South Kerry Greenway: Council planning application to An Bord Pleanála does not comply with EU Environmental Impact Directives

Final_GCC_logo_7_06_2010Campaign submission argues planning board should reject application and order new Environmental Impact Assessment Report.

In August Kerry County council made an application to An Bord Pleanála for the so called South Kerry Greenway running roughly parallel to the N70 national route for 30km between Glenbeigh and Cahersiveen/Reenard on the Iveragh peninsula.  To achieve their proposed design, the county council propose to acquire by compulsory purchase order (CPO) sections of the abandoned Valentia railway.  This railway was abandoned in 1960, the rail lines lifted within two years, and much of the land sold or transferred back to the farmers along the route.  The misguided and unhelpful conduct of some recent “greenway” projects by local authorities has been hugely damaging to the brand of cycling and created needless acrimony between farming and cycling interests. The South Kerry scheme could set a positive or negative national precedent.  If conducted incorrectly, it could set the national farming community in opposition to greenway projects for a generation. The Galway Cycling Campaign wishes to avoid this outcome and has made a submission to An Bord Pleanála.

A central problem identified with the Kerry County Council planning application is an apparent failure to comply with EU directives on environmental impact assessment. The 2018 Guidelines for Planning Authorities and An Bord Pleanála on carrying out Environmental Impact Assessment state as follows:

Reasonable Alternatives: 4.12. The Directive requires that information provided by the developer in an EIAR shall include a description of the reasonable alternatives studied by the developer. These are reasonable alternatives which are relevant to the project and its specific characteristics. The developer must also indicate the main reasons for the option chosen taking into account the effects of the project on the environment.

In the Environmental Impact Assessment Report (EIAR) the alternatives given are as follows –

  1. On-Road Route Option – construct a roadside cycle track within the N70 – which will involve significant engineering works
  2. Abandoned Railway Line Route Option – much of which is in private ownership and which will involve significant engineering works
  3. New Greenfield Route Option – which will involve significant engineering works
  4. Do-Nothing Route Option

The published EIAR does not appear to include commonly accepted alternatives recommended by the applicable policy frameworks. The EIAR consultants make no apparent mention of using minor country lanes or boreens. This option if available could involve little engineering and would be less environmentally damaging than any of the proposed works in the EIAR.

The guiding policy source in this instance is the 2009 National Cycle Policy Framework (NCPF).  Under Ministerial Circular PSSP 8 – 2010 the NCPF is a national policy under the terms of section 9(6) of the Planning and Development act regarding development plans.  Objective 3 of the NCPF provides for a national cycle network that may include greenways and disused railway corridors but also makes extensive use of minor roads.    The NCPF references the 2007 Fáilte Ireland Cycling Strategy, which proposed an Irish Cycle Network using “the network of country lanes and roads throughout the country. These roads have been chosen where traffic levels are light and lanes have a line of green grass up the centre“.

We find no discussion of this option – even to dismiss it – in the EIAR.

Other countries make extensive use of minor country lanes to provide long distance cycling routes.  The South Kerry Greenway is supposed to be a component in EuroVelo 1 the Atlantic Coast Route.  We have discussed the Eurovelo guidelines previously in relation to the problematic Dublin Galway Greenway proposals. Tourist cycling routes should be kept well away from heavy traffic but they do not need to be completely traffic-free. Across Europe cycling tourists and family groups make extensive use of low-traffic roads as part of local and national cycle networks.

This model is not simply a matter of passively finding roads that match the criteria. Local authorities will actively manage minor rural roads to reduce and divert inappropriate motor traffic and provide for walking and cycling.  There is no legal impediment to doing the same thing in Kerry.

The ordnance survey map shows a range of minor roads on the Iveragh Peninsula that might form part of the proposed route.  Possible options can also be found using Google Streetview.    CPO is an intervention that is not be treated lightly and the requirements of natural justice must be seen to be followed.  If the use of obvious alternatives is not dealt with in the current EIAR then it will have to be dealt with at any oral hearing.  Any such discussion at an oral hearing may be incomplete and will happen without formal prior consultation with affected parties along the alternative routes.  This reinforces the need to reject the current application and require a new EIAR that reflects the relevant EU and state policies.

Google street view screen grab showing a country lane near Glenbeigh and running towards Cahersiveen

Google street view screen grab showing a country lane on the route between Mountain Stage and Cahersiveen.  Local farmer on his bike courtesy of Google street view.

 

October 2018: An Bord Pleanala reject child hostile Oranmore housing development

 

Final_GCC_logo_7_06_2010Planning board rejects flawed strategic housing proposal (but for reasons other than child safety)

An Bord Pleanala have rejected an application in Oranmore for a large (212 unit) housing development under the new strategic housing process.  The grounds given include that it will impact on an area of land that is recorded as a wintering site for White Fronted Geese.  In their refusal, the board cite impacts on the Inner Galway Bay, Creggana Marsh and Rahasane Turlough Special Protection Areas.  It should be noted that the current government’s controversial “mini motorway” model for the Dublin-Galway greenway will involve building a new road near the Rahasane Turlough.   However this is an aside.  Why is the Galway Cycling Campaign interested this housing development?   The reason is that it was viewed as an important test case for Government policy on sustainable transport.  Accordingly over the summer we made a submission to An Bord Pleanala seeking changes to the design to favour active travel and child safety.

