed report specifically related to Nos. 6 and 7 St. Stephen’s Green, Dublin 2

(occupied by Top Shop and other tenants). The observers support in principle the Dart

underground project.

However there are number of concerns with regard to construction operation matters

contained in the Railway Order and the EIS.

The observers request that the Board consider that full details of the permanent

substratum landtake including any potential limitations in the future land uses above it

are provided to the observers.

Full details of the construction programme and phasing (including any enabling works

in the area) should be fully set out as part of the Railway Order application.

This is required to ensure full scrutiny of the environmental effects of these elements

of the proposed scheme on the key sites along the alignment including the observers’

property at St. Stephen’s Green North.

Mitigation measures should be put in place to maintain satisfactory pedestrian access

to Nos. 6 and 7 St. Stephen’s Green and environs during the construction phase to

ensure the effective continued retail trading operations at the observers’ premises.


A more detailed construction management plan for the period of the works in this area

is required within the formal confines of the application.

All mitigation measures with respect to noise and vibration should be agreed with the

observers prior to the commencement of the proposed scheme.

The potential for structural damage to the observers’ property should be fully assessed

and full details of the potential structural damage to the building and proposed

mitigation measures should be provided to the observers prior to commencement of

development.

It is critical that all mitigation measures detailed in the EIS and elsewhere in the

application documentation are implemented as part of the construction and operation

phase of the Dart underground.

It is requested that compliance with proposed mitigation measures should be

specifically included as a condition of any railway order consent.

The quantum of land-take even though it is substratum may have a significant and

direct impact on the observers’ property.

The quantum of land-take may have a significant and direct impact on the observers’

investment, the tenant’s business and the viability of the entire building as a retail

store.

The observer is seriously concerned at the impact of this land-take on the legal title of

the property.

The observers need further information in order to assess the damage to the legal title

of the property due to this project.

If the substratum permanent land-take impacts any future development of the property

the impact on value of the pension fund could potentially result in a serious financial

loss (Salix Trust Limited is a Bank of Ireland Staff Pension Fund). The observer is

concerned that commentary within the EIS which suggests that design progression

and refinement will happen apparently at some stage beyond the securing of a consent

leaves uncertainty as to matters of construction and operation particularly in the area

of contingency.

It is submitted that an accurate detailed design of the project and with the fully

assessed range of likely significant impacts is mandatory to ensure the efficiency of

the EIS in this case.

The observer has concerns as to how the Railway Order process will protect the

outcome of what actually will be built and the potential impacts which might arise

from any change in the design unless such possible changes are firstly fully described

and fully assessed by reference to the extent of environmental impact.

The observer respectfully suggests that more precise timings for the start and finish of

main construction activities in the area are required and that it is reasonable that these

should be fully contained within the Railway Order documentation.

It is submitted that a more detailed construction plan should be included in the EIS

outlining the full details of the proposed construction programme as it will apply to

the observers’ property.

The issue of timelines is critical as it affects the day to day operations of this

established retail premises.

It is critical that access to the observers’ premises is not impinged upon during the

construction phase of the proposed scheme and that staff, customers and deliveries are

afforded ease of access as far as possible during the construction phase of the

proposed scheme.


The Board is asked to secure from CIE a more detailed statement of the specific local

changes to the road network and associated traffic movements in this area and with

direct recognition of the needs of key neighbouring operators such as No. 6 and 7 St.

Stephen’s Green.

The observer asks that the Board request further information on the proposed

escalators and footpath treatment where they emerge at ground level outside the

observers’ property.

In relation to potential structural damage given that the impact of the proposed

scheme on the observers’ property remains uncertain following mitigation measures

the observer has serious concerns that the integrity of this protected structure would

be significantly impacted upon.

The observers ask the Board to request that full remediation of any structural damage

caused to the observers’ property during construction or operation of the Dart

underground project be guaranteed by CIE irrespective of the cost.

Further clarification is required on the predicted noise levels and the impacts on the

observers’ tenants, staff and customers.

91. James Adam and Sons Limited, c/o Reed Associates, Sandycove, County Dublin.


follows:

James Adam and Sons Limited, Fine Art Auctioneers and Valuers are located at 26 St.

Stephen’s Green and 13 Kildare Street, Dublin 2.

The submission is in respect of the impact of the proposed Dart underground line on

the operation, vitality and viability of the observer’s business and property.

The Board is requested to hold an oral hearing into the railway order.

The observer has grave concerns that changes in accessibility and service loading

arrangements and noise and disturbance, environmental and visual and traffic impacts

from construction would adversely affect the viability and vitality of their business.

The company operates the only fine art auction house within the city which covers the

entire range of art.

James Adam and Sons Limited contributes to the rich diversity and mix of uses in this

area of St. Stephen’s Green which enhances its unique character and urban sense of

place.

These businesses have taken a long time to establish their reputation but the business

could disappear in a very short period as a result of the difficult trading environment

which will be created by the construction of the Dart underground and other public

transport infrastructure in the area.

The EIS assessment and socio-economic issues is flawed and there has been a failure

to appropriately assess or understand the potential negative impact arising from the

development on local economic conditions and businesses.

There should and must be a better alternative location for the proposed construction

compound, the construction compound should be relocated to a less sensitive

environmental location for the entire duration of the construction period.

The principle should be to intrude as little as possible on the public realm within this

highly sensitive area where other business uses such as the Shelbourne Hotel and


Hibernian and Residents Clubs are also significantly dependent on the local

environmental conditions and public realm to support their business operations.

If the established businesses are to survive in St. Stephen’s Green North then a

surgical approach to insertion of the Dart underground is required.

There is a need for liaison with the observer and the details of the construction

methodology and traffic management strategy should be formally agreed with the

observer and other business operators in the area.

At present there is a lack of detail and certainty in respect of key issues relating to

construction, phasing and methodology.

In relation to rock breaking techniques the EIS concludes that the relevant

methodology will be dependent on the outcome of local trials “when suitable methods

and materials can be selected”, this does not inform the observer as to what methods

are to be used in the vicinity and under this premises, can the observer expect

supersonic shocks to effect fine art class or other delicate items or occur during live

auctions.

These issues need to be addressed in advance so the observer can know exactly what

the level of impact will be.

This is a critical issue and should not be part for future agreement with the contractor.

There is a need for a full building survey and a schedule of dilapidations to be

prepared to assess possible future damage to the building structure.

Considering the fine art nature of the business there is a need to indemnify the

observer against any possible damage to fine art items arising from vibration or

shockwaves.

It is not clear whether the two projects will run in parallel or consecutively.

The construction period could range up to 9 years and if running simultaneously

would have a more intensive impact over 6 years.

The construction phase is of such long duration as to significantly alter the

environmental conditions and perception of public life in the vicinity of St. Stephen’s

Green North in the longer term creating lasting and permanent profound damage.

In relation to traffic impacts it is not clear how access will be maintained and there is

no clear programme in place to reassure the observer in this regard.

The accommodation of Luas BXD and the Metro North and Dart underground station

on St. Stephen’s Green encroaches significantly on the available road space and

necessitates significant changes to traffic management and parking strategy for the

area and warrants the provision of a lay-by outside the observer’s premises.

The observer requests that a specific loading bay be provided outside their premises to

ensure the operation of their business is to remain viable in light of the significant

changes to traffic management occurring as a result of the operation and construction

of the project.

92. Ciaran McGrath c/o OLM Consultancy, 33 Fitzwilliam Place, Dublin 4.


follows:

The observer holds a legal interest in No. 22 St. Stephen’s Green, Dublin 2. The

submission relates to the anticipated deleterious effect of the proposed works and


intended proposed works phasing on the physical fabric of the premises and the

immediate environs of the premises and on the continued commercial viability of

current tenants with consequent effects on the observer’s legal interest in the property.

The premises is a listed building.

The observer acquired the property in the mid-1990s and extensively refurbished and

remodelled the ground and upper floors to provide a boutique townhouse

accommodation and restaurant facilities.

A separate restaurant tenant occupies the basement level.

The upper floors of the premises includes an 84 seat restaurant, bar, private dining

room, ancillary catering facilities and 9 bedrooms.

The basement level of the premises holds a 60 seat restaurant and ancillary catering

facilities.

A large factor in the success of the St. Stephen’s Green area during these difficult

economic times has been a concentration of attractive well maintained buildings

including the observer’s premises in a prime location on a busy pedestrian

thoroughfare that attracts corporate customers, shoppers, tourists and other leisure

clientele.

The lengthy construction period will have a substantive detrimental on-going and

irreversible impact on the premises and businesses operating from the premises.

The effect on trading will compromise the commercial viability of the businesses

which as a corollary will affect the legal interest of the observer.

The proximity of the observer’s premises renders it particularly vulnerable to the

effects of noise, dust and vibration.

The location and impact of Dart underground site compound area is of concern.

In reference to noise the EIS refers to 198 daily lorry movements removing 80,000

tonnes of excavation material, between 8 and 12 per hour accessing and exiting from

the site compound area directly opposite the observer’s business.

The observer is concerned that during the estimated 9 year construction period there

would be significant noise emanating from the site compound area.

This will no doubt discourage footfall to the premises thereby affecting revenue and

profitability and ultimately jeopardising rental income.

It is the observer’s contention that all best practice in measuring and minimising noise

be employed by Irish Rail and their contractors with specific focus on the observer’s

premises.

There should be a defined communication process between the businesses at the

observer’s premises and the contractor to ensure that the businesses are at all times

aware of drilling and blasting works and other activities and that the contractors

compel to take account of tenant’s specific operational concerns from time to time.

Substantial amounts of dust will be raised as a result of excavation and spoil removal.

It is the observer’s contention that all best practice in measuring and minimising dust

and nuisance be employed by Irish Rail and their contractors with specific focus on

the observer’s premises.

It is the observer’s contention that all best practice in measuring and minimising

vibration be employed by Irish Rail and their contractors with specific focus on the

observer’s premises.

The nature of the proposed works is such that significant interface with existing

drainage systems will occur. From experience with properties in this area the existing

drainage installations are prone to collapse and blockage.


The proposed hoarding and overhead covering should become an artistic attraction or

amenity.

93. Perlar Limited, c/o O’Connor Sutton Cronin & Associates, 9 Prussia Street,

Dublin 7.


follows:

The observers own premises at Nos. 53 and 54 South King Street, Dublin 2.

The impact of the structural works on the structural stability of their property and in

particular the impact the vibrations caused by the proposed tunnel boring machine.

The impact of the operation of the Dart underground on their property and particularly

the impact of noise and vibrations caused by the on-going operation of the railway.

The impact of the presence of the railway tunnel in close proximity to their property.

The observers are concerned that certain construction restrictions may be imposed on

their site in order to protect the Dart tunnel.

These restrictions may limit the development potential of the site by way of

preventing or limiting piling operations of the construction of deep basements.

94. Corcia Acquisitions Limited, c/o O’Connor Sutton Cronin & Associates, 7

Prussia Street, Dublin 7.


follows:

The observers are the owners of No. 57 Grafton Street, Dublin 2.










95. Suzanna Jackson, c/o Il Posto Restaurant, 10 St. Stephen’s Green, Dublin 2.


The observer wishes to raises strong objections to the proposed Dart underground,

Metro North and Luas BXD line.

The proposed tunnel alignment, ventilation shaft and station under, and in front of, the

façade of the observer’s building is of concern.


The cumulative impact of the three transport works on the restaurant.

The lack of commercial viability to continue trading.

The inadequacy of the EIS to take into account the continuation of all business on the

green.

The absence of any form of compensation for businesses on the Green who will suffer

greatly due to these works.

The change in the current scenic peaceful atmosphere to that of a 9 year building site.

The effect of the removal of 80,000 tonnes of rubble by 198 lorries per day. The

vibrations, noise disturbance and damage is also of concern.

The movement of gas, electricity and water supply lines.

The inadequate planning for access for daily delivery services.

Proposed traffic restrictions.

The positioning and size of the proposed holding.

The huge amount of dust in the area.

The unavoidable disturbance and movement of vermin.

The EIS is inadequate, incomplete and flawed.

96. Thomas Barry and Company Solicitors, 11 St. Stephen’s Green, Dublin 2.


The cumulative impact of the Dart underground, Metro North and Luas BXD works

are a concern to the observers.

Less disruptive alternatives which have apparently been out ruled should be re-

examined.

The observers submit that the planning inspector should attach a condition to the rail

order seeking a provision that all costs incurred by the observers in relation to making

submissions on the three projects as well as the cost of all mitigation measures

required to be put in place and all on-going costs relating to the supervision of works

be provided by Irish Rail and the RPA.

Central and convenient access is the observers’ standout selling point especially to

new clients.

If clients associate visits to the observers’ firm with noise disruption discomfort they

simply will not come.

No account appears to be have taken of the firm’s established right to park directly

outside 11 St. Stephen’s Green either during the course of construction works or

afterwards.

The building in which the firm is located is a protected structure. It is susceptible to

substantial impact from the proposed works.

The proposed tunnel alignment and station construction under the façade of the firm’s

premises is fraught with danger and needs considerable further consideration.

Once the nature and scale of the proposed works becomes clear the observers will find

it very difficult if not impossible to hold its current tenants and/or find new tenants

with immediate financial consequences.

Full and due account has not been had to the cumulative impacts of the Metro North,

Dart underground and Luas BXD line.

This process should include a strategic environmental assessment.


The observers are also concerned at the inadequacy of the environmental impact

statement which does not address the viability of the firm impacted significantly by

the proposed works.

The observers are unhappy with the fact that this submission had to be prepared

without sight of the findings of the planning inspector in relation to the Metro North

rail application order.

A strategic environmental assessment is required where a project is co-financed by the

European Community (Article 2(a) of Directive 2001/42/EC), the European

Investment Bank has approved lending to Metro North accordingly one of the three

projects will be EU co-funded.

The baseline categorisation using EIS makes no reference to legal service venues.

Why did the EIS not consider in more detail the viability of businesses that are

directly impacted by all three construction projects?

97. Bartral Limited, c/o O’Connor Sutton Cronin & Associates, 9 Prussia Street,

Dublin 7.


The observers are owners of premises at Nos. 39-40 St. Stephen’s Green, Dublin 2.










98. Alric Limited c/o O’Connor Sutton Cronin & Associates, 9 Prussia Street,

Dublin 7.


The observers are owners of premises at No. 58 Grafton Street, Dublin 2.


particular the impact the vibrations cause by the proposed tunnel boring machine.









99. Sean and Madeleine Mulligan, 54 The Green, Woodbrook Glen, Bray, County

Dublin.


The observer has the right to comment on the proposed effect on the environment of

St. Stephen’s Green of the construction and operation of the proposed Dart

underground station.

It is extremely unclear how the present pond is to be preserved during and subsequent

to the works or if it is to be removed.

St. Stephen’s Green is a unique civic space within Dublin.

Preserve an existing tree should be considered preferable to replacing with new or

immature trees.

Proper attention needs to be given to the atmospheric as well as visual impact of the

proposed ventilation/intervention structures.

St. Stephen’s Green in its present state is much enjoyed by residents and visitors alike

and provides a much required open space for respite within the urban landscape.

It is imperative that disruption to biodiversity and conservation should be kept to a

minimum.

Relocating the station under the shopping centre would be preferable.

100. Pat and John Sexton, Michael Power, Acuman Facilities Management,

Swords Business Campus, Balheary Road, Swords, County Dublin.


The observers act as managing agents on behalf of Pat and John Sexton to the

Marconi House development on Digges Lane.

The railway works drawing show a clear route underneath Marconi House.

The observers are seeking further information on the assessment of this site and are

anxious that the plans reflect the ‘as built’ nature of the site.

The building includes a below ground floor level office and basement car park.

101. Gerry Dempsey and Others, Europlan Insurances Limited, 11 St.

Stephen’s Green North, Dublin 2.


The business at No. 11 St. Stephen’s Green, Dublin 2 will be severely affected by the

construction and operation of the proposed Dart underground.

The proposal ignores the effects of the development on businesses affected by

prolonged disruption.

The minimum requirement should be a proper and agreed compensation package for

business who suffer reduced income and possible closure as a result of the said

development.


The individual and cumulative impacts of the Dart underground, Metro North and

Luas BXD works is a cause of deep concern.

The absence of a strategic environmental assessment of the cumulative impacts of the

three projects is of concern.

The prospect of the area in the immediate vicinity being a construction site for up to 9

years and the consequent impact on businesses located on St. Stephen's Green North

is of concern.

The observers are particularly concerned in relation to access to an established

parking right directly outside the property at No. 11 St. Stephen's Green North.

The observers contend that the proposed works will have a significant impact on their

business and that this aspect of the projects have not been thoroughly assessed in

conjunction with business owners.

When the three projects comprising Metro North, Dart station and a Luas stop are

fully operational some 34,000 passengers will alight at peak times at the station at St.

Stephen's Green.

This raises serious issues in relation to personal safety and security for such a

significant number of people arriving on what is a confined pedestrian area.

The observers strongly disagree with the conclusion reached in a socio-economic

assessment that construction will not lead to significant citywide congestion and that

disruption will not be significant in travel terms.

The detailed cost benefit analysis supporting the socio-economic impact of the

proposed Dart underground line has not been published.

The observers submit that the stakeholders be given a copy of this report and be

afforded time to be consulted on its key findings before the public hearings are

concluded.

The risk of potential adverse effects in terms of building damage from vibration and

disturbance of occupants due to ground borne noise and/or vibration has been clearly

identified in the EIS.

The highest anticipated noise levels of the entire combined works is at St. Stephen's

Green North adjacent to the Metro North works.

No conclusion was reached in relation to the cumulative impact of the works on

business activity or on the viability of the sensitive receptors impacted by all three

works and projects.

102. Deks Limited c/o Owen P. Clear Solicitors, 42 St. Stephen's Green, Dublin

2.


The observers Deks Limited trade as MacNally Opticians on the Green, 35 – 38 St.

Stephen's Green, Dublin 2.

The observers rely upon the generality of the matters referred to in the submission by

Kildare Street and University Club as prepared by John Spain and Associates.

The deadline for submissions in relation to this project ought to have been extended.

Lack of availability and access to the report of the planning inspector in relation to the

Metro North project which has yet to be delivered and would be of relevance in

preparing submissions in relation to this related and concurrent project.


The observers are concerned with respect to damage to their property interests.

Of great concern is the duration and extent of the works.

The injury that would be caused by the cumulative effect of the execution of the

works for the three projects namely Metro North, Luas BXD and Dart underground

and the extended duration of same are matters that the observers wish to have taken

into account by the Board when considering the adequacy of the procedures and

remediation measures to be adopted in the execution of the works in question.

The observer is anxious to ensure that any rail order granted will safeguard the quiet

enjoyment of the property and ensure that no nuisance is occasioned during the

execution of works and subsequent operation of the railway.

In advance of granting of the rail order the inspector should condition the applicant

authority to conduct a full and proper evaluation of the economic impact of the project

on all affected businesses in the St. Stephen's Green area.

No such direct consultation or evaluation has ever been engaged by the applicant

authority with the observer.

In the same way that the EIS anticipates a compensation and property protection

scheme a scheme of a similar nature and defining a means of evaluating loss of

business entitlement to compensation for same should be conditioned.

The observer reserves all rights and entitlements both under the constitution and under

the European Convention on Human Rights.


by the observer associated with the submissions, any representation at the public oral

hearing and all costs associated with any further action and advice on foot of the

works or operation of the rail whether pursuant entitlement under the Transport Act

2001 as amended by the Planning and Development Act 2006 or otherwise.

103. William Murray and Rory Fitzpatrick, 11 St. Stephen's Green North,

Dublin 2.


The building is a protected structure and is susceptible to substantial impact from the

proposed works.

The proposed tunnel alignment and station construction under the façade of the

building endangers the structure of the building and needs considerable further

consideration.

Once the nature and scale of the proposed works becomes clear the observers will find

it very difficult if not impossible to hold current tenants and/or find new tenants with

immediate financial consequences.

No account appears to have been taken of tenants established right to park directly

outside No. 11 St. Stephen's Green.

All the options have not been sufficiently evaluated.

There are less disruptive alternatives which have apparently been ruled out.

The inadequacy of the EIS which does not address the viability of businesses

impacted significantly by proposed works.

The prospect of the area in the immediate vicinity being a construction site for up to 9

years and the consequent impact on the building, its tenants and the businesses.


No consideration has been given to levels of compensation payable to owners and

occupiers should it be demonstrated that due to a decline in business as a direct result

of the impacts of the works the commercial viability is threatened.

When the three projects comprising Metro North, Dart station and Luas stop are fully

operational some 34,000 passengers will alight at peak times at St. Stephen's Green.

This raises serious issues in relation to personal safety and security for such a

significant number of people arriving at what is a confined pedestrian area.

Concerns raised in relation to the socio-economic assessment contained in the EIS.

The statement that the impacts on business will be slightly negative massively

understates the real impact.

The detail cost benefit analysis supporting socio-economic impact of the proposed

Dart underground line has not been published.

Stakeholders should be given a copy of this report and be afforded time to be

consulted on its key findings before the public hearing is concluded.

The risk of potential adverse effects in terms of building damage from vibration and

disturbance of occupants due to ground borne noise and/or vibration has been clearly

identified in the EIS.

Disappointingly no conclusion was reached in relation to the cumulative impacts of

the works on business activity or on the viability of the sensitive receptors impacted

by all three work projects.

A revised and much more detailed cumulative impact assessment should be prepared

in close consultation with the stakeholders along St. Stephen's Green North and

adjacent streets.

104. Derek Flood, Bentleys Oyster Bar and Grill, 22 St. Stephen's Green,

Dublin 2.


The business operates from premises on the north side of St. Stephen's Green at No.

22.

The premises includes an 84 seat restaurant, bar, private dining room and 9 bedrooms.

The observer’s location is enhanced by the ease of access to it from various public

transport means, taxi ranks and car parking.

The observer is deeply concerned that the lengthy construction period will have a

significant detrimental and irreversible impact on his business.

This concern is especially heightened given the proposed location of a site compound

area inside the Green and directly opposite the observer’s premises.

No detailed assessment has been carried out by Irish Rail on the likely impact of this

construction project on the observer’s business.

From the upper levels of the observer’s premises his customers will have direct line of

sight to the compound works including earth moving equipment, scared earth and

ancillary site works.

For the estimated 9 year construction period there will be significant noise, dust and

vibrations emanating from this compound.


There should be a defined communication process between the business and the

contractor to ensure that the business is at all times aware of blast works and other

activities.

Best practice in measuring and minimising noise and dust vibrations should be

employed by Irish Rail.

Hoarding and overhead covering should become an artistic attraction or amenity.

This could be in the form of a painting or sculpture of which could itself be the

subject of creative and high profile project.

A critical fact and success of the observer’s business is the timely delivery of fresh

quality produce.

The proposed works do not guarantee any goods vehicle access to premises during

construction period.

There will be significant restrictions on private vehicular access to St. Stephen's

Green and public transport services make it highly inconvenient and thus unattractive

for the observer’s customers to access the premises.

The daily provision of guaranteed goods vehicle access to the premises albeit at

defined delivery times should be included as a condition of any proposed works.

It should be a condition of planning that the observer’s customers have unrestricted

and uninterrupted access to the front entrance of the premises during the construction

period whether using taxis or private cars.

An independent body should be authorised to review claims of financial loss directly

attributable to the proposed works and based on independently verified accounts.

This body should have sufficient funds to compensate business suffering loss and

such amounts as to protect the constitutional property rights of the owner.

Given the proximity of the observer’s business to the compound it is submitted that it

should be regarded as a sensitive receptor and thus a detailed report should be carried

out to assess the likely impact of the proposed works on the business.

105. Anglo Irish Assurance Company Limited, c/o Arthur Cox Solicitors,

Earlsfort Centre, Earlsfort Terrace, Dublin 2.


The observer partially owns 35-45 South King Street, it is proposed to acquire the

substratum of this property to facilitate the project.

The observer’s concerns principally relate to the impact which the project will have

on the structural integrity of its property and its business and trade during the course

of the yet undefined enabling and construction works period.

It is requested that An Bord Pleanála seek further information from CIE in relation to

the detailed design of the proposed enabling and construction works.

It is requested that by way of condition CIE is required to comply with the ultimate

general mitigation measures proposed in respect of both the construction and

operational phases of the project.

CIE should be required by way of condition to conduct regular comprehensive

monitoring throughout the construction and operational period of the project to ensure

that no structural damage is caused to the observer’s property.


106. Bank of Scotland (Ireland), 124-127 St. Stephen's Green West, Dublin 2.

The contents of the observer submission as prepared by John Spain Associates on behalf of

the above can be summarised as follows:

The observer is particularly concerned in relation to the cumulative impact of the

construction of the Dart underground in conjunction with other infrastructural projects

in the area namely Metro North and Luas BXD.

It is respectfully submitted that any construction activity in the vicinity of St.

Stephen's Green should be subject to the same limitations and obligations as were

agreed between the Bank of Scotland (Ireland) and the RPA by way of legal

agreement during the course of the Metro North Railway Order process.

The cumulative impact assessment undertaken by the applicant is insufficient.

The applicant should be requested to prepare a detailed report on the methodology

and mitigation measures associated with the requirement of the tunnel boring machine

to break out of the station box in close proximity to the Bank of Scotland (Ireland).

The applicant should be required to submit proposals to control vibration and noise

associated with the proposed transfer spoil through the tunnels in close proximity to

the Bank of Scotland (Ireland) on a 24 hours basis to an acceptable level.

The applicant should be required to incorporate a vibration reducing floating track

system into the design in the vicinity of the Bank of Scotland (Ireland) to ensure that

minimum vibrations are felt by the hotel guests during the operational stage of the

proposed development.

The applicant should be required to prepare and submit a report which specifically

examines the impact of the construction the Dart underground would have and the

ability of the businesses at St. Stephen's Green to continue trading throughout the


The observer has a number of recommendations in relation to the compensatory

measures and the property protection scheme.

The applicant should be required to present a contingency plan for the construction of

a station at St. Stephen's Green to be implemented in the event that the Metro North

does not proceed.

The absence of this information from the application for a railway order is considered

to be a significant omission and it precludes a full and detailed assessment of the

impact of the proposals.


to An Bord Pleanála under Section 47(d)(i) of the Transport (Railway) Infrastructure

Act 2001 as amended by the Planning and Development (Strategic Infrastructure) Act

2006.

The observer requests that An Bord Pleanála requires that costs incurred by the

observer during the course of consideration of the application to be paid by the

applicant.

The observer submits a copy of a legal agreement between the observer and the RPA

in relation to construction activities in the vicinity of the Bank of Scotland (Ireland).

It is imperative for the on-going operation of the Bank of Scotland (Ireland) that any

Dart underground construction works in the vicinity of the bank do not cause breach

of the agreements reached with the RPA.


It is submitted that An Bord Pleanála should be satisfied that the construction of the

Dart underground will not be severely detrimental to the ability of businesses in the

vicinity to continue to trade.

The applicant should prepare and submit a report which specifically examines the

impact that the construction of the Dart underground would have on the ability of the

businesses at St. Stephen's Green to continue trading throughout the construction

period.

107. Ampleforth Limited, c/o John Spain Associates, Lower Mount Street,

Dublin 2.


The observer owns the Fitzwilliam Hotel at St. Stephen's Green West, Dublin 2.

The Fitzwilliam Hotel is particularly concerned in relation to the cumulative impact of

the construction of Dart underground in conjunction with other infrastructural projects

in the area namely Metro North and Luas BXD.

It is submitted that any construction activity in the vicinity of St. Stephen's Green

should be subject to the same limitations and obligations as were agreed between the

Fitzwilliam Hotel and the RPA by way of legal agreement during the course of Metro

North Railway Order process.

The observer submits a recommended condition to be attached to any railway order

granted.

The applicant is requested to clarify the need for the permanent land acquisitions

referenced under D4AA37 and confirms that Dart underground do not require this

land for construction activity.

The cumulative impact assessment undertaken by the applicant is insufficient.

The progress of the tunnel boring machine beneath the hotel including the

requirement of the TBM to break out of the station box to travel westwards has

potential to have adverse impacts upon the hotel.

The applicant should be required to prepare a detailed report on the methodology and

mitigation measures associated with the requirement of the TBM to break out of the

station box beneath the Fitzwilliam Hotel.

This report should be made available for comment prior to the commencement of the

oral hearing.

The applicant should submit detailed proposals to control vibration and noise

associated with the proposed transfer of spoil through the tunnels beneath the

Fitzwilliam Hotel on a 24 hour basis to an acceptable level.

The applicant should be required to incorporate a vibration reducing floating track

system into the design in the vicinity of the Fitzwilliam Hotel to ensure that the

minimum vibrations are felt by the hotel guests during the operational stage of the


The applicant should be required to prepare and submit a report which specifically

examines the impact that the construction the Dart underground would have on the

ability of businesses at St. Stephen's Green to continue trading throughout the



A number of issues need clarification in relation to the proposed property protection

scheme.

The applicant should be required to present a contingency plan for the construction of

a station at St. Stephen's Green to be implemented in the event that Metro North does

not proceed.

The absence of this information from the application for a railway order is considered

to be a significant omission and it precludes a full and detailed assessment of the

impact of the proposals.


to An Bord Pleanála under Section 47D (1) of the Transport (Railway Infrastructure)

Act 2001 as amended by the Planning and Development (Strategic Infrastructure) Act

2006.

It is requested that An Bord Pleanála requires the cost incurred by the observer during

the course of consideration of the application to be paid by the applicant.

The Fitzwilliam Hotel is one of only five 5 star hotels in the Dublin city region and

plays a vital role in providing much needed accommodation at the very top end of the

market in the city centre.

The Fitzwilliam Hotel is located on St. Stephen's Green West directly above the route

of the southern twin bore tunnel which travels beneath the northern end of the

building.

The subject building is also located directly opposite the combined Metro North and

Dart underground station and to the western ventilation shaft.

The proposed railway order for Dart underground includes proposed surface and

substratum land take from the Fitzwilliam Hotel.

108. Peploes Restaurant, Basement of 16 St. Stephen’s Green North, Dublin 1,

c/o Aidan McLernon, Cunnane Stratton Reynolds, 3 Molesworth Place, Dublin

2.


No. 16 St. Stephen’s Green North is a protected structure.

Generally supportive of the principle of the underground railway line.

Concern with respect to potential impacts on business during construction but also

during operation.

The east bound tunnel of the underground railway is located directly below no. 16 St.

Stephen’s Green North.

Concern and disappointment with the level of consultation undertaken by CIE.

Consider that the construction time of 6 years is conservative and consider that it is

important that businesses are protected from adverse impacts.

Concern with respect to the construction compound at St. Stephen’s Green which is

almost directly opposite no. 16.

Concern with respect to traffic impact and the loss of one of the lanes from part of

Stephen’s Green North to accommodate the construction compound.

Request that a draft Construction Traffic Management Plan be submitted in advance

of a decision by An Bord Pleánala and be open to consultation by the public as any

measures incorporated will directly impact on businesses in the area.


It is important that interim parking measures are in place to accommodate customers

until the LUAS, DART Underground and Metro Line North are complete.

Concern with respect to the loss of service bays and parking for deliveries. Requests

formal notification that parking bays be retained both during construction and at

operation stages of the development.

Concern with respect to construction traffic.

Consideration should be given to removing more excavation material via underground

railways.

The EIS is vague in terms of mitigation measures and their implementation.

Propose that a condition be attached to the Railway Order which states HGV vehicles

are not permitted to transport waste material from St. Stephen’s Green construction

compound between the hours of 8 – 9 and 5 – 6.

Prior to commencement of construction works the appointed traffic management

coordinator must arrange to meet interested parties and businesses affected by

construction traffic to discuss potential impacts. His/her contact details should be

circulated to all interested parties and businesses potentially affected.

Concern with respect to the impact upon St. Stephen’s Green which is a National

Monument.

Concern with respect to a loss of outlook from the observer’s restaurant.

The visual images of the construction compound proposed for St. Stephen’s Green as

set out in the EIS clearly illustrates that the compound is entirely inappropriate in St.

Stephen’s Green even as a temporary structure.

The Landscape and Visual Impact Assessment in the EIS is considered insufficient.

The applicant should be requested to submit a further range of viewpoints for example

at the top of Grafton Street and the corner of St. Stephen’s Green East.

The cumulative impact of other major infrastructure projects in St. Stephen’s Green

have been omitted from the Landscape and Visual Impact Assessment.

Recommend that the EIS is revisited prior to any decision being made to ensure

comprehensive assessment is undertaken.

It has been indicated that the 7 metre hoarding surrounding the north side of the

proposed compound at St. Stephen’s Green may be available for advertising of local

businesses however the application makes no reference to advertising of any kind on

the structure.

The applicants are requested to clarify if advertising space on the hoardings is part of

the application or if it is intended to provide this at a later date.

Request that details of the finish of the hoarding of St. Stephen’s Green be submitted

prior to the determination of the application.

Given the sensitive location of the crane it is requested that the design of this element

be agreed with Dublin City Council in advance of its erection.

It is requested that further information be supplied in relation to the lighting of St.

Stephen’s Green compound as this could potentially affect observer’s business.

Concern with respect to air quality.

It is imperative that the observers are informed and consulted during the formulation

of the Dust Minimisation Plan.

Concern with respect to noise. It is requested that a Baseline Noise Study is

undertaken outside Peploes restaurant prior to construction to establish the current

noise levels.


Noise assessment should be taken at regular periods at different times of the day

during construction to ensure that adverse noise pollution is not being caused in the

area.

Concern with respect to vibrations. Owners of no. 16 St. Stephen’s Green request

further information in relation to the timescales of when it will affect their property.

Request the written notification be issued by the contractor 4 weeks in advance of the

TBM reaching St. Stephen’s Green.

Concern that it is stated in Table 9.6 of the EIS that significant impact duration will be

up to 34 months between St. Stephen’s Green and Pearse Street Station. This is a

considerable period of time and further information is requested on the potential

duration where significant impact is likely to be caused to no. 16 St. Stephen’s Green.

Request the compensation be paid by the applicants where the observer’s business is

forced to close due to unacceptable interference.

Further information is requested in relation to breaking of rock and the methods

which are to be proposed under St. Stephen’s Green.

Request that high explosive methods are not used in the St. Stephen’s Green area.

Submit that a condition should be attached to the Railway Order that explosive

methods for breaking rock are not permitted underneath the historic area of St.

Stephen’s Green at any time.

Where An Bord Pleánala disagrees with the proposed condition and blasts are

permitted it is requested these be restricted to a minimum of 3 per day to avoid a

cumulative impact occurring.

Rock breaking should be restricted to within normal working hours i.e. 9 – 5.

Monitoring of vibrations caused by construction work should be undertaken.

Concern with respect to potential impact of settlement.

Welcome the recommended Phase 3 assessment of the property. However this

recommendation appears to have been ignored in Chapter 4 and Chapter 24 of the EIS

where a number of other properties are identified for such an assessment.

Formally request that no. 16 St. Stephen’s Green be fully assessed in a Phase 3

assessment prior to construction as recommended in Appendix A16.1 of the EIS.

Request that the hours of construction be restricted to no later than 1800 hours

Monday – Friday, which would help to limit the impact on the area and the night time

economy.

Request that businesses are furnished with a contact should issues arise throughout the


A Community Liaison Plan should be put in place.

The Environmental Management Plan should be subject to consultation and be

circulated to all businesses.

Concern with respect to disruption to services in the area such as electricity, water,

sewage etc. and request that a minimum of 2 weeks notice be served where possible.

Request that strict pest control measures be put in place.

Concern that the design of the ventilation and intervention structure to the north of St.

Stephen’s Green is bland and potentially damaging to the amenity of the park.

Concern with respect to security. There is a need that a Security Management Plan be

formulated. This should be a condition of the Railway Order.

Supportive of the principle of the development but opposed to the destruction of St.

Stephen’s Green. Request that alternative design options be considered to protect the

National Monument from long-term impact.


Request that appropriate conditions be attached to the Railway Order to ensure that

the amenities of the area and the observer’s businesses are protected throughout the

construction process.

109. Kildare Street and University Club of 17 St. Stephen’s Green, Dublin 2

c/o Eoghan P. Clear Solicitors, 42 St. Stephen’s Green, Dublin 2.


Concern with respect to damage to property interests at 17 St. Stephen’s Green.

Concern with respect to the cumulative effects of Metro North, LUAS BXD and

DART Underground and the extended duration of same. Consider that the Board

should take into account the cumulative effects of all three projects when considering

the adequacy of the procedures or the remediation measures to be adopted.

Request that an oral hearing be held and reserve the right to further submit

professional reports and oral hearing evidence.

Anxious to ensure that the Railway Order granted will safeguard the quiet enjoyment

of the observer’s property and ensure that no nuisance is occasioned.

Concerns with respect to loss of business or impact to commercial interests.

A full and proper evaluation of the economic impact of the project and all cumulative

works on all effected businesses in St. Stephen’s Green should be carried out.

In the same way that an EIS anticipates a compensation and Property Protection

Scheme, a scheme of a similar nature in defining a means of evaluating the loss of

business and entitlement to compensation for same should be conditioned.

The observer reserves all rights and entitlements.

Request that all costs associated with the submission and any representation at a

public oral hearing and all costs associated with further action on foot of the works or

operation of the railway be discharged.

Submission is accompanied with a report from John Spain Associates on behalf of

Kildare Street and University Club.

Kildare Street and University Club operate as a hotel.

Note that the EIS states that the alignment through St. Stephen’s Green is confined in

position by the Dublin Metro North and existing infrastructure.

No reference is made in the EIS to access and servicing arrangements with the

buildings along St. Stephen’s Green North.

Concern is expressed with the proposed realignment of DART Underground tunnels

at St. Stephen’s Green.

The Kildare Street and University Club maintains that the alignment of the DART

Underground tunnels at St. Stephen’s Green should be moved south into St. Stephen’s

Green Park and away from the protected and sensitive building at St. Stephen’s Green

North.

