(24/10/2008)
Residents for Realignment Ltd is a pro Metro group set up to lobby to ensure that the RPA will choose a route for Metro North which maximises the use of the green and unoccupied zones and run the tunnels at a depth which ensures minimum disruption during construction and eliminates the possibility of post-construction impact.
The community of Drumcondra mobilized and mandated Residents for Realignment Ltd to participate in the decision making process and to ensure the protection of Drumcondra and surrounding areas from any potential negative effect of the construction and operation of Metro North.
The aim of this submission is to assist in bringing to the fore all aspects of the Metro North project from a resident’s perspective in order to achieve a gold standard project.
The RPA published a scoping document in October 2006 which outlined the "selected route" for the Metro North. This route used the green areas and unoccupied lands between the proposed stations in Drumcondra and Griffith Avenue.
On 12 April 2007 the RPA wrote to some residents enclosing a map of the new alignment. These letters caused major concern and anger for the following reasons:
a) There was absolutely no consultation with residents in relation to this new route.
b) Instead of using the green belt and unoccupied lands, the new alignment went under significantly more homes than the previous route
c) The RPA did not issue any maps with the proposed Ventilation Shaft (Shaft) in St. Patrick’s College marked on it to any residents even those residents whose properties backed on to this area. Up to the day the RPA applied for the Railway Order the Shaft was represented on the maps by a dot.
Through extensive lobbying RfR were successful in ensuring that consultation took place with all residents in the Drumcondra area over the summer of 2007 which led to the RPA deciding based on the results of the consultation to come up with a comprise alignment - Option 6. This Alignment moves the cross over tunnel to a green space- under the playing fields at St Patrick’s college as opposed to under people’s homes as previously planned.
RfR welcome this move although we do have major concerns in relation to the construction of this cross over tunnel, which we address later. RfR note that Option 6 does significantly reduce the number of homes that will be tunnelled under in the Ferguson Road area and the increases in depth that the tunnels will be at in the Homefarm Road area.
The Planned Metro North Project is the largest infrastructure project the state has ever undertaken. While the benefits to the city will be great during the operational phase the disruption and impact on the lives of thousands of residents living close to the construction sites and along the route will be huge. Therefore we request that An Bord Pleanala hold an oral hearing so the public may be heard on the issues.
RfR further request that under the EU Directive “Your right to participate” that the oral hearings be held in a manner that will facilitate participation by residents. In order to achieve we suggest that each of the seven Metro North areas as indicated by the EIS Volume 2 be held in and be specific to each of those areas. RfR believe this will achieve significant cost savings for all concerned.
RfR is concerned with the lack of detail, inaccuracies and lack of clarity that is apparent on many issues. The EIS lacks a clear hierarchy of issues and it confuses relatively unimportant secondary issues with important primary issues. Important detail in relation to surface water and traffic management is omitted. RfR request that these omissions are addressed, errors corrected and the impacts of the project assessed in relation to these omissions. RfR wishes to assert its rights under the EU directive ‘Your Right to Participate’ to respond to these issues and to be formally heard on them.
4.1. The EIS base line studies in many areas such as Traffic, Ground Water, Surface Water, Air and Climate have either omitted whole areas or not been carried out at all. All the base line maps carry disclaimers on them.
4.2. The EIS is based on incomplete/inaccurate information as in the case of the Griffith Avenue Station Site which is assessed as tillage field in spite of the planned extensive development for that site which DCU have stated would to be developed concurrently with the Metro.
4.3. The EIS does not contain methodology for the construction of the Ventilation Shaft or the Cross over tunnels - stating that the shaft maybe constructed by mechanical methods or drill and blast. The EIS does not assess the impact of the different methods on nearby residents. No blast trials were carried out.
4.4. The EIS does not contain any plans for operation monitoring in relation to air quality or noise at stations and shaft - in particular to monitor the noise from the fan testing. RfR request that ABP make it a condition of the Railway Order that a monitoring scheme for the construction and operational phases be agreed between the parties involved.
4.5. The level of detail in relation to surface water management is particularly poor and there appears to have been no flood risk assessment carried out particularly in areas that are prone to flooding such as the Millmount Ave., Millbourne Ave., Ferguson Road, Botanic Ave and Homefarm Road areas. The authors of the EIS do not appear to know if there is capacity in the foul water/storm drain system to take any increase water. No details of what the RPA plan to ask DCC to allow them to do in this respect were supplied.
