COMHAIRLE CONTAE ÁTHA CLIATH THEAS
SOUTH DUBLIN COUNTY COUNCIL

south dublin county council crest

MEETING OF SOUTH DUBLIN COUNTY COUNCIL

Monday, November 12, 2007

HEADED ITEM NO. 11

REPORT ON PART 8 OF THE PLANNING & DEVELOPMENT ACT, 2000 AND THE PLANNING AND DEVELOPMENT REGULATIONS 2001 – 2007.

Provision of Proposed Green Pedestrian and Cycle Route along the Grand Canal from Brownstown to Inchicore Incorporating 110KV Ducting

The following report was noted at the Lucan/Clondalkin area Committee Meeting (1) on Tuesday 16th October, 2007.

“REPORT ON PUBLIC CONSULTATION PROCEDURE UNDER PART 8 OF THE PLANNING AND DEVELOPMENT REGULATIONS 2001 – 2007 ON THE PROPOSED GREEN PEDESTRIAN AND CYCLE ROUTE ALONG THE GRAND CANAL FROM BROWNSTOWN TO INCHICORE INCORPORATING 110KV DUCTING

The following report was noted by the Lucan-Clondalkin Area Committee at its meeting held on the 15th May 2007.

“The Council approved the ‘Green Routes in South Dublin County’ report at its April meeting. The Grand Canal route is highlighted in the report as a major spine route recommended for construction in phase one of the network. As outlined in the report the proposal is confined to the southern towpath of the canal and does not interfere with any proposals or objectives which may be brought forward for the northern towpath.

The Council in recognising that the need for the availability of power in the County is a critical element in developing economic infrastructure is endeavouring to address the lack of power in the West of the County by initiating this joint project with the ESB, Waterways Ireland, Dublin City Council and South Dublin County Council. This project will deliver the Grand Canal section of the Pedestrian and Cycle Route network together with the provision of an underground ESB ducting system to facilitate the provision of power to the West of South Dublin County. The Green Routes project includes the provision of footpaths, cycle tracks, canal furniture, public lighting, CCTV and landscaping works along the routes. The project when completed will provide a significant off road route through the heart of the County and will link into the already constructed route in the Dublin City area.

It is now proposed to initiate the Part 8 procedure under the Planning and Development Act, 2000 and the Planning and Development Regulations, 2001 and 2003.”

The proposal was advertised in the Irish Independent on the 17th May 2007 in accordance with the requirements of Part 8 of the Planning and Development Regulations. Plans and particulars of the proposed works were displayed in the Council’s offices in Tallaght and Clondalkin from 17th May. The closing date for receipt of submissions and observations dealing with the proper planning and development of the area was 5 p.m. on the 28th June 2007.

However it was agreed to include the second phase of the route in the Part 8 report and for this reason the proposal including the extension to Brownstown was advertised in the Irish Independent on the 10th July 2007. Plans and particulars of the proposed works were displayed in the Council’s offices in Tallaght and Clondalkin from that date. The closing date for receipt of submissions and observations dealing with the proper planning and development of the area was 5 p.m. on the 4th September 2007.

Fourteen submissions were received as follows:

1. Lucan Planning Council

2. Ronan Herron

3. Loc Canail

4. Loc Canail

5. David Fadden

6. David Fadden

7. Irish WildLife Trust

8. National Roads Authority

9. Department of Communication, Marine and Natural Resources

10. Dublin Transportation Office

11. Concerned Residents of the Grange

12. John and Beverley Power

13. Norah C. Carlson

14. Henry and Timothy Crowley

1. Submission from Lucan Planning Council

Lucan Planning Council Ltd supports the development of the wild life, amenity and recreational uses of the Grand Canal. However they have the following reservations and concerns:

1.1 The use of the towpath as a conduit for cables raises issues relating to destabilizing the banks, flooding of conduits and potential radiation.

The canal banks will be supported during construction to prevent collapse and will be strengthened as a result of these works. There is no risk of flooding of conduits or of radiation. Ducting and chambers will be sealed against flooding.

1.2 The towpath is a major wild life corridor and the environmental impacts require detailed study.

The environmental impacts of the proposed scheme have been studied in an ecology report and archaeology report which have reported no significant impacts for the scheme. Public lighting may be dimmed and / or switched off during core nighttime hours (timeframe to be agreed with relevant interested bodies) to minimize impact on wildlife.