Realignment of the tunnels by 20 metres to the south would not address concerns with

respect to noise impacts, vibration impacts and settlement impacts.

It is understood that there is no engineering reason why the alignment cannot be

moved within St. Stephen’s Green Park.

A series of mitigation measures should be put in place to seek to protect the on-going

vitality and viability of Kildare Street and University Club and the integrity of the


protected building during the construction works, enabling works and operational

phase of the development.

Should the DART Underground go ahead as proposed it will severely impact in terms

of potential damage to the integrity of the protected building, noise, vibration, lengthy

construction activities, traffic and access disruption to the extent that the club may be

unable to survive.

It is submitted that the application does not give significant weight to the future

viability of businesses on St. Stephen’s Green North.

The applicant has not adequately assessed the alternative alignments of St. Stephen’s

Green North in the EIS.

The EIS does not provide a detailed assessment of alternative alignment of the twin

Board tunnels entirely within St. Stephen’s Green Park.

The alternative suggested alignment would entirely avoid the risk to the protected

structures in St. Stephen’s Green North and significantly reduce the potential impact

on the future vitality and viability of businesses on St. Stephen’s Green North.

The construction phase on the park could largely be addressed by reinstatement

measures.

A geophysical survey of the DART Underground by Apex Geo-services identifies the

presence of sub-vertical faults beneath the Kildare Street and University Club. It is a

serious submission that this information has not been fully taken into account in the

EIS in the evaluation of the impact of tunnelling at this location in order to protect the

building.

It is submitted that the alignment should be moved to the south away from the sub-

vertical faults.

There is a discontinuity in the rock in the form of a 3 metre deep depression under no.

17 St. Stephen’s Green North. This means that the depth of rock from the proposed

platform tunnel is 12 metres. Having regard to the limits of deviation which have been

sought by the applicant in a worst case scenario this gives 2 metres of rock under the

building which is clearly insufficient to protect it from the rock coring or blasting

necessary to form this platform tunnel. This worst case scenario has not been assessed

in the EIS.

No building specific survey of no. 17 St. Stephen’s Green has taken place despite the

protective nature of the building in the presence of noted plasterwork.

It is submitted that a building specific Phase 3 Structural Impact Assessment was

carried out.

The application does not include a proper and detailed assessment of the cumulative

effects of the project together with LUAS BXD and Metro North.

No proper assessment of the socioeconomic impacts of the proposed development on

the club has been carried out.

The application is premature pending agreement of the Traffic Management Scheme

for St. Stephen’s Green and Dublin City Council.

It is requested that An Bord Pleánala restrict the surface working hours for DART

Underground to 8am – 6pm Monday – Friday and 9am – 3pm Saturdays, Sundays and

bank holidays. Any working hours in excess of these would render the bedrooms and

public rooms of the club unusable for the construction period.

The club has a number of bedrooms facing onto St. Stephen’s Green North and it is

considered that the anticipated noise emissions would render these rooms unusable.


The proposed mitigation set out in the EIS in the form of a 7 metre high hoarding will

not provide suitable mitigation for the noise generation within the construction

compound.

Confirmation is sought that the existing loading/unloading bays at St. Stephen’s

Green North will be maintained at all times throughout the enabling works and

construction phase of the DART Underground project.

It is requested that the following be put in place.

1. Compensatory measures including contractors insurance in the event of

damage to a building exceeding minor cosmetic damage.

2. Outline proposals for carrying out remedial works immediately after any

damage has been identified and

3. Review the cap of €30,000 on the amount payable under the scheme.

In the course of the examination by O’Connor Sutton Cronin Consulting Engineers of

the geological information contained in the EIS documents a drawing (no. 25082 Ref.

4) from the reference design titled Ground Investigation Geological Long Sections

Sheet 22 of 32 was discovered. This drawing indicates that there is possible faulting

and folding of rock directly under the Kildare Street and University Club. Slightly

weathered to fresh limestone rock and slightly weathered to fresh moonstone rock are

interspersed with steeply inclined fault lines between them. The top of the weathered

rock varies but is generally 7 metres below ground level at the club. The drawing is a

serious cause of concern to the club.

The proposed DART Underground design has chosen this location for the mined

platform tunnel. It is inappropriate to attempt to mine out the tunnel in this location

due to the real possibility of drawdown of large volumes of water present in the fault

lines. This in turn would lead to the potential instability of the ground under the

building.

This information is not contained in the main EIS text rather it is included in the

appendices. The November 2009 report and the geophysical survey for the DART

Underground by apex geo-services states in Section 4.3 under the heading Faults for

the area between CH16 + 000 and 16 + 800 metres. “A number of sub-vertical faults

had been interpreted from the resistivity results for St. Stephen’s Green, Drawing

25082 which may have caused bedrock displacement and could act as water conduits

during construction.

The club is situated approximately between CH16 + 165 and CH16 + 185. It is

directly above this geological feature of the EIS geological long section. Figure

13.29V3 does indicate these features and as a consequence the serious issue of

tunnelling and mining three of these conditions is dealt with adequately.

It is apparent that the EIS has not fully appropriately assessed the impact of tunnelling

beneath Kildare Street and University Club as the presence of sub-vertical faults has

not adequately been taken into account.

It is submitted that the impact of tunnelling with the sub-vertical faults not present

would still remain unacceptable.

The Club is recognised in the EIS as being an important protected structure over the

route of the tunnel and the predicted maximum settlement of the building is 30

millimetres.

Concern in relation to the potential structural impact on the building.

Iarnród Eireann has requested the power to adjust the zone of influence of this tunnel

10 metres vertically in Article 6 of the draft Railway Order, therefore, in a worst case


scenario this gives 2 metres of rock under the building which is clearly insufficient to

protect it from the rock coring or blasting necessary to form this platform tunnel. This

is a worst case scenario and has not been assessed in the EIS.

The building has a basement with foundations likely to extend slightly below it such

that the true effective distance between the building and the tunnel is 5 metres.

The EIS is deficient in not properly evaluating these issues and it is clear that

unacceptable level of vibration settlement and subsequent damage to the structure and

the listed ceilings would occur if Iarnród Eireann is permitted to proceed as proposed

in the EIS.

Concern with respect to platform mining. The Club is genuinely concerned about the

concept of mining a platform tunnel under the building. The process of mining is not

adequately represented in the EIS.

In the absence of detailed information to support the contention of the applicants that

the proposed location and construction methodology of the tunnel will not have

significant detrimental impact on no. 17 St. Stephen’s Green North it is submitted that

the feasibility of relocating the alignment to a location within the park should be

pursued.

No noise levels for the operation stage impact on the club are presented in the EIS and

the club respectively requires that An Bord Pleánala ensure that floating track

technology is used at this location to reduce the below ground noise incorporation

impacts on the building.

Concern with respect to working hours. Respectfully request that An Bord Pleánala

restrict the surface working hours for DART Underground to 8am – 6pm Monday to

Friday and 9am – 3pm Saturdays, Sundays and bank holidays. Any working hours in

excess of these would render the bedrooms and public rooms of the club unusable for

the construction period.

Limit the work in the area to daytime hours and that no noise louder than the

background level is received on the front facade of the club.

A Community Liaison Officer should be appointed during construction. A detailed

monitoring programme should be established for vibration monitoring, noise

monitoring, settlement monitoring and groundwater monitoring.

Where feasible monitoring should be carried out on a real time basis to ensure that the

information is available at short notice.

It is brought to the attention of An Bord Pleánala that Chapter 24 of the EIS states that

no cumulative impact assessment has been undertaken in relation to the potential

impact of the construction of LUAS BXD as it has been assumed that there will be no

concurrent construction activities with DART Underground at St. Stephen’s Green.

However the EIS for LUAS BXD states that Metro North contractors will undertake

the construction and LUAS BXD within their site compound as far as Dawson Street.

It is submitted that the EIS is deficient in relation to assessment of cumulative impacts

in respect of LUAS BXD.

It is submitted that An Bord Pleánala should request the submission of further

information with respect to

1. An independently prepared detailed report examining feasibility of the

realignment of the DART Underground tunnels at St. Stephen’s Green North

to a location within St. Stephen’s Green Park and it is respectively submitted

that this report should be assessed by an independent expert appointed by An

Bord Pleánala.


2. An independent prepared detailed socioeconomic report outlining the potential

impact on businesses in the vicinity of St. Stephen’s Green, appropriate

mitigation and remediation measures should be set out rather than stakeholders

and occupants should be consulted in the preparation of the report.

3. A detailed cumulative impact assessment of the impact of the DART

Underground proposal in conjunction with both Metro North and LUAS BXD

projects with regard to St. Stephen’s Green to include details of phasing

arrangements and common management arrangement with the RPA.

4. With regard to compensatory measures and the Property Protection Scheme it

is requested that the applicant should be required to put in place the detailed

compensatory measures including

1. Contractors Insurance

2. Outline proposals for carrying out remedial works immediately after any

damage has been identified and

3. Review the cap of €30,000 for the amount payable under the scheme.

5. An Bord Pleánala is requested to seek confirmation from the applicant that the

existing loading/unloading bays at St. Stephen’s Green North will be

maintained throughout the enabling work and construction phase.

The submission is accompanied with a report from Benjamin and Beauchamp

Architecture, Design Conservation Architects.

17 St. Stephen’s Green better known as Kildare Street and University Club was built

in 1776 for Joseph Leeson who later became the first Earl of Milltown.

It is renowned for the Michael Stapleton plastered ceilings which are contemporary

with the house.

The house is a protected structure.

It is on record the condition of the plastered finishes and their importance in Georgian

Dublin architecture which is explained at length in Connolly’s recent book on the

Stapleton collection.

Concern with respect to the fabric of the building. Whilst this overall structure has

settled into a steady state it remains flexible and will reflect any imposed vibration.

Any loss or damage to the plasterwork would be severely detrimental to the integrity

of the protected structure.

Concern with respect to the volume of traffic. Background sound levels will increase.

There will be substantial dust migration.

There is no prospect of trying to protect the building by upgrading the existing

windows to double glazing, neither should the windows be removed nor replaced with

double glazed fittings.

The insulation of secondary glazing within the existing internal reveals will only

compromise and potentially damage the existing internal joinery and have an

unacceptable visual impact on the front elevation and the setting of the principle

internal rooms.

It is unlikely that the local Planning Authority would grant consent for any works to

the glazing even on a temporary basis.

Recommend that the client consider commissioning of professional photographs of

the ceiling and other fragile surfaces shortly before construction commences.

The building is of high regional and national importance.

The building needs to be the subject of a Phase 3 building specific assessment before

the determination of the planning application and not afterwards.


The report by Benjamin and Beauchamp Architects supports the Quinquennial report

and demonstrates the building has not changed over the last three years.

The submission is accompanied by Kildare Street and University Club, St. Stephen’s

Green, Dublin report on the Quinquennial survey for the year 2009. Survey carried

out by John Beauchamp. This report was commissioned to provide an independent

review of the current condition of the property.

It sets out a summary of the condition of the building, its history, condition of the

exterior, rear elevation, front elevation, access lane and gates, roof voids, light walls

and escape stairs of the interior.

The report is accompanied with a photographic survey.

110. Ray Mooney, General Manager, Stephen’s Green Hibernian Club, 9 St.

Stephen’s Green, Dublin 2.


The key issues for the Stephen’s Green Hibernian Club (The Club) are as follows:

1. The proposed tunnel alignment with the station construction under the club

should be moved to a location within St. Stephen’s Green, an engineering

option that was favoured and considered feasible by Iarnród Eireann during the

preliminary design stage.

2. Expert advice has concluded that very significant impacts would arise

including a possible ground collapse as a result of the tunnel boring machine

and station box works due to local geological conditions. A very significant

concern exists in relation to a large fault within the limestone under the

building which is infilled with mudstone and limestone boulders. The matter

could give rise to ground settlement and in the worst case scenario a sinkhole

collapse with the consequence of ground collapse at the surface that could

result in the sudden failure of the building.

3. A Phase 3 Structural Impact Assessment on the clubs building should be

completed prior to the determination of the application in order to ensure that

there would be no impacts upon the protected structure.

4. In the absence of any evidence from the applicant to the contrary and based on

the observer’s experience of running the club as a non-profit making entity,

owned by its members, the club will become unviable shortly after the main

construction works commence. As a consequence the club will be forced to

close with the loss of 40 jobs. International evidence shows that a short, never

mind an intensive and intrusive 9-year construction programme in a prime City

Centre location will force businesses to close.

5. The total inadequacy of the EIS in regards the cumulative impacts of the three

projects in relation to the area around St. Stephen’s Green station where some

34,000 passengers per hour at peak will arrive into a small geographic

footprint. In particular the EIS does not deal adequately with the risk of fire

and general health and safety under and over ground.

6. The absence of any provision for compensation including business rates relief

for the inevitable drop in revenue that will result once the main works

commence.


7. The proposed Property Protection Scheme as explained to the observer by the

applicant is insufficient and too inflexible should major and immediate works

be required.

8. The fact this submission had to be prepared without sight of the findings of the

Planning Inspector in relation to Metro North and in particular the conditions

attached to those works and their potential application to the proposed DART

Underground works. The observer therefore reserves the right to make a

separate submission having had time to review the Inspectors report.

9. Lack of clarity in relation to the positioning and indeed the varied availability

of a permanent loading bay and drop-off point for the club’s suppliers,

members and guests adjacent to the club’s building during and after

construction works

10. A condition should be attached requiring the main works on Metro North and

DART Underground to be constructed at the same time. Concern that DART

Underground will have a severe detrimental impact upon the club’s building

and its commercial viability during construction.

Mitigation measures are an essential

According to the EIS St. Stephen’s Green and surrounding area is arguable one of the

most important commercial areas in the state.

It is important that the structural integrity of the building in particular its Lafranchini

plasterworks are protected. These plasterworks date from 1750s and are possibly

priceless being one of only three examples worldwide of the Stucco of the Lafranchini

brothers.

Serious concern with respect to construction activity on the clubs structure and

foundations.

Its interior contains unique ceilings, walls and other features. The building is likely to

be more prone to vibration and transport service access to the club’s entrance will be

at some distance from the front entrance a particular disadvantage to more elderly

members.

There are compelling reasons why the tunnel alignment should be moved southwards

to a location within the Green which relate to the geophysical features and the

presence of a limestone sinkhole under the building which give rise to a serious health

and safety risk and significant increases in damage to buildings.

It is easier and much cheaper to implement mitigation measures to protect the

visual amenity of the Green.

The commercial viability of businesses along St. Stephen’s Green North

where 750 jobs are at risk will be less impacted if the construction works was

moved away from buildings.

Traffic in particular construction transport impacts would be less.

There would be far less disruption in terms of dust, noise, vibration and

general disturbance.

Once operational the noise and vibration impacts on the building would be

less.

A condition should be attached to the application that the construction of Metro North

and DART Underground works commence at the same time.

Concern with respect to lack of Strategic Environmental Assessment.

The DART Underground EIS is also silent about the needs for an SEA. An area based

SEA under the draft Dublin City Development Plan is justified given the


sustainability of constructing three major transport works in a confined geographical

area.

Submit that the SEA should specifically evaluate the following.

1. The cumulative impacts of three major public transport construction works.

2. Alternatives such as the very need for a LUAS BXD line and Metro North if

the DART Underground project provides adequate carrying capacity to the

city centre.

3. Having regard to the cumulative impacts whether the LUAS BXD line should

have a different alignment for example down Merrion Row, Merrion Square,

Pearse Street and across the bridge at Marlborough Street, Hawkins House

Option B

4. A Cost Benefit Analysis of the three projects combined, specific to the

Stephen’s Green North area and in particular consequences and mitigation

measures if there is to be a proven loss of revenues for businesses in the

immediate vicinity during the construction works.

5. The cumulative impacts of construction work including enabling works over a

period of up to 9 years and required mitigation measures

6. Whether the proposed works meet the SEA criteria to promote the protection

and conservation of cultural including architectural heritage.

7. Levels of compensation payable to the club should it be demonstrated that due

to decline in businesses as a direct result of the impacts of the works their

commercial viability is threatened.

The EIS is flawed as it fails to even consider let alone address the issue of commercial

viability of businesses in the immediate vicinity of the works.

The cost benefit analysis supporting the socioeconomic impact of the proposed DART

Underground has not been published. Submit that this report should be published and

that stakeholders be afforded time to be consulted on its key findings before the public

hearing is concluded.

Due to concern with respect to the socioeconomic assessment a survey of the owner

occupiers along St. Stephen’s Green North was commissioned. The main findings of

the survey are as follows:

1. There is a strong general support for the public transport project proposed for

St. Stephen’s Green.

2. Very many businesses, 85% believe that the impacts during construction

would be negative with 30% concluding that there would be severe disruption

3. Opinion is evenly divided about the impact of the proposed traffic restriction

on business activity.

4. An average drop in footfall of some 28% is forecast during construction

works. Such a drop in pattern would jeopardise the jobs of some 750 people

employed in the hospitality and leisure sector in the vicinity of the works.

5. 90% of businesses felt that some form of compensation should be paid if their

commercial viability was threatened.

6. Half of the respondents want a comprehensive building survey carried out

before the works begin.

7. Over half of the companies had doubts that St. Stephen’s Green Station could

cope with projected passenger levels and

8. On completion of the works 63% of businesses believe they would benefit

from the increased footfall.


It is submitted that the applicant be requested to complete a more detailed and robust

socioeconomic study, submit that an assessment of the option of not building a DART

Underground station at St. Stephen’s Green be published bearing in mind that the

capacity of Metro North and LUAS BXD line to serve the city centre.

No reference is made in the EIS to access the servicing arrangements of the buildings

along St. Stephen’s Green North.

Submit that this provision be included as a condition in approving the Railway Order.

There are no proposed pick-up and drop-off locations proposed for taxis and cars at

the new St. Stephen’s Green DART station.

At present some 80% of the clubs members and guests arrive by car, drop off

passengers at the clubs entrance with the driver typically proceeding to the St.

Stephen’s Green Royal College of Surgeons car park or the RIAC car park.

Note that the FitzWilliam hotel has a guarantee of three set down spaces at its front

door during and after the construction works and wishes that the same privilege be

extended to the club.

The club has invested heavily in recent years in wheelchair access, installing ramps

and lifts and widening doorways. This work will have been largely in vein if the

current plans are to proceed whereby drop-off facilities and a taxi access are at too

greater distance for disabled

The submission is appended with:

o The Stephens Green Hibernian Club submission on Metro North

o The Stephens Green Hibernian Club submission on the LUAS BXD Line

o Survey of Owners / Occupiers along St. Stephens Green North

o An Engineering Impact Assessment (Appendix 4) incorporating tunnelling

impacts.

From the Engineering Impact Assessment (Appendix 4) it is clear:

That the most appropriate locations for the tunnels and works in general is away from

the buildings on St. Stephen’s Green North. Practically all of the engineering issues at

risk to the buildings are mitigated significantly by moving the works away from the

buildings along St. Stephen’s Green North.

The information provided in the EIS indicates a large sinkhole feature within the

limestone infill with mudstone and limestone boulders.

This gives rise to the following serious concerns:

1. Tunnel settlements from both TBN tunnelling and NATT impact from

enlargements.

2. Vibrations

3. The groundwater regime will be significantly more complex and dewatering

works could result in surface settlements.

4. The worst case scenario is for the works to initiate a sinkhole collapse with the

consequence of ground collapse at the surface.

The presence of a sinkhole feature significantly increases the risk of damage to the

building.

Concern with respect to dewatering, dust, ground anchors and rock bolts, noise,

building repairs, rock excavation settlement.

Ground anchors and/or rock bolts should not be installed under the building as they

leave voids in the ground.

Appropriate conditions should be attached with respect to noise monitoring.


The clubs most prized assets are the Lafranchini plasterworks on the ground and first

floors. The risk of damage to this plasterwork is a major concern to the club.

Undertaking repairs/restoration to these plasterworks if repairs were possible will be a

very specialised and expensive operation.

Request that adequate prior notice of the use of percussive breaking techniques is

given. Appendix 16.1 of the EIS indicates that 25 millimetres of foundation settlement

could occur, should 25 millimetres of foundation movement occur as predicted this

would certainly result in a very significant damage to the building and its finishes.

This level of foundation movement is unacceptable and inappropriate and puts the

entire building at risk.

Request that a Conservation Architectural Assessment of the building be completed

within 6 months from the date of the agreement including a specific and detailed Risk

Assessment of the impact that the works may have on the plasterworks and the agreed

mitigation measures be identified in costed consultation with the clubs expert

advisers.

Independent monitoring of the building would be very important before, during, after

the works.

Monitoring to include vibration monitoring, noise monitoring, settlement monitoring

and groundwater monitoring.

No details are provided on the extent of enabling works or the programme for these

works.

There should be no ceiling on the maximum amount of available funding for remedial

works.

It is feared that should the LUAS BXD Metro North and DART Underground works

progress as proposed it is almost inevitable that the club will have no option but to

close the business.

The club may have to use every legal option to ensure that its concerns are adequately

addressed.

The EIS recognises there are cumulative impacts of the three public transport projects

against this given the preferred tunnel station alignment and the absence of any

assessment of the impact of the works on the clubs business. The club has concluded

that the EIS is inadequate, incomplete and flawed.

Deep concern has been expressed at the proposal to construct the tunnel and station

under the front of what is a protected structure. These concerns have been ignored.

Submit that during the course of the planning hearing a Framework Plan report/SEA

of the cumulative impact of the works around the Metro North/DART station and

LUAS BXD line be completed in full consultation with local stakeholders.

Submission accompanied with environmental impact of the Metro North works on St.

Stephen’s Green Hibernian Club dated 14th

November 2009 as Appendix 1.

The Stephen’s Green Hibernian Club (The Club) has noted with a huge degree of

concern the Environmental Impact Assessment carried out by the RPA for the

FitzWilliam Hotel which is located in the vicinity. The Club submits that as a

significant receptor that a similar report should be completed in respect of the club.

The submission covers the following issues.

1. Site establishment

2. The position of the escalators on St. Stephen’s Green North

3. Utility diversions

4. Main works


5. The proposed 6-year timescale for the works

6. Socioeconomic impacts

7. Noise

8. Site boundaries

9. Working periods

10. Vibrations

11. Soil and geology

12. Dust

13. Visual impacts

14. Mitigation measures

15. The clubs foundations

16. Protecting their Lafranchini plasterwork

17. Windows

18. Access by fire service

19. Pedestrian and service access

20. Alignment of the LUAS BX line

21. Rates waver

22. RPA indemnification

23. Meeting the clubs expenses incurred as a consequence of Metro North

24. Monitoring and reporting.

The club submits that an agreement should be concluded between the RPA and the

club modelling on the terms and conditions agreed with the FitzWilliam Hotel but

expanded to meet the clubs specific requirements.

The club request an opportunity to address the reconvened oral hearing about its

concerns.

The clubs main concerns about likely environmental effects as described in the

submission are as follows:

1. Securing a written agreement along the lines of the agreement reached

between the RPA and the FitzWilliam Hotel about mitigation measures that

are necessary as a consequence of the high impact enabling and main works.

2. Attaching conditions to the conduct of the enabling and main works.

3. The carrying out of baseline reports in relation to conservation architecture,

noise, vibration, soil, geology and protection of the integrity of the building in

advance of the commencement of any works in the immediate vicinity of the

club.

4. Securing access to the main entrance to the club at all times.

5. Provision of adequate transport and pedestrian access to the club during the

works and on their completion.

6. The relocation of the exit position of the escalator from the ticketing haul.

7. Clarification about the combined environmental impacts arising and the Metro

North DART Interconnector and LUAS BX work over a sustained 6-year

period.

The club submits that it is more important and significant receptor than the

FitzWilliam Hotel.

The description of the works around the FitzWilliam Hotel is assumed to be broadly

the same as will exist in the vicinity of the club.

The submission sets out the RPA - FitzWilliam Hotel Agreement highlighting the

concerns which the club has having reviewed the RPA’s report on the predicted

environmental impacts of the proposed scheme on the FitzWilliam Hotel.


It details the assurances provided to the hotel and provides comment on the clubs

circumstances.

With respect to site establishment the clubs comments are as follows. The hoarding

should be erected not less than 5 metres from the clubs frontage. It should contain

overhead lighting and direction signs to the clubs entrance. The club would also like

confirmation that once the Stage 1 works are completed that the hoarding will be

relocated at the further distance from the club. The RPA has told the club that the

holding will be stepped back from the club but not by how much.

With respect to escalators the location of the entrance of the proposed bank of

escalators from the concourse level is some 7 metres directly opposite the front door

of no. 8 St. Stephen’s Green. Given the volume of people who will use this escalator

and the crawling around the top of the escalator its position should be realigned to a

location where there will be not be congestion at the front of the club.

With respect to utility diversions the RPA should provide a similar level of detail to

the club along with assurances about the duration of works, expected noise and

vibration levels and access to the club for its clients and service deliveries.

The club requests that the utility diversions should be located as far as possible from

the frontage of the building, certainly no closer than 5 metres.

With respect to main works, the works in both Areas A and B is of a similar nature

therefore the club needs a precise description of the nature of the works envisaged,

their impact on the club and their timescale.

With respect to socioeconomic impacts the club submits that it too will face a similar

level of disruption. It expects the same mitigation measures that will be put in place in

respect of the hotel will apply to the club for example as regards appropriate

information and management procedures.

The club has particular issue with access to its location. It poses a particular challenge

for its members and guests.

With respect to noise the RPA should engage with the club to determine the

acceptable limit values of the club having regard to the baseline study which is

planned and the general limitations and noise limit values as set out in the

requirements of the EIS.

It is noted that there will be an increase in daytime airborne noise levels associated

with construction works and in the absence of mitigation measures unacceptable

levels of noise will result.

Noise monitoring should be carried out at the facade of the club during the


The clubs traditionally quiet reading room/library would suffer due to noise. With

respect to site boundaries the club needs similar assurances as the hotel. In addition it

needs to be clarified that enforceable sanctions will apply to the contractor if he fails

to meet these conditions. With respect to working periods the club needs to have

similar assurances about permissible working times. The RPA has informed the club

that working hours will be staggered over three phases. The club wants assurances

that percussive processes will not operate for eight and that with very few exceptions

works will not be undertaken between 8pm and 7am.

With respect to vibration limited information is available on the geotechnical ground

conditions and the foundations to the original building. It is important that appropriate

vibration limits are set to protect the building from structural damage. It is important


that a detailed assessment of the possible effects of vibration of the building is carried

out and that safeguards are put in place to control vibration.

With respect to soils and geology the club requires the RPA to undertake some

detailed assessment in collaboration with expert advisers and notes that a preliminary

assessment in a Stage 2A Preliminary Building Response Assessment has been

undertaken for the St. Stephen’s Green area. The club submits that the RPA should

carry out a comprehensive conservation and architectural assessment of the club

building, a geotechnical site investigation, geotechnical interpretation, ground

investigation to informed detailed design.

With respect to dust the club notes there are no legal standards relating to acceptable

levels. The club expects that the contractor at his expense will clean the clubs facade,

windows, entrance area and doors at intervals to be agreed.

Visual aspects. The clubs main dining room is facing the prospect of looking into a

hoarding for 6 years. The club is considering how it can best reconfigure its

operations during the construction works and will want an assurance from the RPA

that will meet the cost associated with these changes.

Mitigation measures. The club wants the same guarantee as given to the FitzWilliam

Hotel in the form of an Environmental Management Plan.

Foundations. It is important that the RPA take all necessary precautions to ensure that

ground movement does not occur at the building.

Installing bored ground anchors under the building involves the boring and removal of

subsoil which temporarily leaves voids in the ground. These voids are filled with

grout but there is a real risk of ground movement occurring which can cause

foundation movement and damage to the building.

The RPA should clarify at the earliest opportunity and well in advance of the works

the precise engineering works that are envisaged effecting the basement and

foundation of the club and of the basement and foundations of co-adjacent buildings.

The club according to the RPA is one of the very few historic and protected structures

in active use that will be affected by the Metro North works.

The clubs most prized assets are the Lafranchini plasterworks on the ground and first

floors.

The club submits that a Conservation Architectural Assessment of the building be

completed within 6 months from the date of the agreement.

Should the ceilings or walls have to be protected during construction of the works,

this should be done at the RPA’s cost.

The club does not exclude the necessity at the RPA’s cost of installing a false ceiling

to protect the plasterwork.

Windows. It will be necessary to seal the windows to help protect the inside of the

building from dust and noise. The cost should be met by the RPA.

Access of fire engines. The club requires an assurance from Dublin City Council Fire

Service that fire engines will have full access to the club for the entire duration of the

works.

Pedestrian service access. The club submits that it too needs a permanent and

dedicated set down area during and most importantly after construction and that this

be located at the corner of St. Stephen’s Green North on the top of Dawson Street.

A loading bay to accommodate a turning circle for three cars should be provided to

facilitate service deliveries and people accessing the club by taxi or private car.


Alignment of the LUAS BX line. While it is not within the scope of Metro North

railway application order there is concern should a decision be made to recommend

an alignment of the proposed LUAS away from the railings at St. Stephen’s Green

North that this would have the effect of moving the utility diversions and perhaps the

location of the ticket haul/stop box to very close proximity to the clubs frontage.

The club wishes to signal a strong opposition to this proposal and supports the

alignment of the proposed utility works on the basis that they are as far removed as

possible from the building facade.

Rates. During the period of the enabling railway works the RPA should discharge the

clubs commercial rates due to Dublin City Council in recognition of the reduced value

of the premises during these works and the withdrawal of essential facilities and

amenities.

RPA indemnification. The RPA should be responsible for any damage sustained by

the club. Whether this damage relates to damage to the clubs building, the clubs

premises, personal injury to any person or any member of the club or any guest of any

member of the club or any member of staff of the club as a result of works being

carried out.

Meeting the clubs expenses incurred as a consequence of the Metro North works the

club or other businesses in the vicinity of these heavy works will inevitably loose

business as major environmental impacts, disruption, lack of amenity and consider

with inconvenience will result over a 6-year period.

The club submits that the RPA should meet

1. The costs of the club installing temporary sound and dust proofing of all the

clubs windows facing the works.

2. All mitigation measures deemed necessary on foot of the completion of the

expert reports abovementioned in particular as regards the protection of the

Lafranchini Plasterwork.

3. The cost of cleaning the clubs facade, windows, entrance area and doors at

reasonable intervals.

4. The cost incurred by the club having too engaged professional advisers to

advise the club about the impact of the works and to supervise the

implementation of the terms of the agreement between the club and the RPA.

5. All costs incurred by the club in changing its entrance.

6. Any increase in insurance premium which the club suffers as a result of works

being carried out.

7. The cost of the construction of a glass and timber acoustic facade and

8. Any other costs and expenses incurred by the club which are a direct

consequence of the Metro North works.

Independent monitoring of the building will be very important before, during and

after the works.

Given the magnitude of the works over a prolonged period of 6 years the club has set

up a project team with a responsibility for all issues arising from the Metro works.

Ray Mooney the clubs Manager is the main point of contact.

The club will have to appoint a Site Engineer for the duration of the works and

submits that the cost of the service be made by the RPA.

The submission is accompanied with Appendix 2, impact of the LUAS line BXD

works on the Stephen’s Green Hibernian Club, it deals with similar concerns as set

out in that environmental impact of the Metro North works on St. Stephen’s Green


Hibernian Club and impact of DART Underground works on St. Stephen’s Green

Hibernian Club.

Appendix 3, survey of the owners/occupiers along St. Stephen’s Green North.

Businesses in the St. Stephen’s Green area were surveyed in relation to the attitude to

DART Underground, Metro North, LUAS BXD line works and the impacts they

foresee these projects have been other businesses. A sample of the questionnaire is

also attached.

An important finding of the survey is that support for DART Underground Metro

North LUAS BXD line is strong among business owners.

55% of respondents said that they supported the work from the prospective of their

own business.

When asked to consider the work from the prospective of Dublin as a city region this

rose sharply to 79% support.

68% said that they supported the project from their own personal prospective.

55% support the project to the construction phase and this rises sharply to 79%

support for the project once it is operational.

There is a high correlation between businesses that support the project from their own

business prospective and those who support it right through construction.

85% of respondents said that the impact of the work would be negative during

construction.

40% felt it would have a positive impact after construction with 30% suggesting it

would still have a negative impact and a further 30% saying its impact would be

neutral.

This demonstrates that while business owners are generally supportive of the project

there remains some doubt as to the direct benefit it can bring to them.

A major part of the works will be the removal of private cars from the city centre.

A clear and decisive majority of 85% of respondents felt that a more southerly

alignment of the tunnel under St. Stephen’s Green itself would be preferable to the

current plan of boring under the front of the building along St. Stephen’s Green North.

There was widespread disagreement with regard to the question of compensation with

90% feeling that some form of compensation should be paid to businesses that are

threatened with closure as a result of the works.

50% of respondents consider that they will need to carry out a Comprehensive

Building Survey before the works begin.

50% of respondents expected to have to engage external advisers at an average cost of

€20,000.

Opinion was divided on whether St. Stephen’s Green could handle the peak number

of passengers of 34,000 per hour but a majority of 55% felt it would be able to do so.

On the other hand 63% felt that the area would benefit from this level of footfall.

Submission attached with Appendix 4 Engineering Impact Assessment incorporating

tunnelling impacts.

The report sets out an Engineering Assessment of the proposals as presented in the

EIS document for the DART Underground.

It is clear from this assessment that the most appropriate location for the tunnels and

works in general is away from the buildings on St. Stephen’s Green North.

Practically all of the engineering issues and risks to the buildings mitigated

significantly by moving the works away from the buildings to the locations generally

set out in Layouts 0-7.


A very significant concern that does not appear to have been properly assessed in the

documents is a large sinkhole feature within the limestone infilled with mudstone and

limestone boulders.

The Engineering Assessment details layout options 07 and layout option 8D and gives

a general commentary with respect to both on alignment, construction, dewatering,

dust, geology, ground and rock bolts, noise, repairs, rock excavation, settlement

surveying, tunnelling, vibration.

It is submitted the positioning of the tunnel under the buildings on St. Stephen’s

Green North significantly increases the risk of damage to the buildings arising from

vibration, subsidence and foundation settlement.

With respect to construction it is noted that DART Underground stations and shaft

structures will be excavated and built under concrete slabs constructed just below

ground level. However with respect to works in St. Stephen’s Green it is noted that

excavation down to rock level is to be undertaken.

Dewatering of the ground during construction could result in foundation movement

and damage to the buildings. Monitoring of groundwater levels should be carried out

for a period prior to the commencement of construction to establish natural

groundwater conditions. Monitoring should then be undertaken during and after

construction.

An appropriate condition should be attached to the planning permission if granted that

independent monitoring of air quality be carried out to ensure that appropriate levels

of air quality is consistently achieved.

The contract should be fully responsible for period cleaning of the outside of

buildings.

The contractor should also be responsible for cleaning of other parts of the buildings

in the event of air quality standards are not achieved and dust gathers in and around

the buildings.

It will be necessary to seal the windows to help protect the inside of buildings.

Limits should be put on noise exceedance.

It is important that the method of rock excavation is such that the vibrations are

reduced insofar as possible.

Independent vibration monitoring of the building will be very important.

An appropriate condition should be attached to the planning permission to control the

method of rock excavation and to restrict the noise and vibration that will be created.

The club submits that a Conservation Architectural Assessment of the building be

completed within 6 months of the date of the agreement including a specific and

detailed Risk Assessment of the impact that the works may have on the plasterworks

and agreed mitigation measures be identified and costed in consultation with the clubs

expert adviser.

Independent monitoring of the building is very important during and after the works.

The monitoring will include vibration monitoring, noise monitoring, settlement

monitoring and groundwater monitoring.

Consider that blasting is not appropriate in the St. Stephen’s Green area and asked

that blasting be prohibited by way of planning permission condition.

A protocol should be established with regard to alternatives available to the contractor

should the permissible level of vibration be exceeded.

An independent monitoring firm should be engaged to carry out all required

monitoring.


There is a risk of enhanced damage to the structure if the frequency of vibrations is

excessive.

It is clear that the statement provided in 18.3.4 of the EIS should be reconsidered in

light of the proposed construction activities.

AREA 105 - Merrion Square to the River Liffey

111. Rory Dunne, 6 Pearse Square, Dublin 2.


The observer makes recommendations in relation to a number of conditions that

should be attached to any permission granted.

CIE should sponsor a study for publication prior to commencement to compare the

depth of the proposed tunnel to those and other jurisdictions through similar soil types

under similar age structures to include severity of damage incurred.

All properties including drainage systems within Pearse Square should be subject to

full dereliction conditions study.

Vibration and noise levels during build phase should be subject to monitoring to be

publicly displayed on a live or almost live basis.

Acceptable levels of vibration should be agreed with residents during the build in

particular with any residents identified as sensitive receptors.

Disputes should be referred to an independent arbitrator who is available on a 24 hour

basis.

If vibration levels are excessive the speed of progress of the boring machines should

be reduced or work should be halted until deemed acceptable by the independent

arbitrator.

CIE should undertake to contact local doctors to attempt to identify possible sensitive

receptors, such persons are particularly vulnerable and may not appreciate direct

approaches from neighbours.

No explosives should be used in any part of the mining operation close to Pearse

Square due to the acknowledged and identified shallow foundations, delicate clay

sewage systems etc.

Any notified damage should be listed and distributed on a weekly basis to interested

parties.

CIE should offer a scheme of unlimited liability which will allow easy access to any

claimants without requiring recourse to legal action.

The compensation scheme should accept claims for a period of up to five years

following completion of the build.

The independent arbitrator should have direct input to the control over the day to day

operation of the trains.

CIE should confirm unilaterally whether they are is a prescribed organisation with

regard to planning applications, this is not entirely clear from the EIS.

Which body will oversee the enforcement? Clarification of this important issue should

be a condition.

