Councillor Derek Mitchell (FG), B.A.I, MSc, FCA,
Member Wicklow County Council, Mid-East and Greater Dublin Regional Authorities, Wicklow’s Strategic Policy Committee on Roads.
Appeal ZD06D.ZD2010 Cherrywood. Bord Pleanala Oral Hearing 13th March. Academy Plaza Hotel, 10am.
1. The N11 at Fassaroe and Kilmacanoge is at least 30% over capacity because of its poor design. Traffic jams regularly are 4km back to the Cherrywood Junction.
2. 40% of Cherrywood commuters will come from the South, almost all along the N11 at Fassaroe as there is little public transport.
3. The Regional Planning Guidelines to 2022, the superior guidelines for the Region, list improving the N11/M50 as the top road scheme to be implemented.
4. The NRA has produced two reports on improvements required on the N11/M50 in March 2010 but has not moved to implement any of them, seemingly ignoring the RPGs.
5. The NTA submission on Cherrywood, about the N11/M50, is in conflict with the NRA Report and is also not in accordance with its own Strategy document.
6. In view of this, specific improvements to the N11/M50, from these NRA reports, should be a precondition of any approval for Cherrywood.
7. The quantity of retail development is excessive by a large factor.
1. N11 is already 30% over Capacity.
The NTA in their ‘proposals for Phasing…Transport Infrastructure…Cherrywood’ 9.2.1 state the capacity of a two Lane dual Carriageway (UAP 1-3) is 2,300 to 3,600 pcu/hr per direction. Capacity reduces at junctions due to merging traffic going more slowly (Southbound is very poor because of short and narrow on/off ramps) and on hills. These are present at Fassaroe and an assumed capacity of 3,000 would be expected. At Killmacanoge there is additionally a 60kph limit, bus stops and garage entrances and exits with no on/off ramps. Capacity would be at the lower limit of about 2,500.
NRA Traffic Counts for weekdays in 2012 for M11-26 at Fassaroe:
AM peak N/B 3921 (0800-0900) 31% over capacity of 3,000
PM peak S/B 3612 (1700-1800) 20%…………………………………..
Traffic on the M50 uses the Cherrywood exit to avoid the queues using the local road through Shankill to Bray or coming back on the M11 via the Loughlinstown roundabout or the Wilford Junction to queue jump. This can save 15 minutes.
2. Commuting demand to Cherrywood from the South
The NTA Transport Strategy model, table 4.3 in Cherrywood documentation, shows that a large % of workers will come from specified places in Wicklow, 33%. In addition 24% come from ‘other’. Some of these will be from rural areas of Wicklow such as Enniskerry and Roundwood. Thus 40% are likely to commute from the South. Public transport from the South is poor to nonexistent so they will use the already overcrowded N11/M50.
3. NRA Reports on M50/N11
A. M11/N11 Merging Study Final Report March 2010. Roughan & O’Donovan-Aecom.
This report on short term measures to improve Southbound flow in the PM peak period. It recommended improvements to the Killarney Rd, Fassaroe and Wilford Road junctions (includes longer and wider on/off ramps, traffic light junctions instead of roundabouts, etc.). These limited cost measures went to part 8 consultation but were never finalised. I asked for presentations to Wicklow CoCo and its Roads SPC but these never happened. It seems like the NRA just forgot about it. A summary of the report was included in my original observation to this plan.