1.3Turning the towpath into a cycle lane and a footpath would cause a major negative impact on the environment. We would be opposed to a 2m cycle path adjoining the canal bank. We would advocate a gritted or gravel footpath rather than concrete or tar macadam. As the towpath was constructed for horses, and given the interest in horses in the local community, consideration should be given to some controlled horse traffic.

The towpath is already paved between the Naas Road and Ninth Lock Road. The footpath and cyclepath will replace mowed or well trodden grass which is of no environmental significance. Gritted or gravel footpaths are not suitable for impaired mobility use. Horse traffic is not currently permitted along the towpath by Waterways Ireland, and would conflict with the other uses proposed on the re-surfaced path.

1.4 Street lighting is totally inappropriate to the rural atmosphere of the canal. Any security issues need to be addressed by other means – possibly CCTV with night vision.

This section of the canal is urban / semi-urban. Commuters already use the route and lighting is required for safety reasons in addition to security needs. Lighting may be dimmed / switched off during core nighttime hours. CCTV will be night capable with the ability to work in low light conditions.

1.5 There is no provision for the footpath to safely cross the road at the 12th lock.

A toucan crossing will be incorporated into the R120 upgrade works at this point.

1.6 LPC is opposed to these proposals in their present form and requests that a thorough environmental impact or ecological report is completed before any such scheme is adopted.

A thorough ecology report which covers environmental issues including impacts on flora and fauna has been carried out and has not reported any significant environmental impact. An archaeology study has also been completed to Environmental Impact Study guidelines in order to highlight any archaeological or heritage issues along the route. A full Environmental Impact Study is not required under the European Communities (Environmental Impact Assessment) Regulations, 1989.

2. Submission from Ronan Herron

2.1 As a canal user I am just wondering whether the proposed improvements include any provision to dredge this section of the canal or indeed whether Waterways Ireland have any plans to make improvements along this section.

There are no proposals under this scheme to dredge the canal. Waterways Ireland is responsible for maintenance of the canal. However these works will facilitate future dredging of the canal.

2.2 Could you let me know the height of any new footbridges? A minimum of 3.5 metres air-draft is required for a lot of the craft now plying the Grand Canal.

Bridges will take account of future developments. A footbridge proposed under existing development plans may proceed under this scheme in order to link with proposed parkland to the north of Grange Castle. Any footbridges to be constructed will meet Waterways Ireland’s navigation requirements.

2.3 What is the timescale for these improvements?

The works will take circa 18 months to complete and are scheduled to begin in January 2008.

2.4 Will they be completed to coincide with the opening of the Royal Canal in July/August 2008?

The works will not be completed until 2009.

3. Submission from Loc Canail

3.1 Is it proposed to locate the cycleway at the water’s edge, with the pedestrian walkway extending out from it, as would appear to be the case from the indicative drawings – or is a distance from the water’s edge specified – if so, what is the distance?

The path will be set back from the water’s edge by a minimum of 0.5m and will increase in places where space permits

3.2 Where is it proposed to locate the cable route, i.e. distance from the water’s edge, depth to be buried?

The cable route will be a minimum of 1.5m from the water’s edge. This distance will vary to accommodate existing services already located within the canal towpath.

3.3 Design specifications for the cable, conduits and maintenance access points.

The cable and conduits will be to standard ESB specification. Maintenance points will be located strategically over the route.

3.4 Please provide details of bridges proposed – width, design specifications proposed (locations specified on maps)

Bridges are shown as indicative locations on the Part 8 drawings. Bridges will take account of future development projects and be designed to allow access for impaired mobility users

3.5 Will provisions be made in the design to retain the canal bank eco-system and the associated, existing, hedgerows, streams and ditches?

The existing canal bank and associated eco-systems will be protected and enhanced landscaping for the extent of the works will further improve the localized eco-systems.

3.6 Will lighting be on 24/7?

Lighting may be dimmed and/or switched off during core nighttime hours.

3.7 Is the impact/design of lighting on crayfish, birds, bats and other species and the habitat as a whole to be assessed?

An ecology survey has been carried out which classifies ecological impact as minimal.

3.8 Is it intended to include interpretation noticeboards outlining areas of importance for heritage and wildlife in the design?