The Board should convene an oral hearing into the proposed development.


112. Stefano Crescenzi, 8 Pearse Square, Dublin 2.














basis.



arbitrator.






sewage systems etc.


parties.







CIE should confirm unilaterally whether they are a prescribed organisation with



be a condition.


113. Federico Crescenzi, 26 Pearse Square, Dublin 2.















basis.



arbitrator.






sewage systems etc.


parties.










be a condition.


114. Eileen Dunne, 8 Pearse Square, Dublin 2.















basis.



arbitrator.






sewage systems etc.


parties.








regard to planning applications; this is not entirely clear from the EIS.


be a condition.


115. Sean Crescenzi, 7 Pearse Square, Dublin 2.














basis.



arbitrator.







sewage systems etc.


parties.










be a condition.


116. Aislinn Crescenzi, 7 Pearse Square, Dublin 2.

The contents of the observer submission can be summarised as follows:













basis.



arbitrator.


receptors; such persons are particularly vulnerable and may not appreciate direct




sewage systems etc.



parties.










be a condition.


117. Barbara Dawson, 44 Pearse Square, Dublin 2.














basis.



arbitrator.






sewage systems etc.


parties.











be a condition.


118. Timothy Lynch, 51 Pearse Square, Dublin 2.














basis.



arbitrator.






sewage systems etc.


parties.










be a condition.



119. Mark Kelly, 15 Pearse Square, Dublin 2.














basis.



arbitrator.






sewage systems etc.


parties.










be a condition.


120. Patrick Sherwin, 33 Pearse Square, Dublin 2.















basis.



arbitrator.






sewage systems etc.


parties.










be a condition.


End of terrace houses would be more susceptible to damage.

The houses were built on sand.

121. David Hughes, 35 Upper Erne Street, Dublin 2.


The submission complements the submission by Carmel McCormack.

The observer is directly affected by the proposal and are included in the Dart

underground Book of Reference Third Schedule.

The observer’s professional background is quite unusual and highly relevant to the

nature of the application.

The observer is a senior architect and project manager with Iarnrod Eireann.

He has worked with Iarnrod Eireann since 1992.


He has worked on many different railway station designs and rail order submissions

with the company to date.

The observer participates in an international group of railway architects, engineers

and designers known as the Watford Group.

The Watford Group brings together designers and thinkers specific to heavy railway

infrastructure from Asia to the Middle East virtually all European countries and the

USA. Last year’s Watford Group conference theme was particularly relevant to this

rail order application and dealt with the difficulties of predicting passenger numbers

and the chicken and egg question of which comes first, the alignment or the stations.

Having exposure to the key projects and thinking international is key to benefiting

from the experience of others and hopefully avoiding making the same mistakes.

In his career with Iarnrod Eireann the observer has won many awards for his railway

projects including awards from the RIAI, the AAI, Plan, CIF and Opus Awards

Nationally.

An early design of his has recently been added to the Record of Protected Structures

making it one of the youngest in the country and the recent railway building to be

added to the RPS.

The observer is also responsible for Ireland’s first and to date only Brunel Award, the

highest distinction possible for railway design.

In addition to being an architect the observer holds a qualification in project

management from the RIBA and is also an RIAI accredited conservation architect.

The observer has been distinguished in the area’s sustainable and low energy design

and is active as project supervisor design phase and process on railway projects.

The observer feels his background qualifies him to make many of the comments and

recommendations on the shortcomings of the project and possible alternatives which

would remedy those shortcomings.

In addition to his professional background he is a long time resident of Upper Erne

Street.

The observer strongly objects to provision of a station at Sandwith Street Upper and

Boyne Street.

The provision of a station at this location is not consistent with the proper planning

and sustainable development of the area.

The EIS has totally failed to address the very real impact the proposed development

would have on him and the residential amenity of his family home and the residential

amenity of the entire terrace at Nos. 29 to 35 Upper Erne Street.

The Pearse Dart underground station will not serve the very passengers it is intended

for.

The lodging of the rail order at the start of June whether deliberate or not has had the

effect of getting specialist advice such as legal counsel and other expert advice more

difficult.

When the SID process comes up for review the observer requests that the Board

points out to the department that the period for public consultation is too compressed.


The applicant for the rail order has failed to take into account or to understand the

special nature of the site for Pearse Dart underground.

The conclusions drawn in the EIS are incorrect or fail to address the key

environmental impacts completely or satisfactorily.


The applicant did not carry out a proper consultation prior to the lodging of the

railway order.

The applicant has excluded key points and parts of information on either the grounds

of commercial or privileged sensitivity.

The applicant has ignored the unique residential nature and character of the terrace

from Nos. 29 to 35 Upper Erne Street.

The applicant has ignored the largely residential nature and small scale of the street

and footpath network in the immediate vicinity of the station.

The applicant has ignored the age and nature of construction of Nos. 29-35 Upper

Erne Street which are late Georgian / early Victorian period houses founded on

reclaimed land.

The destruction of the residential amenity of No. 35 Upper Erne Street in particular of

a continuous queuing and loading of dumper trucks to remove the spoil from the

excavation.

The removal of access to the off-street parking space.

The removal of pedestrian access to the rear of No. 35 Upper Erne Street.

The applicant clearly intends to develop an air rights development over the station but

has given little or no information about the nature and extent of the development.

The applicant has failed to follow the advice given in a serious of pre-consultation

meetings with the Board in relation to the contents of the application particularly with

regard to Sandwith Street/Boyne Street option in terms of the length of the connection

for passengers and the extent of the future air rights development.

The EIS is unbalanced in its treatment of different issues.

The applicant has failed to stipulate up front acceptable standards from many aspects

of the construction phase in effect leaving it to the Board to attach conditions which

will govern aspects such as noise, dust and vibration, nuisance and the erosion of

amenity.

The applicant has favoured an optimal track alignment over putting the stations where

the desire lines and the most efficient interchange with the above ground station can

occur.

The net effect of this will be that Dart passengers interchanging at Pearse will be

forced to “walk around the world once a week” due to the elongated connection

between the two stations.

There is no provision for non-negligence insurance, a type of insurance which ensures

that even where negligence is shown but damage has occurred that the necessary

funds are in place to pay for damage to adjoining properties.

The attempt to limit the property damage payments to €30,000 vastly underestimates

the potential damage that could occur to a property in a residential conservation area.

In Metro schemes in Holland in spite of best efforts entire houses have subsided and

effectively caved in to the tunnel below.

The use of the PPP Procurement Process and the problems it can potentially generate

was highlighted in the pre-consultations with the Board.

The EIS does not adequately deal with how this relationship will be effectively

managed.

The section on noise in the EIS seems more concerned with hearing impairment than

the nuisance noise can bring about.

The drawings included with the rail order do not have basic information like

dimensions and levels.


In spite of having a rail siding alongside the construction site the applicant proposed

to remove all of the spoil via road using trucks which will be used outside peak hours.

No other location has such a direct juxtaposing of a construction site with residential

use separated only by a garden wall.

The presence of a tunnel below or in proximity to the observer’s home will preclude

him from using geothermal or ground source heat as illustrated in a planning

application he made for his home in 2008.

The EIS claims there will be no residual impacts post construction and during the

operation of the station.

Pedestrian flows are a very significant post construction residual effect.

The impact of this pedestrian traffic has not been adequately modelled in the EIS.

The levels of service (LOS) being predicted represent a huge increase in the number

of pedestrians using Upper Erne Street and Boyne Street.

The fact that the Dart underground at Pearse is the only interchange between the two

Dart lines means that many people will exit at the Dart underground station rather

than try to interchange between the lines as the length and the level changes involved

in interchanging would take longer than the time it would take to walk particularly

when combined with the waiting time for a train at the next part of the journey.

The completion of a single-storey building in a pivotal city centre site will be too

much temptation not to develop.

Which comes first the railway or the station? The alignment or the best location for

the station?

With reference to various reports by Parsons Brinkerhof, Arup Engineers and Mott

McDonald it seems amazing that across all three reports none recommend a station in

its present location on the corner of Sandwith Street and Boyne Street.

The Pearse Interchange will be the only interchange between the two Dart lines, lines

which are heavy rail mass transit lines capable of carrying up to 1,400 people per train

in up to 16 trains per direction per hour.

In the morning and afternoon peaks up to 20,000 every day will be forced to walk an

additional 200 metres twice a day to make a “direct” connection at the only point the

two Dart lines meet.

The choice of Sandwith Street location is purely an expedient or opportunistic use of

an underused site in the vicinity of the station.

Stations should be put where they are most wanted and needed and not put just where

we can fit them in.

The observer proposes a real and viable alternative to the proposed station location at

Pearse. The observer proposes a station beneath Cumberland House on Fenian Street.

The deviations sought within the rail order are quite significant.

None of the drawings furnished with the application illustrate the full extent of the

potential area that the alignment and the stations may occupy.

No levels are given in the cross-sections.

The observer will be living in a mining operation not for weeks or months but for

years.

Nowhere in the EIS are the effects of the trucks movements and the associated noise

and disruption dealt with in a meaningful way.

Where is the analysis of the diesel fumes they will produce and their associated

pollutants?

An alternative to removing the spoil by truck is to remove the spoil by rail.


The Board is requested to direct the applicant to provide a plan illustrating how spoil

can be removed via the surface railway.

A second option is if stations could be mined from underneath and any spoil can be

taken away via the bored tunnel route.

No other station entry/exits are located in a residential area.

If the rail order is granted do the Board have any powers to adjudicate on whether in

their opinion it is reasonable to expect people to live adjacent to what is in effect an

open mining operation?

The EIS deals with sound in a most peculiar way. The observer attaches a report from

Mr. Karl Searson in relation to sound.

CIE plan to build the interconnector tunnel and all of the Dart underground stations by

means of a PPP Process. This has enormous implications for the completeness and

robustness of the EIS and rail order documentation in this application.

Effectively the standards and any conditions attaching to the grant of a rail order for

this development will be the backstop in terms of what the contractors held to account

for in executing the work.

Once this project is awarded it will be up to the contractor to develop the designs for

the stations from the reference design and the rail order and the design of the entire

civil, structural, mechanical and electrical works in a similar fashion.

The location of the vent shaft proximate to the west wall of Nos. 29 to 35 Erne

Terrace exasperates the residual effect of the development on the terrace.

122. Residents of Upper Erne Street, c/o David Hughes, 35 Upper Erne Street,

Dublin 2.


The observers request an oral hearing.

The observers are concerned about potential structural damage to their properties

from dewatering, changes to the water table, potential subsidence etc., both during

and after the construction phase.

The houses on the residential conservation terrace of Upper Erne Street were built on

reclaimed land from the sea and were built without modern foundations.

The tidal water table is very close to ground level and as yet has posed no problems

but the proposed development could alter drastically the water table and have serious

consequences in relation to potential ingress of water to the observers’ properties.

The observers would like to see calculations of the impact of such a deep excavation

for this station on the tidal water table in light of the accumulated impact on the water

table from other recent developments in the area many of which included basement

construction.

The observers are concerned about any rising damp, flooding or subsidence due to

displaced tidal water and sediment deposits.

The observers ask the Board to put in place firm measures to protect their residential

conservation properties from any structural damage.

The proposed property scheme offers inadequate cover.

This is like giving the contractor licence to do untold damage.

It can be very difficult to successfully repair damage to historical properties.


The observers request that a bond is put in place to cover any damage to property

during or for a reasonable period of at least 5 to 10 years after construction and during

the operation of the station.

The observers ask for non-negligence insurance to be put in place to cover problems

which may arise during construction or after completion of the works.

The observers request that their rear Dalkey granite wall be protected and that it will

not from any misreading of any drawings or other error be included in any demolition

work.

The observers are concerned about general disturbance during the construction period

which has a timescale of 5 years minimum and perhaps 10 years in total.

In general the observers are concerned about the noise, vibrations, dust, fumes, loss of

residential amenity etc.

The observers request that the spoil be located onto a covered travelator type ramp

and emptied onto goods wagons to be located up on the railway track between the

Upper Erne Street and Sandwith Street railway bridges where there is a spare track

and that the spoil is taken away by rail.

A wheel-washing system should be put in place to keep down dirt and dust and the

spoil and other materials and all trucks be properly covered.

The observers request that the length of time of continuous boring be reduced to 8

hours at any one time and only allowed during the day and that any percussion piling

be strictly prohibited in a residential area.

The observers are concerned about the operation of an unmanned station.

The observers are concerned about the disruptive nature of a huge influx of transient

commuters into a well-established yet balanced residential inner city community.

Full time manned security should be provided on the Pearse Dart underground station.

The observers question who will be responsible for general maintenance and cleaning

and running of the stations and for the security of the stations.

The observers are concerned about excessive noise levels, vibrations and fumes from

the station complex itself.

In terms of noise alone are the observers going to hear trains underground passing by?

Will these trains vibrate their property?

Are they going to hear constant train announcements?

Residents of Upper Erne Street in addition to being subject to potential negative

impacts from tunnelling will also be subject to potential negative impacts from an

adjacent open mine/deep excavation site.

It is simply inhumane to expect anyone to live more or less on such a building site for

upwards of 5 years.

The observers seriously object to the widening of the footpath in front of Upper Erne

Street and the subsequent loss removal of their on-street parking.

The observers object to any increase in traffic being diverted up Upper Erne Street.

At the time that the noise monitoring was carried out the Dart underground were

drilling test piles in the site to the rear and the Trinity Bio-Science building nearby

was under construction. The observers therefore argue that the noise tests are

incorrect.

A request is made for a high quality replacement granite slab path which respects the

existing footpath levels, granite doorsteps, granite garden edging, the existing gradient

for good water drainage and that the existing granite kerbing be reinstated.

The proposed station entrance design is lacking in imagination and vision.


The underground passage connection between Pearse underground and Pearse over-

ground stations is far too long.

The proposed underground station is located in a historical residential conservation

area.

Cumberland House site is a more viable and a more civic site location for the

proposed station.

The observers are concerned about any potential health risk from chemical blasting,

dust, noise pollution and undue disturbance of residents’ sleep.

They are concerned about the length of construction works hours.

It is hard to believe that the EIS says that there will be no significant environmental

impact on local residents.

The observers are concerned about future development of the air rights overhead.

They are concerned about the scale and height of any future development permitted

over the new Pearse underground railway station.

The new Pearse underground station has the potential to become one of the busiest

stations in Dublin where two railway lines intersect.

There was a lack of consultation with the residents of Upper Erne Street.

The observers request that during construction and then during the operation of the

station that local residents be given a contact number and an out of hours contact

number with a member of CIE staff with experience and the authority to deal with any

problems which may arise.

The observers are concerned with respect to rodent infestations.

The observers are concerned about any disruption to services during the construction

phase.

The proposed station development is likely to immediately lower the value of their

properties.

There could be potential security problems and stations can lower the whole tone of a

neighbourhood if poorly designed and poorly managed.

The proposed acquisition of substrata and its negative impact on the value and future

development potential of their properties.

The proposal by CIE to permanently acquire part of the substratum beneath the

observers’ properties has serious consequences for the type of title of their property

and for the present and future value of their property and its present and future use.

123. Carmel McCormack, 35 Upper Erne Street, Dublin 2.



The Pearse Dart underground station is adjacent to a historical residential

conservation area in a very well established residential community.

Where in the world are there examples of similar stations/transport hubs in terms of

scale, design and projected passenger numbers located in a residential conservation

area?

Cumberland House site is a more viable and a more civic site location.

The project is flawed from the start in terms of its incredibly bad urban planning due

to poor site location and is lacking in imagination and creative intelligence solutions.


Whatever happened to the idea of using the existing line which runs through the

Phoenix Park for the Dart underground?

The observer is concerned about any potential structural damage to her property,

dewatering, changes to the water table, potential subsidence etc., both during and after

construction.

The houses on the residential conservation terrace of Upper Erne Street were built in

reclaimed land from the sea and were built without modern conventional foundations.

The tidal water table is very close to ground level and as yet has posed no problems

but this proposed development could alter drastically the water table and have serious

consequences in relation to potential ingress of water to her property and ground

disturbance causing potential subsidence.

The cumulative impact of the deep excavation associated with this development

should be considered in the context of other recent developments in the area.

The water table is very near the surface.

The property protection scheme of €30,000 is completely inadequate cover.

This is like giving the contractor licence to do untold damage.

In the likelihood of having to rectify any damage €30,000 would hardly cover the cost

of hiring a good conservation architect, engineers, quantity surveyor, loss adjustor and

legal fees etc.

The observer asks for non-negligence insurance to be put in place to cover problems

which may arise during construction or after completion of the works.

The observer requests that the rear Dalkey granite wall will be protected during the

construction.

The observers concerned about the disturbance during construction and the period for

which this disturbance is likely to last.

The observer is concerned about the noise, vibrations, dust, fumes and loss of

residential amenity.

The observer has concerns relating to the trucks taking away spoil, these concerns

relate to noise, vibrations, fumes and dust.

The observer requests that the construction site entrance and construction site

compound be relocated away from No. 35 Upper Erne Street to a less sensitive part of

the site.

The observer requests that the spoil be taken away by rail.

A wheel-washing process must be put in place on the site.

The observer requests that the length of time of continuous boring be reduced to 8

hours at any one time.

Percussion piling should be strictly prohibited in a residential area.

The observer is concerned about the operation of an “unmanned” station.

In relation to the operating of the station under a PPP process the observer questions

who will ultimately be responsible for general maintenance and cleaning and running

of the stations and for the security at the station?

The observer is concerned about excessive noise levels, vibrations and fumes from the

station complex when it is in operation.

What is it going to be like living next door to an underground railway station?

In terms of noise alone are the observers going to hear trains underground passing by?

Will they vibrate the observer’s property?


No. 35 Upper Erne Street will be more noticeably affected by the proposed

development immediately adjacent to the proposed construction site entrance and

construction site compound and eventually the maintenance service/access for the

station and the Boyne Street pedestrian entrance/exit to the new Pearse underground

station.

There are plans to develop the air rights overhead so that could entail another five

years construction.

The proposed development will completely devalue the observer’s property.

It is simply inhumane to expect anyone to live more or less on a building site for

upwards of five years.

The observer lives and works from home, she is also a writer.

The observer’s vehicle access/pedestrian side entrance is at the end of the terrace on

Boyne Street.

Blocking this access will interfere with any plans the observers may have to maintain,

renovate and redevelop their property. The observer seriously objects to any

restriction or obstruction to their private vehicle access/off-street parking.

The observer also seriously objects to the widening of the footpath and the subsequent

loss/removal of on-street parking on Upper Erne Street.

Concerns are also expressed relating to the proposed removal of on-street parking on

Boyne Street.

The observer objects to any increase in traffic being diverted down Upper Erne Street.

The noise tests were rigged and are flawed and incorrect.

A request is made for a high quality replacement granite slab path which respects

existing footpath levels, granite doorsteps, granite garden edging and the existing

gradient of fall for run-off water and good drainage and that the existing granite

kerbing be reinstated.

The entrance design of the proposed underground station is lacking in imagination

and vision.

The underground passage connection between Pearse underground station and the

exit/entrance of Pearse Street and Westland Row is far too long.

The ground conditions at this location are less than ideal for excavation.

Rock was hit quite soon and the water table which is tidal is very near the surface.

The rock has to be chemically blasted out for at least 3 years.

The observers concerned about potential health risks from chemical blasting, dust,

noise, associated stress etc.

The observer is concerned about the proposed permitted hours of construction, the

observer requests that the hours of construction be limited to the normal daily

working hours.

The observer finds it hard to believe that the EIS says that there will be no significant

environmental impact on local residents.

The observer is concerned about the scale and height of any future development

permitted over the new Pearse underground railway station. The observer feels that

the finally presented predicted numbers to use this station have been seriously

underestimated.

The observer’s personal experience in the public consultation process has been a very

bad one.

The observer has found her dealings with Irish Rail very frustrating.


The observer requests that during construction and operation of the station that local

residents be given an out of hours contact number of CIE staff with the experience

and the authority to deal with any problems which may arise.

Concern is raised in relation to rodent infestations.

Concern is raised in relation to the clay sewage pipes that run in the back gardens.

How does the design of this station take into account global warming and the

predicted future rise in the water table and associated flooding which could have

consequences to the proper operation of the station?

Concerns raised in relation to litter generated in the area from the proposed

development.

The observer totally disagrees with CIE putting a nil valuation on their substratum.

The observer will no longer own the ground below the property and will probably be

restricted by CIE from carrying out any works below ground.

124. Marie Mackey, 32 Upper Erne Street, Pearse Street, Dublin 2.


The proposed Dart is virtually on top of the observer’s house and will make life

intolerable.

The observer is asking the Board to refuse the order.

The 7-10 year construction underneath the house will create an absolute appalling

level of dirt, dust and noise.

The foundations of the house will be shaken to the core.

It is hard to imagine expecting any human being to endure such behaviour.

The value of the observer’s house will also be affected as there most certainly will be

damage done to the house.

The observer is concerned about the removal of the on-street parking.

The observer finds the station location in a residential area totally unacceptable.

The compensation scheme is not adequate.


125. Michael Keegan, 35 Upper Leeson Street, Dublin 4.


One of the observer’s sons resides at 33 Upper Erne Street, Dublin 2.

The residents of Erne Street should not have the enjoyment of their houses diminished

in any way due to the development.

Concerns raised in relation to the loss of on-street parking.

If this is a public private partnership development an insurance bond must be

purchased to cover the period of the development and for an appropriate period after

its completion.

The developers or the state must make good any damage caused by the development

and its subsequent operation (subsidence).


There must be an agreement at the outset that there will be no further development on

the site and the height for access to the station is kept to a minimum.

The noise from the venting shaft should be minimal and the shaft invisible.

The proposed station should be nearer to the existing railway station, it should be

immediately below it.


126. Edith MacGarry and Damien MacGarry, 196 Rathfarnham Road, Dublin

14.


The observers own no. 34 Erne Street Upper, Dublin 2.


The proposed Pearse Street Station is immediately behind the observers’ property.

The underground lines will have a serious impact on the observers’ house.

The EIS does not address the residential properties in Erne Street Upper.

The focus of the EIS is on heritage areas of the city such as St. Stephen’s Green,

Christchurch, Cook Street etc. and does not adequately address other areas.

A curtailment of parking on Erne Street Upper would impact on residential parking

permits in the area.

The application documentation does not explain the right of way been sought at the

main junction or the long term changes to traffic patterns.

24 hour working underground adjacent to residential buildings will impact on the

quality of life of local people over a minimum period of five years.

Overground noise and vibrations underground will combine to provide a serious

nuisance.

No. 34 Erne Street Upper is part of the lovely terrace built in circa 1860. One house

in the terrace had been restored or conserved in a sympathetic way.

The houses were built on river silt been so close to the River Liffey. The ground is

soft and wet.

As the ground is soft under the house the observers are extremely anxious about the

impact of underground drilling/boring on the fabric of the terrace in general.

Even if the houses survive the works the water table in the immediate vicinity will

change and the observers could have longer term problems.

The observers took their own noise levels and they are included with the observers’

submission.

The Dart underground property protection scheme is insufficient.

This amount should be increased to €50,000, it is acknowledged that property owners

have the right to pursue for damages in the normal manner.

127. Una O’Kane, 29 Boyne Street, Dublin 2.



Major building works are proposed to the front, below and behind the observer’s

dwelling.

The building works will last for a period of 6.3 years and will have a great impact on

the amenities the observer has enjoyed at her premises for the last 10 years.

Six weeks is too little to determine the impact of construction, settlement, vibration,

noise, dust, dirt, traffic, parking and working hours in relation to the impact of such a

major development on a residential area. The observer requests An Bord Pleanala to

extend this time.

There is no clarity in the EIS to show the effects of vibrations and settlement on the

observer’s dwelling and the impact of blasting, tunnelling and station construction.

The observer is financially dependent on her tenants.

It would appear that a truck will pass by her tenant’s bedroom window every minute

and a half.

The applicant should consider the use of alternative methods including rail to lessen

the impact of construction traffic.

Conditions should be introduced to reduce the air borne and ground borne noise

impact on her residents, including better and higher hoarding and limits of noisy

vehicles and construction machinery.

More research noise models and surveys should be carried out to determine the likely

impact on the observer’s house of both the noise emanating from construction and the

noise emanating at operational stage.

Noise screening should be employed in the works.

Street paths and street furniture should be cleaned and hosed.

All adjacent residents’ windows should be regularly cleaned.

Working hours at upper ground level should be similar to those hours normally laid

down as a condition of Dublin City Council area and not as those suggested in the

EIS.

The reduction in car parking spaces during construction and permanently afterwards

will probably occur in front of the observer’s house and this is not clearly shown in

the EIS.

An Bord Pleanala should condition adequate parking for residents during and after the

construction stage.

It would appear that many of the surrounding streets including Boyne Street would be

closed and it is not clear in the EIS how this will be programmed to ensure that access

is available to residents at all times.

There should be no cap of €30,000 in the proposed property protection scheme.

There should be a well managed community liaison plan specifically for the area

around the proposed Pearse Street station to ensure that there is minimal impact on the

amenities enjoyed by the residents.

The operational effect of the completed project is difficult to determine and the EIS

should give some idea of the future pedestrian vehicular and bicycle traffic and its

impact on adjoining streets and footpaths.

128. Patricia Ford, Boyne Street Residents, 26 Boyne Street, Off Westland

Row, Dublin 2.



The observers request that the Dart underground project contact Dublin City Council

and have the ‘no right turn’ at Erne Street removed for the duration of the works to

allow the observers gain access to their homes and for emergency services to gain

access to their complex.

The demolition of Eircom car park and mosaic assemblers will cause a lot of extra dirt

and dust in the area. The observers request that the demolition site be cleared on a

daily basis and that the area is cleaned daily.

The observers request that the working hours are set at the standard working hours for

all construction sites.

This is a residential area and working hours outside these hours will affect the

residents in this area.

The observers are objecting to the hoarding been erected on Sandwith Street for the

duration of the works, there are six flats directly opposite the Eircom car park.

When the hoarding is erected there will be no light at all coming into the residents

homes.

There are a lot of elderly residents in Boyne Street and Sandwith Street, Irish Rail has

not taken this into account.

The observers have concerns relating to rodent infestation caused by the proposed

works.

Boyne Street is a small residential area and the observers will now have to deal with

lorries removing the rubble from the site, the observer’s request that all lorries exit

from Bass Place via Sandwith Street and that the roads are cleaned and washed on a

daily basis.

It is a concern to the observers that an ESB generator/sub-station is being built in

South Cumberland Street and that this sub-station/generator will be used to supply

electricity to the Dart underground.

The submission has four signatories.

129. Brenda Reilly, Boyne Street Residents Group, 8B Boyne Street off

Westland Road, Dublin 2.


The observers request that a special committee be set up involving the residents and

other stakeholders to engage with all those involved in this project so as to be

informed of all the events so as to ensure proper communications and the enjoyment

of their homes and environment.

The observers request that all information concerning community funds and

community gain projects that are associated with Dart underground and this railway

order be made available to the community representative in an open and transparent

manner.

The observers request that a proper channel of complaint and enquiry be set up and

that a time line of response be arranged.

The observers request that the Dart underground project contact Dublin City Council

and have the ‘no right turn’ at Erne Street removed for the duration of the works to


allow the observers gain access to their homes and for emergency services to gain

access to their complex.

The demolition of Eircom car park and mosaic assemblers will cause a lot of extra dirt

and dust in the area. The observers request that the demolition site be cleared on a

daily basis and that the area is cleaned daily.

The observers request that the working hours are set at the standard working hours for

all construction sites.

This is a residential area and working hours outside these hours will affect the

residents in this area.

The observers are objecting to the hoarding been erected on Sandwith Street for the

duration of the works, there are six flats directly opposite the Eircom car park.

When the hoarding is erected there will be no light at all coming into the residents

homes.

There are a lot of elderly residents in Boyne Street and Sandwith Street, Irish Rail has

not taken this into account.

The observers have concerns relating to rodent infestation caused by the proposed

works.

Boyne Street is a small residential area and the observers will now have to deal with

lorries removing the rubble from the site, the observer’s request that all lorries exit

from Bass Place via Sandwith Street and that the roads are cleaned and washed on a

daily basis.

It is a concern to the observers that an ESB generator/sub-station is being built in

South Cumberland Street and that this sub-station/generator will be used to supply

electricity to the Dart underground.

The submission has a number of signatories.

130. Joan Coburn, 31 Boyne Street, Dublin 2.


The observer’s dwelling was erected in 1908.

The proposed building works will take place immediately behind the house.

This involves the demolition of all the properties on Bass Place which adjoin the

entire western boundary of the observer’s home.

Hoarding will be erected immediately adjacent to the observer’s home and will have a

height of 8-10 feet.

The observer raises concerns relating to construction traffic levels.

The observer has a health issue and does not want to be subjected to on-going periods

when there will be large concentrations of dust in the atmosphere.

The observer does not wish to be subjected to the stress and inconvenience which will

undoubtedly be a by-product of the works.

The amount of construction traffic is very intense and undoubtedly will cause damage

to the observer’s home.

The carrying out of these construction works will adversely impact on the quality of

the lives of the residents in the area.

Concerns raised over noise from general construction works.

Proposed working hours are not fair or reasonable.


The works will impact greatly on both light levels and air quality during construction.

Access to the observer’s property will be greatly inhibited during the works.

Concerns over impact on privacy of the observer’s home.

When the works are completed there will be approximately 15-20 train journeys per

hour passing directly underneath the property.

There will be a huge increase in the volume of people using the Sandwith Street

entrance.

There will be a great reduction in privacy enjoyed by the residents on Boyne Street

arising from the proposed station.

Nobody has explained to the observer how the issue of noise pollution from the

ventilation shaft fans will be dealt with.

The Board is requested to reject CIE’s proposal.

131. Geraldine Byrne, Sandwith Street Residents, 5 Sandwith Street Upper,

Dublin 2.


The observers formerly request an oral hearing.

The proposed project will have a massive impact on residents both during the

construction phase and when operational.

In recent years this community has seen massive developments taken place around

them and have suffered from impacts.

Despite imposed conditions and promises of “best practice” residents have been

subjected to unacceptable consequences from prolonged working hours, noise, dust

and dirt, vibrations and excessive and poorly planned traffic movements.

It is essential that these past experiences are not repeated.

Any grant of permission must be water tight and leave no room for manoeuvre or

backtracking in relation to monitoring mitigation and protected measures.

An accessible and effective regime of enforcement must be in place.

A channel of communication must be in place for residents to address difficulties and

concerns that may arise.

The proposed working hours are excessive and will involve a huge disruption to

residents in Sandwith Street.

The number of vehicle movements per day is excessive for a built up residential area.

The majority of roads in the vicinity are subject to the HGV restrictions and such

volumes proposed during construction would be a major reversal of this effective

strategy.

The proposed closure of Sandwith Street to cars during the construction phase to

facilitate HGV vehicle movements will severely restrict residents’ access to their

homes.

There will be considerable noise during the construction phase and best practice

methods noise reduction and mitigation measures and regular monitoring are

essential.

Vibration and noise levels during built phase should be subject to constant monitoring

to be publicly displayed on a live or almost live basis example on the internet.




In relation to dust generated best practice method reduction mitigation measures and

regular monitoring are essential.

An agreed programme of window cleaning and car wash may be appropriate for

adjoining streets.

There will be considerable dirt associated with the works.

High intensity lighting on the site must be positioned and operated in such a way as to

cause minimum disruption to adjacent households.

The observers have concerns in relation to the compensation scheme being offered.

CIE is a public body and as the commissioning authority of this project should offer a

scheme of unlimited liability.

The proposed limitations whereby any claims must be submitted within 12 months of

completion of the build is unfair and unacceptable.

Settlement which can cause subsidence can occur some years following completion of

the works.

The observers note with great concern that the EIS does not consider the operational

phase of the Dart tunnel.

Residents in Sandwith Street have for a number of years had cause to complain with

regard to on-going maintenance of the railway line directly adjacent to their homes.

The proposed widening of the footpath directly outside the six residential units in

Sandwith Street and the resulting increased footfall would undoubtedly have a hugely

negative impact on resident’s privacy and access.

Concern with respect to the loss of residential parking spaces.

There are eight signatories to the submission all from Sandwith Street Upper.

132. Melanie Woods, St. Andrews Court 1-16 Residents Group, 15 St.

Andrews Court, Fenian Street, Dublin 2.


An oral hearing is essential.

The proposed project will have a massive impact on residents both during the

construction phase and when operational.

Any grant of permission must be watertight and leave no room for manoeuvre or

backtracking in relation to monitoring mitigation and protection measures.

An accessible and effective regime of enforcement must be put in place.

A channel of communication must be put in place for residents to address difficulties

and concerns that may arise.

The proposed working hours are excessive.

The number of vehicular movements per day is excessive for a built up residential

area.


methods noise reduction mitigation measures and regular monitoring are essential.

Vibration and noise levels during built phase should be subject to constant monitoring

to be publicly splayed on a live or almost live basis.




In relation to dust generated at the site best practice methods reduction and mitigation

measures and regular monitoring are essential.

An agreed programme of window cleaning and car wash allowances may be

appropriate for adjoining streets.


Where high intensity lighting is being uses this must be positioned and operated in

such a way as to cause minimum disruption to adjacent householders.

The cumulative impact on the water table from the unprecedented level of

developments in the broader docklands must be considered.

There is anecdotal evidence of a rise in water level as suggested by flooding of

gardens very quickly during bouts of heavy rain.

An agreed structure in the form of committee/liaison/monitoring group would be of

benefit to all parties.

A clearly defined accessible and effective method of addressing problems is essential

for residents.

At the end of the construction phase it would be expected that the visual impact of all

railway lands would be acceptable to residents which are subject to its appearance

everyday.

The proposed compensation scheme is extremely unfair and unacceptable.

CIE is a public body and as the commissioning authority of this project should offer a

scheme of unlimited liability.

The proposed limitation whereby any claims must be submitted within 12 months of

completion of the build is unfair and unacceptable. Settlement which can cause

subsidence can occur some years following completion of the works.

The observers note that the EIS does not consider the operational phase of the Dart

underground.

CIE should confirm unilaterally whether it is a prescribed organisation in regard to

planning application and the legal status of any conditions must be clarified.

The observers have significant concerns regarding the proximity of the ventilation

shaft so close to their homes.

133. Paul Mangan, Trinity College Dublin, Director of Buildings Office, West

Chapel, Trinity College, Dublin 2.


TCD confirms support in principle for the proposed scheme.

It is noted that the new station and tunnel at Pearse Street is to be located within 50-60

metres of the Trinity bio-sciences institute on Pearse Street.

There is also to be a connection tunnel to the existing Pearse Station below

ground/existing vaults located approximately 25 metres away from and running 40

metres in parallel to the institute.

Of most concern to the observer is the impact of the underground construction works

of the connection tunnel on the institute’s activities and the building structure.

This institute building is a seven-storey structure over a three-storey basement.


The main activity of the institute is bio-medical teaching and research with a bio

resources facility.

This facility includes the breeding and storage of animals within the institute on level

B3 (third basement level).

Most notably of concern to the observer are the impacts of the vibrations from both

underground construction works (drilling, boring, blasting, excavation etc.) and from

the operation of the railway itself on the various activities within the Bio resources

building.

The sensitive machines and operation on a level B3 include an MMR machine and

two x-ray machines.

The observer is concerned that vibrations experienced in this structure of the building

will impact on the sensitive calibration of these machines.

The animals within the bio resources on a level B3 require a stable living environment

and any changes in their environment will cause disruption to their habitats and

breeding patterns which the activities of the institution largely depend on.

The observer is concerned about the impact of the underground works on the

structural integrity of the secant piling structure of the basement.

The underground works may cause vibrations/unsettling in the conditions below

ground and this may in turn impact on the secant piling structure of the institute.

The observer has discussed TCD concerns with Arup for the applicant and they have

undertaken to take account of these concerns in developing the project.

The observer requires that Iarnrod Eireann take measures in construction/operation of

the railway that will ensure that sensitive research work in the bio-science institute

will not be compromised.

It is requested that within the railway order Iarnrod Eireann is directed to reduce,

minimise or avoid disruption of the activities in the institute.

The observer requires that Iarnrod Eireann liaise with TCD in relation to the impacts

of their works on TCD’s three-storey basement and activities held therein.

134. Petra McDonnell, 28 Pearse Square, Dublin 2.














basis.




arbitrator.






sewage systems etc.


parties.










be a condition.


135. Noel Ryan, Romara, White Cross, Bray Road, Foxrock, Dublin.














basis.



arbitrator.







sewage systems etc.


parties.










be a condition.


CIE should confirm that the development will have no adverse effect on the

development of the observer’s site at Pearse Square, Hanover Street East including

the development of an underground car park.

136. Tom Bailey and Caroline Bailey, Culcommon, Batterstown, County

Meath.

The contents of the observer submission on behalf of the above as prepared by Brian Meehan

and Associates, Planning and Development Consultants, can be summarised as follows:

The observers are the owners of lands at Dunlow Hall, 25-29 Merion Street, Dublin 2

Lands beneath Dunlow Hall, 25-29 Merion Street will be required to facilitate the

Dart underground project.

The observers’ primary concern relates to the potential negative impact on residential

amenity arising from the proposed works on the longer term impact on the structural

integrity of their lands at Dunlow Hall, Merion Street.

It is considered that the proposal to undertake construction works on a 24 hour basis

in relation to the proposed tunnelling is excessive and significantly increases the

potential for adverse impact on residential amenity.

The potential impact on the integrity of structures above the proposed 2 no. tunnels

should be carefully considered and sufficient measures should be taken to protect

residences.

It is submitted that appropriate measures should be taken to inform residents of the

likely period of a current of ground noise and vibration as a means of minimising

adverse impact on residential amenity.

In addition the Property Protection Scheme devised by CIE should provide for

increased monitoring of the structural integrity of properties during the relevant

period of intense ground noise and vibration.