The EIS is inadequate in relation to Traffic. Specifically
5.1.1. RfR have repeatedly requested the traffic impacts from the RPA and DCC. RfR have also lobbied the board of the RPA and DCC on this matter.
5.1.2. The base line traffic report carried out in November 2007 and updated August 2008 by MVA Consultancy does not contain an assessment of the Traffic Management (vehicle or pedestrian) around the Ventilation Shafton Millbourne Ave. As a result there is no impact assessment or any mitigation measures put in place. Neither is there any assessment of the impact of the construction of the Shaft on this area in relation to traffic. As the Shaft is being built in a school play ground RfR find this an unacceptable omission. RfR have previously requested that this be added back in to the scoping document and were assured that the Shaft would be treated in the same manner as all stations. (See email from MD O’ Reilly). Still it was not assessed. RfR does not understand how this omission could occur.This is a fundamental flaw in the EIS in the Drumcondra area. RfR request that ABP does not grant the railway order until this traffic assessment has been carried out and the impacts assessed. RfR wishes to assert its right to respond and to be heard on this important issue.
5.1.3. RfR understand that the RPA have put forth their strategic traffic plans in the EIS. However these are required to be supported at the detailed, local level by what are referred to as “Scheme Traffic Management Plans” which have to be developed in consultation with key stakeholders. This has not been done. (Emails from DCC 21/10/08)
5.1.4. This Shaft has been represented by the RPA as a dot on all the maps up to this application in spite of it being 33m long by 18m wide and 9.5m high. The RPA have told us that there will be 12 movements in and out of this site each hour and that Millmount Ave is the preferred route for construction traffic. Residents in Millmount have no front garden or off street parking. Children walking to school will have to walk across the exit to this site as this is the preferred route to school. (St Patrick’s College have requested that parents do not use the college to access the schools).
5.1.5. The method of construction of the cross over tunnel will also impact on the traffic. RfR would request that An Bord Pleanala will make it a condition of the Railway Order that the spoil from the construction of the crossover tunnel be brought out via the tunnels to the depot in Albert College Park and not via Millmount Ave. RfR request that it also be a condition of the railway order that construction material be brought to the cross over tunnel via the tunnel to reduce the impact on the schools.
5.1.6. RfR note that due to soil settlement during Metro North construction road maintenance along Griffith Ave may be needed. Is there a maintenance proposal? The EIS contains no plans for traffic management during these maintenance periods.
5.1.7. The EIS does not give details of the planned alternative accesses that it will put in place around the Drumcondra Station when existing access to certain roads and properties is cut off.
5.1.8. The EIS states that the contractor will further develop construction vehicle routing arrangements in line with the programme. This is unacceptable and we request that the traffic routing be part of the conditions of granting the railway order.
5.1.9. The EIS does not contain an assessment of the traffic management plan for a major incident occurring in the tunnels and how emergency vehicles will access the shaft or stations. There is no impact assessment of this scenario on the local areas. There is no report from the hazon hazop committee.
5.1.10. The EIS states that there will be pressure on parking as a result of Griffith Ave station but offers no mitigation measures for residents. RfR suggests that as part of the Property Protection Scheme residents who previously enjoyed on street parking, and who are no longer able to do so as a result of the project, be provided with front driveways or compensated if they have already paid for same.
5.1.11. The planned routes for construction traffic do not include mitigating measures for existing commuter traffic.
5.1.12. The EIS does not deal with construction workers parking. RfR request that it is a condition of the railway order that construction workers coming into area 106 and 107 are bussed into the area.
5.2.1. RfR object to the total lack of detail in relation to surface water management. The area between Griffith Ave and the Ventilation Shaft in Drumcondra and the Botanic Road area has been subjected to bad flooding in the past and this subject is one of concern to residents.
5.2.2. The EIS states that the major flooding in the past occurred outside the study area which is 500m. Major flooding has occurred within the study area – Millmount, Millbourne, Homefarm Road, and Botanic Ave are all within the study area and the impact of the planned increase in surface water entering the foul and storm drains on these areas has not been addressed in the EIS.
5.2.3. The TolkaRiver has flooded in the past and the EIS does not state if it plans to discharge to the Tolka .The EIS states that water will be discharged to foul/ storm drains if there is capacity. The EIS does not find out if there is capacity.
5.2.4. The EIS states that water will be discharged to surface water bodies if available. The EIS does not find out if they are available or name them.