Interpretation notice boards will be included as part of the enhanced landscaping.

3.9 Will the design be cognizant of the fact that this route is a wildlife corridor linking urban and rural areas, the importance of which has never been assessed in terms of its importance for protection of bio-diversity? If so, in what way/s?

Bio-diversity has been considered within the ecology report which has classified the impact of this scheme as minimal. All necessary measures will be included to protect and enhance the natural environment of the canal within the proposed landscaping, including possible incorporation of bird boxes and otter holts.

3.10 What environmental protection measures are built into the design in relation to construction materials and processes?

All construction processes will comply with environmental protection law. Every effort will be made to ensure protection of the environment during construction.

3.11 What consideration, if any, has been given to alternative routes, e.g. on the north bank of the Canal, which is already in use for vehicular access?

The north bank of the canal has in general a higher level of existing flora and fauna. Existing users generally use the southern towpath as a green commuter route as it provides the most direct access from areas such as Clondalkin. This scheme will improve access for these existing users and encourage others to use the route for green transportation. The northern towpath route may be developed as part of future development plans.

3.12 What areas is the power to be supplied to – is its purpose to provide power to proposed or planned new development, enhance existing power supply, other?

Currently there is a clear deficit of power supply in the south west of the county. The project will enhance the present supply and provide security of power supply to existing and proposed users.

3.13 What is the sustainability of the electricity source to be drawn from, details of any alternative “greener” sources from which power could be drawn?

Power will be drawn from existing sources. There are no alternative sources of energy available within the region at present, however this project does not preclude their use in future.

3.14 How does this integrate with standards aimed for in the Balgaddy Local Area Plan?

This scheme provides pedestrian and cycle access between the southwest Dublin area and the centre of the city, providing environmentally sustainable linkage to the area. The project is also in line with the approved report on “Green Routes in South Dublin County” which outlines a network of cycling and walking routes throughout the County utilising links through parks, open spaces, along waterways and roads which has the purpose of facilitating secure, safe and attractive connections for schools, work and leisure purposes.

3.15 We understand that an “environmental study” rather than a full EIS is to be carried out and are concerned this will not adequately identify in detail the environmental importance of local features of the proposed route, or put forward full protective measures available, through legislative and design measures. Is an EIS to be carried out? If so, what is the scope of the EIS?

A thorough ecology report which covers environmental issues including impacts on flora and fauna has been carried out and has not reported any significant environmental impact. An archaeology study has also been completed to Environmental Impact Study guidelines in order to highlight any archaeological or heritage issues along the route. A full Environmental Impact Study is not required under the European Communities (Environmental Impact Assessment) Regulations, 1989.

3.16 We understand that an ecology study has been commissioned?

An ecology study has been carried out by Roger Goodwillie and Associates, Application Ecologist, to identify any items of significant ecological interest, protected or otherwise Rodger Goodwillie met with members of Loc Canail during the course of this study and the opportunity was given to highlight any items of which they had knowledge. A separate Bat Survey was also carried out by Aardwolf Wildlife Surveys as part of this study. The Bat Survey states that the impact on bats is considered to be negligible to minor. The Ecological Assessment Report and the Bat Survey can be viewed on Membersnet.

3.17 Has an Archaeological study been commissioned?

An archaeological and architectural desk study has been completed for the route. Margaret Gowan and Associates carried out the study in order to identify any items of archaeological significance along the route. The report highlights an area of minor significance around the area of the 11th Lock which will be monitored during excavation, although significant finds are not expected. The Archaeological and Architectural Report can be viewed on Membersnet.

3.18 Has a Human Impact Study been commissioned?

The existing uses of the canal were examined in the feasibility study for this project. The project also conforms to recommendations of the approved “Green Routes in South Dublin County” report. The archaeological and architectural desk study highlights any heritage issues along the route. A Human Impact Study has not been commissioned, however, the project achieves an objective of the County Development Plan 2004-2010 under policy 7.8.1 – Cycling and Walking.