The Board is requested to carefully consider the observers’ concerns in relation to the

potential impact of the proposed development on existing residential amenity and the

long term structure integrity of the structure at Dunlow Hall, 25-29 Merion Street.


137. Irish Prison Officers Association, c/o DBFL Consultant Engineers,

Herbert House, Harmony Row, Dublin 2.

The contents of the observer submission on behalf of the Irish Prison Officers Association

can be summarised as follows:

The Irish Prison Officers Association own property at No. 18 Merrion Square North,

Dublin 2.

The Irish Prison Officers Association are the owners and occupiers at No. 18 Merrion

Square North and No. 18 Denzille Lane, (the mews property at the rear of No. 18

Merrion Square).

It is understood that it is proposed that the substratum of land underneath the portion

of the above mentioned property is to be required for the purposes of the construction

of the Dart underground and that the value of each substratum is to be set at nil.

The value of this sub structure should not be set to nil.

The site is located within the business district of Dublin city centre and is prime for

future development.

The acquisition of the substratum limits the future potential development of the lands

No. 18 Denzille Lane.

The acquisition thereby reduces the market value of the lands at No. 18 Denzille

Lane.

In the event of the redevelopment of No. 18 Denzille Lane deep foundation, deep

basements and foundation piling options would not be allowed thereby reducing the

potential development floor area, height and basement construction options on the

site.

The possibility of introducing deep boreholes for the production of geo thermal

energy will not be possible on the overall site. The observers will be making

application to the Dart underground and the property protection scheme programme.

Given the nature and location of the properties the observers consider that the €30,000

figure may be inadequate depending on the extent of any damage.

The observer’s submission includes a copy of the relevant book of reference, third

schedule.

138. Catherine Guy, ByrneWallace, 2 Grand Canal Square, Dublin 2.


Generally welcome the proposal to construct the Dart Underground.

Primary concern relates to potential for obstruction or interference with or access to

Macken Street and buildings on Grand Canal Square.

Likely interference of the use and occupation of the observer’s building for the

purposes of their business arising from construction works.

Concern with respect to noise and vibration during the construction phase and also

noise and vibration arising during the operational phases.


Welcome the opportunity to make further representations to An Bord Pleanála and

reserve the right to expand on the submission and raise additional issues at the oral

hearing on the project.

139. James Synott, Cedar Cottage, Old Russian Village, Kilquade, County

Wicklow.

The contents of this submission from the above can be summarised as follows:-

Owner of 79 Merrion Square, Dublin 2 which is located circa 25 metres at the nearest

point of the proposed tunnel.

Over the past 20 years considerable money has been spent in renovating his property

using Georgian standards.

No undertaken has been given by the project manager of Dart Underground that no.

79 will not be affected.

Legal and engineering fees will not be paid which may incur.

It is unacceptable that a very limited protection scheme is provided.

Request that An Bord Pleanála protect no. 79 Merrion Square, Dublin 2 and at least

impose a proper unlimited protection scheme.

Submission accompanied by a letter to Mr. Muldoon, Dart Underground Manager

from James Synnott, Cedar Cottage.

140. O’Callaghan Hotels and Associated Companies, c/o John Spain

Associates, 10 Lower Mount Street, Dublin 2.


The submission is in respect of lands at Bass Place, Fenian Street, Sandwith Street

Upper, Boyne Street, Mosaic assemblers at Boyne Street and Sandwith Street Upper,

5 Merrion Street Lower, Mont Clare Hotel, Davenport Hotel, Alexander Hotel,

Hospitality House, KBC Bank and apartments, apartment 25 and 23 Alexander Court

and the Alexander Court car park.

Acknowledge the benefits that will result from the delivery of the Dart Underground

in Dublin.

Concern that key sites are not blighted for long periods of time as this would be

detrimental to Dublin City and the objectives of the Dublin City Development Plan.

The applicant has proposed that the Notice to Treat should remain valid for up to 10

years however, in the EIS it is stated that commencement of construction will begin in

the second half of 2012. Therefore the 10 year requirement appears to be entirely

unnecessary. It is respectfully requested that An Bord Pleanála revise the rail order to

an 18 month timeframe, the same timeframe which applies to road CPOs.

A comprehensive planning application for the redevelopment of the majority of the

urban block at Boyne Street, Sandwith Street comprising of a 240 no. bed hotel and

conference development has been prepared.

The proposed railway order provides for the construction of a ventilation intervention

shaft on this site which will render the proposed hotel development unviable.


The reconfiguration of the plan layout of the hotel as a result of the ventilation

intervention shaft renders the development unviable.

It is requested that the intervention ventilation shaft currently proposed for Bass Place

be relocated to a more suitable site.

The submission details a number of alternative locations where the intervention shaft

could be located to.

O’Callaghan Hotels owns and manages three hotels, Mont Clare Hotel, Davenport

Hotel and the Alexander Hotel plus 13 no. apartments on Boyne Street KBC Bank

and Hospitality House all in the immediate vicinity of the Pearse Street area which

will be greatly affected by the proposed Dart Underground.

The construction period in particular will have a detrimental impact on the apartments

and the offices given the proximity to the proposed Pearse Dart Underground Station.

Ensuring that the standards within the hotels are maintained is of uppermost

importance.

Concern with respect to air quality, noise, vibration and disturbance.

The potential impact of the construction phase of the Dart Underground could have a

detrimental impact on the development of the Pearse Street area and the wider city.

Necessary mitigation measures are required to alleviate the negative impacts.

Welcome the opportunity to submit further detailed information to An Bord Pleanála

under Section 47D 1 of the Transport Railway Infrastructure Act 2001 as amended by

the Planning and Development Strategic Infrastructure Act 2006.

Request the opportunity to make representations to An Bord Pleanála at an oral

hearing.

Request that in accordance with Section 37(H) of the Planning and Development Act

2000 as amended in making the decision on the application An Bord Pleanála requires

the costs incurred by a client during the course of consideration of the application to

be paid for the applicant CIE/Iarnrod Eireann.

It is submitted that Bass Place ventilation/intervention shaft is not appropriately

located and that there are more suitable locations in the immediate vicinity.

The proposed location of this ventilation shaft is of serious concern.

The ventilation intervention shaft greatly undermines the development potential of the

site at Bass Place as the overall site will be significantly reduced in scale.

The significant reduction in the site area makes it impossible to develop the planned

hotel scheme on the remaining portion of the lands available for development.

The EIS states that the design of the intervention and ventilation shaft on Fenian

Street, Bass Place allows passive provision for six-storeys of development above. It

is understood that the development rights above the ventilation shaft would be in the

ownership of CIE and therefore it is at their discretion whether any development is

permitted above the shaft.

In the event that CIE allowed the observer to build above the ventilation shaft. The

shaft is 7.5 metres high and would still occupy a significant portion of the site.

Studies would need to be carried out in order to determine whether this site has the

capacity to accommodate an appropriate scale to meet the observer’s needs in addition

to the proposed shaft.

If it was considered feasible to build above the ventilation shaft this is likely to greatly

increase the construction costs associated with the development of a hotel at this

location. It is considered unlikely that it would be possible to locate bedrooms with

opening windows above the vent shaft.


The observer is seriously concerned with respect to the Notice to Treat as it will in

effect blight the lands for up to 10 years potentially until 2021/2022. In this period no

development may commence on the lands nor would the observer be in a position to

sell the lands which will result in the effected lands remaining stagnant.

It is understood that no compensation would be payable to the observer during this

extended period of uncertainty and blight. The observer is still required to service the

interest occurring on the loans in respect of these sites. This will have a major adverse

impact on the observer’s interest.

It is respectfully submitted that An Bord Pleanála gives serious consideration to this

issue and to the potential detrimental impact on development in Dublin City possibly

up until 2022.

In respect of road schemes the comparable timeframe is 18 months as opposed to the

10 year time frame provided for in the Draft Railway Order for the Dart Underground.

Under Section 217 of the Planning and Development Act once An Bord Pleanála

confirms a CPO the Local Authority has 18 months in which to serve notice to treat

on any landowner affected. If they fail to serve the Notice of Treat within 18 months

the CPO lapses. This is considered a more reasonable and appropriate time frame.

Furthermore given that CIE state in the railway order application that they intend to

commence construction in the second half of 2012 a notice of treat timeframe of 18

months would be sufficient and allow adequate time for the applicant to acquire the

lands.

In regards to the permanent acquisition of land the current timeframe for the Notice to

Treat could potentially sterilise the land for up to 12 years.

An issue of even greater concern is that if the applicant had the option not to issue the

Notice of Treat for a period of 10 years and the construction takes six years the land at

Bass Place which is to be temporarily required by CIE would not be released for

development until 2027-2018.

The observers are fully opposed to the temporary acquisition of their lands and it will

further delay their ability to commence construction of a hotel on the site.

It is submitted that the applicant should either permanently acquire the lands so they

are no longer in the ownership of the observer or alternatively in preference the

applicant should identify a more suitable site to accommodate the construction

compound and therefore would not be necessary to temporarily acquire the observer’s

lands.

Phase 3 Option 2 which involves the location of the ventilation intervention shaft at

the corner of Fenian Street and Bass Place also has issues identified with this

particular location. As discussed in the EIS Chapter 2. Notably

1. The demolition of properties in Bass Place.

2. Size of construction compound

3. Possibility of a third entrance at Merrion Square in the future.

It is proposed to construct a 240 bed hotel and conference development over a double

basement. The area of the shaft in the inner boundary is circa 550 square metres. It is

proposed that this land is permanently acquisitioned. The submission goes on to

indicate the impact on the proposed development as a result of this land take which

includes loss of 25 car spaces and emergency exits and the reduction of conference

room by 20%. The removal of bar function room waste and recycling room, the

removal of 3 no. meeting rooms and toilet areas, removal of 19 bedrooms from

second floor, 19 bedrooms from the third floor, 30 bedrooms from the fourth and fifth


levels, the removal of 20 bedrooms from the sixth and seventh levels, removal of roof

space and plant room areas. It is submitted that the reconfiguration of the plan layout

of the hotel as a result of the above renders the development unviable.

The submission identifies an alternative location for the proposed Bass Place

ventilation and intervention shaft.

Option 1- indicates the repositioning of the intervention shaft and the reconfiguration

of the ventilation shaft to an open area of land to the south-east corner of the

Cumberland House site.

Option 2 – This option is similar to Option 1 with the exception of the relocation and

separation of the ventilation shaft to the rear of Cumberland House site. The

intervention shaft will remain at the south-east corner of the site to the open area site.

Option 3 – This option involves relocation of the ventilation shaft to Denzille Lane.

Concern with respect to enabling works such as hoarding and the preparation of the

various sites located along the proposed route of the Dart Underground. In the

vicinity of the Davenport, Mont Clare and Alexander Court Hotels and along the

landholding at Bass Place, Fenian Street, Sandwith Street Upper, Boyne Street.

The proposed relocation or disruption of vital services such as ESB and Gas will lead

to serious repercussions for the servicing of the above mentioned businesses.

The proposed construction phase will undoubtedly lead to major disturbances to

adjacent business interests.

The EIS submitted does not give adequate management plans for how negative effects

such as deterioration of the local air quality will be dealt with by the construction

team and as such without a firm methodology to mitigate these hazards the local

business interests may become unviable.

The vent at Bass Place will cause dust particles to be pushed out into the atmosphere

as the trains pass by. It has not been established in the EIS how during the operational

phase this will be mitigated.

Concern with respect to, site preparation works to enable the construction phase to

commence, leading to disruption of local business interests.

Concern with respect to nuisance to the business community during the construction

phase. Resultant noise levels, traffic congestion, construction hours - working times

should be curtailed.

The proposed scheme will have a detrimental effect on the working of residential

quality of life for the KBC bank and apartments along Boyne Street.

The noise levels estimates provided are based on average levels and the true increase

in noise levels may be greater than predicted.

Stated working times should be reduced from 7.00 a.m. - 11.00 p.m. to 8.00 a.m. -

6.00 p.m. in line with current best practice.

The location and covering and diversion of services and utilities which may include

disruption to supply are unacceptable. The local works required to facilitate these

works will include drilling and gutting of pavements will generate unacceptable levels

of noise. Detailed plans of how these measures are mitigated should be firmly

established in the EIS.

Noise and vibration will have a negative consequence for local businesses.

The EIS does not adequately demonstrate the level of vibration that will be

experienced due to the proposed use of explosives to extend the tunnel’s progress.

With the use of explosives to occur any time during a 24 hour period there is a risk of

unacceptable disturbance to residents and hotel users.


The tunnel boring machine will also be a cause of substantial disturbance as the

vibration from the machine operating will be felt as the TBM passes beneath.

Unregulated operation of the TBM will have substantial implications.

When the system is complete and operational there will be on-going noise and

vibration issues due to the location of the wind shaft at Bass Place. The EIS does not

adequately show how this will be mitigated.

It is requested An Bord Pleanála give consideration to seeking further information

from the applicant prior to commencement of the oral hearing.

It is submitted in the event the items listed below do not form part of a further

information request they should be reflected in conditions attached to any railway

order that is granted.

Bass Place intervention/ventilation shaft.

The applicant is requested to consider the alternative options outlined for this

intervention / ventilation shaft as detailed in the O’Callaghan Hotel submission and to

provide an alternative location other than Bass Place.

Air Quality – the EIS proposes that the measures contained within the plan will fully

mitigate any additional problems caused by the construction works, however the

following potential hazards have not been acknowledged or assessed.

1. The potential exists for excavated material to contain harmful material. Is a

testing regime proposed to address any such eventuality? Adjacent properties

identified in the EIS as potentially at risk, what is the offered recompense for

the potential nuisance of dust debris and how it may affect them.

2. The close proximity of the Alexander Court Hotels existing car park to the

proposed ventilation shaft at Bass Place is of particular concern during


3. The applicant’s proposals to minimise negative impacts to the residential

amenity of the apartment on Boyne Street and the employees of KBC bank

should be provided in detail.

Noise and vibration management plans should be submitted to An Bord Pleanála to

assess any proposed mitigation measures.

The EIS does not give details of type of mitigation measures to be used for the

ventilation systems. The choice of mitigation system would have an effect on the

overall levels of noise experienced at these locations.

The close proximity of the Alexander Court Hotel’s existing car park would suffer

from the noise and disturbance during the construction phase and as such a

remediation plan should be developed and submitted through a review as part of the

EIS.

Proposed conditions – Notwithstanding the above request for further information, it is

submitted there are a number of issues that can be addressed by condition suggested

below as:

1. Notice to Treat part 3.16(1) of the railway order to read as follows: -

The powers conferred by this order to acquire compulsory land or rights in relation to

land and enter upon and take up temporary position of land shall cease at the end of

the period of eighteen (18) months beginning on the day upon which this order comes

into force.

2. Hours of operation


By means of a condition it is respectfully submitted that the stated working times

should be reduced from 7.00 a.m. - 11.00 p.m. to 8.00 a.m. - 6.00 p.m. in line with

current best practice.

141. Chartered Land, Usher House, Main Street, Dundrum, Dublin 14 c/o

Stephen Little & Associates, 6 Upper Mount Street, Dublin 2.


The observer owns property at both South King Street, Dublin 2 and also at Grand

Canal Square Scheme.

Support for Dart Underground Project in Principle.

Lands directly under both of the properties are being required for tunnels to

accommodate the Dart Underground.

It is imperative that the timely and efficient delivery of this important project occurs

without disruption to property interests and ensures that once completed it does not

have any long term adverse impacts on investments.

Submit that the minimum six weeks statutory consultation period has been insufficient

and request that An Bord Pleanála allow an opportunity to submit further detailed

information under Section 47D(1) of the Transport Railway Infrastructure Act 2001

as amended by the Planning and Development Strategic Infrastructure Act 2006.

Reserve the right to raise any additional items at an oral hearing.

The South King Street development which opened in autumn 2008 is a six-storey

block of premier offices over retail and accommodating flagship stores.

The South King Street development is not solely a commercial scheme. It also houses

4 no. residential units at fifth floor level all of which are occupied.

It is submitted that both the South King Street development and the Grand Canal

Square Scheme could be materially and negatively affected to an undue and

unacceptable level by the works proposed in the railway order application.

Concern with respect to vibration of floors, walls and ceilings and low frequency

rumbling noise.

The EIS identifies that without mitigation short term temporary significant adverse

effects will result at the following non-residential receptors; Marconi House, the

Gaiety Theatre and Grand Canal Theatre.

Note that the office uses in the south and north block of Grand Canal Square have not

been identified in this assessment. This is unsatisfactory given that the theatre is

situated between both office buildings and there is likely to be a maturing impact on

the offices. It is acknowledged that the theatre is subject to more stringent noise

sensitive criteria. However due regard must also be had to the potential impact within

the north and south office blocks given their direct proximity to the tunnelling

activities.

Note that the assessment in the EIS has not taken any account of the 4 no. occupied

residential units at fifth floor level and the South King Street development.

The EIS notes that the noise impact criteria differ between residential and non-

residential buildings yet the assessment has failed to distinguish the mixed use nature

of the South King Street Scheme and the resultant noise sensitivity of the residential

units therein.

Query the accuracy of the predicted period of disruption.


Concern with respect to the lack of clarity and details surrounding the proposed

mitigation measures proposed during construction and operational stage of this

proposal.

It is wholly unacceptable for mitigation to be left to the contractor as proposed in

Section 9.5.1 of the EIS.

There is no information on the detailed content of the proposed noise and vibration

management plan that is intended to deal specifically with management processes and

strategic mitigation measures to remove or reduce significant noise and vibration

effects.

Note that Article 6 of the Draft Railway Order contains a request from CIE that they

be granted permission to extend the zone of influence of the construction work to

allow for amendments by the contractor.

Submit that this will give scope to the contractor to modify the alignment of the tunnel

to some degree which may then result in a more significant impact on the observer’s

properties.

Request that An Bord Pleanála omit flexibility from the final Railway Order.

The proposal may result in unacceptable levels of significant impact over a long and

extended period to a number of property interests.

It is unclear as to why the office building immediately abutting the Grand Canal

Theatre at 2 Grand Canal Square is not acknowledged in the EIS.

Concern that the dwellings at South King Street do not appear to have been

considered in the noise vibration section of the EIS.

Reserve the right to raise any additional items or indeed elaborate on any of the above

at an oral hearing.

142. Grand Canal Theatre Company Limited, Grand Canal Theatre, Grand

Canal Square, Docklands, Dublin 2, c/o John Spain Associates, Planning and

Development Consultants, 10 Lower Mount Street, Dublin 2.


It is imperative that the proposed Dart Underground does not have a negative impact

on the Grand Canal Theatre as this would have a detrimental impact on Ireland’s

theatrical reputation.

Grand Canal Theatre was the first theatre ever designed by Daniel Liebeskind and

incorporates a range for architectural acoustic features to create a world class theatre

in terms of architecture and acoustics.

The theatre represents both Dublin and Ireland.

To build this cultural icon a significant cost was added to both the design and

construction costs. Jeopardising the acoustics of the theatre means risking the world

class standing of the theatre and ultimately its commercial success.

The Board is requested to take account of the national importance of the theatre in

making its decision on the proposed railway order for the Dart Underground.

The Dublin Docklands Development Authority granted a Section 25 certificate in

June 2005 (DD328) for a Broadway style theatre fronting onto the Grand Canal

Square with a retail and office development and associated car parking. At this time it

should be noted that there was no knowledge by the applicant that the Dart

Interconnector would run under the building. There is no reference to the Dart


Underground in any of the assessment reports prepared by DDDA and the Dublin

City Council in respect of the proposed development. In the event that the Grand

Canal Theatre had been aware of the location of the Dart Underground the building

would have been designed in a different manner.

It would appear from the documentation submitted that the impact of the proposed

Dart Underground on the Grand Canal Theatre was not considered in the selection of

the most appropriate route option.

The Grand Canal Theatre company was not aware of the proposal to locate the route

under the theatre until they were contacted by the applicant and a meeting held in

June 2010 just prior to the application being submitted to An Bord Pleanála.

It is submitted that the Grand Canal was not specifically identified or assessed in the

EIS to fully determine whether there would be any impact on the theatre. This is a

major deficit in the EIS.

The west bound running tunnel of the Dart Underground project is located directly

under the stage of the new world class Grand Canal Theatre.

Serious concern with respect to detrimental impact and the acoustics of the building.

Daryl Prasad, Director of Marshall Day Acoustics has carried out a detailed

assessment on behalf of Grand Canal Theatre.

It is identified that there is potential for the vibration of walls, floors and other

structural services generated by the propagation of ground borne vibration to give rise

to audible low frequency noise.

Marshall Day Acoustics have calculated an unmitigated internal level of 44 dB which

provide good correlation to the predicted results of 40-45 dB.

However the calculated results in terms of PNC are 64 which are significantly higher

than the existing background noise level of PNC 15. This demonstrates that the

decibel metric is inappropriate for determining a significant effect in theatres.

Given the large number of significant effects of the proposed Dart Underground on

the Grand Canal Theatre it is essential that the proposed railway be realigned so that it

does not undercut the theatre and the alignment reassessed to ensure that no residual

effects are present.

It is submitted that the applicant did not attempt to contact the Grand Canal Theatre to

determine the existing background ambient noise levels within the auditorium or to

consult on its sensitivity. The background services noise criterion for the auditorium

is set as PNC 20 with the services noise commissioned at PNC 15. The EIS should

have noted this.

The commercial impact on the theatre may be much greater than identified in the EIS.

Shows are booked months if not years in advance and tickets are sold months in

advance. There will obviously be a loss in revenue due to structural noise from the

TBM. It would be imperative that exact dates for the TBMs operation be provided to

the theatre with sufficient notice.

It is requested that the applicant or the contractor is conditioned to liaise with the

Grand Canal Theatre to agree the timing of the TBM so the observer does not

schedule events for the times that TBM is operating within a zone of influence of the

building.

Machine breakdowns, unforeseen obstructions, rock discontinuities, faults,

underground services and tunnelling activities will all delay the TBMs progress and

will be difficult to predict. As such the theatre will not be able to schedule shows in

advance with a degree of certainty.


Given that the proposed exposure is expected to last over three years this is

considered to be a significant effect. The EIS assessment is very light on the exact

details of the mitigation.

Realignment of the railway should be considered so the theatre is not exposed to the

construction or operational noise.

Concern with respect to blasting, operation of trains frequency, tunnel supply trains,

track isolation.

There is no mention in the application documentation of an allowance for track/wheel

deterioration over time. This could result in increases of operational noise within the

theatre of 10 possibly 20dB over time.

There are questions over the allowances made for the uncertainty of the model.

Model parts and measurements may indicate an accuracy of up to 13.5dB. This is

much higher than the 5 to be assumed in the EIS. This may mean that the assessment

using the EIS may underestimate the predicted noise levels.

The overall duration of the theatre exposed to TBM noise will be 40 days but given

the difficulty in predicting the exact date the overall impact on the theatre will be for a

much greater duration.

The supply train ground borne noise assessment is highlighted as a significant effect.

This could mean a significant noise impact on the theatre for 37 months.

It would not be suitable to simply reduce blasting noise within the theatre during

critical times. This must be either removed or rescheduled around critical times.

The EIS implies that the floated slab track will need to be adopted under the theatre.

In the U.K. floated slab tracks are not common and usually rejected on safety grounds

for heavy rail.

Assessment shows even with a floated slab track the structural borne levels within the

auditorium would be exceeded. Trains would be clearly audible and intrusive within

the theatre.

Given the large number of significant effects it is recommended that the proposed

railway be realigned so that it does not undercut the theatre and reassessed to ensure

no residual effects were present.

Respectfully request An Bord Pleanála give consideration to seeking further

information from the applicant prior to the commencement of oral hearing with

respect to realignment of the proposed railway so that it does not undercut the theatre.

The applicant should be requested to undertake a borehole test to measure the

vibration ground loss and transfer function to the theatre.

The applicant should be requested to submit a detailed vibration assessment

demonstrating the relevant criteria as achieved due to both operation and

construction.

Notwithstanding the request for further information it is submitted there are a number

of issues that can be addressed by condition, suggested conditions are as follows:

Prior to the commencement of construction the contractor/applicant shall agree the

construction timeframe with the Grand Canal Theatre to ensure the TBM does not

disrupt the performances or rehearsals from the theatre

Required that the vibration assessments are based on actual surveyed data.

The theatre shall nominate the allowable thresholds of noise and vibration for

construction and operation before construction commences.


Submit a detailed vibration assessment demonstrating no adverse coincidence

between natural frequencies, track isolation of theatre before the underground is

allowed to commercially operate.

Submit annual commissioning measurements to monitor the effectiveness of the track

isolation system and remediate where necessary.

143. Tim Lynch, (E. Dunne, Barbara Dawson and Rory Dunne), Pearse

Square Residents Association, c/o 51 Pearse Square, Dublin 2


Pearse Square is a three-sided Victorian Square built in the 1840s consisting of two-

storey over basement houses of what was originally reclaimed land

Pearse Square residents welcome the Dart Underground and recognises its

advantages.

However submit objections and observations and highlight the conditions which

should be imposed when any build commences.

Request that the Board convene an oral hearing

The EIS does not contain any comparison to international best practice with regard to

tunnelling depths for similar builds and other jurisdictions.

Submit that the depth of basement and underground facilities, car parks etc. do not

appear to have been taken into account in the EIS.

Concern with respect to vibration levels and impact on structural integrity of

buildings.

Submit that all properties in Pearse Square and immediate environs should be subject

to a thorough internal damage dereliction condition study inspection.

Residents should have recourse to an independent arbitrator where a dispute arises in

order to avoid expensive legal action where the solution offered is not deemed

acceptable to an individual resident.

Consider that the offer of access to a genuine independent arbitrator would greatly

alleviate resident’s concerns.


full dereliction condition study.

Vibration and noise levels during boring phase should be subject to constant

monitoring to be publicly displayed on a live basis.


particular with any resident identified as sensitive receptors. If levels cannot be

agreed and are contested disputes should referred to an independent arbitrator who is

available on a 24 hour basis and whose decisions can be imposed.

If vibration levels were in excess of acceptable agreed levels - the speed of progress of

the boring machine should be reduced or work should be halted until deemed

acceptable by the independent arbitrator.


receptors. Such persons are particularly vulnerable and may not accept or appreciate

direct approaches from neighbours.



Square due to acknowledged and identified shallow foundations, delicate clay sewage

system etc.


parties by both letter and electronic means.


claimants without requiring recourse by way of legal action.

The scheme as currently offered makes provision for damages up to €30,000. Any

claims in excess are liable against the contractor. It is unclear how to progress a claim

if it is in excess of this amount. This is extremely unfair and therefore unacceptable.

The compensation scheme should accept claims for a period up to five years

following completion of the build. The proposed limitation whereby any claims must

be submitted within 12 months of completion of the build is unfair.

CIE should commit to on-going live monitoring which is publicly accessible via the

internet during the operation of the tunnel verified by an independent arbitrator.



CIE should confirm whether it is a prescribed organisation in relation to planning

applications. This is not entirely clear from the EIS.

How will any obligations or conditions be legally enforced. Which body will oversee

enforcement? Clarification of this important issue should be a condition.

AREA 106 - River Liffey to East Wall

144. Elizabeth Corrigan, 7 Abercorn Road, East Wall, Dublin 3.


An Bord Pleanala is urged to refuse planning.

There was little or no public consultation.

The new plans are substantially different from the plans that were shown previously at

public meetings.

The EIS was done for the previous and different plan.

The suggestion/promise of 75% of spoil been removed by rail seems to have been

completely forgotten in the new plans.

Because objections in Inchicore have reduced the works there, Irish Rail now have

changed the plan so the vast majority of this spoil, almost double, is to be removed

through the North Lotts immediately adjacent to the observer’s property.

At the very least a grant should be made available to the residents surrounding the

North Lotts for triple glazing to reduce the extra noise.

The observer objects to the proposed 6 metre high wall being including in the new

plans without her expressed permission.

Traffic calming measures can be introduced without removing residential parking

spots.

The new plans have largely ignored the impact of reduced parking on Abercorn Road

residents.


The introduction of double yellow lines will only cause daytime parkers to move

further into Abercorn Road.

Concern raised in relation to the placement of large transformers so close to houses

having specific regard to likely noise impact.

The observer has not had sufficient time to examine and assess the new plans.

The observer submission includes plans one referring to the original layout and the

second as per the current proposal.

145. Lawrence Redmond, 80 West Road, East Wall, Dublin 3

The contents of observer submission from the above can be summarised as follows:

The new dual line runs directly behind the observer’s house.

The proximity of the first line to the observer’s house is not more than two metres

away.

Because the tunnel comes up out of the ground behind the observer’s house, the

observer imagines that the level of excavations in the location behind his house would

be substantial in the extreme.

Rock breaking of the magnitude proposed is an extremely industrial grade level of

work and would involve large breaking machines working literally on the observer’s

back doorstep.

The noise levels from rock breaking would be unbearable.

The observer is 76 years of age and his wife is 68 years of age.

Not only would they have to contend with the constant noise of the rock breaking on a

24/7 basis, but because they are literally connected to the railway wall, the vibrations

and dirt and dust levels would also be unbearable.

There is the risk that these works could cause structural damage to the observer’s

home.

Considering the fact that the trains have been running over these lines for many years

carrying all sorts of cargo, soil must be contaminated.

The excavation removal of contaminated soil would be of concern as it could have

serious health implications.

The observer is worried that his privacy and visual enjoyment of the back yard will be

lost due to these works.

The observer is also worried with the disruption that these works would cause to the

natural habitat of the area and will result in rodent habitats becoming disrupted,

causing them to flee into gardens and houses closest to the works.

The thought of having this monster development in his back garden is horrifying and

is of huge distress to the observer and his wife.

There is also the huge imposition which the planned train operation would have on

their lives.

The observer has been informed the trains will be required to sound the horns each

time they enter and exit the tunnel.

This would impose fog horn noise pollution on the observer and his wife every couple

of minutes.

Surely there must be other alignment options that Irish Rail can use which would not

impose such a level of disruption.


The observer requests an oral hearing on behalf of the East Wall Protection Group

who are officially representing East Wall.

146. Phyllis Doyle & Others, c/o 25 Crescent Gardens, East Wall, Dublin 3


Health concerns relating to existing conditions being worsened and sleep deprivation.

Noise concerns relating to worker’s vehicles, 24/7 working hours.

Pollution concerns relating to the moving hazardous waste.

Inconvenience concerns relating to the relocation of West Road Bridge and loss of

spaces.

Damage to homes due to flooding and six years of disturbance.

A station should be added to East Wall to encourage people to use public transport.

The observers request an oral hearing on behalf of the East Wall Protection Group

who are officially representing East Wall.

The observer submission includes a petition with 25 signatures.

147. James Duffin, 3 Abercorn Road, East Wall, Dublin 3.

The observer submission from the above can be summarised as follows:

Vibration effects on houses in the area

HGVs carrying the excavated soil will exit through the area.

Significant need to limit the hours of construction.

Trucks carrying the earth should be prevented from going through residential areas.

Given that the East Wall and North Wall is reclaimed land tunnelling exasperates the

risk of flooding.

Concerns expressed over dust and vermin.

Concerns raised over the height of the proposed ESB building on West Road and

Sheriff Street.

An oral hearing is essential so that the concerns local people have regarding the

construction and operation of the proposed development are addressed.

148. Carmel Kelly & Others, c/o 8 Killane Court, East Wall, Dublin 3.


One of the observers suffers from very serious heart problems and is concerned about

the amount of dust which will be generated by the proposed development.

Concern raised over the noise generated by the boring which the observer believes

will be 24/7.

The observers feel that one boring machine is sufficient.

The least CIE could do for East Wall is to give a station to the area.

The general disruption to the area is also of concern to the observers.

The observers support the Protect East Wall Campaign.


149. Paul O’Brien, 171 Crosby’s Yard, Ossory Road, Dublin 3.


The observer is a resident in Crosby’s Yard apartment complex, the EIS alludes to a

“Crosby’s Yard Business Park”, this is not accurate.

Crosby’s Yard is predominantly residential with approximately 200 apartments.

Many of the apartments have bedrooms that overlook the proposed new route for the

railway.

Despite the fact that the new West Road Bridge, the sinking of the rail line, the

realigned West Road and the new operation centre are all directly adjacent to the

apartments, the EIS does not seem to acknowledge that the apartments exist.

EIS Figure 8.6 outlines noise baseline study locations, Crosby’s Yard and vicinity are

entirely omitted from this.

The proposed mitigation in no way mitigates the noise or vibration for the residents of

Crosby’s Yard, who will now have a fully exposed mainline Dart running next to their

bedrooms.

The barriers erected are for the benefit of residents on the east side of West Road who

have the additional benefit of the railway embankment in between acting as a barrier.

There needs to be a comprehensive and significant erection of noise barriers along the

route of the railway as it descends to the eastern tunnel portal on the side adjacent to

Crosby’s Yard.

The visual impact for residents in Crosby’s Yard apartments of the sinking rail line

into the eastern tunnel portal is not addressed in the EIS.

There needs to be a comprehensive and significant planting and screening plan for the

areas directly adjacent to Crosby’s Yard apartments.

The option of locating the eastern tunnel portal adjacent to the Clontarf Dart Station

must be examined.

The residents of East Wall, in particular those in Crosby’s Yard apartments, are being

asked to sacrifice a lot in terms of real long-term disruption and decay in financial

value and enjoyment of their homes in return for nothing.

150. Aidan Foley and Master Labs Limited, 81 West Road, East Wall, Dublin

3.


follows:

Michael Campion and Company Solicitors are acting on behalf of Aidan Foley and

Master Labs in the making of the submission.

The observer lives at 81 West Road with his wife and two daughters, his elder

daughter suffers from asthma.

Master Labs operates a sound engineering premises from a specially designed studio

located at the rear of 81 West Road.


It provides mastering and re-mastering services to the music industry and relies

heavily on the expertise of the observer.

Mastering involves the fine tuning of recorded music before it is mass produced for

sale.

Re-mastering involves restoration and enhancement of older recorded music to release

in the market.

Both processes require the use of expensive and delicate equipment in a studio

environment which is entirely soundproof and especially designed to optimise the

quality of the finished product.

The studio comprises an interior structure inside and exterior shell and contact

between the two structures is minimised in order to limit transmission of outside

vibrations.

The interior structures are carefully constructed to avoid parallel surfaces.

The portal and cut away through which the Dart underground will pass, will be

located directly at the rear of the observer’s property.

An element of the proposed works is the deposited excavated earth at the rear of the

observer’s property and its removal by trucks.

When the Dart underground has been completed the tracks will be located

immediately to the rear of the observer’s property and consequently there will be a

continuous passage of trains only a metre distance from the studio.

The business of Master Labs will be rendered inoperable as soon as construction

works commence and will remain inoperable through the construction and operation

phases of the Dart underground.

The observer submits an expert report by an audio consultant for the attention of the

Board.

That report states that the operation of the studio will be completely impossible during

the construction and operational phase.

The observer will suffer financial loss arising from the necessity to locate his business

elsewhere.

The observer’s daughter will suffer deterioration of the symptoms of her asthma as a

result of the dust caused by the construction works including the piling of earth at the

rear of the observer’s property.

The Draft railway order does not appear to contain mitigation measures in respect of

the observer’s property.

The observer does not believe that any mitigation measures could ensure the

continued operation of the studio during the construction and operational phases.

The observer requests that the twelfth schedule to the railway order contain conditions

which, by ensuring that no vibrations caused by the construction or operation of a

Dart underground are perceptible in this studio, enable Master Labs to continue in

business at 81 West Road.

The observer requests that a condition be imposed requiring CIE to compensate the

observer for the loss of the studio.

The observer requests an oral hearing into the proposal.

The observer submission includes a report entitled “Predictive noise impact report on

Master Labs studio in relation to proposed upgrade works to the Dublin Dart

underground system”, as prepared by John Munnis Audio Consultant.

151. Angela Wigglesworth and Other, 9 Abercorn Road, East Wall, Dublin 3.




There will be a serious effect on the residents both during construction and at the

operation stages.

It is essential that there is clear communication between the residents and the project

management throughout the works.

In order to ensure that the concerns of the observers are systematically addressed

during the construction and operational phases, the observers urge the establishment

of a forum to facilitate on-going communication between the project management and

the residents.

Concerns expressed in relation to the proposed temporary possession of part of

Abercorn Road.

Concerns relating to the protection of the observers’ property including the boundary

walls.

Concerns in relation to vermin are expressed.

Proposed working hours should accommodate the lives of residents. It should be

discussed and agreed in advance with residents.

The observers seek clarification on the use of the yard on Abercorn Road and the

implications for the increased amount of traffic.

Best international practice should be applied for control and monitoring of noise and

vibration levels.

Air quality will be affected by the rise in dust levels.

Air quality should be protected to the highest possible standards with a minimum

deterioration of the present levels.

Measures must be put in place to protect the observers from mud and dirt generated

by the excavation and building processes.

High density lighting is to be used during the construction phase. It is vital that it is

controlled enough to cause the least possible nuisance to residents.

The observers need to be protected from the eventuality of flooding and the

possibility of water stoppages to homes throughout the construction phase.

The observers want to be involved in the planning of landscaping to ensure maximum

enhancement of the environment.

In the event of structural or other damage to the observers’ properties they seek a

guarantee of adequate compensation which will facilitate the essential repairs or

reconstruction.

The observers seek clarification on the use of a number of proposed structures in the

CIE yard adjacent to their homes.

The observers seek clarification in relation to the use of the yard at Abercorn Road

during the operational phase and estimate of traffic using the yard.

The observers seek clarification in relation to the increased levels of noise/noise

pollution from the trains.

The observers are concerned about possible damage to their homes due to vibrations

caused by the running of the underground service.

Projecting lights and installations at operational phase must be sensitive to the fact

that people are living in this neighbourhood.