 

The development “Arlum Oranmore” was to consist of 212 residential units, a crèche and an external play area.  However on review we found the development to be conceived and laid out in a manner that is hostile the needs of sustainable transport – particularly schoolchildren.  The layout of the development did not comply with the principles of the Design Manual for Urban Roads and Streets.  The provisions for cyclist and pedestrian access were the same as the provisions for motorised traffic. Providing for people on foot or on bicycles was essentially treated as an appendage to providing for motorised traffic. The plans also clearly intended to direct arterial interurban traffic into residential streets.

Observations on the Arlum site

The Arlum site is located on the eastern side of Oranmore near the former N18 National Route.  There are four schools within 2km of the site and all the schools are located on a similar alignment to the northwest.  Existing roads providing a potential route to the schools carry fast and heavy traffic and have hostile junction layouts. In particular, there is a pair wholly unsuitable junctions that involve slip roads to and from the Maree Road.  The site is on a clear desire line for a safe route to school not only for its own residents but also for children from adjacent developments at Oranhill to the south and Coill Clocha to the north.

 

Figure: Google map extract labelled to show the site and the four schools located to the northeast.

Potential desire lines for safe school travel are shown by the green arrows.

 

Figure: Google satellite view extract showing hostile and unsuitable slip-road

junctions within Oranmore village and on the proposed travel line for children.

 

Cycling Campaign Recommendations

In order to the comply with the principles of the Design Manual for Urban Roads and Streets we argued that the applicants should be required to provide safe attractive pedestrian and cyclist only links to adjacent developments.  If links were provided to Oranhill to the south and Coill Clocha then an additional link to Beech court would give children a route to school using mainly residential streets and roads.  Beech court was constructed using an unsustainable car-dependent cul-de-sac based layout and there was now an opportunity to remedy this mistake and provide a safe link for children.

 

 

Figure: Planning file extract showing the northwest corner of the site where it backs onto Beech court.

There is scope here to provide a safe route to school by providing a link.

Our submission to the board argued that as a planning condition a gap should be constructed through to Beech court. The developer should be required to obtain and demolish existing dwellings in Beech court so as to provide a safe school route.  It might be possible for the developer to simply construct equivalent dwellings for the current Beech court occupants elsewhere in the Arlum development.   Section 3.3.3 of the Design Manual for Urban Roads and Streets refers specifically for a need to retrofit existing areas to create more sustainable neighbourhoods.  The proposed link to Beech court is an example of exactly the type of works needed and could have set an important precedent for other projects under the Strategic Housing Development process.

A similar observation applied to the boundary of the Arlum development and Oranhill to the south.  The Arlum development “backs on” to Oranhill instead of integrating with it.  The applicant’s drawings appear to show dwellings in Oranhill backing onto their development. As with the boundary to Beech court we argued for the plans to be rearranged provide a coherent and attractive walking and cycling only link between both developments.

Routing arterial traffic through residential streets

There was reference in the planning application to a north south distributor road.  It turned out that the intent was to re-purpose existing exclusively residential streets in Oranhill and Coill Clocha as some form of distributor road.  Indeed the Traffic and Transportation Statement by stated that the new roads arrangements were intended “to operate as a link road to serve traffic from the N67 National Route to the Maree Road”. The new road would start an existing but incomplete roundabout on the old Limerick road south of Oranmore and use residential streets to connect through to the Maree (coast) road.  In our view this was wholly unacceptable. If Galway County Council perceived a requirement for a relief road linking the N67/former N18 and the Maree road then they should set aside lands for that specific purpose. Due to car dependency imposed by poor planning practices, there is extensive peak hour traffic congestion on the outskirts of Galway.  This has resulted in a problem with rat-running at various peripheral locations that offer potential alternative routes into the city.   In this case creating this proposed distributor road would provide an obvious link for arterial traffic trying to use the coast road as a means of avoiding queuing at junctions on the main roads in or out of the city.  This type of traffic is incompatible with the “place function” of this area as a residential amenity.  In our submission we argued that the internal roads should be rearranged to prevent through traffic or that the link to the old N18 (N67) be dropped.  It should be noted that the planning files contained an assessment of the impact of traffic from the housing development on the main roads but contained no assessment of the impact for local residents of routing arterial traffic through their streets.

Conclusion

The planning Board’s decision to refuse on environmental impact grounds was probably a correct decision based on the information available.  It may also set an important precedent for other environmentally hostile developments such as the current Dublin-Galway greenway proposals. However we will have to find another place to fight the battle on safety and safe access for vulnerable roads users.

 

 

 

 

 

Athenry Tuam Greenway is Galway’s only chance for foreseeable future

The Galway Cycling Campaign is writing to all the county councillors calling on them to support a feasibility study into the use of the disused Athenry – Tuam – Miltown railway as a Greenway. The cyclists say the Athenry to Miltown proposals are Galway’s best chance to achieve a long distance cycling and walking amenity for the county for the foreseeable future. They say that little progress can be expected on either the Connemara Greenway or the Dublin-Galway proposals following the publication of a fundamentally flawed Government Greenway Strategy last July.