5.2.5. RfR cannot find information in relation to a flood risk assessment carried out in the EIS for this area and can not see what mitigation measures will be put in place to cope with increased surface water run off from the Griffith Ave station or where the water collected at the pumping station in the ventilation shaft will be pumped to. RfR have been asking for this information since mid 2007. The surface water from this green field site has not been assessed in any detailed way in the EIS. This is an area that suffered severe flooding in the past – the EIS excludes it stating that the areas that flooded from the Tolka were outside the study area. There is to be a water pumping station in the shaft. RFR request details of how much water will be pumped to this area; how it will be held; and where it will be released to. RfR have concerns that it will be discharged to the existing foul/surface water system or existing storm drainage system which in our opinion does not have capacity. This causes ponding further up the line – along Ferguson and Homefarm roads for example. RfR would also have concerns should this water be discharged to the Tolka which has flooded in the past.
5.2.6. The Griffith Avenue site has been assessed in the EIS as a part of a tillage farm with the RPA planning to reinstate the land to tillage and preserving soil profile post construction. There is a large development planned for this site. Throughout the consultation phase the RPA stated that this station would not be economically viable with out major development-(ROC-Public meeting 9/5/07). We request that this be taken in to consideration in relation to the impacts on residents with regard to noise air quality, surface water management, ground water movement, subsidence and traffic.
5.2.7. RfR request that prior to granting of the railway order that a flood risk assessment be carried out. RfR wishes to assert its right to respond and to be heard on this important issue.
5.3.1. It is RfR’s position that the EIS on Ground water is neither adequate nor comprehensive. This is highly worrying to residents. As there is no specific construction methodology in relation to tunneling and the different modes of tunneling have a huge impact on ground water in relation to tunneling and ground water - how can this issue be fully assessed? RfR would request that prior to granting the order that An Bord Pleanala would request the methodology and then an assessment of the impact.
5.3.2. As the study area for ground water is 500m RfR request that it be a condition of granting the railway order that ongoing sample surveys of homes outside the planned survey zone of 30m be carried out – homes within the 500m study area should be included in ongoing sampling.
5.3.3. The EIS is based on incomplete information as there has been no full report into the vulnerability classes for aquifers in our area. The EIS does not assess the existing capacity in local foul water system and the impact of increasing water to this system.
5.3.4. The EIS does not assess the fact that the existing system is a dual system - a dual foul and surface water system – with old clay pipes in many areas which overflows in heavy rains and high tides - and the impact of introducing ground water to this system.
5.3.5. The EIS does not state who will monitor or check and maintain the surface and foul sewers. The EIS does not state who will monitor the emergency response protocol for pollution incidents - will it be self regulated? RfR request clarification on this critical issue.
5.3.6. The EIS does not give the criteria as to when it is possible and not possible to recharge ground water to aquifers and who monitors this and if it is a cost factor.
5.3.7. The EIS does not assess the impact of discharging the treated ground water to surface water body. It does not assess the impact of this water, its volume or what body of water will be used. The TolkaRiver has flooded both in the recent past and also historically. Its ability to accept more water has not been shown in this EIS.
5.3.8. The EIS repeatedly states that all of the discharge of ground water is subject to approval or license by the relevant local authority but no details have been given of what the RPA plan to apply for. The EIS does not state who will monitor this post construction.
5.4.1. RfR have concerns in relation to noise level around the stations and shaft and in particular the lack of detail in relation to mitigation measures detailed in the EIS. Baseline noise level monitoring is insufficient at certain points.
5.4.2. RfR believe the maximum noise levels set for daytime and night time are too high and the EIS is unfair in its classification of noise above these levels.
5.4.3. RfR object to works at night in residential areas and note that with the exception of concrete pours all others works are assessed as daytime works in the EIS.
5.4.4. Specific mitigation measures at crossover passages and crossover tunnel not defined.
5.4.5. There is no noise assessment or details given in relation to maintenance of track and equipment.
5.4.6. Rupert Taylor stated at Independent Expert meeting 22/10/08 that he had not done any assessment of the Ventilation Shaft.
5.4.7. The EIS does not give details of how many concrete pours will occur at night and what the impact of doing these pours by day would have – and why they must be done at night? It does not state if concrete is made on site or imported readymade. RfR requests clarification and assessment of impact.
5.4.8. In the area surrounding the shaft the noise level will increase significantly at night and there is no mitigation in place. Sound proofing for these homes will be necessary.
5.4.9. The EIS stated that the homes around the Drumcondra station will be subjected to very high levels of noise. Sound proofing for these homes will be necessary.