The submission is signed by a number of persons representing nine residences along

Abercorn Road.

152. Ian Hand, 40 Blythe Avenue, East Wall, Dublin 3.


There will be considerable disruption during the six year construction period.

360 trucks a day will add considerably to traffic congestion and noise pollution. This

will have consequences for road safety and will result in on-going diversions and road

closures which will, in turn, affect access to public transport.

It will also affect access to residents by emergency vehicles. Parking for residents on

the construction area will also be adversely affected.

Noise and vibration from trucks and construction will create much discomfort and

structural damage to housing on business property in what is essentially a residential

area.

The additional possibility of damage to housing through subsidence and flooding will

have a negative impact on property evaluation.

There will be a considerable amount of dust created during the construction which

will result in deterioration in air quality and this along with an increase in vehicle

emissions will be a serious health risk especially to those with respiration difficulties

and will result in physiological problems for many people.

The transport of hazardous waste through a residential area is a considerable worry.

The concerns are raised in relation to vermin associated with the proposed

development.

With construction proceeding on a 24/7 basis rest and sleep for residents will be

severely impacted by noise and vibration.

The lack of sleep could result in mental health problems.

During the construction phase there will be severe negative visual impact with

residents having to watch numerous construction vehicles on a daily basis.

The entire character of the area would be affected with people moving out and leaving

buildings vacant.

The residents will not benefit from the provision of this public transport as there will

be no train station provided in the area.

Diversions and road closures will cause difficulty for the observer’s children getting

to school and for the observer going to work.

The observer’s children’s bedroom faces directly into the construction site and they

will be badly affected by noise and dust.

Following construction the observer will have no front garden and will exit his house

directly onto the footpath.

During construction the observer will have no privacy as his house faces directly onto

the site and will be overlooked by everyone involved in the construction.

The observer supports East Wall Communities objectives as expressed in their

submission.

153. Martina Kelly and Paul Corrigan, 38 Blythe Avenue, East Wall, Dublin 3.



The observers have been living on Blythe Avenue since 2004 and they have serious

concerns about how the proposed works will impact on enjoyment of their home and

their quality of life.

The observers do not dispute the importance of this infrastructure on the future of the

country but cannot agree with the burden it places on their community and in

particular on their avenue.

It is noted that CIE proposed to take temporary possession of the entrance to Blythe

Avenue.

This would mean that the observers would be unable to enter their house from the

front door.

The rear door access to the observers’ home leads onto Church Road a very busy

street.

The proposal would also mean that the observer would no longer be able to park their

car safely outside their door.

Some houses along the road do not have rear door access, the observer therefore

cannot see how this proposal is viable.

The proposed development would have a negative impact on the value of their

property.

The scale of the disruption caused by the proposed works would mean that the house

prices in the area would plummet.

The proposal should be reconsidered and an alternative site be found to carry out the

works proposed at the entrance to the avenue.

The construction phase is projected to last nine years in East Wall, this is longer than

any other works along the route.

The majority of the waste material from tunnel boring some 1.5 million cubic metres

is expected to be transported by truck along the streets of East Wall.

The observers understand that there would be approximately 390 trucks moving

through East Wall each day.

This will create huge volumes of dirt and dust impacting on their health and the

cleanliness of their streets, homes and cars.

The construction works will continue 24/7.

The observers appeal strongly that machinery not be allowed to run at night or during

the weekends.

The scale and length of the activity and disruption to the area should be reviewed and

scaled back to a more reasonable level.

While the area of East Wall will suffer the vast majority of the adverse impacts of this

project, it will not have the benefit of a train station at the end of the project.

154. Karl O’ Grady and Deirdre O’Reilly, 41 Blythe Avenue, East Wall,

Dublin 3.



The observers’ house is located on Blythe Avenue in East Wall, a small and safe cul-

de-sac which looks directly onto the railway tracks and the proposed site for the

tunnelling to take place.

It is situated just a few metres from where the spoil from the tunnel is to be removed.

This will involve the removal of earth stretching the complete length of the tunnel

which was originally intended to be carried out at the Inchicore end of the tunnel but a

decision was recently taken to move this to East Wall which raises questions about the

accuracy of the Environmental Impact Statement.

Blythe Avenue has been ear marked as a high impact area and this worries the

observers greatly.

The observers have three children and as the gardens along this avenue are very small

the children rely on the street for their play.

The dirt, dust and noise will force them to stay indoors.

This is very upsetting for the observers as at least six very important years of their

childhood would be badly affected by these works.

In relation to noise and vibration and impacts from same Iarnrod Eireann needs to be

more specific and provide factual information about its intentions as otherwise their

plans are open to interpretation.

The noise model locations referred to in figure 8.13 of the EIS don’t include Blythe

Avenue.

Given that the observers’ house is directly opposite the main construction site for the

East Portal tunnel boring machine, the noise modelling is inadequate.

With reference to Table 8.12 of the EIS summary of construction noise assessment

assuming standard site hoarding Blythe Avenue/Malachi Place is explicitly referred to

in both spoil removal scenarios.

Due to the proximity of the observers’ house to the noise, and length of time it will

take for the construction phase, it is unacceptable that they should have to endure

increased noise levels.

With reference to the EIS the observers are not being properly informed on the actual

levels of noise predicted and it seems to the observers that Iarnrod Eireann don’t seem

to know themselves.

The observers refer to health problems associated with exposure to excessive noise.

The EIS shows the observer’s properties having shallow foundations on 10 millimetre

contour and at risk of settlement impact.

The EIS indicates that the observer’s house would suffer cracking of less than 1

millimetre, it is noted that their house is situated directly on the contour for 10

millimetre damage so this may be increased.

The observers were not informed or consulted with on this very serious matter.

If the walls of the house are predicted to crack what does this say about the effects on

their health.

The proposed compensation scheme is inadequate as it does not take into

consideration the other effects such as disturbance, stress, annoyance and health

problems that this is surely going to cause.

The top of Blythe Avenue will be required for temporary use.

Blythe Avenue is a cul-de-sac so the observers can’t see where the alternative

temporary access for vehicles will be provided.

The subject portion of land should not be used to help with this construction as it will

add to the negative impact that will exist on East Wall due to on-going works.


Section 49 of the Planning and Development (Strategic Infrastructure) Act 2006

provides an amendment to Section 44(2)(g) of the Transport (Railway Infrastructure)

Act 2001 stating that a railway order contain provisions requiring a gain to the

community.

There is no benefit whatsoever to the community.

The existing bus services should be protected for the duration of their proposed

construction phase.

The observers question the wisdom of proceeding to build in an area that according to

the Irish Insurance Federation is still at risk of flooding.

With such disruption on the very doorstep the value of the observer’s house will be

seriously affected.

The East Wall Community will be greatly affected by the road closures which will

occur due to the construction.

Is this interconnector actually needed? The Luas already links Inchicore and Heuston

Station to Connolly Station.

A much more cost effective solution would be to link the existing St. Stephen’s Green

Luas terminus of the green line to the Luas red line.

The observers request that an oral hearing be held.

155. Lisa McQueen and Sandra McQueen, 12 West Road, East Wall, Dublin 3.


The observers support the protect East Wall campaign objectives as expressed in their

submission.

The observers contend that the Environmental Impact Statement is flawed and should

be considered as null and void because the basis on which it was completed has

changed fundamentally due to the fact that now the two boring machines will start

simultaneously in East Wall.

The doubling of all disruption due to excavation clearance and tunnelling works,

which is all to be based in East Wall.

Disruption to no. 53 bus.

Diversions, road safety, parking restrictions.

Concerns relate to impact on on-street parking facilities.

Movement of hazardous waste are of concern.

Proposed 360 trucks a day, unacceptable traffic impact.

Noise, light pollution, dust, air quality, vibration, loss of sleep.

Proposed working hours should be reduced from 24/7 to 8 a.m. to 6p.m. five days a

week.

Structural damage to the observer’s home.

Impact on value of property.

Mitigation is required for operational phase.

Will Irish Rail replant trees and shrubbery along embankment of train tracks?

Will the works increase the risk of more flooding in East Wall?

Will the observers be provided with 24 hour phone no. for Irish Rail to report and

resolve any major issues that occur?

East Wall is a residential area and not an industrial one.



156. Lisa Reade and Brian Reade, 23 Portside Court, West Road, East Wall,

Dublin 3.


The observers live in a cul-de-sac on the West Road which is within a short distance

of the proposed works.

The observers contend that the impacts of the works will give rise to pollution

Living in close proximity to the works the observers are fearful that the negative

impact on the air quality in the area will have a detrimental effect on one of the

observer’s breathing and skin, this observer has a number of health problems.

The observer has concerns regarding access to and from work, which will be

disrupted adding extra time onto the journey.

157. L. Hynes, 53 West Road, East Wall, Dublin 3.


Should the order be granted the observer requests a number of conditions be attached.

Strict limits on construction times examples 7a.m. to 6.00p.m. Monday to Friday,

8.00a.m. to 2.00p.m. Saturday and no activity on site Sundays and Bank Holidays.

These limits should apply in particular to all surface construction works within 750

metres of dwellings on West Road and environs.

A reduction in the height of the operations control centre which appears to be

excessive, this excessive height will result in considerable shading of opposite

dwellings on West Road which currently enjoy unobstructed light at all times.

An increase in height of 1 metre of the existing acoustic barrier adjacent to the

existing branch line.

Strict limits on construction related vehicular traffic movements on West Road east of

the existing branch rail line embankment.

158. Lynn Durie and Cormac O’Brien, 49 West Road, East Wall, Dublin 3.


The observers support the Protect East Wall campaign.

The proposed works are having a seriously detrimental effect on the value of the

observer’s house made worse by the effect that even when the works are finished

there will be no added benefit.

No Dart station nearby and ugly structures and high rise blocks facing the observer’s

house, blocking out sunlight.

The observers are concerned that they will not be able to sell or even rent out their

property.


Their property seems to be in a hot spot where these works are concerned. The

observers are worried about the noise levels, the dust and pollution levels, the

inaccessibility of the property, the immense duration of the works, the health risks

that continual exposure to dust will bring vibrations and the structural damage to the

90 year old foundations.

There has been flooding in the area before.

There are concerns that the proposed development would generate empty boarded up

houses with the associated anti-social problems.

The observers are extremely anxious and angered that the community of East Wall

appears to have been ignored as an inevitable consequence of progress without a

though to the people’s lives and their rights as Irish citizens.

159. Denise Wright, 64 West Road, East Wall, Dublin 3.


The observer is not in principle opposed to the DART underground project but is

strongly opposed to the lack of consideration given to her as a resident of East Wall

and also the portrayal of East Wall and West Road in the EIS report.

The observer supports the protect East Wall Group submission.

The public consultations arranged by Iarnrod Eireann in the Sean O’Casey Centre

were grossly inadequately advertised.

At no time did Iarnrod Eireann mention or show plans that included an emergency

portal footbridge clearing above the embankment directly opposite the observer’s

house or inform her of their decision to launch the boring machines from East Wall

only.

For the duration of the construction phase the observer will not be able to use her

front west facing garden.

The negative impact of the proposed emergency portal footbridge will result in a loss

of amenity of the garden.

It will also result in a loss of privacy as the portal bridge will be directly opposite her

bedroom windows.

It is clear from the drawings in the EIS that no effort was made to harmonise this

proposed construction with the character of West Road.

It is both striking and obtrusive against the existing landscape.

The observer respectfully requests An Bord Pleanala to have this bridge relocated.

In relation to the proposed temporary possession of Ossory and West Road the

observer is concerned that this will have a devastating negative impact on her life and

business.

The increased volume in traffic due to the proposed HGV movements is also of a

concern.

The portrayal of East Wall throughout the EIS is that of industrial character with a

low socio economic standard, this is simply not true and the observer is personally

insulted by this comment.

The area does have poor air quality, the cause being pollution omissions from Iarnrod

Eireann’s commercial trains, rather than redress the existing problem Iarnrod Eireann

uses it as an excuse to justify further degradation of the community.


Why was a residential community like East Wall chosen to bear the brunt of this

major strategic infrastructure project? Why were no options other than East Wall

explored?

The inevitable result of proposed road closure on West Road will be parking chaos.

This will be further exacerbated by the parking of construction workers cars.

Iarnrod Eireann should be required to provide a proper management plan that will

provide for on-street parking for residents and that access to West Road will not be

impaired.

The existing noise levels on West Road due to Iarnrod Eireann commercial trains are

unacceptable. It is proposed that these levels will be increased (one train every 3

minutes in each direction).

The sleep deprivation the observer’s family will experience will have the associated

negative consequences on their health.

An Bord Pleanala is requested to ensure that at the very least proper mitigation

measures are in place to counteract these concerns.

Should the project go ahead as predicted in the EIS there will be elderly people in the

community that having resided in a quiet residential community all their lives will

live out the last days in the chaos dirt and filth of a building site.

There are children in the community that will spend their formative years in a

building site.

The Board is requested to grant an oral hearing and to appoint an independent

arbitrator to ensure proper standard of mitigation measures and ensure that a

residents’ ‘charter of rights’ is written into the railway order to ensure proper

enforcement of conditions laid down by the Board.

160. Shalom Binchy and Niall Nolan, 15 Hawthorn Terrace, East Wall, Dublin

3.


The observers reside at 15 Hawthorn Terrace with their 20 month old daughter.

It appears from the plans that the works will be very noisy over a very protracted

period, approximately 6 years.

It is intended that the works will be carried out on a 24 hour basis.

The estimated decibel levels which of course may be underestimated will have a

severe impact on the observers’ lives.

The observers also work from home as much as they can.

This work will be hampered and their family life will be affected.

Lack of sleep even over a short period will seriously affect the observers’ lives and

lead to health problems.

The observers are very worried out the effect the noise will have on their daughter.

It is completely unacceptable that they should be expected to bear such a burden over

such a lengthy period.

The work should be carried out during working hours from 8.00a.m. to 6.00p.m. for

example.

The proposed noise barriers on West Road are only 1 metre to 1½ metres high which

appears to be wholly inadequate.


There is no proposed baseline vibration or noise monitoring location on the observers’

street.

The noise will affect this area, the trains will have to sound in advance warning before

going underground.

The works will lead to a huge increase in dirt and dust levels over a number of years.

The enjoyment of their garden will be affected by the proposed work over a six year

period.

The proposal to close Ossory Road and other access routes is of concern to the

observers.

It will lead to huge delays getting to and from work.

It will be much more difficult for emergency services to gain quick access and egress

to East Wall.

Their walk will also be longer due to the proposed Ossory Road closure.

It is outrageous that residents of the area must put up with enormous inconvenience

over a very long number of years while a major infrastructural project is undertaken

which has no benefit to them.

There will be no local station.

The observers’ house is over 100 years old.

Their house has shallow foundations and the observers are concerned that the works

particularly the drilling will cause structural damage to their house.

The proposed Property Protection Scheme is totally inadequate. The time limit

should be extended to at least 5 years.

The amount of restitution should be increased to at least €100,000 and the zone of

properties to be included in this scheme should be extended to the entire of East Wall.

The observers’ house will be impossible to sell or let for many years.

There will be a massive impact on the visual appearance of East Wall.

This project will be ugly in the long and short term and will make East Wall a much

less attractive area in which to live.

It will affect the observers’ privacy.

The proposal to bore two tunnels from East Wall is a major change to the plans and

should have been included in the railway order.

The EIS does not take into account the changes to the plans.

The East Wall has been the subject of severe flooding in the recent past.

It would seem that the plans do not fully consider this risk or assess whether the

works will increase the risk of flooding in the area.


161. Terrance Mehlhorne, 26 Hawthorn Terrace, East Wall, Dublin 3.


The observer objects to the proposal.

The observer lives in one of the oldest houses adjacent to the proposed construction

works.

The observer’s concerns relate to the damage that will be caused by the underground

and over-ground works due to the vibrations these works will cause.


The observer will lose the enjoyment of his back garden due to the noise and

pollution.

The observer will not be able to dry his washing due to dust.

The closure of the West Road will affect access to his home.

The observer is concerned his health will deteriorate due to the continual noise.

The proposed development will also affect the value of property due to the upsurge in

rail traffic noise.

The development is being forced on the local community.

The observer also has great concerns about the effect the underground works will

have on the underground river courses in the area.

There is the probability of flooding due to these works.

There would be inconvenience to people’s daily lives.

162. Maria Ronan, 22 Sea View Avenue, East Wall, Dublin 3.


The observer supports the Protect East Wall campaign.


The constant noise from boring machines working 24/7.

The impact on the quality of people’s lives will be detrimental to their health and

everyday life.

The proposal is in the residential zone and there should be restrictions on the hours

worked.

The noise levels should be monitored and kept within the guidelines.

If trucks are going to be taking away soil the noise, dirt, dust and again health risks

are enormous.

Some soil could be contaminated because a lot of the land is reclaimed.

With diversions in road closures the community will not be able to move freely.

Extra traffic will again increase noise.

Maintenance and upkeep of properties will be affected, homes could be structurally

damaged. The value of homes might possibly decrease because sub-stations, traction

station and control station being so near to these homes.

There is no benefit to the community after the long period of construction.

It is now proposed that two boring machines will start simultaneously in East Wall.

Inchicore has over 70 acres of land that these sub-stations and traction station could

be built on. Why can’t these stations be moved there?

East Wall is a residential area not industrial.

163. Tommy Seery, 9 Sea View Avenue, East Wall, Dublin 3.


Health concerns, loss of sleep, breathing difficulties, Weils disease.

Noise from working 24/7, trucks accessing.

Pollution, moving of hazardous waste, vermin.


Inconvenience, relocation of entrance and exits, relocation of bus routes, construction

for approximately 6 years.

The houses were built in the 1800s and the observer has fears relating to the

foundations and flooding.

Local labour should be used.

There should be a station in East Wall.


The observer submission has 10 signatories.

164. Margaret Ballot and others, 40 Sea View Avenue, East Wall, Dublin 3.


The observers believe that the East Wall community has been very poorly informed

about the consequences of the construction phase for the DART underground with

reference to noise, pollution, traffic management, heavy plant etc.

The required consultation process was inadequate.

The observers would question why the community in Inchicore was able to block the

plans for construction on the basis of pollution and noise and the effect these aspects

would have on their community whilst it was thought acceptable that the construction

be sent over to East Wall.

The proposal to make West Road a one way single lane roadway will lead to serious

shortage of parking along all the perpendicular roads leading from West Road.

No consideration has been given to remedial contingencies.

The observers are very concerned that the impact of the underground work on the

structure of the houses is unclear.

CIE have capped the amount of compensation at €30,000, the cost of damage cannot

be determined until the damage service have been carried out during and on

completion of the works.

The amount of compensation should remain uncapped.

There are a number of benefits to the location of a station near the proposed

operational control station.

The observers fail to understand why a community who will currently not benefit

from this initiative should have to bear a disproportionate amount of disruption

without any thorough consultation. The observers request an oral hearing.

There are 10 signatories to the letter representing residents from Sea View Avenue

and Fair Field Avenue.

165. Pavla Simdova and others, c/o 10 Fairfield Avenue, East Wall, Dublin 3.


The observers are highly supportive of the proposed DART underground in principle

but have a number of concerns.

East Wall is physically cut off from the city and its amenities to the north, south and

west.


While the importance of the proposed infrastructure is acknowledged it brings no

direct benefit to the community of East Wall but rather separates the neighbourhood

from its urban context as well as being a source of noise, air and visual pollution.

The proposed development will cause additional blockages to the already limited

access routes during construction, and additional noise, air and visual pollution during

construction and later during operation when traffic on the railway line will be

significantly increased.

It would be appropriate and of benefit to the East Wall and North Strand community

to build a station at the location of the proposed operation control centre.

The distance between the existing Clontarf Road Station and the proposed Docklands

Station is more than 1.9 kilometres, East Wall lies halfway between these stations, but

neither station is within a comfortable walking distance from the neighbourhood.

The construction of a station adjacent to the proposed OCC building should be made a

condition of any railway order granted.

This is the only way to connect this almost forgotten quarter with the city.

The observers request that An Bord Pleanala ensure that a bridge for pedestrians and

cyclists be provided from the southern end of Church Road and East Wall over the

enclosing railway line to give access to the proposed docklands station.

Such a bridge/link was envisaged in an Action Area Plan for East Wall prepared by

Dublin City Council in 2004.

It is also indicated in the Dublin Docklands Area Master Plan 2008.

It is disrespectful to the residents of East Wall who are expected to tolerate significant

noise, air and visual impacts as a result of CIE’s existing operations and proposed

developments without any benefit in return.

The observers request that An Bord Pleanala ensure that no impediments to the

provision of such a bridge can be created by the proposed works.

It should be a condition of the railway order that CIE enter into a partnership with the

appropriate Authority to provide funding for such a bridge/link from Church Road

leading to the proposed docklands station.

The DART underground project offers the unique opportunity to improve East Wall’s

connectivity with the surrounding city for the benefit of its residents and businesses.

It is not clear what structural materials would be used to construct the deck of the new

railway bridge at East Road. An Bord Pleanala should ensure that steel will not be

used as a steel bridge would be very noisy.


The submission includes a petition with 27 signatories representing residents from

Fairfield Avenue and Sea View Avenue.

166. Carmel Cosgrave and Others, 31 Fairfield Avenue, East Wall, Dublin 3.


The observers have health and safety concerns relating to loss of sleep, existing

conditions worsened, Weils disease, hearing impairment.

The observers have property concerns relating to valuation, residential, not industrial

area, overlooking, loss of light, structural damage and settlement.


Sense of community concerns relating to quality of permanent fixtures, local

employment, character of the area, disruption to number 53 bus and impact on church

services.

Environmental pollution concerns relating to light, noise, vibration, dust, air quality,

hazardous waste and vermin.

General impact concerns relating to sewage capacity, tunnelling from East Wall, 24/7

working hours, emergency response acts, negative visual impact, walking distance to

city centre, flooding, relocation of West Road Bridge and 6 years of disturbance.

Traffic concerns relating to bus access, parking, workers vehicles, truck access, loss

of spaces, road closures, diversions, and road safety.


The observes support the East Wall communities objectives.

There are three signatories to the submission.

167. Emma McDonnell, 73 West Road, East Wall, Dublin 3.

The contents of the observer submission as prepared by Patrick McDonnell, Architect and

Planning Consultant, on behalf of the above can be summarised as follows:


The matters of concern relate to the ambient noise levels resulting from trains insofar

as the effect the residential amenities of the observer’s home at West Road and the

neighbourhood closest to the proposed rail lines.

It should be recognised that this project represents an opportunity to reduce the

current physical isolation and inaccessibility suffered by the East Wall community.

The project during its construction phase will cause huge parking problems on West

Road and surrounding it. It is necessary to see that there is a traffic plan implemented

which is realistic, environmentally acceptable and enforceable.

An explanation and reassurances are required in relation to the maximum noise levels

and vibrations which will be experienced by residents during the construction phase

of the new railway lines and the tunnel boring and excavating.

It is necessary to protect the amenities of the residents by implementing appropriate

design measures in the project.

The surface finish of the retaining walls at the start of the tunnel could incorporate

absorbent materials or acoustic screens or surface modelling to reduce the noise

impact effect and thus the propagation of sound into the adjacent residential areas.

The large beams straddling the cutting should be clad in similar absorbent materials or

be used as supports for screens or sound baffles.

It would seem to be a reasonable, practical and sensible solution to roof over this

cutting.

If the proposed acoustic screens are similar to the existing fence type structure on the

railway embankment then it has to be said that in practical terms it is proved less than

satisfactory.

Can assurances be given that there would be no sound signals, horns or sirens used by

trains approaching entering or exiting the tunnel?

Will diesel trains be using the tunnel?


Because of steep gradients necessary to enter the Liffey tunnel and the general

undergrounding, diesel trains would have to operate on much increased engine power

resulting in very intrusive noise levels.

This major infrastructural investment offers a unique opportunity to address and solve

what are probably the most serious problems facing East Wall namely its isolation

and lack of connectivity with the surrounding urban structure.

A footbridge should be built at the southern end of Church Road over the goods line

into the large triangular area of former railway lines which has a residential land use

zoning objective in both the Dublin City and Docklands Development Plan.

The Docklands station must be regarded as serving East Wall as much as the rest of

the docklands area.

The building of a pedestrian bridge or bridges as linkage and public transport access

ways must be regarded as a critical part of this project.

The area has poor access by public transport.

It would be unacceptable and impracticable to assume that parking for workers

engaged in project construction can be accommodated on West Road or in the wider

East Wall area.

West Road is a quiet settled residential area. It is not suited to carry heavy

construction traffic.

To impose such a level of disruption on the lives and environment of the residents

would be unreasonable and unacceptable.

There is a clear opportunity to solve this parking problem at other sites in the wider

area.

Standards to be adopted for noise, vibration and air quality must match those of outer

suburban residential areas.

The system of continuous monitoring has to be applied with a means available to the

residents for a quick and effective response from the project contractors following

complaints or problems.

One way to reduce the problem of noise propagation would be in the approach

cuttings which would produce environmental benefits at construction stage and for the

long term operation of the new railway.

168. Protect East Wall Group, c/o BPS Planning Consultants, 23 Saville Park

Road, Dalkey, County Dublin.


Sensitivity of this residential area. The project will have massive implications for the

area in which they live.

The EIS refers to East Wall as being industrial this is not the case, it is a residential

community of approximately 3,600 people.

This is a sensitive community of approximately 2,330 households.

The community already suffers impacts from rail, noise and air pollutants.

It is a community containing a large number of people with existing medical

conditions.

The project will permanently damage the unique character and ambience of this quiet

historic residential East Wall community.


It will disrupt normal life in the neighbourhood for at least the next 9 years with

further operational impacts thereafter.

East Wall has not only being chosen as a project starting point but also it is to receive

and transport onward all spoil rising from the project.

It is the location of a maximum project impact.

The East Wall community considers the proposed impacts to be unjustifiable.

The assessment must begin by examining the strategic decisions made by CIE and on

which the project detail is now based.

Why has East Wall formed part of every alignment considered as part of the process

of identifying the route?

To minimise impacts on East Wall tunnelling should occur from both ends of the

route.

Construction impacts should be shared between East Wall and Inchicore not placed

entirely on East Wall.

The decision to tunnel from East Wall only was not communicated to East Wall

residents and has since made it difficult for the community’s voice to be heard.

Why is it acceptable to tunnel only from one end with two tunnel boring machines

when tunnelling from both ends using 4 TBMs would dramatically reduce the impact

on East Wall?

Why is it considered acceptable that East Wall experienced the majority of impacts

arising from the project with none of the benefits?

There has been a lack of consideration shown for the East Wall community in all

aspects of the project to date including the EIS.

East Wall should benefit from this project by way of a new station or permanent free

shuttle bus transport to a station, a local employment scheme, funding for community

projects etc.

An oral hearing is requested.

The residents request that the oral hearing deal with East Wall as a single module, this

will make it more manageable for the residents.

Project issues which require retention.

The residents request that An Bord Pleanala appoint independent experts to review all

sections in the EIS to ensure that it is credible.

The community wants to know the levels of actual noise which the project will

generate within East Wall.

The community wants to know the levels of actual vibration which the project will

generate within East Wall.

The community wants to know how far dust will actually travel within East Wall and

the impacts of this dust on residents’ health.

The community maintains serious concerns about traffic impacts.

The residents of East Wall seek a restriction of working hours for all parts of the

project from 8.00a.m. to 8.00 p.m. Monday to Friday, 8.00 a.m. to 3.00 p.m. Saturday

and Sundays and Bank Holidays should be treated as Sundays and not as weekdays.

No night time work should be permitted.

The EIS is vague on precisely how much spoil may be transported by rail therefore it

appears that road based transport of spoil will dominate.

If this is the case then spoil should be taken from Inchicore directly to the M50.

The proposed traffic management plans require serious revisions.


The residents of West Road consider that either a no new bridge option or a

repositioned bridge option would reduce impacts on existing residents. The proposed

new bridge is located directly opposite residential dwellings. The existing bridge is

not.

If this bridge has to be constructed then it should be no wider or higher than the

existing bridge.

The bridge should not be constructed from metal as such bridges are extremely noisy.

The residents of West Road seek an alternative route for the tie-in between Dart

underground and the northern line.

The residents of West Road seek the relocation of the operation control

centre/management suite and the relocation of the traction sub-station.

The residents of East Wall seek the reorientation of the maintenance facility such that

noise is directed away from East Wall and they also seek the movement of the

intervention shaft located close to Blythe Avenue away from the area.

Proposed utility diversions utility connections and associated works will involve

serious impacts for East Wall residents, these impacts need to be minimised.

Existing sewage system is at capacity.

The residents of East Wall are concerned that the proposed works will result in future

flooding in the area.

The proposed Property Protection Scheme requires careful scrutiny.

As proposed the Property Protection Scheme aims to minimise the exposure of the

project contractor to any damage to properties arising from the project.

The residents of East Wall consider that the scheme needs to be substantially adjusted

in order that all homes in East Wall which may be potentially impacted on by the

project are protected from the impacts arising.

The residents of East Wall seek clarification of and confirmation that all mitigation

proposals set out within the draft railway order and those subsequently required by An

Bord Pleanala are enforceable.

The noise and vibration plan, the Environmental Management Plan, the construction

code of practice and the TBM mitigation plan, traffic management plans etc. have not

been produced and are unavailable for scrutiny by residents.

These plans should be produced prior to the grant of any railway order and made the

conditions of same.

The contractors should have to work to the requirement of the plans that form part of

the assessment process not to some non assessed versions.

The residents of East Wall seek the appointment of an independent arbitrator in

relation to the implementation of all conditions applied by An Bord Pleanala to a

railway order.

Summary of issues arising in the submissions made to the Protect East Wall Group.

Section 1:

1. An oral hearing is requested.

2. A number of mistakes in the draft railway order and an EIS have been noted.

3. Concerns have been noted with respect to the validity of the draft railway order

application

4. Concerns have been noted that the decision of the metro north will not be

available prior to the making of this submission.

5. The community requests that its costs should be covered by Section 145 of the

Planning and Development Acts.


Section 2:

1. The project would impact negatively on the community.

2. The residents of East Wall have noted concerned in respect of initial testing work

undertaken at East Wall.

3. It is not an industrial area, it is a residential area.

Section 3:

1. CIE has identified East Wall as the location of maximum project impacts.

2. The choice of East Wall should be reviewed.

3. East Wall is to experience the most project impacts for the longest.

4. Concerns were raised over the project’s starting date which is not disclosed in the

details submitted.

5. The draft railway order sets out up to nine years of project work to East Wall.

6. Alternative tunnel boring strategies should be considered.

7. The residents seek a project completion guaranteed bond to ensure that the project

is finished.

8. The residents maintain concerns over the proposed project phasing which appears

designed to maximise the length of time works will take place at East Wall.

9. The proposed construction strategy should be compared to alternative strategies

involving either tunnelling from Inchicore only or tunnelling from both ends.

10. Proposals are provided for only the eastern portal tunnelling option.

11. The proposed tunnelling approach would minimise community impacts, no single

community should experience the vast majority of impacts.

12. A two tunnel boring machine strategy will take longer and impact more heavily

on the East Wall community and on the city.

13. CIE should be asked to explain why it proposes to avoid the Inchicore community

at the expense of East Wall.

14. East Wall experiences all the pain but no gain from the project.

15. East Wall will not get a station.

16. CIE should consider possible community compensation measures such as a train

station, local employment commitment funding for community benefit etc.

Section 4:

1. Public consultation with the East Wall Residents has been poor.

2. East Wall got a public presentation of the project not a pubic consultation.

3. Residents’ concerns have not been addressed in the EIS, they have been

amplified. Consultation with CIE did not include tunnelling from East Wall only.

4. The EIS is now based on strategic decisions made without consulting East Wall

residents.

5. The residents request that the strategic decisions made on the draft railway order

and on which the EIS is now based be revisited on the basis that no project should

be imposed on the community.

Section 5:

1. There is a need to limit working hours in order to mitigate proposed impacts on

East Wall.

2. 24 hour work seven days a week cannot be accepted in such close proximity to

residential dwellings and the East Wall Residential community.

3. CIE wants to speed up the project it should use a four tunnel boring machine

strategy and to start from both ends not work nonstop from East Wall.


4. No work should take place 24 hours a day.

5. Working hours for construction of portal structures should be limited.

6. The operation of commercial vehicles should be limited to certain times.

7. No deliveries to sites at East Wall should occur outside of normal working hours.

8. The EIS refers to how work required to reconfigure the existing railway

infrastructure at the locality is proposed to occur in the evenings and weekends,

this cannot be permitted.

9. All trains involved with the project should be marked and only operate during

normal working hours. A restrictive definition of emergency work should be

applied.

Section 6:

1. While the EIS makes every attempt to limit the reference to high levels of noise

in East Wall during the project’s construction operation it is clear that East Wall

will if all aspects of the project are permitted as currently designed to be a noisy

place.

2. The noise impact assessment requires further examination by an independent

expert as it does not currently appear to stand up to scrutiny.

3. An independent assessment of noise impact is especially required at East Wall

where the nosiest works are supposed to take place.

4. The EIS baseline for noise is not acceptable, and independent review of the

proposed approach to identifying a noise baseline requires review.

5. The EIS predicts high noise levels (but not as high as the Searson report prepared

for the observers) without mitigation measures being implemented and being

effected.

6. The Searson report maintains concerns over whether the proposed noise

mitigation measures are trusted.

7. There are concerns arising in respect of the credibility of the EIS Noise Impact

Assessment.

8. The residents are concerned as to how the results of the assessment of noise

impacts are shown.

9. An insufficient number of noise receptors were assessed as part of the noise

impact assessment.

10. The observers provide a list of specific concerns relating to noise mitigation

measures.

11. A binding commitment is required from CIE in respect of acoustic barriers.

Section 7:

1. The East Wall residents and properties require protection from vibration, the EIS

does not satisfy the concerns of the residents.

2. The residents do not consider the baseline vibration monitoring at East Wall to

have been adequate.

3. Concerns will respect vibration arise from the effect vibration may have on

individuals in the families and on their properties.

4. The EIS settlement criteria require review as there appears to be a bias versus

standard inhabited dwellings.

5. Following consultation with O’Ceallaigh’s solicitors the residents retain the right

throughout this project to take legal action in the event of damage to any property

within East Wall.


6. The proposed property protection scheme appears to be an exercise in public

relations.

7. If CIE wants to avoid future legal cases it needs to make claims for damages

simple and to make any settlement in respect of damages acceptable.

8. While the EIS places considerable emphasis on what is called a noise and

vibration plan it is noted how this plan has not yet been produced.

Section 8:

1. There will be an air quality impact on East Wall if the project is granted as it

stands.

2. The main concern residents have is over dust and especially dust particles.

3. The observers provide a list of particular areas of concern relating to dust.

4. The residents of East Wall do not consider the EIS to be credible in respect of

dust movements and the impacts of same.

5. The residents request the use of NRA guidelines for distance dust travels during

roads projects, for use at East Wall, where the spoil from over 7.6 kilometres of

tunnelling is to travel through.

6. The dust minimisation plan in respect of works at East Wall also appears to lack

credibility as the measures proposed are either inadequate or unlikely to be

implemented as predicted by EIS theory.

7. Reference is made to an Environmental Management Plan however this has not to

date been produced and therefore residents have had no opportunity to respond to

it.

8. How will the dust minimisation plan be enforced?

9. The observers propose a number of measures to minimise dust. To end the

observers also have air quality concerns relating to traffic generated and also

pollution from diesel supply train serving the TBMs.

Section 9:

1. The location of the eastern portal at East Wall has been presented as a fait

accompli. No other location has been considered.

2. Tunnelling from East Wall only is a recent decision made by CIE to avoid

Inchicore, East Wall appears to be considered a location of less opposition.

3. All spoils should not be removed from East Wall only but split with Inchicore.

4. On-going spoil storage at East Wall will have a visual impact and settlement of

land and property may arise from the weight of the wet spoil heaps.

5. Surface work and cut and cover work at East Wall is significant and greater than

that at Inchicore.

6. The proposed operation control centre/management suite at West Road should be

moved outside of East Wall.

7. The proposed maintenance facility should be either moved to another location or

its position revised to minimise noise impacts on East Wall residents.

8. The location of the eastern intervention shaft will cause impacts on East Wall.

9. Works proposed at West Road cannot be justified.

10. The proposed location of the ESB sub-station requires review.

11. The traction sub-station on West Road would have noise, traffic and visual

impacts.

12. Proposed works to utilities need to be further articulated by CIE and further

examined by the residents


13. A range of temporary works are proposed as part of the project, these temporary

works need to be individually reviewed as the impacts of each area of works can

be substantial in East Wall.

14. Proposed works at and behind Abercorn road are substantial and will impact on

existing residents.

15. The eastern portal site will contain a range of equipment which will impact on

residents of East Wall.

16. Residents are concerned over the impacts which will arise from the TBM launch

chambers. The TBMs will be on the surface with associated additional noise and

vibration.

17. Details of rail track removal and new rail track installation required as such works

will cause significant noise and disturbance.

18. The backup haul route to the rear of Abercorn Road and Ervine Terrace should

not be permitted.

19. Residents are concerned over the extent of fill between eastern portal and cut and

cover section.

20. Residents are concerned over the proposed demolition of signal box and water

tower.

21. The proposed recharged well behind no. 14 Abercorn road needs to be explained.

22. Why is there no derailment barrier along the outside of the goods line to protect

houses on West Road?

23. The residents are opposed to CIE’s request for four active tracks to be installed

over the River Tolka at East Wall Road.

24. No workers should be accommodated on CIE sites within East Wall during the

project.

25. Residents are concerned that the impact of the project on St. Joseph’s church.

26. Future plans for attracting CIE services should not be included.

27. There is a risk from unexploded ordinance at East Wall which may endanger

residents.

Section 10:

1. Many residents have existing medical conditions and these conditions may be

worsened by the project’s serious impacts.