According to the campaigners Athenry to Tuam is effectively “tarmac ready” with no questions about land ownership and with CIE, the single land owner, amenable to granting a licence for the use of the route. CIE have also stated that the corridor could be converted back to railway use if needed.

In contrast they raise the “Strategy for the Future Development of National and Regional Greenways” published last July which they describe as fundamentally flawed and implies more conflict with private landowners who are a key stakeholder group. The overwhelming focus of the strategy document is on “constructing” greenways as new roads through lands. The focus on constructing new roads through lands assures more conflict with landowners on the Dublin-Galway route and that little progress can be expected here for the foreseeable future. The public consultation guidelines provided with the Greenway Strategy put consultation with landowners as the last step in the process. According to the cycling campaign this assures more conflict with landowners. The same issue will arise with those sections of the Connemara Greenway where there has been no agreement to date.

“Given the profoundly flawed nature of the Greenway Strategy our view is that Athenry-Tuam now represents the best chance for a long-distance Greenway in Galway.” stated Shane Foran for the campaign. “For the moment the best thing for Connemara and East Galway is a cooling off period to reduce tension” he continued “if built the Athenry Tuam Greenway will need connections to other places in the county and these will naturally grow to link towards both Dublin and Connemara.”

Reference

Strategy for the Future Development of National and Regional Greenways

Comment: Despite various attempts at more positive language the consultation process given at the back of the document puts discussions with landowners at the bottom of the list.

Background reading

July 2017: Greenway Strategy consultation is misconceived and should be set aside.

December 2016 Eurovelo 2 Galway – Moscow: Department “consultation” sets up more conflict with local communities.

5th August Coastal Cycling Exploration

9 km leisurely cycle for novice and curious cyclists ‘Huntsman’ to Oranmore village via suburban Renmore and rural Roshill.

11:30am Sunday 5th August

 

C’mon now, summer weather will return for the weekend. Ideal for a leisurely Sunday cycle to Oranmore for a light lunch, and back before the hurling replay. This 9km route for novice and curious cyclist is from ‘Huntsman’ to Oranmore village via suburban neighbourhoods of Lakeshore drive, Lisbeg, Lurgan park and using a side path to connect to the old Roshill Road route.

This safe route has been selected for no right-hand-turns from or onto any main traffic road, and the R338 Coast road to Oramnore has hard shoulders.

This easy route also has very nice views of the bay.

  • 11:30am Assemble at Huntsman.
  • 11:45am Depart via Lakeshore drive, Lisbeg, Lurgan park   (first 4km for 25 mins at leisurely 10kph)
  • 12:10-12:30, twenty minute tea-stop at Norio’s, a convenient half-way location with a rail outside it to lock up to.
  • 12:30 Resume from Norio’s to Oranmore.     (Another 5km of 20 mins at warmed up 15kph)
  • 12:50-13:20 Light lunch stop in Oranmore village.
  • 13:20 pm Depart Oranmore for return to GalwayArrive back at Huntsman approx. 14:15pm

Note that Roshill rd still has a safe path under the bridge during maintenance works, so never mind the road closed signs there.

New online membership facility launched

Galway Cycling Campaign (GCC) are calling on all cyclists to join them in their mission to get Galway cycling, and are launching a fresh membership drive from April 3rd to April 6th 2018.

The GCC are calling on cyclists and everyone who wants Galway as a place where people can travel easily, safely and enjoyably by bicycle to sign up.

The GCC is an independent, membership-driven organisation made up of dedicated volunteers who advocate for all road users, including pedestrians, families, people with disabilities and public transport users.

Acting chairperson Mairéad Ní Chaoimh said, “Cyclists are woefully underserved in Galway, and we are fighting hard to get our voice heard, to get better facilities and infrastructure for cyclists. I am calling on anyone out there who wants a more cycling friendly Galway to join us today.”

GCC, the voice of cycling in Galway since 1998, have just launched an online membership facility to make it easy for people to join.

It costs just €10 for waged annual membership and €5 for unwaged annual membership. People can sign up either as active members or as supporters.

“We are very keen to sign people up as supporters. They may not have time to volunteer, but by becoming a supporter they help us give cyclists a louder voice, and add weight to our campaigns. They cheer us on from the wings, giving us a mandate. Of course we want active members too,” added Mairéad.

Newly signed up members and those interested in joining are especially welcome to attend our social which is taking place in a city centre pub on Friday April 6th at 7pm. To book your place please email mairead@galwaycycling.org.

 

5 Reasons to join Galway Cycling Campaign

·         Be socially part of your local cycling community

·         Add your voice to much needed campaigns to improve Galway’s cycling infrastructure

·         Use your skills for a good cause

·         Get up to speed on current cycling issues

·         Do your bit for climate change

 

Anyone interested can join by following this link:

http://www.galwaycycling.org/get-involved/