5.4.10. There is planned concurrent construction at the Griffith Ave site. RfR are concerned as to how noise can be managed at this location
5.4.11. There is no operational noise monitoring of the fans at the stations or shaft. RfR request that it be a condition of the railway order that operational monitoring is put in place at the shaft and all stations. RfR request clarification as to whether ventilation fans are tested individually or collectively at stations and Shaft. RfR request that ‘normal mode’ for the operation of the fans is specified in the EIS as this will impact the noise assessment.
5.4.12. RfR request that ABP make it a condition of the railway order that the actual noise level resulting from the combination of the selected track forms and LMVs purchased do not exceed the estimates in the EIS.
5.5.1. As no blast testing was carried out this section is incomplete. Again as we do not have the method of construction for the shaft or cross over tunnel the EIS can not fully assess the vibration impact. RfR request that this information be made available prior to granting the railway order
5.5.2. RfR learnt during the consultation phase that one of the tenders intends to construct the cross over tunnel prior to the construction of the main tunnel. This means that he will have to gain access via the shaft to the site by increased blasting which will have an impact on the residents and also the traffic. RfR request that it be a condition of the Railway Order that the cross over tunnel be constructed in a manner that minimizes disruption to residents.
5.5.3. RfR request that the construction of the cross over passage ways does not occur at night.
5.5.4. As tunneling proceeds under houses the vibration is likely to activate house alarms and car alarms. Residents security would be seriously compromised and in particular the vulnerable elderly in the area. The EIS does not assess this and RfR request that this is looked at and mitigation measures put in place to address this.
5.6.1. The Air modeling report, which is based on impact on air quality in terms of changes in traffic movement, is faulty as the traffic impact around the ventilation shaft has been omitted from the traffic base line report.
5.6.2. The EIS does not assess changes in air quality at local levels around the stations and shaft. There does not appear to be any monitoring of dust at local level. The EIS does not give any mitigation measures for the dust that is bothering residents within the 150m boundary - nothing in relation to window cleaning for residents’ homes and cars, no increased road cleaning or gully cleaning. How are residents close to compounds expected to dry clothes? RfR request that a scheme be agreed by the parties involved. There is no baseline dust assessment.
5.6.3. The EIS is based on inaccurate information in relation to land use with regard to Griffith Ave station site. It assesses this area as a specialist tillage area and states that development in this area is unlikely. The EIS plans a full programme of agriculture reinstatement around compound 13. However this is where Dublin City University (DCU) plans to build R&D facilities, 8 storey buildings, a hotel, leisure centre, student accommodation etc.
5.6.4. DCU are expected to look for planning permission later this year for the development of the ten acre site around this Griffith avenue metro stop. DCU have published master plans. RPA also stated during consultation phase that the station at Griffith Ave was not economically viable without development and were aware that development was planned as evidenced by email correspondence from Mary Denise O’Reilly (RPA) to Cllr. Mary Fitzpatrick regarding the large number of jobs that will be created on the site.
5.6.5. DCU also stated to RfR that they planned to develop the field concurrently with the Metro. This is an issue - as the EIS assesses the Griffith Ave compound as an open vegetated area and not an extended construction site. How will the dust etc be managed from the whole site? RfR request that the emissions from this whole site be looked at in relation to allowable emission levels in the area of air quality, noise production, vibration, ground and surface water, and traffic.
5.6.6. RfR request that EPA air monitoring be located in the Griffith Ave station site as the potential for problems with this site is high.
5.6.7. The Ventilation shaft can act as minor source of dust during operation – e.g. trains breaking and friction on the tracks. During a fire or major incident the fans at the ventilation shaft will be turned on. RfR request ongoing monitoring at this site .RfR request information in relation to plans for the evacuation of nearby homes and nearby schools and the assessment of these plans as to their adequacy.
5.6.8. RfR would like to know if PM10 levels rise to certain critical level in the tunnels will the fans be turned on to clear the PM10.
5.6.9. RfR would like to know will the ventilation shaft be a source of emission outside of two weekly testing or a major fire.
While RfR note that the RPA plan to monitor Radon levels during construction there appears to be no plans to monitor Radon levels during the operational phase. We feel that monitoring could continue in operational phase without much added cost and request that this be a condition of the railway order. Radon levels need to be monitored within a representative sample of homes above the tunnels and over a minimum of three months post construction. RfR note that radon can be carried in water.