3.19 Details of the public consultation process.

The proposals have been on public display as part of the Planning and Development Act 2000 and Planning and Development Regulations 2001-2007 Part 8 procedure. The proposed Green Pedestrian and Cycle Route along the Grand Canal from Brownstown to Inchicore incorporating 110kv Ducting project was advertised in the Irish Independent on July 10th, plans and particulars of the project were on display at the Council offices in Tallaght and Clondalkin until the 4th September and the closing date for submissions was 4th September. Any member of the public wishing to speak to Council officials was met and Loc Canail had a meeting with the consultant and Council officials. Loc Canail and the Irish Wildlife Trust also met with the ecologist. Notices were located on-site from the 10th July until 4th September advertising the project and notices were sent to the statutory bodies referred to in the Planning and Development Regulations 2006.

3.20 Is there a written outline of the process, public invitations to participate etc?

Public comments were invited through advertisements in the Irish Independent, notices on site and the Council’s website. The proposal and drawings were on public display at the Council offices in Tallaght and Clondalkin for at least 6 weeks with a further 2 week period for receipt of submissions. Notice of the proposal was sent to the relevant statutory bodies as mentioned in the Planning and Development Regulations 2006 for comment. Submissions received are considered and responded to in the report to the Lucan/Clondalkin Area Committee (1) and the decision of the Area Committee is brought to the County Council. Notice of the decision made at the Council meeting is sent to all persons/bodies who made a submission.

3.21 What heritage and environmental protection agencies have been notified of the proposal?

The Department of Environment, Heritage and Local Government, The Heritage Council, National Parks and Wildlife Service and An Taisce – The National Trust for Ireland, The Central Fisheries Board, Waterways Ireland, Dublin City Council and Kildare County Council have amongst others received notice of the project.

3.22 Have any observations been received in response to notifications? Are copies available?

All comments received are included in this Part 8 planning report.

3.23 What is the tender process for completion of the work?”

The work will be tendered as a public tender conforming to EU and government guidelines.

3.24 What are the tender specifications for?

Specifications are currently being drawn up as part of the detailed design process. Construction processes will vary along the route.

3.25 Loc Canail is concerned with built, natural and cultural heritage. Protected species and habitats have been identified along the proposed route – White Clawed Crayfish, Kingfisher, Otter, and Groenlandia dansa, the opposite-leaved pondweed... The built heritage of the canal is well established. We understand that no biodiversity plan, Heritage Officer or Environment Officer is in place in SDCC, is this correct.

South Dublin County Council has an Environment Awareness Officer, a Conservation Officer and Parks and Landscape Services. The Council are currently in the process of recruiting a Heritage Officer.

3.26 The proposed route is in an area which has been identified as one of the highest for bio-diversity in the County. How is it proposed to ensure the construction has due regard for bio-diversity, in particular:

All ditches and streams will be protected from pollution under normal construction regulations and practices.

3.27 What steps will be taken to protect all water features (stream and canal) from pollution?

The successful tenderer will be required to protect all water systems from pollution as part of the construction process.

3.28 How will spoil from trenches etc. be stored or disposed of?

The successful tenderer will be required to store or dispose of spoil as part of the construction process, conforming to all applicable environmental and construction laws.

3.30 Will provisions be made to retain existing hedgerows, streams and ditches?

All existing hedgerows, streams and ditches will be maintained where practical and improved / replaced for the extent of the project.

3.31 Where will equipment be stored during construction?

The successful tenderer will be required to store equipment in a secure location along the route. The precise location of these storage areas will be confirmed at detailed design and construction stage.

3.32 Will there still be access for pedestrians during construction?

Access will be closed to pedestrians during construction for health and safety reasons. The route will be constructed in phases and alternative routes for pedestrian and cycle traffic are available on nearby road networks. Alternative routes will be signposted appropriately, and inconvenience to pedestrians will be kept to a minimum.

3.33 When is construction planned for and how long will construction take?

Construction is scheduled to begin in early 2008. The project will take circa 18 months to complete.

3.34 What legislative and regulatory measures will be applied to the construction process?

The construction process will be subject to all applicable Irish Law, including environmental, employment and health and safety regulations.

3.35 Who will monitor the construction process to ensure compliance with the requirements?

South Dublin County Council, Dublin City Council, Waterways Ireland and ESB will monitor the construction process.

3.36 How will protected plant or animal species be identified in the construction process?

While the ecology study has not identified any protected plant or animal species which may be affected by the works, in the event that any are identified all appropriate measures will be taken to protect and conserve protected wildlife and plant in conjunction with the appropriate agencies.

3.37 What is the procedure for identification of a protected species, and what is the procedure if one is identified during constructions?