3. Impacts on health of residents may arise from exposure to noise vibration, air

pollution, dust particles etc.

4. If the scheme can have a property protection scheme if can have a Health

Protection Scheme too.

5. The residents have therefore proposed that a Health Screening Scheme is adopted

by CIE as part of this project, and then in the event that a person’s condition

worsens it would be possible to determine whether the worsening condition does

or does not arise from the impacts of the project.

6. CIE should cover costs of health expenses incurred as a result of construction.

7. Concerns relating to emissions from rail engines and concerns in relation to the

control over vermin.

8. Emergency vehicle access.

Section 11:

2. The project proposes the most significant traffic impact should take place to East

Wall.

3. The traffic impact assessment lacks credibility and requires an independent

review.


4. The level of construction traffic movements predicted for East Wall is excessive.

5. Commercial vehicles should operate only between the hours of 8.00 a.m. and 8.00

p.m. Monday to Friday and 8.00 a.m. and 3.00 p.m. Saturday and Sundays.

6. Construction traffic proposed at different stages of the project requires

independent assessment.

7. All spoil moved by commercial vehicles should travel on Sheriff Street. The

backup haul route should not be used.

8. Abercorn Road is not appropriate for HGVs.

9. How will construction traffic operate when the O2 is being used?

10. Traffic management proposals raise a number of concerns.

Section 12:

1. During construction and operation the project will cause a significant visual

impact on the residents of East Wall, these impacts will be experienced primarily

by those properties which border construction compounds or those located along

a road down which construction traffic will pass.

2. The observers note the areas of particular significant visual impact concerns.

3. Dart underground proposes dramatic alteration to the urban fabric and

features of East Wall during the project and after the project is completed.

4. The visual impact of the project at East Wall is almost ignored within the EIS.

Five of the residents are concerned over the proposed visual mitigation measures

which appear inadequate.

Section 13:

1. Construction water from the eastern portal will discharge to the Liffey

estuary via existing DCC outfalls, the residents are concerned over surface

water contamination.

2. De-watering at the eastern portal would result in the lowering of groundwater

levels in the immediate area of excavation, the residents of East Wall seek further

information in respect of an impact referred to as “moderate adverse”.

3. It is proposed to substantially raise site levels within the project areas, residents

are concerned that while the project may in the future be protected from flooding

East Wall may become more prone to flooding from additional run off from the

new higher ground areas.

4. The EIS does not adequately address how the proposed temporary lowering of

water table which will occur outside of the excavations may also impact on

settlement.

5. The East Wall residents are concerned that the existing sewage system which is

already at capacity and may be proposed to serve additional substantial demands

from this project.

6. The residents are not satisfied that the EIS has confirmed that wastewater pumped

out of the portal will not be contaminated.

7. The residents are concerned over what it proposed for the significant quantity of

water which is to be pumped out of the tunnels.

Section 14:

1. Specific one to one consultation has not to the knowledge of the residents taken

place in respect of any residential property in East Wall.


2. The design of DART underground does not appear to avoid adverse impacts and

property is claimed.

3. The proposed Property Protection Scheme Settlement zone needs to be

substantially widened.

Section 15:

1. Dart underground will have extremely significant impacts on East Wall unless

revisions to the scheme are made; the residents trust that An Bord Pleanala will

apply all relevant planning policies with respect to community protection.

2. Section 4 Planning and policy of the EIS fails to include the mention of the East

Wall Area Action Plan 2004.

Section 16:

1. There is a need to ensure that if a railway order is to be granted than the conditions

attaching to it are enforceable.

2. Enforceable means policing a contractor as this project will be built according to

CIE by a contractor.

3. It is not sufficient for CIE to refer to a construction code of practice, and noise

and vibration plan, an environmental management plan, a TBM mitigation plan,

traffic management plans, a dust minimisation plan etc. as plans which will be

produced by the contractor.

4. The East Wall community should be given an opportunity to view all of these

plans prior to the granting of any railway order.

5. In order to police the contractor an independent arbitrator should be appointed

whose sole responsibility is to check that all measures proposed to protect people

and property at East Wall are implemented in full.

6. The independent arbitrator should be available via an emergency helpline 24

hours a day and should be immediately able to respond to any problems arising.

7. There should be an emergency plan in place to protect residents of East Wall in

the event of a major issue arising during construction or operation of this project.

8. No matter how well managed this project will inevitably fail to prevent some

impacts or fail to mitigate others.

9. The proposed development will also impact on the value of properties in East

Wall generally, the observers refer to a report as prepared by Andrew Foran head

of valuations at Gunne Residential.

10. The residents of East Wall consider that the only approach to ensuring that all

measures aimed at protected East Wall residents are enforced is for a charter of

residents’ rights to be produced.

The observers request that during construction and then during the operation of the

station that local residents be given an out-of-hours contact number for CIE staff with

the experience and the authority to deal with any problems which may arise.

169. Philip McGovern & others, 29 Church Road, East Wall, Dublin 3


The EIS does not provide adequate mitigation measures to protect the residents of

East Wall.


Church Road is one of the locations in East Wall closest to the proposed construction

site.

The construction of the eastern portal and ventilation shaft level will have a serious

negative visual impact on Church Road.

Concerns expressed over increased noise, vibration, pollution and dust from

construction of proposed structures.

Increased noise, vibration, pollution and dust from proposed increased in rail

movements.

Increased noise, vibration, pollution and dust from proposed haul road.

Increased noise, vibration, pollution and dust from works undertaken to temporarily

divert the existing utilities and the reinstatement of same.

Enormous reduction in the quality of lives in the area.

Loss of amenity.

Increased stress and frustration.

Access to observers’ homes.

Exacerbation of existing health problems.

The lack of fresh air as observers will not be able to open their windows.

Properties and cars being permanently dirty.

Car parking chaos. No measures are given in the EIS to facilitation of construction

work as car parking.

Loss of off-street parking.

Lack of consideration of residents of East Wall.

24/7 working hours totally unacceptable.

Residents will suffer from sleep deprivation to light, noise and air pollution from

overnight construction works.

In the interest of fairness it is asked that 4 TBM option and tunnelling from both ends

of the route be considered.

The EIS disregards the possibility of hazard to human health arising from this project.

There are no measures for vermin control in the area, all mitigation measures as set

out in the EIS are to protect construction workers.

Serious concerns for traffic safety issues.

Hazardous waste being transported by road.

Regard to the high level contamination and mitigating measures in the EIS are vague.

As mitigation levels set out in the EIS are not based on ambient sound levels, the

danger to the health and wellbeing of residents has not been given adequate

consideration.

The Property Protection Scheme is based on a predicted damage to properties within a

restricted alignment zone to a maximum limit of €30,000.

The alignment zone is inadequate as it does to include Church Road.

There will be serious depreciation in the value of properties of the observers.

The EIS largely portrays East Wall as being industrial in nature and this is not so.

It is a settled residential area that will suffer major negative visual impact from the

construction proposed strident obtrusive features.

No effort has been made to sensitively integrate the new structure into the existing

settled residential area.

There is no community benefit whatsoever for the residents of East Wall.



It is requested that an independent arbitrator be appointed.

170. Leslie Maher, Zen Hair and Beauty, 32 Church Road, East Wall, Dublin

3.


The observer has operated a hair and beauty salon on Church Road for 30 years.

The EIS does not provide adequate mitigation measures to protect the residents of

East Wall against a severe detrimental impact from the proposed Dart Underground

project.

The observer has strong and real concerns that the business will suffer and will

eventually result in a loss of livelihood.

The observer has never been approached by any representative of Iarnrod Eireann.

The remainder of the observer’s submission is as that submitted by Philip McGovern

and Others, Church Road, East Wall, Dublin 3.

171. Helen McCabe and Others, 11 Church Road, East Wall, Dublin 3.



The observers support the Protect East Wall Campaign.

East Wall has over many years had serious flooding problems particularly in 1954,

2002 and more recently in July, 2009.

The Board should be made aware of the fact that CIE were directly implicated in the

major floods of 1954 and 2002.

The observers are concerned that the works involved in the Dart underground will

increase the flood risk in the area once more.

Any Railway Order granted should include protection and provisions to alleviate the

concerns of the observers.

172. Susie Lynam and Others, 133 Church Road, East Wall, Dublin 3.


CIE have shown little or no regard for the fact that East Wall is a very well

established neighbourhood with a number of unique aspects and not an industrial area

as described in the EIS.

East Wall is one of only a small number of villages within Dublin City that does not

have a main arterial route through it, giving it a very tranquil atmosphere.

The area has limited pedestrian vehicular access points.

If the area were to benefit from a new station this would make it a more desirable

place to live and possibly even see some of those ghost units in a number of the

residential blocks in the area being purchased and occupied.


That East Wall is the only option proposed for tunnelling seems like an incomplete

assessment of the Dart underground.

Why should the burden of the entire scheme be located on one area? When CIE own

73 acres of land within Inchicore why was this completely dismissed as a potential

tunnel site to be used in conjunction with or instead of East Wall?

Full description of the mitigation works have been left to the discretion of the

contractor.

This is such a vital aspect of the EIS and should be agreed in writing and reviewed by

an independent expert before any approval is given for Dart underground.

Specific concerns raised in relation to noise, vibration, dust, air quality, hazardous

waste, vermin and dewatering.

A request for 24/7 working practices is unacceptable.

Concerns expressed in relation to the No. 53 bus services.

Concerns expressed in relation to the displacement of parking on the streets of East

Wall.

An option whereby spoil could be removed out of the residential area via the existing

train lines that run through the CIE yard where trucks could be filled and exit via the

Port Tunnel along non-residential portion of the East Wall Road should be

investigated.

East Wall is an area that suffered at the hands of flooding over the years.

Red terracotta tiles are not an acceptable option for all of the proposed buildings in

the area.

The new bridge location increases the walking time for all pedestrians and the

reorientation of the road creates more blind spots not ideal for road and personal

safety.

The observers are in full support of the Protect East Wall Campaign.

173. Bernie Fleming and Others, 5 Church Road, East Wall, Dublin 3.


The proposal will have a very negative impact on the area.

The area is going to be devastated by these on-going works.

The area has suffered enough in the past few years with the Port Tunnel construction

and all the apartments that surround the area.

It is very much a health hazard, 360 trucks carrying hazardous waste through the area,

all hours of the day and night 24/7.

Concerns expressed over vermin being disturbed.

Concerns expressed over air quality and dust.

Concerns expressed over loss of sleep.

A lot of homes in the area have been flooded twice in the past few years.

The value of their homes will go down.

Impact of road closures and the impact it will have on the No. 53 bus service.

Emergency service access.

Their local park and wildlife in the River Tolka will also be badly affected by all the

drilling noise and dust.

Structure damage to homes.



174. Ann Flanagan and Others, 48 Church Road, East Wall, Dublin 3.


Damage to property.

Impacts from boring works.

Changes to the water table.

East Wall has a long history of flooding.

Impacts of trucks and other vehicles moving through the narrow streets of the area.

Vast increased traffic volumes into and out of and around the area.

Risk to vulnerable members of the community.

Access for emergency vehicles.

Increase travel time into and out of the area whether by car or by foot.

Increased noise levels. Loss of sleep.

Risk of hearing damage.

Increased stress levels.

Devaluation of homes.

Structural damage to the residents or detriment to property.

Difficulties associated with selling the home.

Levels of dirt and waste released directly into local area.

Earth moving will affect the vermin numbers.

The content of the waste being moved through residential area.

The manner in which waste will be moved.

Pollution of the air.

Increase in general dirt in the area.

Parking implications.

Project duration and hours of operation.

Implication for the No. 53 bus service.

The community should have a direct and independent liaison for all stages of this

process.

A forum must be agreed for dealing with residents’ concerns and must have the

involvement of all stakeholders.


The observers support to Protect East Wall Group and their objectives.

175. Eugene Gilsenan, 43 Church Road, East Wall, Dublin 3.



Noise pollution.

Air pollution.

East Wall is built on reclaimed lands.


Some parts of East Wall area are below sea level and have been flooded on two

previous occasions.

The water table level in the area is tidal due to the River Liffey and some gardens

experience flooding with heavy rainfall.

Any operational control building should be placed as far away from homes as

possible.

Clarification is needed in relation to the type of maintenance and machinery

movements to and from the maintenance building at night-time and the impact this

will have in the future for residents on Abercorn Road, Church Road and Blythe

Avenue.

High intensity lighting must be positioned and used with sensitivity to the

surrounding residents.

Concerns raised in relation to potential of noise pollution from the ventilation shaft.

The cut and cover structure should be of the highest quality soundproofing material

and beeping of horns from Dart trains should be monitored.

The observer requests clarification and explanation in relation to the proposed

recharge well.

The signal box on Church Road should be retained, it is a 19th

century original

building.

The proposed operational control centre is very intrusive to homes on West Road.

The proposed traction station should be relocated south of the new bridge and lowered

so as not to be intrusive on residents of West Road.

Relocate the new bridge either north to Strangford Gardens or south to Strangford

Road East as it is unfair to residents to have the bridge ending facing homes on West

Road in a T junction.

An increase in height of the noise barriers on West Road to East Wall Bridge is

essential and should also include proposals in relation to Stoney Road. Concerns

expressed over potential settlement and vibrations.

The observer requests access to their own independent experts.

The working hours in the EIS are excessive and need to be more realistic and pre-

agreed with residents.

Further landscaping of all railway lands in East Wall, North Wall and North Strand

area should be agreed with residents’ groups.

Has the possibility of using four TBM machines, two from Diageo lands at Heuston

Station or Inchicore being explored?

The Board is expected to grant an oral hearing.

176. Steve O’Connor and Others, c/o 167 and 168 Church Road, East Wall,

Dublin 3.



The observers question is there any compensation package for residents for all the

inconvenience, disturbance, health risk and possible structural damage and

devaluation of property in the area.


There is a higher risk of flooding with so much construction and destruction in the

area.

The observers support the East Wall Community’s objectives.

The East Wall is a residential area not an industrial one.

The value of their houses would be zero.

The observers will have no privacy.

There is sure to be structural damage with all the heavy machinery operating only

yards away from their houses.

The houses in East Wall are built on reclaimed land.

All the vibrating will have a damaging effect on the foundations and structure of the

houses.

6 to 10 years of disruption and convenience and yet no benefits for East Wall.

Concerns expressed over disturbance of vermin.

Concerns expressed in relation to health issues.

The dirt and dust in the air will be damaging to health.

Work will be going on 24 hours a day, 7 days a week.

All the tunnelling is getting done from the East Wall end and not from the Inchicore

end.

Truck movements generated through residential area.

A station should be provided at the proposed operation control centre.

If East Wall is not getting a station surely the residents should at least get easier

access to the Spencer Dock via a new bridge.

The submission has 10 signatories representing residents from Church Road, Malachi

Place and Blythe Avenue.

177. James Lee, 69 Church Road, East Wall, Dublin 3.


An oral hearing should be held.

It could bring clarity to a number of points being raised.

The project contains a number of flaws.

The recent decision by CIE that both boring machines be located at the East Wall end

of the tunnel is discriminatory and unfair.

Concerns expressed over noise, dust and possible structural damage.

Concerns expressed over the potential impact of the development on the observer’s

health.

Concerns raised over the presence of contaminated soil on the construction site.

Concerns raised in relation to proposal to provide a truck egress route between

Church Road and Abercorn Road/Irvine Terrace and the implications of this on dust,

noise and health concerns.

As the issue of removing spoil by rail being adequately considered.

Concerns raised over possible traffic diversions, increased traffic flows and impact on

local bus service.

Within the area the option of an additional station has been actively canvassed.


178. Christopher Kavanagh, 20 Strangford Road, East Wall, Dublin 3.


The impact will be serious from the observer’s health point of view.

The observer outlines his health situation.

The observer is concerned that the negative impact on the air quality will have a

detrimental effect on his health.

The consequences on the observer of having breathing difficulties could be fatal.

The Board is requested to take this into consideration in its deliberation.

179. Adrienne Redmond and Others, 6 Strangford Gardens, East Wall, Dublin

3.


The new dual lines running close to the observers’ houses.

The observers are very concerned with the level of excavations in this location.

Proposed rock breaking and tunnelling works on a scale such as this would be deemed

extreme and constitute to be at “industrial grade level”.

Concerns raised in relation to the proposed new bridge works.

Concerns raised in relation to noise on a 24/7 level.

Massive disruption over 6 year period will restrict access to their homes.

Concerns raised in relation to potential soil contamination.

Concerns raised in relation to disruption of the works over 6 year period, the

devaluation of their homes, the visual impact of the new bridge and administration

offices, the increased use of the track by trains which will sound a horn before

entering and leaving the tunnel.

No direct benefits to the community.

The parking ban in the area will add further inconvenience.


The observer submission has nine signatories all from Strangford Gardens.

180. Patricia Mulhall, 126 Caledon Road, Drumcondra, Dublin 3.


Concerns raised in relation to the health risk the proposed development will create.

Concerns raised in relation to levels of hazardous waste involved in the development.

Impact of high dust and noise levels.

The increased level of traffic will severely affect the safety of the environment.

Impact on parking for residents.

No station proposed for East Wall.

The area is getting all the disadvantage but none of the benefits.

Concerns raised in relation to structural damage and effect on the value of property.



181. Shane Roe, 18 Moy Elta Road, East Wall, Dublin 3.


The EIS is no longer valid as it was based on the premise that only one boring

machine would be assembled and operated from East Wall.

It is now proposed that two machines would be assembled and operated from East

Wall.

The movement of contaminated soil and the generation of dust etc., is likely to create

significant health risks to the residents of East Wall.

There would be unacceptable noise disruption from the tunnel boring machines and

trucks moving material from the tunnel.

Structural damage will be caused to homes in the area.

The proposed permanent control centre at Ossory Road will be an eyesore and would

impact on the privacy of homes on West Road and Moy Alta Road.

Individuals and families will be unable to sell their homes in East Wall.

The development will continue for at least 6 years.

Up to 20 trains per hour will pass through East Wall when the development is

completed.

East Wall will be significantly disadvantaged by the development but would not

benefit from the final product.

The observer wishes to object to the manner in which CIE has dealt with the people of

East Wall with regard to the development.

One tunnel boring machine should be assembled and operated from Inchicore.

East Wall should get a station.

A detailed operational plan should be agreed with the East Wall Residents

Association.

Significant funding to be provided by CIE to East Wall as compensation for the

disruption.

182. Laura O’Connor, 130 Caledon Road, Drumcondra, Dublin 3.


Concerns raised in relation to noise pollution and dust from the construction and the

health risk associated with the project.

The lack of parking due to traffic and machinery. The negative impact on daily bus

route due to closure of roads. The difficulty in driving in and out of the area. The

difficulty in getting to the North Strand with the closure of Ossory Road.

The huge increase of traffic.

The risk of structural damage to property.

Property will devalue.

Will be difficult to sell property in the area.

No station for East Wall.


The visual impact of all the construction hoarding, footbridge and office block.

The observer supports the Dart Underground however she feels that East Wall will

bear the brunt of the years of construction and pollution and will not get any of the

benefits.

The observer requests an oral hearing on behalf of the East Wall Protection Group.

183. Stephen O’Brien and others, c/o 9 Hawthorn Terrace, East Wall, Dublin

3.


One of the observers runs a small business from his home.

It is clear to the observer that the noise and vibration caused by the works will be an

intolerable disruption to his work much of which is computer based.

Much of his business involves collections and deliveries without the crucial Ossory

Road access to the city he can only foresee terrible traffic delays for all in the area.

The houses on Hawthorn Terrace/Oxford Terrace are nearly 170 years old, some

older.

These structures cannot sustain the kind of vibrations caused by the proposed boring

machines and the paltry €30,000 offer for possible damage caused is quite frankly

naive.

It is obvious that the project will have a further negative effect on the value of

properties in the area.

As an asthma suffer the observer is concerned about the dust levels.

Concerns in relation to other negative health issues are also raised these include noise

disruption and general destruction from the project.

The No. 53 bus service will be restricted for this period.

The physical environment will be adversely affected in the long term as well.

The creation and visually intrusive permanent structures is of concern.

Concerns raised over glaring security lights.

There are no positive outcomes for the people of East Wall from the project.

No station is proposed.

The area will continue to be encircled by rail infrastructure.

The observers request an oral hearing on behalf of the East Wall Protection Group.

The observer submission has four signatories.

The observer submission also includes a station walking catchment map. It indicates

that Hawthorn Terrace is not served by either the proposed Dockland Station or

Connolly Station.

184. Karen Broderick, Irvine Terrace, East Wall, Dublin 3.


The proposed construction will have a significant impact on the observer financially,

professionally and personally.


This is an Irish Rail project to which the observer should not be burdened with the

negative side effects the construction would bring over a period of 6 to 10 years.

The observer has made significant investment in the renovation of her home. The

level of work intended for this project during construction and operation phase will

have a serious impact both structurally and aesthetically.

Concerns raised in relation to cracks, dust, disruption of services and noise.

Concerns raised in relation to construction, road damage, light pollution and vermin.

185. Karen Greene and Others, 23 Shelmalier Road, East Wall, Dublin 3.


Concerns raised in relation to health risks, noise, dust, traffic, parking, hazardous

waste, no station for East Wall, structural damage, overlooking, impact on privacy,

visual impact, property value and value damage.

All of the disadvantages for at least 6 years yet none of the benefits the rest of the

country will get.

An oral hearing is requested on behalf of the East Wall Protection Group.

186. Michael Muldowney, 7 St. Barnabas Gardens, East Wall, Dublin 3.


The proposed closure of Ossory Road and West Road would cause serious disruption

to residential traffic who use this route almost exclusively as a direct route to the city

centre.

This closure will also reduce the amount of parking available to residents.

The current proposed plan regarding the operation of large heavy vehicles in and out

of the East Wall area for the duration of the project seems hugely impractical at least

and very dangerous at worst.

These are narrow residential streets and with cars parked on both sides, it is often

difficult for 2 cars to pass each other.

The sharp turn onto East Wall Road from West Road would cause massive disruption

to a main traffic artery.

The current plan needs to be revised to allow transportation and removal of all

materials by rail.

The proposed closure of Sheriff Street will also appear to signal the loss of the 151

bus service which is essential for the observer in getting across the city.

The amount of proposed excavation of contaminated soil will generate a huge amount

of dangerous dust.

The proposed excavations will be open to the elements so all dust generated will be

blown into the residential area nearby.

It is quite possible that heavy excavation, pipe driving and construction of this nature

on a long term basis will result in structural damage to property.

Noise pollution is the greatest concern about the proposed project.

It should not be a 24 hours a day problem for 6 years.


No work should be undertaken between the hours of 8 p.m. and 8 a.m.

The proposed development could have a serious negative impact on property values.

No effort has been made by CIE to incorporate a Dart station anywhere for East Wall

residents which is unbelievable given the area’s proximity to all the existing rail lines.

An oral hearing is requested on behalf of the East Wall Protection Group.

187. Declan Rogers, 34A Kincora Avenue, Clontarf, Dublin 3.


The effect of the development on the tenants who have businesses in the Ossory

Industrial Estate in East Wall is of concern to the observer.

General impact concerns relating to 24/7 working hours, flooding, sewage capacity,

traffic chaos and 6 years disturbance.

Environmental concerns relating to noise levels, vibration, hazardous waste, dust,

fumes and vermin.

Traffic concerns relating to access to industrial estate, diversions, road closures,

parking, trucks and heavy machinery.

Health risk concerns relating to diseases associated with vermin and existing

conditions worsened.

The observers face losing tenants due to the scope and enormity of the works

involved.

The disruption to the daily running of business in Ossory Industrial Estate will be

huge.

The observer is very concerned with the valuation of his premises and future planning

issues concerning the estate.

The observer fully supports the East Wall Community’s objections.

188. Business Owners, Ossory Road Industrial Estate, Dublin 3 - Michael

Kennedy and Other.


The noise and vibration of the work being carried out will be unbearable.

There will be a lot of dust, vermin and hazardous waste which will incur bad air

quality.

The use of at least 360 trucks a day will add chaos to the area and present an added

danger to employees and customers.

The valuation of the observers’ buildings will decrease and the structural damage that

will be caused during this development is of concern.

If this development goes ahead it will make it very difficult for customers to visit the

observers’ factories causing observers to lose business and may leave the observers

having to let employees go.

It will lead to road closures, diversions, parking facilities, extra vehicles in the area

for workers employed for this development making it more difficult for the employees

and customers to gain access to the observers’ businesses.


The time structure for this development of 6 years plus and the 24/7 working hours

and the relocation of the West Road Bridge will cause a lot of disturbance.

Concerns raised in relation to emergency access during this development.

The business owners of Ossory Road Industrial Estate fully support the Protect East

Wall Campaign.

The observers request an oral hearing on behalf of the business owners in Ossory

Road Industrial Estate.

The observer submission has 15 signatories representing various businesses in the

Ossory Road Industrial Estate.

189. Declan Roche and Others, c/o 75 St. Mary’s Road, East Wall, Dublin 3.


The observers have a number of concerns relating to health risks including noise,

dust, loss of sleep, chest infections etc.

The observers are concerned about damage to property, decrease in value of property,

loss of light, privacy etc.

Concerns raised in relation to loss of bus service and loss of sense of community.

The observers are very concerned about all the work being done from East Wall.

It was impossible to read all the EIS in six weeks, this is most unfair.

Access to the community will be severely disrupted due to road closures and

increased traffic levels especially trucks carrying soil.

Flooding and negative visual impact are also concerns.

East Wall is a residential area.

The observers are concerned about the displacement of vermin caused by the

proposed works.

The observers support the submission by the Protect East Wall Group.

The observers request an oral hearing on behalf of the Protect East Wall Group.

The observer submission has a number of signatories representing five dwellings on

St. Mary’s Road in East Wall.

190. Eva Dillon, Daisy Days Community Childcare, Sean O’Casey Community

Centre, St. Mary’s Road, East Wall, Dublin 3.


The observer operates a crèche for young children aged 6 months up to 5 years.

The observer is very concerned about the impact the work will have on the children’s

health and wellbeing and also on the business.

The observer requests an oral hearing on behalf of the East Wall Protection Group.

The submission has five signatories.

191. Gerry Fay, Chairman, North Wall Community Association, 77 Seville

Place, Dublin 1.



The North Wall Community Association is duly elected by the people of North Wall

at an open meeting to represent and safeguard the interests of the community and the

people of the community.

The North Wall is in transition, major development has taken place over the last 13

years and much more is at planning stage, this will add considerably to the number of

people living and working in the North Wall.

In this context plans for the new Dart station have to be welcomed.

The issues of concern the observer wishes to raise relate to the building and

construction stage.

Iarnrod Eireann have put in place very impressive safeguards but these can only be

fully effective through strict monitoring.

The observer is requesting that monitoring should become a condition at planning

permission.

The issue of local employment in the current climate is important.

Interestingly the site of the proposed new underground Dart station is the original site

of the passenger rail station sited directly behind the old London and Western

Railway Hotel, North Wall Quay which is still there as a listed building and will

become part of the new Dart station.

The observer believes that with the spirit of co-operation and goodwill from all sides

and a genuine regard for the concerns of local people a first class facility for the

people of the city can be delivered.

192. The Crosby’s Yard Residents Committee, c/o Hannah O’Neill, 169

Crosby’s Yard, Ossory Road, Dublin 3.



The East Wall is physically cut off from the city and its amenities to the north, south

and west.

There is no station proposed for the East Wall area and indeed a footbridge over the

Dart line is planned.

The observers request that a station be constructed instead of a footbridge.

Whilst acknowledging the importance of the development of the city’s infrastructure

the proposed development brings no benefit whatsoever to the community of East

Wall but rather further separates the neighbourhood from the surrounding areas and

amenities.


access routes during construction and additional noise, air and visual pollution during



By closing off the access between Ossory Road and West Road the residents of the

Crosby’s Yard development will be entirely cut off from their local community.

Closing West Road Bridge would pose a severe health and safety risk with specific

reference to emergency vehicle access.


It is requested that An Bord Pleanála ensure that there is safe access to the Crosby’s

Yard development at all times.

If the West Road is closed the residents of Crosby’s Yard development will have no

means of access to the No. 53 bus service.

An Bord Pleanála should ensure that access to the proposed improved Dart network

from East Wall is provided in one of two ways either by provision of a station from

East Wall/North Strand or by appropriate pedestrian access from Church Road to link

the neighbourhood to the proposed Spencer Dock station.

East Wall lies halfway between the Clontarf Road station and the proposed Docklands

station but neither station is a comfortable walking distance from the neighbourhood.


the location of the proposed OCC building.

The observers strongly object to the construction of the OCC building in an area

within such close proximity to established residential developments.

The noise pollution and negative visual impact will make the area unbearable for

residents and devalue the property immensely.

An alternative location for the OCC building should be found.

There is no mention of a noise mitigation strategy for the East Wall area from where it

appears that there are now to be two boring machines starting simultaneously and

therefore mitigation strategy at least is urgently required.

This proposed boring should not be granted permission as it will cause an intolerable

level of noise pollution making the area almost uninhabitable.

The OCC building and the traction substation will be located directly adjacent to the

Crosby’s Yard development.

The observers request An Bord Pleanála imposes a strict condition in relation to the

operation hours both in terms of the construction of these facilities and with the daily

activity with regard to noise levels.

The proposed working hours are relentless and excessive.

The proposed large-scale construction in the immediate vicinity of the Crosby’s Yard

development may interfere with the sewage system.

Concerns raised in relation to disturbance of vermin.

The proposed development will result in large amounts of hazardous waste being

produced.

Health risk concerns are raised relating to hearing, sight impairment, loss of sleep,

speech communication and sleep deprivation.

The observers request that CIE provide a 24 hour telephone number for residents in


The contact person should have authority to order work be stopped.

193. Declan Tuite and Anna Weiss, 114 Crosby’s Yard, Ossory Road, Dublin

3.



The East Wall is physically cut off from the city and its amenities to the north, south

and west.


There is no station proposed for the East Wall area and indeed a footbridge over the

Dart line is planned.

The observers request that a station be constructed instead of a footbridge.

Whilst acknowledging the importance of the development of the city’s infrastructure

the proposed development brings no benefit whatsoever to the community of East

Wall but rather further separates the neighbourhood from the surrounding areas and

amenities.


access routes during construction and additional noise, air and visual pollution during



By closing off the access between Ossory Road and West Road the residents of the

Crosby’s Yard development will be entirely cut off from their local community.

Closing West Road Bridge would pose a severe health and safety risk with specific

reference to emergency vehicle access.

It is requested that An Bord Pleanála ensure that there is safe access to the Crosby’s

Yard development at all times.

If the West Road is closed the residents of Crosby’s Yard development will have no

means of access to the No. 53 bus service.

An Bord Pleanála should ensure that access to the proposed improved Dart network

from East Wall is provided in one of two ways either by provision of a station from

East Wall/North Strand or by appropriate pedestrian access from Church Road to link

the neighbourhood to the proposed Spencer Dock station.

East Wall lies halfway between the Clontarf Road station and the proposed Docklands

station but neither station is a comfortable walking distance from the neighbourhood.


the location of the proposed OCC building.

The observers strongly object to the construction of the OCC building in an area

within such close proximity to established residential developments.



An alternative location for the OCC building should be found.

There is no mention of a noise mitigation strategy for the East Wall area from where it

appears that there are now to be two boring machines starting simultaneously and

therefore mitigation strategy at least is urgently required.

This proposed boring should not be granted permission as it will cause an intolerable

level of noise pollution making the area almost uninhabitable.

The OCC building and the traction substation will be located directly adjacent to the

Crosby’s Yard development.

The observers request An Bord Pleanála imposes a strict condition in relation to the

operation hours both in terms of the construction of these facilities and with the daily

activity with regard to noise levels.

The proposed working hours are relentless and excessive.

The proposed large-scale construction in the immediate vicinity of the Crosby’s Yard

development may interfere with the sewage system.

Concerns raised in relation to disturbance of vermin.

The proposed development will result in large amounts of hazardous waste being

produced.


Health risk concerns are raised relating to hearing, sight impairment, loss of sleep,

speech communication and sleep deprivation.

The observers request that CIE provide a 24 hour telephone number for residents in


The contact person should have authority to order work be stopped.

194. Residents of Nos. 61, 62, 63, 64, 65, 66, 67, 68, 69, 70, 71, 75 and 77 West


The contents of the observer submission on behalf of the above as prepared by BPS Planning

Consultants can be summarised as follows:

The observers support the overall Protect East Wall Group submission.

However the observers consider that the particular issues at West Road require a

separate submission.

The observers wish to point out and object to those project impacts which would

specifically impact on themselves and their properties.

The observers do not in principle oppose the Dart underground but are strongly

opposed to the lack of consideration given to the residents and the portrayal of West

Road and its environs within the EIS.

The observers’ houses are located in a quiet and leafy settled residential road in East

Wall, it is not an industrial area.

The observers have experienced no contact with CIE apart from a few inadequately

advertised public consultations, these consultations prove to be project presentations

rather than project consultations.

The proximity of heavy surface work and cut and cover work, required to facilitate

Dart underground, to properties on West Road is very close.

Additional considerations required of how the noise, dust and other impacts from the

proposed development can be mitigated.

The observers consider that a revised alignment could reduce impacts.

An alternative route for the tie in between Dart underground and the northern line

should be considered to avoid construction operational impacts on the residents.

The relocation of West Road Bridge should not take place.

The works required are substantial and will significantly impact on adjoining

residents along West Road by way of noise, traffic and visual impacts.

It is not clear why the new bridge needs to be taller and wider than the old bridge.

The cycle lane at the proposed new West Road Bridge should be removed. This cycle

lane is not required and serves only to make the bridge bigger than necessary.

The operational control centre/management suite should be relocated away from West

Road.

To facilitate this structure a bridge is being removed, a bridge built and a road moved.

At minimum the management suite should be removed to reduce height.

In the event that An Bord Pleanála decides not to require the movement of the

operational control centre elsewhere a revised site layout which reduces impacts on

the residences should be provided.

The traction substation on West Road would have noise, traffic and visual impacts,

this substation should be moved.


The observers are concerned over the proposed location of the emergency evacuation

footbridge at West Road.

It is above the embankment directly opposite their houses, it will be an eyesore, the

footbridge will cause construction impacts and result in visual and residential amenity

impacts during its operation.

The observers are concerned over currently non-existent retaining wall shown on

alignment at West Road, this retaining wall if built would have a negative visual

impact.

The observers query as to why there is no derailment barrier along the outside of the

goods line to protect their houses on West Road.

Hours and days of work should be 8 a.m. to 8 p.m. Monday to Friday and 8 a.m. to 3

p.m. on Saturday and Sundays, no night-time work should be permitted.

The observers are concerned with respect to the impact of vibration, both during

construction and during operation, on themselves and their families and on their

properties.

There is a concern that the vibrations may exasperate existing medical conditions.

There is a need for a health protection scheme to be initiated.

The observers are concerned about structural damage to their homes, their homes

were built in 1905 and have no foundations.

To protect properties there is a need for independent vibration monitoring.

The project as proposed would reduce sunlight to the observers’ properties.

The elements that would contribute to loss of sunlight/overshadowing will be the

hoarding during the construction phase, the proposed retaining wall along the

embankment, the new West Road Bridge, the operational control centre/management

suite and the proposed pedestrian footbridge.

If the project proceeds the area will no longer be quiet and residents will experience

the consequences of noise such as lack of sleep, headaches etc.

Proposals are required to mitigate against the noise from the TBMs at West Road, this

noise will be high at West Road as tunnelling starts at ground level not 30 metres

deep.

Proposals are required to mitigate against general construction noise at West Road,

proposals to date have been poorly considered.

Proposals are required to minimise noise from the construction operation on the new

West Road Bridge.

Existing commercial goods trains should be curtailed during the project.

Acoustic barrier proposals at West Road are inadequate. They need extending and to

be increased in height.

Enhanced low noise and vibration tracks system should be used for all new track

proximity to West Road.

All windows of affected properties on West Road should be triple glazed at the

expense of CIE.

The property protection scheme needs to be substantially adjusted in order that homes

along West Road are protected from impacts arising.

Dust raises health concerns for the residents.

There are 10 people with asthma represented by this submission alone.

It is reasonable to state that the observers’ homes will be constantly dirty from

construction dust and dirt.

They will not be able to open windows because of noise and dust levels.


They will not be able to use their external clothes lines.

Traffic management proposals raise a number of concerns for the observers.

The observers are extremely concerned that project works will include the full and

part closure of West Road and Ossory Road at different stages of the project which

would result in their being no direct access to city centre by car via the Ossory Road

or West Road.

The concerns relate to access to local schools, access for deliveries, access for

emergency vehicles and the fear for children who walk to and from school.

The observers are extremely concerned about the proposed loss of their on-street

parking.

Traffic implications also from the proposed hoardings that will be placed immediately

to the front of the observers’ dwellings.

Proposed temporary possession of West Road, West Road/Ossory Road should not be

permitted.

The observers are opposed to the removal of on-street car parking for residents for the

period of the project.

This loss of car parking is a significant impact and could last up to over 9 years.

The project as the EIS predicts will result in residents spending more time indoors in

darkened houses due to closed windows and doors.

Concerns raised over devaluation of residential properties in the area.

The observers hired Gunn Residential to make an assessment and this is included in

the observers’ submission.

The observers consider that compensation should be paid in respect of the expected

impact on the value of their properties.

Triple glazing should be fitted on their properties to reduce noise.

Proposed hoarding invites anti-social behaviour unless there is a permanent security

maintained on the site, the observers request that the issue of site security be reviewed

by An Bord Pleanála.

The observers are concerned about the possible loss of public utility such as water,

drainage, electricity, street lights etc., at various times during the project.

The works proposed at and adjoining West Road will have a significant visual impact

on the properties on West Road, Caledon Road and Strangford Gardens.

