UPDATE - 17/11/2009
RfR response to the additional information submitted to An Bord Pleanala by RPA in respect of Metro North
RfR welcome the opportunity to make a submission on the additional information. However we would like to state at the outset that some of this additional information had previously been sought by us during the initial consultation period but was not released by the RPA.
Item 2 – Movement of utilities
RfR note with alarm that this information was not part of the original application and no consideration was given to the impact this work will have on the city especially as the city center works will take place in advance of the main Metro works. It is our opinion that as all of this work will take place and impact at surface level the consequences for the city will be significant.
RfR has to date not involved itself in the cost or economic aspects of the Metro North project. However as many residents are employed in city center businesses any impact on this trade will affect families throughout our area.
The RPA state (5.5) that this work will have a temporary impact on adjacent businesses. In the present economic climate where DCC have felt it prudent to lift the evening bus gate because of claims by city center traders that the bus gate was reducing trade RfR are concerned that the impact of the utilities movement works will in essence close down Dublin’s city center and we hereby call on all city councilors to address this issue immediately.
DCC have stated that they have not seen or been given any study in relation to this issue. With some of the works expected to take up to 64 weeks and involving the loss of taxi ranks, street parking, loss of traffic lanes and the need for temporary foot paths etc., RfR feel it inadequate for RPA to just state that there will be a ”temporary impact on adjacent businesses”. RfR feel that an economic assessment of the impact on city center businesses of this specific movement of utilities for Metro North should be undertaken prior to the commencement of this work or the granting of a Railway order.
RfR also request that:
a) ABP set down the hours of work for the movement of utilities rather than leaving this to local authorities where residents have no mechanism to appeal. (2.1).
b) The cost of the movement of utilities it be disclosed by RPA/DCC to the public without delay.
c) RPA and DCC upgrade utilities as they move them so that there will be no need to dig up Dublin again for many years.
RfR would like details of any assessments or lack of same as to the impact on tourism to the capital in light of so many monuments being removed for the duration of Metro North.
Methodology for Construction of Cross Over Tunnel
RfR have requested information as to the methodology for the construction of the cross over tunnels and the route for materials in and spoil out. This is still ambiguous in the additional information-
“The likelihood is that this crossover will be constructed from the tunnels with material being removed through Albert College Park after the TBMs have passed the location of the crossover.
The tunnels will be driven past the location of the emergency crossover by the tunnel boring machines. Additional ground investigation will then be undertaken through the area in which the crossover tunnel will be constructed. This will enable the contractor to validate the design ground condition assumptions and complete the design of the crossover as appropriate.”
This leaves it open for the contractor to build the cross over tunnel first which has a significantly greater impact on the residents of Millmount and Ferguson Road.
The GWP tunnelling expert David Donaldson has indicated to RfR that this latter method would be the preferred method of construction for a contractor. RfR request that ABP make it a condition of granting the railway order, that material and spoil from and for the cross over tunnels enter and exit via the Albert College depot.
Construction of and Discharge from Ventilation Shaft
With regard to the Ventilation shaft RfR note that it is planned to use a 360 degree excavator and request information as to the expected noise from same. RfR would like to know if there is a warm up and cool down period for such a machine and will those times be outside working hours.
RfR would again like to state its’ concerns in relation to the amount of blasting planned in this area as it is a junior school play ground.
RfR wish ABP to note that we have continuously requested information about the fans in the Ventilation Shaft. RfR have been told that the louvers will be in the roof or on all four walls or that it depends what way the wind is blowing in the course of the consultation phase. The additional information now states that:
“The louvers, through which the fans discharge, are located in the north wall and roof of the headhouse so that any discharge is blown clear of the school and emergency services access.”
RfR request the Inspector seek clarification of this issue as it appears that the discharge will be blown in the direction of the prevailing wind and should that be a north wind the discharge will be blown directly in to the school. When questioned by RfR at one of the open days Mr Geoff Fetherstone (RPA) gave a long account of how if there was a southerly wind you would open the north louvers and if it were a northerly wind you would open the south louvers. RfR did ask to speak to the ventilation experts at this open day as it was specific to the ventilation shaft but were told that they were in California.
RfR has also requested the emergency plans for this site due to our concerns in relation to the proposed access for more than one or two emergency vehicles to this site but have been unsuccessful in this respect.
With regard to working at night RfR feel that this situation is too ambiguous and requests that ABP do not grant the Railway Order unless ‘hours of work’ in residential areas have been agreed, are reasonable and are made a condition of the Railway Order.
Mitigation Measures
RfR believe the following statement by RPA is incredulous:
“8.2.3 Mitigation measures.
With regard to effects on people, the contractor will be prevented from operating the tunnel boring machine at night unless the level of groundborne noise in occupied sensitive rooms of inhabited buildings does not exceed 40 dB LAmax,S the only exception being in cases where there are no complaints.”
RfR seek clarification as to:
a) How many complaints are required?
b) Who does one complain to?
c) Does a resident have to complain every night?
d) How quickly will complaints be addressed?
RfR consider this a totally unacceptable position and request that ABP do not grant the Railway Order unless this issue is dealt with as a condition that no works be carried out in residential areas at night.
RfR also have concerns that the ground borne noise level is relying on the contractor designing and the operator maintaining the track both of whom will be driven by cost. Surely this design should have been part of the application. See below
“7.3.3 Mitigation measures
The contractor will be required to design a vibration-isolating trackform, and the operator will be required to maintain the railway, so as to ensure that groundborne noise from the operation of Metro North does not exceed the “low impact” category.
The contractor will be required to design a vibration-isolating trackform, and the operator to maintain the railway, so as to ensure that vibration from the operation of Metro North does not exceed the “very low impact” category at night at nearby residential receptors or the “low impact category” by day.”
In Conclusion
RfR remain concerned about all the issues contained in our first submission such as surface water management, traffic etc. Indeed RfR found the traffic management schemes difficult to follow.
We also wish to formally state that the absence of daily transcripts or web casting does not allow us to fully participate as is our right under the Aarhus Convention and we hope this will be rectified prior to the recommencing of the hearings.
We note the Independent Experts’ GWP comments on the EIS;
“We have some specific reservations about the breadth of coverage and/or the way in which the results of the environmental assessment have been communicated for some topic areas. However, overall; we are satisfied that no major subject for concern has been overlooked in the EIS and we note that in some respects, it goes beyond what is statutorily required to be covered in an EIS. The EIS is of limited usefulness to a non-technical readership without some additional guidance.”
Accordingly we would like to sincerely thank the Inspector for seeking this additional information. | 