While the ecology study has not identified any protected plant or animal species which may be affected by the works, in the event that any are identified all appropriate measures will be taken to protect and conserve protected wildlife and plant in conjunction with the appropriate agencies.

3.38 What will happen in the event of damage or destruction to the built or natural heritage features on the proposed route?

This scheme is intended to improve and enhance the features of the Grand Canal. As built and natural heritage features have already been identified on the route it is unlikely that damage or destruction will occur during construction. However, the contractor will be conditioned to take due care and attention and will be required to rectify damage from any unplanned incidents which may occur.

3.39 We would propose that rather than financial penalties for damage to heritage, a condition be included that the contractor should be required to restore features or habitats damaged during construction.

This scheme is intended to improve and enhance the features of the Grand Canal. As built and natural heritage features have already been identified on the route it is unlikely that damage or destruction will occur during construction. However the contractor will be conditioned to take due care and attention and will be required to rectify damage from any unplanned incidents which may occur.

3.40 In our view, financial penalties represent the lowest level of engagement with sustainability and active, high level engagement and best environmental and sustainability practices should be incentivised, during design, build, maintenance and use of the proposed route.

The contractor will be conditioned to take due care and attention during construction and will be required to rectify damage from any unplanned incidents which may occur.

3.41 Is the Development Department aware of plans for restoration of equine use of the towpath by Cherry Orchard Equine Centre and the proposed North Clondalkin Equine Centre?

Waterways Ireland, as owners of the canal towpaths, is not aware of any plans to restore equine use of the towpaths. After wide consultation in 1993, the Minister of State at the Office of Public Works confirmed that horse riding should not be permitted along the canal. Bye-laws introduced under the Canals Act 1986 also require prevention of damage to canal property, and equine use is considered dangerous for other canal users. Waterways Ireland therefore does not permit equine use of the canal towpaths and has no immediate plans to do so in the future.

3.42 What provision, if any, has been made in the design for continued access to the towpath?

Equine use of the canal is not permitted by Waterways Ireland. Horses are not currently used for towing barges, however this scheme does not preclude such use in the future.

3.43 What happens after observations are sent in, how is it proposed to work in partnership with local communities for the remainder of the process?

The planning process does not provide for any formal public consultation after the Part 8 planning process has been completed. As heretofore, the Council will respond positively to requests for involvement in this project.

4. Submission No. 2 from Loc Canail

4.1 We do not feel that currently the towpath proposal meets such standards and given that the LAP to be completed in the next couple of months, we would strongly feel that the proposed towpath development should conform to the standards set If Possible, it is our view that the towpath development, should be planned in a way which is integrated with the Local Area Plan and which has full local consultation and engagement.

The proposed scheme forms part of the approved report “Green Routes in South Dublin County”. The purpose of the green route network throughout the County is to provide, where possible, the maximum amount of off road cycleway and footpath and conforms to the objectives of the South Dublin County Development Plan 2004-2010

4.2 We believe there is an opportunity to create a vision for the future of the Grand Canal as a whole, with strong local engagement by communities, which is in danger of being lost.

It is our understanding that the green area between Lockview Road, St. Cuthbert’s Road, Fonthill Road and the Grand Canal, is to be developed for amenity purposes as part of the Balgaddy Local Area Plan.

This area, as can be seen on the map enclosed, is on the south bank of the canal and includes a section of the proposed electricity cable/cycle and pedestrian route, but it is not clear how these two plans are to be integrated.

Access to the canal bank via this green area could be inhibited by the proposed cycle path, as cyclists can travel at significant speeds and this could negatively impact on the proposed amenity development.

It is our understanding that it is proposed to restore Omer’s Lock House, on the north bank for community use in the Local Area Plan, and the cycle path proposed route may more appropriately be located on the north bank in this context, as well as in the context of the wildlife issues associated with this section of the south bank of the canal, where natural features (bankside eco-system, towpath surface, associated ditches. Hedgerow and stream system) are intact.

This project does not inhibit or preclude further developments along the canal. The project objective is to upgrade and enhance the Grand Canal towpath. The northern towpath may be further developed as part of other developments to the north of the canal.

4.3 We would suggest that the cable route and cycle and pedestrian path location and design, for this section should be integrated with the overall plan for amenity development in this area.