Railway works on top of the existing embankment, including a pedestrian footbridge,

the demolition of part of the existing embankment and the installation of a 14 metre

wide bridge, the construction of the operational control centre and the traction

substation, all associated machinery and truck movements, and any hoarding/acoustic

barrier/screens etc., erected will all be visible from the front gardens and front

windows of the residents’ dwellings.

Observers of West Road are extremely concerned that the proposed works may result

in the defacing of their properties arising from the movement and use of machines,

trucks etc.

Observers are concerned that this project will result in many years of works being

constantly outside their homes with consequent disturbance impacts and general

impacts on residential amenity.

Concerns raised over possible contaminated waste from site excavations and

tunnelling.

The enforceability of conditions must be ensured.


It is not sufficient for CIE to refer to a Construction Code of Practice, and Noise and

Vibration Plan, Environmental Management Plan, a TBM Mitigation Plan, Traffic

Management Plans, a Dust Minimisation Plan, etc. as being plans that would be

produced by the contractor, these plans need to be produced now and the contractor

should be required to follow all parts of each.

An independent arbitrator should be available via an emergency helpline 24 hours a

day and should be immediately able to respond to any problems arising.

195. Sean, Mary and David O’Connor, 33 West Road, East Wall, Dublin 3.

The contents of the observer submission as prepared by BPS Planning Consultants on behalf


The submissions specific to the concerns of No. 38 West Road with respect to impacts

of the project which arise in close proximity to their house.


However they consider that the particular issues at No. 38 West Road require

articulation in an individual submission.

Generally as per the submission by the residents of Nos. 61 to 71 and 75 and 77 West


196. Marie and Angela Broderick, 35 West Road, East Wall, Dublin 3.

The contents of the observer submission as prepared by BPS Planning Consultants on behalf


The submission is specific to the concerns of No. 35 West Road with respect to the

project which arise in close proximity to their house.


However they consider that the particular issues at No. 35 West Road require


Generally as per the submission by the residents of Nos. 61 to 71 and 75 and 77 West


197. Seamus Cummins and Delphine Guine, 40 West Road, East Wall, Dublin

3.

The contents of the observer submission from the above as prepared by BPS Planning


The submission is specific to the concerns of No. 40 West Road with respect to

impacts of the project which arise in close proximity to their house.


However they consider that the particular issues at No. 40 West Road required



Generally as per the submission of the residents at Nos. 61 to 71 and 75 and 77 West


198. Marcella Shanley, No. 39 West Road, East Wall, Dublin 3.




impacts of the project which arise in close proximity to her house.

The observer supports the overall Protect East Wall Group submission.

However the observer considers that the particular issues at No. 39 West Road

required articulation in an individual submission.



199. Jody Toner and Anna Morgan, 37 West Road, East Wall, Dublin 3.




impacts of the project which arise in close proximity to this house.






200. Patrick and Ann Lacombre, No. 36 West Road, East Wall, Dublin 3.










201. Andrew and Elizabeth Hulton, No. 34 West Road, East Wall, Dublin 3.





impacts of the project which arise in close proximity to this house.






202. Margaret Roper, 82 West Road, Pat Ferry, 83 West Road, Michael and

Ann Kane, 14 Hawthorn Terrace and Oliver Martin, 20 Hawthorn Terrace,

East Wall, Dublin 3.



The submission is specific to the concerns of those residents with respect to impacts

of the project which arise in close proximity to their house.


However they consider that the particular issues proposed at Hawthorn Terrace and

West Road required articulation in an individual submission.



203. Doreen and Freda Caprani, 10 Strangford Gardens, East Wall, Dublin 3.



The submission is specific to the concerns of No. 10 Strangford Gardens with respect

to impacts of the project which arise in close proximity to their house.


However they consider that the particular issues proposed at No. 10 Strangford

Gardens required articulation in an individual submission.



204. Thomas and Ita Hulton, 99 Caledon Road, East Wall, Dublin 3.




The submission is specific to the concerns of No. 99 Caledon Road with respect to



However they consider that the particular issues at No. 99 Caledon Road required




205. Mary Corcoran and Richard Hewer, 8 Abercorn Road, East Wall, Dublin

3.


There will be a significant effect on the lives of the observers and on their home

during both construction and operation stages of the project.

The observers have had very little time to digest and respond to what is planned.

The observers purchased a 19th

century cottage and have invested everything they

have into it, renovating it completely.

The proposed development impacts on their health, on their current wellbeing and on

their home both structurally and aesthetically. The observers request that Irish Rail

fund an independent survey and test the soil for contamination and assess the health

impact on the observers from this and also other air borne particles and dust from the

project.

The observers believe that the old structures on the site may contain asbestos.

The observers support the East Wall Protection Group who are officially representing

East Wall and support their request for an oral hearing.

The observers want to be certain that there is a vehicle/forum wherein residents’

concerns will be heard and adhered to during the construction phase.

The observers are concerned that their dwelling will be impacted by unnatural

settlement caused by subterranean shock waves and vibration.

Trains running past the end of Abercorn Road already make the walls and floors of

their dwelling shake and vibrate.

Any crack of any size in their dwelling is unacceptable.

The houses on the road do not have modern foundations.

The observers insist that sufficient notice of any disruption to services be given well

in advance.

The value of their property would be impacted upon during the construction phase.

The observers are concerned with the possibility of a very high level of noise.

One of the observers works from home a number of days of the week.

Concerns were raised in relation to day to day building site noise, cars, truck

transporting rubble, cargo trains, general haulage, trucks reversing etc.

Sub-stations make noise, vans and pumps and telephones make noise.

The observers are concerned about the proposed temporary offices directly behind

their house.

The observers question what is planned to address noise from drilling, boring piping,

blasting hauling trucks trains etc.?

This is a long term project in relation to the observer’s lives and timeframes.


The observers raise concerns in relation to the proposed access to the site adjacent to

1 Abercorn Road. This will allow for at least 360 trucks every day.

The observers raise a number of concerns relating to dust pollution.

The observers raise a number of concerns relating to health implications from the


Concerns were raised in relation to possibility of light pollution.

Concerns were raised in relation to distance of proposed cranes to existing dwellings.

Concerns raised in relation to the impact and the condition of the roads.

No on-street parking should be removed from Abercorn Road.

Concerns are raised in relation to the height of the proposed ESB sub-station.

Noise from the building electromagnetic emissions and the visual impact were also

concerned relating to this proposed sub-station.

This sub-station should be relocated in a docklands station.

The observers have a number of questions relating to the proposed recharged well that

is to be located near their home.

The observers have concerns relating to the back wall along their property.

206. Marie, Matt & Jack O’Reilly, 2 Upper Mayor Street, North Wall, Dublin

1


Given the size and complexity of the proposed development the observers are

requesting an oral hearing.

The construction phase and operation phase will have a huge impact on the observers’

home.

The observers have suffered from the impacts caused by huge developments in the

area over the last number of year, including the recent construction of the Luas Line

to the Point.

Measures to protect the residents and community have been largely inefficient.

Despite imposed conditions, residents have been subjected to unacceptable

consequences from prolonged working hours relating to noise, dirt, dust, vibrations

and poor planned traffic movements.

Agreed and promised mitigation measures were not implemented.

These past experiences should not be repeated.

Any grant of permission must be completely water-tight and leave no room for

manoeuvres or back-tracking in relation to monitoring mitigation and protective

measures for the residents.


A channel of communication must be put in place for residents to address difficulties

and concerns.

A clear chain of command should exist to avoid the previous experience of

responsibility for particular issues being shunned by all.

Examples that have worked in the past need to be looked at, such as the community

liaison meeting during the Port Tunnel Project and the 24-hour manned telephone

during the East Wall Road Rail Bridge construction.


The proposed working hours are excessive. The launch pit in operation 24 hours for

20 months will involve a huge disruption to residents.

There will be the cumulative impact of noise, dirt, dust and high intensity lighting.

These impacts will continue over a period of years.

Residents’ lives will be made very difficult and the unrelenting working hours are

unacceptable.

The number of vehicles movements per day is excessive for a built up residential area.

The majority of roads in the vicinity are subject to HGV restrictions and such volumes

licensed to operate within the cordon would be a major reversal of this effective

strategy.

The surrounding streets are narrow and very confined and major problems can be

envisaged if the traffic flow is not adjusted.


methods noise reduction and mitigation measures and regular monitoring are

essential.

Monitoring data must be freely available to community representatives and residents.

Vibration and noise levels during the build phase should be subject to constant

monitoring to be publicly displayed on a live or almost live basis, for example, on the

Internet.



Any dispute should be referred to an independent arbitrator who is available on a 24-

hour basis and whose decision can be imposed.

This is particularly relevant to the residents who have just gone through the

construction of the new Luas Line to the Point where major breaches of noise and

vibration were recorded.

If vibration levels are excessive, the speed of progress of the boring machine should

be reduced or work should be halted until deemed acceptable.


parties.

The area in which the observers live has had massive development over the past 15

years and unfortunately little responsibility has been taken by individual developers.

Enforcement by statutory agencies has been patchy to say the least.

No agency is willing to take responsibility for damage caused by the developments,

rather preferring to blame each other.

In relation to dust, best practice methods, reduction and mitigation measures and

regular monitoring are essential.

Monitoring data must be made freely available to community representatives and

concerned residents.

An agreed programme of window cleaning and car wash allowances may be

appropriate for adjoining streets.


This needs to be addressed with on-site measures scheduled and as necessary, street

sweeping and cleaning provided.

High intensity lighting must be positioned and operated in such a way as to cause

minimum disruption to adjacent households.

The cumulative impact on the watertable from the unprecedented level of

developments in the broader North Docklands must be considered.


It has been noted by residents that the excavation of development sites in recent years

has been problematic due to flooding of the sites.

There is anecdotal evidence of a rise in the water level as suggested by the flooding of

gardens very quickly during bouts of heavy rain.

Negative impacts during the construction could be overcome and avoided if an

effective communication strategy is implemented.

An agreed structure in the form of a committee/liaison/monitoring group would be of

benefit to all parties.


for residents.

It would be a last opportunity not to use the large space at this proposed Spencer Dock

Station for the public good.

The compensations scheme has currently offered makes provision for damage up to

€30,000, any claims in excess are liable against the contractor, it is unclear how to

progress a claim if it is in excess of this amount, this is extremely unfair.

CIE should therefore offer a scheme of unlimited liability (all claims are obviously

contestable).

The proposed 12-month limitation on the compensation scheme is unfair and

unacceptable.

Settlement which can cause subsidence can occur some years following completion of

the works.

The observers note with grave concern that the EIS does not consider the operational

phase of the Dart Tunnel given the lack of information regarding the operational

phase of the development.

The EIS is statutory deficient.


Internet during the operation of the tunnel verified by an independent arbitrator.

The independent arbitrator should have direct input to the control over the day-to-day



planning applications and the legal status of any conditions must be clarified.

207. Spencer Dock Owners Committee, c/o Concierge Office, Spencer Dock

Apartments, Park Lane, North Wall Quay, Dublin 1.


The submission is being made on behalf of the apartment owners and residents in the

Spencer Dock that is Block STUV which currently comprises approximately 600

households, some of which are directly above the tunnelling area.

These households include couples/singles and also a significant amount of families

with young children.

The vast majority of apartments are occupied.

While the observers welcome the development of this key infrastructure for Dublin

they have concerns in relation to the effect on their living environment for the long



Vibration, noise and dust pollution in particular are harmful to health and the

observers expect that sufficient mitigation and adaption measures be put in place to

ensure that disruption is minimised.

The observers deem it essential that Irish Rail consult directly with their committee as

the management company for the development is still under the control of the

developer.

The Railway Order needs to specify dispute resolution processes.

As a general point the EIS is very unwieldy, difficult to access relevant information

for specific areas and the costs associated with getting printed copies of documents

seen to be well in excess of commercial rates.

Noise is a primary concern for residents.

No noise levels have been calculated at Saunders and Packenham House (Block

STUV) below second floor level.

The effect of Dart underground construction noise should be quantified for ground

and first floor.

The EIS does not assess the impacts of ground borne noise from blasting and the

occupants of Saunders and Packenham House.

The observers have strong doubts the proposed working hours and the attendant noise

are sufficiently in line with the legislative requirements of Council Directive

2002/49/EC relating to the assessment and management of environmental noise which

was transposed by the Environmental Noise Regulations 2006.

The construction of suitable noise barriers is essential for residents in terms of both

the northern construction compound and the construction of Spencer Dock station.

The Railway Order needs to provide that funds are made available for regular

independent monitoring of noise (daytime and night-time) to ensure that the

mitigation measures are effective.

The occupants of the apartments within Block STUV and in particular Saunders and

Packenham House will be negatively impacted by above ground vibrations from

piling and road works.

Station piling works and road works on Park Lane should be limited to daytime hours

to reduce the impact on the building occupants.

The potential for dust nuisance in Spencer Dock is high.

The observers are asking Irish Rail to present detailed proposals to eliminate and

mitigate nuisance from dust including considering options such as covering the north

and south boxes with dust rings for the duration of the works.

As part of the Dust Minimisation Plan the observers propose that a regular cleaning

schedule for the buildings in Spencer Dock be agreed.

In relation to the proposed working hours it is unacceptable that works will be carried

out on Sundays and Bank Holidays and late on Mondays to Fridays.

With regard to the underground working hours it is not acceptable that underground

works including mining will take place on a 24 hour basis in an area containing a

large number of occupants.

It is essential that there is detailed liaising with residents and an appropriate

programme of work should be developed in relation to the underground construction

hours.

The loss of the central square for a period in excess of six years is incalculable with

no alternative temporary proposal being made available.


The central square currently hosts regular farmers markets, concerts and is a play area

of children present in the neighbourhood.

The proposed access ramp onto Sheriff Street Bridge will increase traffic noise levels

for the residents and occupants of buildings in Spencer Dock.

It will injure the amenity value and health of the residents.

The works will have a series impact on the living environment amenity value of all

the apartments but particularly the apartments which face directly onto Sheriff Street

and onto Park Lane.

The volume of noise, dirt, traffic and general disruption and in particular the impact of

site and vehicle lights and the noise from train carriages bringing the excavated soil

from the tunnels will make beneficial occupation of these apartments impossible.

There is a strong case that the existing train tracks in the docklands area should be

used to transport waste material out from the tunnels rather than by road transport.

Noise limits at apartment levels should be specified in the Railway Order which at a

minimum adhere to the Environmental Noise Directive.

Independent monitoring of noise should be undertaken during the construction phase

to ensure that limits are specified.

Enforcement bodies should be specified and identified and available to residents.

Irish Rail should directly consult with Spencer Dock Owners Committee.

A dispute resolution process should be put in place.

Working hours should be limited as far as possible so as not to disturb residents.

A cleaning programme should be undertaken by Irish Rail to alleviate dust build-up

which would otherwise put a financial cost on residents.

The entire plan for the northern construction compound needs to be reviewed

including the undertaking of a full noise mapping exercise and the construction of

noise barriers.

Dust screens should be constructed during the building of Spencer Dock station.

The observer submission includes an explanatory note relating to the Environmental

Noise Regulations 2006.

208. Spencer Dock Development Company Limited, Connaught House, 1

Burlington Road, Dublin 4.


follows:

Spencer Dock Development Company Limited (SDDCL) and their associate and

subsidiary companies have significant land interest in the North Docklands area and

are actively engaged in development of numerous sites in the wider docklands.

Spencer Dock which sits at the heart of the North Docklands is one of the largest and

most ambitious urban regeneration projects in Europe.

It is made up of circa 21 hectares of brownfield lands through which the proposed

Dart Underground will pass.

SDDCL is fully supportive of the development of Dart Underground in principle.

The integration of Dart Underground with future development proposals for Spencer

Dock would be a fundamental element in achieving sustainable intensification of this

part of the city and the maximisation of high quality public transport investment.


SDDCL has the exclusive right to develop the 21 hectares of former railway lands

pursuant to a Master Development Agreement (the MDA) with CIE and Iarnrod

Eireann and others.

The MDA provides for CIE to receive a proportion of proceeds from SDDCL’S

development activities and for license fees as and when SDDCL draws down land to

develop.

SDDCL’s associated companies also own certain lands and properties within Spencer

Dock and Spencer Dock Management Limited as subsidiary of SDDCL has on-going

role as the Estate Manager for Spencer Dock.

SDDCL has already developed a number of buildings in the area. These include

apartment blocks, offices and the new convention centre.

SDDCL is anxious to ensure that transport infrastructure is delivered in an integrated

and efficient manner that best complements and facilitates and integrates with the

planned and sustainable development of the area.

Notwithstanding the strong support for the provision of this transport infrastructure, it

is considered that the construction and operation of the proposed Dart Underground as

currently described in documentation already has and will increasingly have serious

impacts on existing and future development at Spencer Dock.

The purpose of the submission is to seek that the necessary measures are put in place

to ensure that the development of Spencer Dock as an emerging key urban quarter in

the city is not unduly restricted or prohibited by the Dart Underground proposals and

that the amenities of existing and future occupants of the area are protected.

The prospective tenants for new buildings within the Spencer Dock development are

unlikely to agree terms to occupy properties currently available in close proximity to

potentially the largest building site in the city centre and the impacts such proximity

shall have including resultant noise, dust, vibration and traffic disruptions.

The proposed Dart Underground works will impact substantially on the 616

apartments within Block S, T, U, V including the sale and letability of the remaining

residential units.

Occupation of the units fronting onto Sheriff Street and overlooking Spencer Dock

North will not be possible, during the course of the works, on the basis of the

proposed 24 hours per day, seven day per week construction activity.

Those units on the eastern side of Park Lane will be similarly impacted.

The volume of noise, dirt, traffic and general disruption and in particular the impact of

site and vehicle lights and the noise from vehicles bringing the excavated spoil from

the tunnels will make beneficial occupations of these apartments impossible.

The works will impact directly on the operation of the Luas Line along Mayor Street

and on the Sheriff Street Railway Station.

The proposal that spoil will be removed via North Wall Quay and under Sheriff Street

Bridge is unacceptable, as it will seriously increase the traffic level in these areas to

an unsustainable level.

The proposal to remove all of the spoil for the whole of the Dart Underground project

via the North Spencer Docklands is unreasonable.

This along with the proposed land take sterilises all of the North Spencer Docklands

for the full duration of the total Dart Underground Project.

The combined effect of permanent and temporary acquisition of lands and the

resultant impact by the proposed works on both the existing buildings and the future


development potential of sites and buildings in the control of SDDCL including its

interest in the MDA Agreement with CIE is a very significant issue for SDDCL.

It will have a very substantial impact on the value of existing investment holding and

businesses and also the financial viability of planned developments and also those

sites where planning permission has already been obtained.

It is submitted that in their current format, the Dart Underground proposals would

obstruct the implementation of the relevant policies and objectives of the planning

policy context, as it is relevant to Spencer Dock.

Due to the proximity of the tunnelling portal, the impact on Spencer Dock would be

greater than anywhere else along the tunnelling route.

In many instances the EIS fails to adequately assess the impact of the proposed Dart

Underground development on Spencer Dock.

The observer’s particularly concerned at the Spencer Dock development site would be

sterilised during the construction period of Dart Underground.

The situation would be further exacerbated in the event that the implementation of the

Railway Order was indefinitely delayed or were construction to commence and then

cease for an indefinite period.

The limits adopted by the applicant for impacts such as noise, vibration and settlement

are excessive and need to be revised.

The application does not provide sufficient information in relation to the timing,

extent, duration and impact of the enabling works period in relation to Spencer Dock.

The route alignment and station layout fails to take account of the potential future

development of this key urban location, the proposals in the current format which

significantly hinder the development of the site.

As a result of works required for both the construction of the Spencer Dock Station

and the construction compound, the impact upon Spencer Dock in terms of land take

is significant in the long-term.

There will be a sum total of land acquisition from the observer of some 91,500 square

metres, the total land take excluding substratum land take is approximately 71,000

square metres, this is 7.13 hectares representing approximately 33% of the overall

Spencer Dock area which the observer either owns or has right to develop.

The permanent land-take proposed in the application in respect of Spencer Dock is

excessive and is not justified by the EIS and this has a significant impact on the

development ability of the Spencer Docklands.

The EIS fails to take appropriate account of the impact of the construction impact on

protected structures within the Spencer Dock area and fails to propose appropriate

finishes and uses for these protected structures.

The EIS in defining the working hours for the project fails to recognise that the

Spencer Dock area is a primary residential and commercial hub, the hours set out in

the EIS are unacceptable.

The amenity value of the existing central square should not be underestimated.

The existing temporary rail station situated on North Spencer Dockland should be

removed at the point when Dart Underground station is operational.

An Bord Pleanála should seek further information from the applicant which is

intended to ensure that current developed properties, under construction developments

and future developments at Spencer Dock are recognised and facilitated by Dart

Underground and which allow An Bord Pleanála to make a full and proper assessment

of the proposal.


209. Tony, Hilda & Derek McDonnell, 1 Mayor Street Upper Docklands,

Dublin 1


The proposed project will have a massive impact on residents, both during the

construction phase and when it becomes operational.

The EIS does not address the operational element as such the application should be

rejected until such time as the EIS reflects the operational aspect.

The area has suffered greatly from the impact of massive developments taking place

in recent years.

Construction has been constant in the immediate vicinity of the observers’ home since

early 2000.

The observers have just come out of a period of 24/7 works as carried out by the RPA

and they do not want to go back to this hell.

It has been an unfortunate reality that measures to protect the indigenous community

have been largely inefficient if not totally absent, and despite imposed conditions,

residents have been subjected to unacceptable consequences from prolonged working

hours, noise, dirt and dust, vibrations and excessive and poorly planned traffic

movements.

During the Luas line extension, the RPA via its subcontractors were responsible for

loss of tap water on many occasion and massive vibration and noise.

The observer and his neighbour had to seek solace in the courts under Section 108

regarding noise.

Numerous developments took place in clear breach of the attached conditions and

agreed/promised mitigation measures were not implemented.

Experiences of effective enforcement have been few and far between.

It is essential that past bad experiences are not repeated.

Any grant of permission must be watertight and leave no room for manoeuvre or

backtracking in relation to monitoring, mitigation and protective measures.

An accessible and effective regime of enforcement must be in place with the powers

of work being stopped immediately if warranted.

A channel of communication must be place for residents to address difficulties and

concerns that may arise.

A clear chain of command should exist to avoid the previous experience of

responsibility for particular issues being shunned by all.

The working hours requested is excessive.

The launch pit in operation 24 hours for 20 months will involve a huge disruption to

residents in the North Port Dwellers’ Residents Association Area.

Residents’ lives will be made very difficult and the unrelenting working hours are

unacceptable.

No cognisance has been taken as to the operating hours of the Luas and associated

maintenance.

The number of vehicular movements per day is excessive for a built up residential

area.



methods, noise reduction and mitigation measures and regular monitoring are

essential.

Monitoring data must be made freely available to community representatives and

concerned residents.

Vibration levels are excessive, the speed of progress of the boring machine should be

reduced or work should be halted until deemed acceptable by the independent

arbitrator.

All properties including drainage systems within the study area should be subject to

full dereliction conditions.

In relation to dust an agreed programme of window cleaning and car wash allowances

may be appropriate for adjoining streets.

A water mist suppression system around the entire site of Dockland Station should be

considered.


High intensity lighting must be positioned and operational in such a way as to cause

minimum disruption to adjacent households.

The cumulative impact on the watertable from the unprecedented levels of

development in the broader North Docklands area must be considered.

An agreed structure in the form of a committee/liaison/monitoring group would be of

benefit to all parties in relation to communications.


for residents.

The proposed compensation scheme is extremely unfair and therefore unacceptable.


internet during the operation of the tunnel verified by an independent arbitrator.




planning applications.

CIE should be compelled by way of condition to rebuild the houses numbers 1-6

Mayor Street Upper.

210. North Port Dwellers’ Residents’ Association, c/o Tony McDonnell, 1

Mayor Street Upper Docklands, Dublin 1

The contents of the observers’ submission from the above can be summarised as follows: -

As per the observer submission from Tony, Hilda and Derek McDonnell of 1 Mayor

Street Upper Docklands, Dublin.

211. Price Waterhouse Coopers, 1 Spencer Dock, North Wall Quay, Dublin



Price Waterhouse Coopers occupies 25,000 square foot of office space and employs

in the regional 1,800 people at 1 Spencer Dock, North Wall Quay, Dublin 1.

The observer is very concerned that all appropriate measures will be taken during the

construction phase for the Dart Underground to ensure the following:

(1) Minimum disruption to traffic, including public transport in the area.

(2) Minimum disruption to pedestrian access to their offices.

(3) Control of noise and vibration during working hours.

(4) No interruption of water, sewage, drainage, telecommunications, power or

gas supplies and systems.

(5) No impact on their building arising from boring underground.

(6) Adequate communication of construction activities and their impact.

212. Caren Gallagher, 16 Irvine Terrace, North Wall, Dublin 3.


Serious concern with respect to road noise.

No. 16 Irvine Terrace is located less than 5 metres from the boundary of the CIE

railway line.

Concern with respect to impact of noise from the service track which is proposed via

the haul route from the eastern portal to the East Wall freight yard.

It is proposed in Section 5.15.2.2 of the EIS that spoil from excavations could be

transported to East Wall freight yard by dumper truck or equivalent for removal by

rail.

It is further stated in the EIS that the assumed amount of traffic over the 8-hour night

time period using Sherriff Street, East Wall haul route during Phase 4 is 844 vehicles

(106 movements per hour) (Appendix A8.2, Table A8.2.11).

Irvine Terrace is located less than 5 metres from the proposed haulage route. Concern

that construction noise at Irvine Terrace will exceed NRA Guidance and maximum

permissible noise levels.

Concern with respect to rail noise.

Based on the observer’s personal experience of freight rail activity along this stretch

of rail line the proposed increased level of rail activity could prove to be very

disruptive and will impact greatly upon the vitality of life of the residents of Irvine

Terrace.

The shunting, idling and revving of large 30-40 year old diesel freight train engines is

a nuisance during the day and very disturbing during the night.

Concern with respect to overhead conveyor noise.

It is proposed that spoil from TBMs will be carried on overhead conveyers to

stockpile areas located near the eastern portal and/or stockpile areas at the East Wall

freight yard Section 5.15.2.3 of the EIS. There does not appear in the EIS to be any

detail on the potential noise emitted from these proposed overhead conveyers.

Concern with respect to the function of the recharge well located directly behind the

back yard of 16 and 17 Irvine Terrace and Irvine Cottages.

Request that An Bord Pleánala reconsider the proposal to use the East Wall haul route

for construction traffic.


Request that An Bord Pleánala review the assumptions within the rail noise models

and evaluate the usage of average noise levels to measure the likely impact of

construction noise.

213. Emma and Sarah Donnelly, 124 Caledon Road, East Wall, Dublin 3.




Impact of air pollution on asthma sufferers.

Concern with respect to dust on a residential area.

Concern with respect to children’s ability to play in the area due to increase in traffic.

Disruption of flow of traffic to and from West Road.

Increase in traffic flow on Church Road.

Lack of revised EIS based on two boring machines being located in East Wall.

Lack of Impact Assessment on residents of East Wall.

Lack of planned DART rail access stations for East Wall residents.

Impact of the control centre on the light of the gardens to the east and including West

Road/Barnabas Gardens, Caledon Road and Moyelta Road.

The disruption to the no. 53 bus route for residents of East Wall.


214. Edward Rainsford and others, c/o 41 West Road, East Wall, Dublin 3.

The submission from the above can be summarised as follows:

Health risks, asthma sufferers.

Increase in noise levels.

Dust pollution. The long-term damage this will have on property and the condition

they will be left in.

Parking and traffic. How will traffic be controlled and will own door parking be

affected?

Hazardous waste. Will there be any hazardous waste and how the waste will be

removed from site?

Structural damage. How will damages caused by drilling be assessed?

Overlooking of properties. How will the height level of the development impact on

properties?

Value of properties. What impact will works have on the value of properties during

construction and the level of compensation will be made available?

Bus route. Will they still be available to use West Road and if not what will be the

alternative?

Request that an oral hearing be heard.

215. Mr. Aiden Murray, Ross Spelman and Lillian Spelman, c/o 76 St.

Lawrence Road, Clontarf, Dublin 3.



There is no station proposed for the East Wall area. Request that a station be

constructed instead of a footbridge so that the local community will be able to use the

new DART line and the area would benefit from the additional services.

Concern that the Railway Order application will enhance physical barriers to the

environment and limit access to the East Wall area.

Concern with respect to access during construction and additional noise, air and visual

pollution during construction and later during operation when traffic on the railway

line will be significantly increased.

No benefit to the community of East Wall.

If West Road is closed off from Ossory Road to allow construction of a new bridge

for any substantial period of time it will cause traffic chaos.

Concern with respect to access for Dublin Fire Brigade.

Request that An Bord Pleánala ensure that there is safe access to the Crosby Yard

residential development at all time from both Ossory Road and West Road during

construction of works.

Request that an alternative to the closure of West Road Bridge be sought.

There is only one bus, no. 53 which services the East Wall area. The stop is located on

the West Road side of the bridge. If the road is closed the residents of Crosbies Yard

development will have no means of accessing the bus service.

Better bus services run on North Strand Road however this is only a valid point for

people living in East Wall itself and not applicable to those living in Crosbies Yard.

Request that An Bord Pleánala ensure that access to the proposed improved DART

network from East Wall is provided in one of two ways, either by provision of a

station from East Wall-North Strand or by appropriate pedestrian access from Church

Road to link the neighbourhood to the proposed Spencer Dock station.


the halfway point between Clontarf Road and the Docklands Station.

Request that An Bord Pleánala ensure that a bridge for pedestrians and cyclists be

provided from the southern end of Church Road in East Wall over the railway

enclosing line to give access to the proposed Docklands Station.

Request that even if it is a case that CIE has no responsibility to provide a bridge link

from Church Road to Spencer Dock that An Bord Pleánala make it a condition of the

Railway Order that CIE enter into a partnership with the appropriate authority and

provide funding for such a link bridge.

Strongly object to the construction of an operational control centre in such close

proximity to a residential area. This is not an industrial area as indicated in the EIS.



Concern with respect to devaluation of property.

Concern with respect to noise.

There is no mention of a mitigation strategy for the East Wall area and where it

appears there is now to be two boring machines starting simultaneously and therefore

a mitigation strategy is urgently required.

Concern with regard to access and egress of construction traffic for the proposed

operational control centre.

Concern with respect to working hours in particular night time working hours and

resultant noise.


Request that CIE provide a 24-hour telephone number for residents in case of

infringements of planning permission.


216. Phyllis Corcoran, Roger and Adrienne Gallihue and Jimi and Kay Alford

C/O Phyllis Corcoran, 38 Church Road, East Wall, Dublin 3.


Support the view of the Protect East Wall Group submission.

Disappointed with the lack of communication and consultation from Iarnród Eireann.

Concern with respect to proposed temporary possession of Ossory Road and West

Road.

Concern with respect to noise levels, dust levels, devaluation of property.

Request that mitigation measures be put in place by An Bord Pleánala which gives

serious consideration to the residents of East Wall as Iarnród Eireann have failed to

do.


Request that an independent arbitrator ensure a proper standard of mitigation

measures and ensure that the residents Charter of Rights is written into the Railway

Order to ensure proper enforcement of conditions be laid down by the Board.

217. Carmel Gormley and others, c/o Carmel Gormley, 4 Hawthorne Terrace,




Concern with respect to lack of communication and lack of consultation from Iarnród

Eireann.

Concern with respect to the proposed temporary possession of Ossory Road and West

Road.

Concern with respect to noise levels, dust levels and devaluation of property.

Request that mitigation measures imposed by An Bord Pleánala give serious

consideration to the residents of East Wall as Iarnród Eireann have failed to do so.

Request that An Bord Pleánala grant an oral hearing.

Request that an independent arbitrator be appointed to ensure a proper standard of

mitigation measures and to ensure that an independent Charter of Rights is written

into to Railway Order to ensure proper enforcement of conditions laid down by the

Board.

218. Aidan Hurley, 4 Oxford Terrace, East Wall, Dublin 3.


Concern with respect to the impact of the proposed works on residents of East Wall.

Concern with respect to the length of duration of the construction works and the

impact this will have on resale value of property during this period.


Concern with respect to value of property in the East Wall area.

East Wall seems to have accumulated all of the disadvantages associated with this

construction while deriving none of the benefits that the remainder of the City

receives i.e. no station for East Wall.

Concern with respect to the schedule construction to take place 24 hours a day, 7 days

a week.

Concern with respect to construction in terms of noise and traffic pollution, flood

lighting etc.

Concern with respect to construction traffic and removal of spoil.

Query the logic of having two tunnel boring machines in East Wall.

Why has the EIS not been amended to reflect the two TBMs proposed in East Wall

and Inchicore rather than 1 TBM?


219. John Meade, 72 Russell Avenue, East Wall, Dublin 3.



Concern with respect to impact of the project upon the residents of the East Wall,

North Strand and North Wall area.

Concern with respect to noise pollution, air pollution, impact on health, flooding.

Concern with respect to location of the power station. Submit that any power building

should be placed as far away from homes as possible.

Query with respect to the maintenance building. Need clarification as to the type of

maintenance and machinery movements to and from this building at night time and

impact this will have on the future residents on Abercorn Road, Church Road, Blythe

Avenue and operational practices to cause minimum disruptions to residents.

Concern with respect to impact upon children playing in the area and children’s lives

given the extent of the construction period 6-9 years.

Request that mitigation measures are put in place to minimise the disruption to East

Wall.

220. Jean Delaney, 29 Caledon Road, East Wall, Dublin 3


Strong objection to the proposed DART Underground system.

Negative impact upon the quality of life especially the elderly.

The current train line already gives rise to disamenity.

Concern with respect to flooding the Port Tunnel.

The project won’t benefit Dublin Port residents.

Can see no need for the proposal.

Concern with respect to structural damage to buildings and flooding.

Concern with respect to disruption to traffic especially during construction.

221. Angela Foley and others, C/O Angela Foley 22 West Road, East Wall,

Dublin 3.



Do not in principle oppose DART Underground project.

Strongly opposed to the lack of consideration and consultation given to the residents

of East Wall and also the portrayal of East Wall and West Road in the EIS report.


Concern with respect to lack of consultation and communication from Iarnród

Eireann.

Concern with respect to proposed temporary possession of Ossory Road and West

Road.

Request that An Bord Pleánala give serious consideration by way of mitigation

measures to the residents at East Wall as Iarnród Eireann have failed to do so.

There is a real danger that the health of any residents would be severely affected by

the proposal.

Request that An Bord Pleánala ensure that measures are properly in place to mitigate

the concerns of residents.

Request that an oral hearing be granted.

Request an independent arbitrator to ensure a proper standard of mitigation measures

and ensure that a residents Charter of Rights is written into the Railway Order to

ensure proper enforcement of conditions laid down by the Board.

Hand written note attached by Angela Foley. Concern with respect to impact of the

proposal from a noise and dust point-of-view on the elderly. Concern with respect to

security. Concern with respect to impact on property and subsidence issues. Request

that a survey of her garden be carried out prior to construction.

222. Anne Fegan and others, c/o 122 Caledon Road, East Wall, Dublin 3.


Negative effect on the residents of East Wall.

Concern with respect to health impacts.

Concern that proper mitigation measures on monitoring are put in place.

East Wall is not an industrial area as stated in the EIS.

East Wall is a residential area and as such operating hours as requested for this project

are excessive and unacceptable.

Concern with respect to the proposed temporary possession of West Road.

East Wall Road has a 3 tonne limit.

Impact on street parking from construction vehicles.

Concern with respect to access to the area for emergency services vehicles.

Concern with respect to dust levels and property values.

Why is East Wall not getting a station?

Request that an independent arbitrator to ensure proper standards and mitigation

measures and ensure that a resident Charter of Rights is written into the Railway

Order.


223. Joe Mooney, 34 Merchant Square, East Wall, Dublin 3




Concern with respect to construction and operational phases of the development.

Concern with respect to impact upon residential amenity of residents in East Wall,

North Port, North Wall and North Strand areas.

Concern with respect to unacceptable consequences for prolonged working hours,

noise, dirt, dust, vibrations and excessive and poorly planned traffic movements.

Stringent monitoring mitigation and protective measures need to be put in place and

need to be enforced.


Communication must be put in place for residents to address difficulties and concerns

that may arise.

A Community Liaison Officer should be appointed. Guarantees in clear conditioning

are needed under the following headings.

Working hours

Traffic and transportation

Noise

Dust

Dirt

Lighting

Vibrations and possible property damage watertable

A 7am start time is unsuitable for residential areas particularly at weekends. A 9am

start at weekends would be standard.

The number of vehicle movements per day is excessive for a built-up residential area.

The majority of roads in the vicinity are subject to HGV restrictions and such volumes

licenced to operate within the area would be a major reversal of this effective strategy.

The closure of West Road through traffic in relation to increased volume on other

roads and the dispersal of existing on-street parking from West Road will all

contribute to a severe traffic flow problem for residents.

There is a need for a genuine engagement with resident representatives with respect to

vibration and property damage.

Iarnród Eireann has traditionally been an organisation that is difficult to deal with and

has a poor attitude to consultation and community relations.

Disappointed that Iarnród Eireann has not used the success of the Docklands Station

and the genuine dialogue that opened up in that instance as a blueprint for community

relations on this project.

At meetings in East Wall residents were told certain documents were not legally

available until the Rail Order was lodged. This was accepted as fact. It now appears

that similar documents were available to other communities during this period with no

legal impediment. This is a major breach of trust between the company and the

community.

No indication was given that the launch pit and boring operations would be based

solely in this community.

Residents are relying on An Bord Pleánala for adequate protection during this project.


Clear and water tight conditions need to be imposed and a clear indication of what

enforcement measures will be applicable to ensure compliance.

Welcome the incorporation of protected structures and North Wall into the station

design.