6.1. Griffith Ave
6.1.1. The EIS does not give details of the final design and station finish of the Griffith Ave station- in particular the design of the above ground structures including entrance and planned plaza RfR requested this information throughout the consultation phase without success and continually requested that residents in this area were afforded the same information as other residents were in relation to other stations. This information was also requested under FOI and we were told that it would be ‘contrary to the public interest’ to give this information (letter ROC 16/4/2008). RfR request that this design be made available and as with all other omissions from the EIS, RfR request the right to respond on these issues when this information is forthcoming. RfR request that the Railway order is not granted until these responses have been formally heard.
6.1.2. This station is situated in a residential area and RfR request that it be a condition of the railway order that no works are carried out at night on this site.
6.1.3. The EIS assesses the Griffith Ave site as a tillage field and RfR request that this error is corrected and the emissions from this site are correctly assessed. RfR request that the Railway order is not granted until this is addressed. RfR will assert their right to respond and to be heard once this information is available. In the EIS this site has been assessed as a part of a tillage farm with the RPA planning to reinstate the land to tillage and preserving soil profile post construction. There is a large development planned for this site. Throughout the consultation phase the RPA stated that this station would not be economically viable without major development-(see MDOR email attached). We request that this be taken in to consideration in relation to the impacts on residents with regard to noise air quality surface water management ground water movement subsidence and traffic. If An Bord Pleanala cannot be satisfied as to the management of the noise and air quality at this site that they make it a condition of the railway order that no concurrent major development can occur at this site.
6.1.4. The lighting for the planned compound is very large. RfR would like the impact of same on residents sleep assessed. RfR would like it clarified as to what works are planned at night on this site
6.1.5. The size of compound is ‘16?’ in the EIS – please clarify.
6.1.6. The size of the planned platform and projected people movement for this station is larger than most other stations including the interchange station. RfR would like this explained.
6.1.7. There are no detailed plans for the management of surface water run off from this site. This site is at present a green field site and we feel that this omission is a serious one and we would urge An Bord Pleanala to withhold the granting of the Railway order until this is addressed. As previously stated there is flooding present at the entrance to Courtland estate on Griffith Ave and on Homefarm Road - which floods into the homes of residents in heavy rains. Ferguson Road and Millmount and Millbourne Ave have also been badly flooded in the past. There has been no flood risk assessment carried out in the EIS. RfR brought this issue up with the RPA over a year ago at our first meetings with them and are disappointed that this important issue was overlooked.
6.1.8. There is no assessment of ground water movement impacts on the area and again RfR request that this be addressed and we also request that sample homes outside the 30m zone be assessed into the future for subsidence due to ground water movement and subsidence.
6.1.9. There needs to be protection of the trees surrounding the station put in place as part of the railway order. These trees will help to absorb noise, improve air quality and improve the aesthetics
6.1.10. RfR request that operational monitoring of noise at the ventilation fans be put in place and seek clarification as to whether the fans are tested individually or simultaneously and the duration of this testing.
6.1.11. RfR request that it be a condition of the railway order that the routine testing of these fans takes place during the daytime and not at night or at the weekends.
6.2.1. As previously mentioned The EIS does not adequately assess the traffic impacts of the ventilation shaft during construction. (Ref. section 5.1.2). The RPA have previously stated that this area is not suitable for a station because of the narrow roads and residential nature of the area (as per MDOR letter attached). RfR would like clarification as to why it is therefore suitable as a major emergency escape facility.
6.2.2. The EIS does not assess how children will access St Patrick’s Junior and Senior schools. At present from 6th October 2008 parents have been told where possible to walk to school via Millbourne Ave. This will bring children right across the entrance and exit for construction traffic. This is also the route that our many elderly residents use to gain access to shops and library and banking. RfR request that it be a condition of the railway order that this be assessed properly and mitigation be put in place to ensure safety of all. Given the close proximity of the shaft to a junior school all construction staff working on the shaft site should be cleared by An Garda Siochana.
6.2.3. Again the surface water from this green field site has not been assessed in any detailed way in the EIS. This is an area that suffered severe flooding in the past – the EIS excludes it stating that the areas that flooded from the Tolka were outside the study area. There is to be a water pumping station in the shaft. RFR request details of how much water will be pumped to this area; how it will be held; and where it will be released to. RfR have concerns that it will be discharged to the existing foul/surface water system or existing storm drainage system which in our opinion does not have capacity. This causes ponding further up the line – along Ferguson and Homefarm roads for example. RfR would also have concerns should this water be discharged to the Tolka which has flooded in the past.
6.2.4. RfR request that no works take place on the Ventilation shaft or cross over tunnel at night as this is a quiet residential area.