The project location is in line with recommendations of the approved report “Green Routes in South Dublin County” which provides for a green off-road pedestrian and cycle network for business, school and leisure users. The project conforms to the walking and cycling objectives of the South Dublin County Development Plan 2004 – 2010.

4.4 The local community has campaigned long and hard for amenity development, including a horse stables, in this area, and would feel it is essential to ensure that we take an integrated approach to the proposed development in this regard.

As stated above, equine use of the canal is not currently permitted by Waterways Ireland. This development does not preclude the use of the canal by horses in the future should this change.

4.5 If a horse stable is located here, as is hoped locally, as part of community benefit from the Balgaddy Local Area Plan, then it would be hoped to retain the south bank for use for a stable.

As stated above, equine use of the canal is not currently permitted by Waterways Ireland. This development does not preclude the use of the canal by horses in the future should this change.

4.6 The Local community also aspires to barge-building and other activities, and would like to retain the possibility of use by horses of the towpath, to restore this tradition.

As stated above, equine use of the canal is not currently permitted by Waterways Ireland. This development does not preclude the use of the canal by horses in the future should this change.

4.7 We are concerned that the proposed development could cause unnecessary destruction of natural habitats and the wildlife corridor, which must be maintained as a continuous unit to protect bio-diversity.

A thorough ecology report which covers environmental issues including impacts on flora and fauna has been carried out and has not reported any significant environmental impact. An archaeology study has also been completed to Environmental Impact Study guidelines in order to highlight any archaeological or heritage issues along the route.

4.8 The design of the path appears to be wider than that in use in towpaths developed for walking and cycling in Northern Ireland and UK, and to require, in places, that it will go right to the water’s edge, which will damage the eco-system. The proposed width could also, in our estimate, damage the ditch and hedgerow system associated with the canal, which form an essential part of the eco-system and are very well preserved on the stretch from 9th Lock in particular.

The route is planned to develop the existing towpath surface. Any ditches or hedgerows which may be altered during the course of the works will be reinstated and improved where possible.

5. Submission from David Fadden

5.1 Is it at all possible to have the cycle route avoid crossing the Killeen and Kylemore Roads? The key issue to bear in mind in relation to cyclists is that they expect to be on the move as much as is possible and will avoid having to dismount.

Cyclists will share the restricted footpath passing under the Kylemore Road. There is insufficient space to pass under the Killeen Road with this scheme. Cyclist will have to dismount at certain points along the route to accommodate fishing and access / egress control points along the route.

5.2 The access to the cycle route from the Yellowmeadows/New Nangor Road junction needs some improvement work as part of the scheme.

This access will be incorporated in the scheme.

5.3The critical long term issue will be maintenance of the route which has been prone to a lot of vandalism. I note that lighting and CCTV is proposed which is welcome but ongoing maintenance will be necessary to keep the route free of glass, for example.

CCTV will be linked to a South Dublin County Council monitoring station. Waterways Ireland will maintain the towpaths, with assistance from the respective Local Authorities in their area.

6. Submission No. 2 from David Fadden

6.1 I query the separation of cyclists and pedestrians on the section of the route which is most likely to be used by commuting cyclists as distinct from recreational ones. A commuting cyclist can travel at up to 30 kmh and there is a difficulty in putting the cycle path between the pedestrian seating areas and the pedestrian route as shown on the drawing.

This project will make the best use of the restricted space of the canal towpath. The cycle path has to be kept away from the canal to avoid interference with fishing. It is also desirable to keep faster moving cyclists away from the open water of the canal.

6.2 If you look at the experience of cycle routes in the Phoenix Park, a lot of pedestrians walk on the routes, In Denmark this is addressed by having the cycle route on a level between that of the footpath and the road.

There is insufficient space on the canal towpath to safely provide separate levels. Cycle and pedestrian routes are regularly constructed at the same level however.

There is insufficient space on the canal towpath to safely provide separate levels.

7. Submission from Irish Wildlife Trust

7.1 The Irish Wildlife Trust supports the promotion of sustainable activities such as walking and cycling which encourages a greater appreciation of our natural heritage. If planned and developed sensitively to the natural and cultural environment the use of canal banks for promoting sustainable activities is beneficial for enhancing enjoyment and appreciation of our natural heritage. I submit the following observations:

7.2 Pedestrian and Cycle Route – It is felt that there has been insufficient time and consultation with all members of the local community in order to fully explore the potential impacts that the proposed route would have, as well as the potential benefits (if properly constructed) this could bring. Not all uses of the towpath have also been fully explored.