Submission is attached with letter from Joe Mooney, East Wall Residents Association

and Gerry Fay, North Wall Community Association in respect of the Docklands

Station and residents’ concerns regarding noise.

224. Michael Kennedy, Gore and Grimes, Cavendish House, Smithfield,

Dublin 7.


Acting on behalf of Michael Kennedy, Director of Balladur Ltd. trading as A1

Kitchens and Bedrooms of Unit 12, Ossory Road Industrial Estate, Dublin 3

Concern with respect to adverse effects on the observer’s business throughout the

course of construction including impacts of noise, vibration, dust, hazardous waste

and increased volume of traffic.

Highly concerned that said construction work will have a negative effect on the

profitability of business.

A1 Kitchens and Bedrooms Business uses precision equipment to manufacture

kitchens and wardrobes to the high standards. Any vibrations in the area will cause

significant problems to this manufacturing process necessitating additional cost to be

incurred to protect against same.

The levels of dust created will affect the finished product requiring additional labour

and other materials to protect against same thereby increasing observer’s overheads.

Concern as to the impact the works will have on the evaluation of property both

during construction and into the future.

Concern with respect to settlement and structural damage and consequently

diminution in value of property.

The observer wishes to develop on his property to expand his business and he is

concerned he will be unable to do so given the proximity of the proposed works.

Support for the submission by the East Wall Protection Group.


CIE have represented that a meeting was held in and around the 30th

April with the

observer and it was an in depth consultation acting on behalf of all interested parties

within the Ossory Industrial Estate. It is submitted and advised that this was not the

case and that the observer was present at the said meeting solely on his own behalf

and was merely instructed by CIE as to the proposed location of the underground

railway line.

225. Margaret Mulhall, 58 Ravensdale Road, East Wall, Dublin 3.

The content of the above submission can be summarised as follows:

Concern with respect to noise levels and duration of construction works and hours of

operation of machinery.


Concern with respect to proposed 24-hour lighting.

Concern with respect to dust and dirt levels in the area and the impact upon residential

amenity in particular health problems.

Increased traffic problems in an already congested area.

The fact that trucks may be constantly going through or around the area which is

already a major problem for residents giving access or exit from the area.

Long-term blocking of roadways in the area.

Submit that adjacent CIE lands could be looked at with regard to access and egress for

construction material.

Lack of proper and meaningful consultation with local groups.


Support the submission by East Wall Protection Group who officially represent East

Wall.

226. Christine and Martin Taylor, Ossory and District Residents Group, c/o 7

Ossory Road, Dublin 3


Concern with respect to construction and operational phase of the development.

Particular concern regarding noise vibration and traffic movements during the

construction phase.

The level in noise will have a detrimental effect in particular on sensitive receptors for

example the infirm, the very young particularly and the proposed 24-hours a day work

plan.

Concerned that vibration from the bore will travel, damage foundations and cause ill-

health.

Have concerns regarding significant increases in traffic movements both during the

building and operational phase due to building of the operational station.

Request that an oral hearing be held to expand on issues.

Request that mitigation and detailed conditions be placed on the Railway Order to

protect residential amenity.

227. Karim White and others, c/o 48 West Road, East Wall, Dublin 3.


Concern with respect to disruption to residential amenity.

Request that mitigation be put in place to protect residential amenity.

Request that an oral hearing be held where a more detailed consideration could be

given to issues.

Supports the submission by the East Wall Protection Group.

There is a lack of direct benefit of the interconnector to East Wall.

No plans are currently being considered for a DART stop in East Wall nor are there

plans to erect pedestrian bridges across the rail tracks that would speed access to

existing infrastructure in Docklands and at Connolly. This is a missed opportunity.

Request that options for an East Wall station and a new pedestrian bridge that creates

new shortcuts are properly considered for incorporation into the Plan.


Request that CIE consider the overall enhancement of the appearance of the East Wall

area.

Concern with respect to noise and dust.

Request that sound barriers be increased in specification to better insulate against

noise from train services.

Request that trees be planted along the whole of West Road and Ossory Road.

During the construction phase of the project request that all trucks exiting from the

site be sprayed with water to prevent transmission of clouds of dust.

Concern with respect to access to West Road. Request that care be taken to ensure

that everyday services such as post and waste collections etc. are facilitated

throughout the construction period.

The OCC building to overlook the West Road will inevitably affect the sightline,

skyline and light levels of the street.

Request that if the building is to be above the height of the existing freight line that it

be visually attractive building of architectural merit and not merely a utilitarian

structure.

Request that all areas around the building be generously landscaped with attractive

trees and shrubs.

Hours of operation should be limited to regular working hours. East Wall is a

predominantly residential area.

Concern with respect to potential damage to property from vibration.

Request that the idling position for engines being moved to Fairview Park where there

are no residents to be disturbed.

Concern with respect to drainage and flooding. Request that the risk of flooding from

backed up drains be minimised and that CIE undertake to keep all drains clear of

waste.

228. Nascadh Community Development, 75 Teeling Way, East Road, East

Wall, Dublin 3


Nascadh CDP works with the community in an inclusive way working against the

causes of poverty and social exclusion.

It is the view of the community that the proposal to build the DART Underground is

in the national interest and should go ahead but with limited impact on local residents.

East Wall has the misfortune of being in the Dublin Docklands catchment area but on

the periphery.

Neither the Dublin Docklands Development Authority nor Dublin City Council have

taken responsibility for planning in the East Wall area.

Very little has been done in terms of flood prevention in a high risk area.

The Dublin Docklands Development Authority developed an Area Action Plan which

has never seen the light of day.

The East Wall Community Development Council which represents 18 communities

and voluntary groups in the area prepared a submission to Dublin Docklands

Development Authority’s Masterplan which they would like considered when

planning the DART Interconnector.

Careful consideration needs to be given to East Wall Older Persons Needs Analysis.


Concern with respect to property prices in the area.

There should be a station in East Wall. The population warrants a station.

Boring should not take place on East Wall.

24-hour working should not be allowed under any circumstances.

There is a necessity for a Charter of Works agreed with an independent authority.

Enforcement is essential. Any independent authority must have power to impose fines

on breaches of the Charter. This should include hours of work, noise levels, dust

levels, access and egress etc.

There should be a programme for community gain to be agreed with the community.

There is a need for independent assessment of property.

Concern with respect to proposed works along West Road.

There needs to be better communication with the community.

Concern with respect to health impacts and risks, in particular asthma sufferers.

A Dust Prevention Programme should be built into the plans.

There is a need for a Flood Risk Assessment to be carried out.

The development must take cognisance of existing plans for the area, either Dublin

City Council or Dublin Docklands Development Authority’s.

An oral hearing should be convened.

A submission is attached in Appendix 1 which sets out the submission on Dublin

Docklands Development Authority’s draft Dublin Docklands Area Masterplan 2008,

submission prepared by community voluntary sector in East Wall and North Lotts,

East Wall Residents Association, East Wall Community Council, North Lotts

Community Residents Association and Nascadh CDP and East Wall Older Persons

Needs Analysis Implementation Steering Committee.

The submission is also accompanied with the Docklands East Wall Action Area Plan

2004.

The submission is also accompanied with the East Wall Older Persons Needs

Analysis Project January 2008.

229. Dolores Steele, Chairperson, Parkside North Strand Residents Group, 13

Hope Avenue, Dublin 3.



The East Wall area contains over 500 private residential dwellings and compromises

an aggregate population of c.1,200 people the interests of which are represented by

the Parkside North Strand Residents Group.

There is a need for complete transparency on its communication.

The draft Railway Order and accompanying documents make no reference to the

human impact of the development specifically on residents living adjacent to works

on the East Wall and North Strand.

The submission is based on the community experience of recent large scale

infrastructural works namely the replacement of the East Wall Road Railway Bridge

2002 and the construction of the Dublin Port Tunnel 2001-2006. In both these projects

the concerns of residents were not considered in any meaningful way in advance of or

during the programme of works.


CIE has once again made absolutely no effort to consult with residents who live in

close proximity of the proposed tunnel works site.

Urge An Bord Pleánala to hold an oral hearing so that the concerns of residents

groups can be heard openly and considered prior to any Railway Order being granted

for alternative work sites to be thoroughly considered.

Could the tunnelling and boring works not commence on CIE owned lands within the

Docklands catchment area which are not in close proximity to private residential

dwellings?

Concern with respect to construction traffic on East Wall Road between West Road

and North Strand Road.

Contamination. The railway embankment located on West Road/Stoney Road is

highly contaminated after over 100 years of rail use. Disturbing this embankment to

accommodate the works would result in significant contaminants being released into

the local environment.

The Railway Order makes no effort to address the issue of contamination.

Concern with respect to noise, dust and light pollution. The Railway Order does not

adequately address the long-term issues of noise, dust and light pollution.

Concern with respect to vibration from works undertaken and impact on structural

condition of property in the area.

No meaningful consideration is given by the CIE as to the disturbance that residents

will have to endure for several years.

Negative impact upon residential and community amenity.

Submit that An Bord Pleánala has a duty of care to ensure that all planning matters are

in full compliance with the permission granted.

CIE has a long history of non-compliance.

CIE cannot be trusted to honour any commitments it gives.

Seek commitment to be written into any Railway Order granted.

Request that an independent arbitrator be appointed in advance of any works being

undertaken.

The submission is attached by Appendix 1 outlining an agreement between Iarnród

Eireann and the members of the North Strand Community Group. It sets out 8 points

which the members of the North Strand Community Group require to be agreed with

Iarnród Eireann.

1. An agreed arbitrator to be appointed

2. Absolute guarantee that a retaining wall being constructed at Stoney Road will

be removed and the embankment reinstated and landscaped within 6 months of

completion of the work.

3. Iarnród Eireann agrees to make good the damage of any that may be caused to

homes on the North Strand East Wall area due to works.

4. Iarnród Eireann agrees to make payment to residents who experience

disturbance and are inconvenienced from the works to such an extent that in

the opinion of the arbitrator payments of compensation is warranted. The

amount will be decided in each case by the arbitrator on the basis of claims to

be submitted in writing by the residents.

5. Iarnród Eireann agrees to have all payments for a disturbance and are

inconvenienced to residents as adjudicated by the arbitrator paid for with

further agrees to make all payment for damage to property as adjudicated by


the arbitrator as soon as possible but not later than 6 months after the removal

of the wall.

6. Iarnród Eireann agrees to make available to the residents through the arbitrator

all professional studies and surveys it conducts in the area in connection with

the works which affect their homes.

7. Iarnród Eireann agrees to make an ex-gratia payment of €15,000 to the

NSCAG for the benefit of the community affected by the works.

8. If the above procedures are selected i.e. arbitration then the decision of the

arbitrator shall be final and binding.

9. In consideration of the Iarnród Eireann agreements listed 1-8 above the

members of the NSCAG will cease their protest when this agreement is signed

by the representatives of Iarnród Eireann on behalf of Iarnród Eireann with the

authority of that company and by members of the NSCAG. The NSCAG and

its members agree to make every effort to ensure that no protest resumes after

this agreement is signed and further agree that if any current member of

NSCAG who has signed this agreement resumes the protest to the extent that

the contractors impeded in the exclusion of the works this agreement shall be

null and void and Iarnród Eireann shall not be liable for any payment of

compensation to the residents

10. This document and its provisions are legally binding and enforceable in the

event of a breach of any provision contained therein.

230. Amanda Ralph, Apartment 138, Crosbies Yard, Ossory Road, Dublin 3.



Concern with respect to access to Crosbies Yard residential development during

construction of the DART Underground.

Concern with respect to connectivity within the Dublin 3 area during construction

works being carried out.

Concern with respect to the proposed temporary possession of West Road whether it

is a long-term possession or for a period of 6-8 years.

Concern with respect to access to the area for fire tenders and bin collection.

Concern with respect to dust levels during construction activity and impact on quality

of life of residents in the area.

231. Crosby Properties, Unit 24, Point Village, East Wall Road, Dublin 1


The submission is made with respect to the following properties. The Stockyard,

Sheriff Street, Dublin 1, Crosbies Yard, Ossory Road, Dublin 3 and Point Village O2.

Request that an oral hearing be held and that the right to submit additional

information be realised.

Support for public transport in principle and can see the benefits of the interconnector

concept.


Concern with respect to the general vagueness of the construction proposals within

the North Wall Yard north of Sheriff Street.

The unacceptable concept of 24 hour working in this area for the full 6 year duration

of the project due to the east – west boring proposal with consequent severe impact on

residents and businesses.

The sterilisation of a large area of the North Wall Yard post-construction contrary to

Spencer Dock Masterplan expectations.

Significant increase in HGV traffic on Sheriff Street impacting on O2 and Stockyard

with day and night movements of spoil and materials, contend that this material

should be moved by rail.

Sheriff Street is weight-restricted and the bridge propping proposal is not the

appropriate solution for an arch structure.

The impact on Ossory Road development of the alterations of West Road is not

clearly explained in the EIS and in particular the presence of a Trust Board Service

under the railway line adjacent to the road is not considered.

The Stockyard will be sandwiched between two electricity substations with no

evaluation in the EIS why the existing substation is not suitable for the needs of the

project.

Concern with respect to noise, vibration, dust, traffic, visual impact, duration of the

works, possible damage to the developments and impact on existing utilities.

While the construction phase traffic impact has been assessed no strategic assessment

has been carried out.

Concern with respect to the visual impact on the area. Concern with respect to

duration of the works. Possible damage to property from ground settlement and

flooding.

Reviewing Section 16 in particular Figure 16.12V3 the Stockyard building falls

between 1 millimetre and 10 millimetres settlement contour has shown a Figure 7.

The shape of the contours is interesting as they dip significantly in towards the DART

Underground alignment. There is no explanation as to why this is the case. It is

possible that the assessment is misrepresenting the level at Sheriff Street Bridge.

As the building falls between settlement contour lines 1.0mm and 10mm this

automatically qualifies the building for a Phase 3 assessment as directed by Section

16.2.2. Further to this the building is founded on 600mm board piles which also

qualifies it for a Phase 3 assessment.

With respect to Crosby Yard development during construction a significant amount of

works were carried out to prevent flooding due to the nature of the site. Section 4.3.1

of A15.2 describes the changes to ground levels in the area of the OCC. It is proposed

to raise the existing level by 1.9 metres OD to 4.3.1 metres OD. The basement of the

Crosby Yard is 0.79 metres OD. No impact on the surrounding environment when

changing the existing ground levels has been carried out.

Concern with respect to impact on existing utilities.

Note: A rising main was installed during the construction of Crosbies Yard

development. Its location is shown on Figure 8 included in the submission. This rising

main has not been identified in the utility search.

It is difficult to understand the proposed diversions.

Concern with respect to operational phase impacts such as noise, traffic and visual.


There is a general vagueness of the construction proposals within the North Wall

Yard, North Sheriff Street. The EIS is not consistent in the permanent works it has

assessed through its various sections.

Concern that all impacts of the project have not been fully assessed and mitigated.

Concern that the nature of construction works have not been given sufficient

consideration.

Many of the mitigation measures proposed at the construction phase require the

contractor to write some form of plan. These plans such as the Construction

Management Plans, Noise and Vibration Plans or any other plan cited as the

contractors responsibility post contractor award should be in draft format and

available at the oral hearing to allow the robustness of the mitigation measures to be

assessed.

24-hour working is unacceptable for the full 6-year duration of the project.

Working hours should be restricted to more sociable hours.

It is unclear from the EIS what the full intent of the new track work within the

existing CIE lands is. There will be sterilisation of larger areas of the North Wall post

construction contrary to Spencer Dock Masterplan expectations.

As no strategic traffic assessment has been carried out in construction stage it is

impossible for the applicant to determine what the traffic impacts are.

There will be a significant increase in HGV on Sheriff Street impacting on O2 and the

Stockyard with day and night movements of spoil and materials.

It is contended that all this should be moved by rail.

The main access and egress on the eastern portal site is via a new ramp constructed off

the Sheriff Street viaduct. There is a weight restriction on this structure at present and

propping the bridge is not the appropriate solution. A new proposal should be

determined which will protect this structure.

The impact on Ossory Road development of the alteration of West Road is not clearly

explained in the EIS and in particular the presence of a Trust Board Service under the

railway line adjacent to the road is not considered.

The Stockyard will be sandwiched between two substations with no evaluation in the

EIS of why the existing is not suitable for the needs of the project.

There is general confusion with regards to the amount of fill required.

The substation if required should have a roof installed to reduce the noise emissions

and to allow external walls to be reduced in height to be less visually intrusive.

Submission attached by photographs relating to Crosbies Properties including the

Stockyard and Crosbies Yard.

232. Diarmuid Reidy and others, c/o 5 St. Barnabas Gardens, East Wall,

Dublin 3.


Support the construction and infrastructure upgrade as a positive development.

Concern with respect to access especially along West Road and environs.

Request that access to West Road be upheld in a way that does not jeopardise health

and safety for residents.

Request that proper traffic management and safety precautions are put in place to

mitigate against concerns of heavy traffic.


Request that risk associated would undetonated explosives and their potential impact

on residents and properties be taken into consideration.

Concern with respect to noise. Request that mitigation in the form of noise barriers be

put in place to alleviate concerns of noise.

Request that idling position is relocated near to Fairview Park where there are no

residential areas to be disturbed and also that appropriate sound barriers are erected to

mitigate the noise disturbance both during and after construction of DART

Underground.

Concern with respect to the construction and location of the OCC building

overlooking West Road in particular the height of the building, it is visually

interfering with the sightline and skyline of the railway tracks.

Request that the construction of the OCC building is made in such a way that the

height of the building does not exceed the level of the railway track. Also we request

that planned landscaping around the OCC building is extended to include the full

length of Ossory Road and West Road including the continuation of the treeline on

West Road.

Concern with respect to the description of East Wall as an industrial area in the EIS.

East Wall is a residential area.

Concern with respect to drainage and flooding. There is no mention of any emergency

plan should any flooding occur and this would lead to serious problems in this area.

Request that before any construction work begins all drains are cleaned and that there

is a regular cleaning cycle in place throughout the construction phase.

Request that CIE would indemnify the local residents against any flooding and

structural damage caused by the construction.

Concern with respect to impact on property values.

Request that CIE provide for the resurfacing of both West Road and Ossory Road due

to the wear and tear of the construction traffic. Also request that a DART station is

provided in East Wall.

Request that working hours be limited to regular working hours.

Request that categorisation of work be amended and that a proper analysis be made

which assesses the full environmental, social and residential impact on East Wall

residents’ health, homes and properties.

Request that an oral hearing be held on behalf of the East Wall Protection Group who

are officially representing East Wall.

233. East Wall Water Sports Group Ltd. c/o Paul Dolan, PO BOX 11314, East

Wall, Dublin 3.


Realise the importance of DART Underground system for the City.

Concerned with respect to the negative impact upon East Wall Water Sports Group

members and also potential pollution arising out of the proposed works and the length

of time it will take to carry out such works.

Endorse this submission by protecting East Wall Action Group and share their

concerns.

Request that an independent arbitrator be appointed to ensure enforcement.

Request that an oral hearing be carried out.


Request that a Community Charter of Rights be agreed with Iarnród Eireann.

Seek an assurance that no polluted substance of any nature will be discharged into the

River Tolka.

Volume 2 of the EIS report, Chapter 23.3.8 states that there is no water sports facility

in the study area. This is an error.

The East Wall Water Sports Group was founded in 1980 and have a new purpose built

facility which was opened in May 2007 for a cost of €1.2 million.

The Tolka River and estuary are integral to the operation of the centre. Concern that

the project will cause serious pollution to the Water Body.

EWWSG is an accredited teaching centre. Concern that any pollution would close

down the centre on health and safety grounds.

Concern with respect to connectivity to the area and groups travelling to the centre.

Submission accompanied with a synopsis of the group giving a brief history of the

group’s membership and also the various numbers of groups from Dublin who use the

facility. Submission is signed by Paul Dolan, Chairperson, 17 Russell Avenue, East

Wall, Dublin 3, Billy King, Honorary Secretary, 174A Springdale Road, Raheny,

Dublin 5 and Margaret Croke, 127 Claedon Road, East Wall, Dublin 3

234. East Wall Medical Centre, c/o Dr. Joseph Murphy, 145 Church Road,




Concern with respect to effects of tunnelling, soil removal, dust levels and heavy

traffic.

There are a high level of respiratory diseases in this community.

Respiratory diseases include asthma, chronic bronchitis and emphysema.

The area has a large elderly population who will be adversely effected by all the

above issues.

It is imperative that CIE and its contractors would use the best possible dust and noise

control procedures during tunnelling construction.

235. Elaine and Paul Kenny, 35 Blythe Avenue, East Wall, Dublin 3.


Object to the development.

Negative impact upon the current safe environment and play areas for children.

Concern with respect to impact upon south facing garden fronting onto Blythe

Avenue.

Any increase in traffic and noise pollution, reduction of privacy, air quality and light

will affect residential amenity.

Blythe Avenue is residential, an industrial site operating 24/7 within meters of the

observer’s home would make life unbearable.

Concern with respect to potential risk to family health.

Concern with respect to noise and sleep deprivation.

Concern with respect to impact upon evaluation of property.


Concern with respect to dust and dirt and impact upon property.

Concern with respect to impact upon the structural or properties foundations.

Concern that access to the property may be restricted for unspecified periods during

the works.

Request that noise and air pollution mitigation measures are put in place to protect

residential amenity.

Request that the applicant reconsiders the original plans to tunnel both west-east and

east-west thereby reducing the impact for the residents in East Wall.

Consideration should be given to employing local residents at every level.

The community should benefit from a local station in consultation with the residents.

Permanent fixtures should be of the highest quality and aesthetically pleasing.

Road safety should be a priority.

CIE should consult with both the residents who will be impacted during the project on

the East Wall Protection Group.

Highest standards should be applied to both tunnel and cover to ensure that noise and

sound pollution is kept to very minimum in the operation and maintenance of DART

Underground.

Request that compensation is forthcoming to local residents with the inconveniences

and expense incurred.

Request that the Developer pays for full independent surveys of property prior to

construction and again in completion.


236. Ian Slacke and Emma Bradley, c/o 12 St. Mary’s Road, East Wall, Dublin

3.


The EIS does not reflect the change from 1 to 2 TBMs.

Concern with respect to pollution - dust, noise, vibration, drilling, heavy machinery,

waste, light etc. which will have detrimental impacts on the residents of East Wall.

Concern with respect to construction trucks carrying spoil every couple of minutes.

Constant pollution is unacceptable, due to risks to homes and people both during

construction and the operational phase.

Concern with respect to people with health issues.

Concern with respect to basic facilities including gas, electricity, water and sewage

and access to same.

Concern with respect to increase in traffic both during construction and operational

phase.

Safety concerns accompanying traffic. Concern regarding the route the spoil will be

taking and the effect of this on the surrounding area.

Concern with respect to the duration and length of the infrastructural works.

Residents will experience extended periods of stress and security, lower quality of life

as well as invasion of privacy.

Concern with respect to impact on the value of homes in the community.

Concern with respect to the lack of regard by Iarnród Eireann for fundamental safety

going into this project, in particular in light of the collapse of a viaduct in Malahide.



237. John Conway, 56 West Road, East Wall, Dublin 3.


It is unclear from the EIS whether any of the projections and assumptions made in the

EIS were altered or amended as a result of a major change in the direction of

tunnelling. Can this point be clarified with CIE.

In Section 2.7.8 of the EIS it is stated that the original intention was to have two twin

TBMs in operation at one time. One from the western Portal in Inchicore and one

from eastern portal in East Wall. This option would have reduced the time required

for the construction phase by 6 months. However Section 2.7.8 indicates that the

decision to proceed with only one TBM tunnel form the eastern portal was taken in

early 2010.

Concern with respect to the location of the operational control centre on West Road.

There is no operational need to place this new structure overlooking residential homes

on West Road.

Concern with respect to construction works on West Road in relation to the

approaches to the East Wall Bridge and reconfiguration of the existing railway

infrastructure.

It isn’t clear from the EIS what is the operational reason for continuing construction

24 hours a day on the West Road portion of the works. The EIS states that Pile Drive

will occur in order to build-up the land between the existing railway lines that run

along West Road. Pile Drive is by necessity a heavy duty construction activity and as

a result extremely noisy.

Concern with respect to traffic restrictions and West Road. The EIS mentions in one

section that West Road will be reduced down to one lane of traffic for three months

while in another section it states that traffic restrictions will be in place for four

months. There is a need for clarification.

The count and the resulting estimates in the Traffic Impact Assessment do not take

into account the opening of the Samuel Becket Bridge across the Liffey in December

2009.

Is it possible to ask CIE to undertake another traffic count so that we have some more

accurate and more recent data upon which to base assumptions?

Concern with respect to removal of excavated material.

Contend that a more detailed plan in the form of permanent rail-centred extraction

material removal methodology be supplied by CIE in advance of approval being

granted by An Bord Pleánala.

The applicant should give a commitment to used rail as a primary method of goods

delivery in and waste material extraction.

Concern with respect to movement of HGVs during construction phase of the project.

Goods and construction material delivery by HGV to the eastern portion of the site

could be reduced if a rail approach was adhered to.

Concern with respect to the need for 24-hour removal of materials or even of the 7am-

3pm on the weekends proposed.


Ensuring that a 48-hour onsite storage facility is provided for the West Road works

would negate the need to have 7am-3pm HGV movements on West Road on Sundays

or public holidays.

The proposed strategic cycle network – premium cycle route proposed by Dublin City

Council across the Tolka at East wall and West Road junction and then down West

Road and along the Royal Canal will be impacted upon by the DART Underground.

There is no detailed analysis as to how

1. This amenity will be effected once construction works on West Road begins

and

2. A narrowing of the road carriageway as a result of introducing the cycle lanes

will further limit the carriageway available once the construction works on

West Road commence.

Concern with respect to on-street parking for site workers. Concern with respect to

landscape and visual impact in particular the Operational Control Centre (OCC).

Contend that a structure that will be in operation for 24 hours of every day for 7 days

in the week, which will be at least 15-20 feet above the height of the railway line, will

have a long-term impact on the residents of West Road.

There is no operational reason why this building is being placed in East Wall

Necessity to reinstate trees, foliage and sound reduction barriers on West Road

railway embankment.

Serious concern about the floodlights being in operation all day every day for 3-6

years.

Construction activity along West Road portion of the works should be limited to

normal working hours Monday – Friday with no works on Saturday or Sunday or

public holidays.

Concern with respect to ground noise and vibration contend that 24/7 working will

give rise to unacceptable noise levels particularly along West Road.

CIE should notify owners of all properties within the settlement zones. There is no

indication of how a home owner is to know whether their property lies within the

zone or not.


No problem baring a large amount of discomfort for the common good however

request that before granting approval the Board considers what socioeconomic

benefits will accrue to the residents of East Wall as a result of the project.

Contend that an underground entrance with ticket barrier to the Docklands Station on

Church Road/Blythe Avenue would provide direct and immediate benefits to the

residents of the whole of East Wall once the Underground is operational.

By their own admission in the EIS CIE fully accept that two thirds of the passengers

entering the Docklands underground station will be entering through the northern

Sheriff Street entrance.

Having another entrance on the northern side will only increase the accessibility of

the station.

Providing an underground access to the Dockland Station via Blythe Avenue will

provide a tangible reward to East Wall residents’ forbearance.


238. Sinead Courtney, 53 St. Mary’s Road, East Wall, Dublin 3.



Concern with respect to health risk during construction.

Concern with respect to construction traffic.

No station is being provided for East Wall.


Support the submission by the East Wall Protection Group who are officially

representing East Wall.

239. Anne Fegan, 122 Caledon Road, East Wall, Dublin 3




Concern with respect to the impact of air pollution on health.

Concern with respect to dust on residential amenity.

Impact on flora and fauna in the gardens of East Wall and on trees and public roads.

Impact on children’s ability to play in the area due to increase in traffic.

The disruption of flow of the traffic to and from West Road.

The increase in the traffic flow on Church Road.

The lack of a revised EIA based on two boring machines being located in East Wall.

The lack of Impact Assessment on residents of East Wall.

The lack of planned DART rail access stations for East Wall residents.

The impact of the control centre and the light of the gardens to the east of and

including West Road, Barnabas Gardens, Caledon Road and Moyelta Road.

The disruption to the no. 53 bus route for the residents of East Wall.


240. Brendan McManus, Ossory Properties, Unit 16, Ossory Court, 24 Ossory

Road, North Strand, Dublin 3.


Strongly object to the proposed development.

Concern with respect to impact of the works on East Wall.

Serious concern with respect to noise levels, vibration from tunnelling, waste, air

quality, vermin.

Concern with respect to traffic. Access to industrial estate by delivery vehicles,

customers and suppliers, road closure and diversions parking.

The increase of trucks and heavy machinery on access routes to Ossory Road.

There has been no consultation with the tenants and owners of residential properties

on Ossory Road and the businesses who have operated from there over many years.


241. Anne Gahan, 3 Hawthorne Avenue, East Wall, Dublin 3.



Concern with respect to the impact of the DART Underground on the East Wall area.

Concern with respect to duration of construction hours, 24 hours 7 days a week.

Concern that the Impact Assessment is not based on two boring machines being

located in East Wall.

There is a need for a station in the area.

Concern with respect to traffic implications of the DART Underground for

connectivity in the East Wall area.

242. James Smith, 128 Caledon Road, East Wall, Dublin 3.



Concern with respect to lack of communication and lack of consultation from Iarnród

Eireann.

Concern with respect to the proposed temporary possession of Ossory Road and West

Road.

Concern with respect to noise levels, dust levels and devaluation of property.

Request that mitigation measures imposed by An Bord Pleánala give serious

consideration to the residents of East Wall as Iarnród Eireann have failed to do so.

Request that An Bord Pleánala grant an oral hearing.

Request that an independent arbitrator be appointed to ensure a proper standard of

mitigation measures and to ensure that an independent Charter of Rights is written

into to Railway Order to ensure proper enforcement of conditions laid down by the

Board.

243. Ruairi O’Meara, Coady’s Yard, West Road, Dublin 3 c/o Eversheds

O’Donnell Sweeney, 1 Earlsford Centre, Earlsford Terrace, Dublin 2.


Ruairi O’Meara is the owner of .52 hectares of land proposed to be acquired by CIE

for the purpose of the provision of DART Underground.

The lands are located at the eastern extremity of the proposed works to provide DART

Underground.

The lands are referenced D6B A02 and D6C A02 in the Railway Order application.

A number of concerns have been identified regarding procedures adopted by the

applicant in the lengthy design phase of the scheme for DART Underground.

Concern regarding content and conclusions of the EIS.


The statutory newspaper notice states that the proposed works including operational

control centre building and traction substation to be located on CIE lands adjacent to

West Road however the proposed operational control centre is to be partially located

on lands owned by Mr. O’Meara. The newspaper notice is inaccurate and misleading.

Mr. O’Meara is concerned with respect to the lack of consultation by CIE.


Mr. O’Meara advises that he has received no correspondence or contact from CIE or

its advisors regarding the impact of the interconnector or DART Underground on his

property prior to January 2009.

Mr. O’Meara advises that for his part his objective has been to secure a scheme of

development on his lands.

Mr. O’Meara advises that his first contact from CIE regarding the DART

Underground proposal and its potential effect on his lands was a phone call on 14th

January 2009 inviting him to a meeting to discuss the proposal.

By the time he had prepared a scheme of development for his lands it was close to

lodging an application for planning permission.

Mr. O’Meara lodged the planning application Reg. Ref. 2219-09 to Dublin City

Council which sought permission for a mixed use development. Permission was

refused for a single reason relating to the provision of DART Underground.

An Bord Pleánala upheld the decision for a single reason relating to the identified

need to secure the site for the purposes of the proposed DART Underground scheme.

Submit that notification of Mr. O’Meara’s by CIE of its proposals for DART

Underground was wholly inadequate.

The proposals of CIE have not been adequately reflected in planning policy guidance

documents since their inception in 2002.

The EIS does not consider the land use implications and impacts of the transport

proposal.

Submit that the proposed works associated with the DART Underground and the

subject lands materially contravene the land use objective for the site.

As no alternative location for the tie-in of DART Underground to the main northern

rail line railway was studied by CIE it is contended that the EIS lodged with the

Railway Order application is deficient.

Mr. O’Meara’s site is a serviced inner city site zoned for enterprise employment type

uses.

The EIS lodged with the Railway Order application does not consider the impact of

loss of the employment land resource that is Coady’s Yard on the proper planning and

sustainable development of the area.

CIE demonstrates its lack of appreciation of the importance of Mr. O’Meara’s lands

when it misrepresents the location of the OCC and the traction substation in the

newspaper notice advertising the Railway Order application.

In view of the flaws in the Railway Order application documentation and the

significant shortcomings in the design procedure for DART Underground and the

severe flaws in the EIS lodged with the application, the Board is asked not to approve

this application.

Submission accompanied with maps indicating the location of Mr. O’Meara’s lands.

The submission is accompanied with a report by O’Connor Sutton Cronin and

Associates Consulting Engineers dated 17th

August 2010.

This report examines the proposed acquisition of lands from Mr. O’Meara under the

proposed Railway Order application. It concludes that significant areas of land have

been acquired for non-core activities.

These include the construction of a large operational control unit with access road and

car parking area along with the traction substation.

Each of these facilities could be located elsewhere and neither is mission critical to

the DART Underground station.


A number of alternative locations have been identified for each of these facilities in

the scheme EIS.

The report finds no evidence of the investigation of alternative horizontal railway

alignments outside of the O’Meara lands.

It further finds that significant acquisition of land is required in order to accommodate

a realignment and improvement of West Road.

This realignment is necessary only because the vertical alignment of the DART

through the Mr. O’Meara lands reduces headroom under the existing West Road

Bridge. A very minor amendment to the vertical alignment would obviate the need for

such realignment and this coupled with the relocation of the operational control centre

and the traction substation would result in a minimal impact on the Mr. O’Meara site.

No information has been provided in respect of alternative realignments of West Road

nor has any information been provided in respect of alternative realignments of West

Road nor has any information been provided in respect to design standards of road

safety audits having been carried out for the realigned road.

The bulk of the subject site could be maintained free from acquisition subject to minor

agreements to the vertical alignment of the DART Underground.

244. Vincent Keane, 201 Crosbies Yard, Ossory Road, Dublin 3.



Concern with respect to connectivity within the East Wall area.

There is no station proposed for the East Wall area.

Request that a station be constructed instead of a footbridge so that the local

community would be able to use the new DART line and the area would benefit from

the additional services.

Concern with respect to traffic chaos at the junction of Ossory Road and North Strand

especially when trying to turn right.

Concern with respect to access restriction to and from Crosbies Yard residential

development and Ossory Road.

Concern with respect to access for Dublin Fire Brigade to Crosbies Yard residential

development.

Concern with respect to health and safety risk.

Concern with respect to inconvenience and disruption to residents of the Crosbies

Yard development.

An Bord Pleánala should ensure that there is safe access to the Crosbies Yard

development at all times from by Ossory’s Road and West Road during construction

of the works.

Submit the construction of an operational control centre is proposed to take place

halfway between Clontarf Road and Docklands Station. It would be appropriate and

of benefit to the East Wall community to also build a station at this location.

In addition to pedestrian access request that An Bord Pleánala ensure that a bridge for

pedestrians and cyclists be provided from the southern end of Church Road in East

Wall over the railway enclosing line to give access to the proposed Docklands Station.

Strongly object to the construction of the OCC in an area in such close proximity to a

residential area.




It will reduce the rental income for the Crosbies Yard development.

The OCC should be relocated somewhere near the Docklands.

Concern with respect to noise in particular from tunnel boring machines.

Concern with respect to access and egress for construction traffic for the proposed

OCC and West Road will be from West Road. This will cause significant noise and

inconvenience.

Concern with respect to construction traffic and hours of operation.

A Community Liaison Officer should be appointed.


245. Patrick Tuite, 165 Church Road, East Wall, Dublin 3.


Welcomes the project.

Note that an East Wall Area Action Plan strives to connect the East Wall area into the

wider Docklands Framework by identifying and suggesting mitigations to the hard

physical barriers that surround it.

There is no mention of the East Wall Area Action Plan in the submitted Railway

Order.

This is a serious omission.

Submit that the design of the railway alignments, the tunnel layout and other ancillary

works at East Wall should take into account accommodating at some time in the

future a pedestrian crossing footbridge and the CIE owned lands from Church

Road/Malachi Road direction into the Docklands for the future benefit of the residents

of East Wall. In connecting to the public transport hubs the commercial and retail

facilities and the recreation facilities that are currently planned in the Docklands.

Concern with respect to lighting. It should be a condition that lighting during

construction and operational phases is reflected down.

Concern with respect to traffic and access points into and out of East Wall heading

into the city centre and south city direction.

Concern with respect to the level of traffic on Ossory Road.

Believe that the traffic projections outlined in the EIS are widely optimistic and any

constrictions of traffic from Ossory Road will have a significant impact of movement

in the local area.

Mitigation measures should be put in place to control traffic.

Submit that West Road/Ossory Road/Coady’s Yard is not the correct location for the

operations and control centre.


The submission is accompanied by a letter from Gerry Keegan, Public Affairs

Manager for DART Underground to Patrick Tuite:

It is concerned with the possibility of installing a pedestrian footbridge as

indicated in the East Wall Area Action Plan. It states it is Iarnród Eireann’s

understanding that engineering constraints prohibit this.

It is unlikely that residents along West Road and Church Road would welcome

such a structure in proximity to and in full view of their homes. Footbridges


can be quite large structures in order to comply with modern day safety

guidelines and therefore may have an impact on space availability for traffic

movements on the local road where it is situated.

There are engineering constraints with respect to locating a station in East

Wall.

Another consultation evening will be held in East Wall prior to the submitting

of the Railway Order application.

__________

Tom Rabbette

Senior Planning Inspector

5th October 2011

appendix 1 - summary of written submissions

Documents