B. N11 Corridor Review Fassaroe Junction to Kilmacanoge March 2010. Roughan & O’Donovan-Aecom.
This is a comprehensive study of the problem. It states (p3) ‘because of the piecemeal nature of the historical development of the N11 mainline in the Bray area there are a number of aspects of the route that are inconsistent with the overall N11 route standard, are non compliant with current road design standards and/or not suited to cater for current traffic volumes’. In summary the central problem is that local traffic going from Bray to/from its satellite villages of Enniskerry, Kilmacanoge and Roundwood must merge and demerge on the N11 mainline. This slows through traffic. The main solution recommended is to build parallel slip roads taking local traffic off the mainline as in almost all other dual carriageways. This can be done without building any overbridges which limits the cost. In detail these are:
1. Fassaroe Distributor Road
2. Dargle Road-Herbert Road link
3. Upgrade Fassaroe Interchange
4. Link N11 Western Parallel road to Fassaroe
5. N11 Western and Eastern parallel roads
6. Southern Cross to Kilmacanoge
7. Kilmacanoge parallel links.
It also states (p5) that putting the LUAS to Fassaroe will not improve traffic as it will still have to travel through the congested section to reach a Park n’ Ride there. In my view that Park n’ Ride would reduce N11 mainline capacity because of the large volume of merging/demerging. This report was produced in March 2010 and was never presented to Wicklow Councillors who were not aware of it. Over the last couple of years there has also been talk of a Kilmacanoge interim scheme but no plans presented.
Although the RPGs, the superior planning policy, list this road as the top one for improvement in the GDA no action has taken place to implement a single part of these plans in 3 years. It is essential that a precondition for building any more Commercial and Retail is that a number of improvement items should be completed first in view of the extra load it will place on the N11/M50. Specifically these should be the interim ones in the merging report, item 4 Link N11 Western Parallel Road and 3 upgrade Fassaroe Interchange. It would also be useful for the NRA, the NTA and the 2 Councils to set up a working group to implement these proposals.
4. M50/N11 Status in RPGs as the top Road Scheme for Implementation to 2022
Regional Planning Guidelines for the Greater Dublin Area 2010-2022 S6.3.2 Road Transport
In addition to the above, it is recommended that relevant Local Authorities and transport departments undertake, as part of an overall strategy developed as part of the NTA Vision document, a range of actions to improve the functioning of the M50/M-N11 area including measures such as traffic management and upgrade works, expansion of road capacity, bus priority, improved rail services and other identified options.
Table 9 RPG. Proposed Transport Investment Proposals for GDA.
Undertake, as part of an overall strategy developed by relevant stakeholders a solution and range of actions and works to improve the functionality of the strategic road network, including the M50/N-M11 area, consistent with the NTA Strategy.
The only other road schemes mentioned in the RPGs are the Outer Orbital Route and Eastern Bypass both of which are to be implemented after 2022. The requirement to improve the M50/N11 and the N11 at Arklow are the only other schemes explicitly listed in the RPGs, the guiding planning document. The Arklow scheme is underway which leaves the M50/N11 as the only other one explicitly listed for the period to 2022.
5. NTA Proposals for Phasing… Transport Infrastructure … Cherrywood, conflict with NRA N11 Corridor Review Report and also conflict with clarifications made by the NTA during the Statutory Approval process of the NTA Strategy to 2030.
The NTA Cherrywood proposals state (10.6 p49) ‘it is necessary to review road capacity (M11/M50) over time as development occurs in Cherrywood’. This conflicts with NRA Report 3B above which states ‘it is not suited to cater for current traffic volumes’.
Mr Creegan’s (copy of this NTA letter in first submission) letter to the Dublin Regional Authority states that their Strategy ‘provides a comprehensive commitment to addressing the functionality and performance of the strategic road network (which includes the interface of the M11 and M50 motorways)’. The NTA proposals on Cherrywood do not conform to their previous clarifications given to the DRA as part of the Statutory approval process of their Strategy.
I am very disappointed that the NTA proposals on Transport conflict with the NRA and the NTA’s own Strategy. The recent letters from the NRA Chief Executive and NTA Director do not deal with the conflict with the NRA’s own report nor the above points.
6. Quantity of Retail development
In my original submission I showed that there was about twice too much retail as was required by the projected population and this will negatively impact on Bray as a retail centre.
To Summarise: A normal planning application, for even a small industrial estate, would be turned down if the access road was inadequate. It does not make sense to build a large new town in Cherrywood on a road which already has 4km traffic jams without a precondition to fix the problems with this road.