6.2.5. RfR requests that operational noise monitoring in relation to the fans be a condition of the railway order.
6.2.6. RfR request that operational air quality monitoring be a condition of the railway order as this shaft is in a school play ground. RfR request that the proposed management, maintenance of equipment, frequency of emissions, results of air quality and compliance monitoring be fully disclosed. The EIS does not contain an evacuation plan for residents and/or school children in the event of air pollutants or other major incidents
6.2.7. RfR request that all routine maintenance takes place during 10week days and not at night.
6.2.8. RfR request that the testing of the fans does not take place at night or at the weekends and request that this be a condition of the railway order. We again seek clarification as to whether the fans will be tested individually or together and the total duration of testing.
6.2.9. RfR request that it be a condition of the Railway Order that the contractor ensures that alternate sites for State/College Examinations be arranged should work be ongoing during State/College Exam time on the shaft or crossover tunnel.
6.3.1. We request that there is no night time work on the Drumcondra station due to the residential nature of the area.
6.3.2. The existing night traffic noise levels already exceed acceptable levels. RfR request clarification as to how night time concrete pours can occur in this area.
6.3.3. RfR request clarification as to the pedestrian management at this construction site given the large numbers using the mainline rail station
6.3.4. RfR would like further information in relation to planned increased rail activity at the Drumcondra station once the metro stop is operational and the noise impacts of same in particular.
6.3.5. RfR request that the fans are not tested at night or at weekends.
6.3.6. RfR request that surveys of homes outside the 30 m area be carried out due to ground water movement and projected settlement.
RfR have throughout our campaign invited the RPA to sign up to a Resident’s Charter. The charter has the full support of Dublin City Council. RfR believe that a simple well structured charter will outline a clear complaints and dispute resolution procedure which may have significant cost saving benefits. A sample charter, previously submitted to RPA, is attached. RfR requests that it is a condition of the Railway Order that the RPA implement a residents charter and that they are the primary responsible authority and liable for all claims in relation to damage to property, vehicles etc.
RfR request that as a gesture of good will an annual pass be granted to each house under which the tunnels run. The passes would remain a feature of the house and pass on in any subsequent resale.
RfR would like disclosure of mitigation measures that are planned to deal with the displacement of rats and request that it be a condition of the railway order that this problem of rats and vermin be the responsibility of the RPA and not left to the individual householder.
Volume 3, Book 1: Contains 15 maps which show an incorrect alignment. Volume 3, Book 2: Contains 7 maps which show an incorrect alignment
The limits of deviation are not clear within the EIS and RfR request that this is clarified and will respond on this once this information is available.
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It is RFR position that the projected noise levels from the fans during operational phase is unacceptable in residential areas and we request that it be a condition of the railway order that this noise level be reduced and that monitoring of this noise level during the operational phase is a condition of the railway order.
RfR would like clarification as to whether during construction these fans will be operational to remove dust etc and to ventilate the tunnels. RfR would like the projected emissions both particulate matter and noise from the fans during construction and operational phases to be monitored.
RfR notes the high noise level these entail and requests ABP to make it a condition of the railway order that mitigation measures are put in place to reduce this noise to an acceptable level or to limit the pours to daytime hours.
RfR request that additional policing be put in place during the construction phase as these large compounds will attract antisocial activity to our area.
7.9. 3-D Models
RfR request that all residents have access to 3D models of stations and crossovers as the EIS and RPA have failed to produce adequate information to date.
The EIS lacks information obtained as a result of boreholing.
RfR does not believe that this is adequate. RfR also requests that the generic sample surveys already carried out on specific homes “types/styles” be made available to other residents in similar style homes
RfR would like to express its frustration at the entire process and its handling by the RPA. The RPA has not been equal in its treatment of people in providing information. Residents have raised their fears in relation to the impacts of the project (e.g. electromagnetic radiation) and been dismissed by the RPA however school boards have been given information and access to experts in relation to the same queries. Professionals working on behalf of St Pats College were given diagrams of the Ventilation shaft in order to assist them with making their submission (FOI August 2007) and this was specifically withheld from residents.
RfR submits that the burden of legal costs inflicted on residents and their representative bodies as a result of this project should be born by the RPA.
The late report and meetings of the Independent Expert allowed little time for assimilation and identification of issues. Accordingly we submit that we have not had enough time to properly consider the report and thus this submission may be incomplete. We reserve our right to bring any additional issues we discover to the attention of An Bord Pleanala.
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