The time for consultation is in accordance with Part 8 planning procedures. The purpose of the scheme is to improve and enhance the existing towpath. As heretofore, the Council will respond positively to requests for involvement in this project. The project location is in line with recommendations of approved report “Green Routes in South Dublin County”

7.3 The area of the Grand Canal from the 9th Lock is the last area of the Grand Canal that has remained relatively unchanged and supports a variety of structures that have local and historical value. It is also the last stretch of open green space along the canal within the Dublin boundaries before entering the well developed city environs. This does not appear to have been included for consideration of the design of the pathways. More value should be placed on the importance of the area for Dublin in terms of natural and built heritage.

The Grand Canal extends from Ringsend Basin in the centre of Dublin and links with the River Shannon in the west of Ireland. This project is intended to enhance and open up this 8.5km stretch of green space, which is considered as semi-urban, for the safe use and enjoyment of a significantly increased number of people. It will provide access for all, including access for those with impaired mobility who have limited access at present.

7.4 Route Plan – The proposed route following the south bank does not take into account existing tracks on the North Bank. While the North Bank appears more important for supporting the biodiversity within this area, the top of the bank is already used for access towards the Western end of the proposed route and contains a former hard track. Only one route has been proposed and we feel it essential that alternatives are also fully considered.

The north bank has been considered for development. It is likely that this bank will also be enhanced in future developments along the northern towpath, however the southern route is currently used by existing commuters and will provide more direct access to Clondalkin and Grange Castle.

7.5 Hedgerows and Vegetation – All hedgerows and bankside vegetation must be retained. Of particular note is the hedgerow adjoining the Grange Castle complex. This serves a purpose in screening the canal from the industrial units which would otherwise be an eyesore and spoil the landscape value of the canal. The banks and bank footings also provide a habitat for a variety of wildlife.

There will be no significant negative environmental impact as a result of this project. Enhanced security along the route will provide protection for both residents, users and flora and fauna. Extensive enhanced native planting is planned as part of the scheme. A thorough ecology report which covers environmental issues including impacts on flora and fauna has been carried out and has not reported any significant environmental impact.

7.6 The bank side and sides of the towpath are perhaps the most important for wildlife in terms of species supported. The combined width of the paths may infringe on these areas resulting in the loss of these areas.

The path will not remove the bank sides and the sides of the towpath have minimal impact close to the canal and back ditches.

7.7 Hedgerows and other features must be retained for both their landscape and wildlife value.

There will be limited trimming of hedges and trees. This project is designed to enhance the existing towpath and should not encroach significantly on other areas.

7.8 The width of the paths may also need revising to ensure natural features to the sides are not infringed.

The path widths will be adjusted to suit the local widths. A total width of 3.5 metres is generally achievable although this will widen to 4 metres where possible.

7.9 Hedgerows and green areas must be sensitively managed.

There will be limited trimming of hedges and trees. Enhanced native planting is planned as part of the scheme.

7.10 Areas sensitive to damage (natural and historical value) should be avoided.

This project will enhance the existing towpath. Damage to areas of natural or historical value has not been highlighted in either the ecology or archaeological and architectural report.

7.11 Flooded habitats at canal bank footings preserved for wildlife value. (This would include no dumping of spoil or drainage).

Back ditches will not be removed as part of this project. Towpaths will continue to drain into back ditches as at present. There will be some minor increases in runoff where paving area is increased.

7.12 Pathway Construction – From examining the plans and images it appears that the route is to be made from tarmac or other similar material. We find that the use of this material would have several impacts:

The pathway will be constructed from similar material to that used on canal towpaths in other areas to enable the scheme as designed to provide mobility-impaired access.

7.13 Potential for damage to surrounding habitats from possible leaching from bitumen and other chemicals used during construction.

Protocols will be in place as part of the contract to prevent against potential damage. In the unlikely event that damage does occur, this will be rectified.

7.14 Encouraging anti-social behavior – The use of tarmac in the past has often resulted in encouraging anti-social behaviour, such as graffiti etc.

CCTV is planned to discourage anti-social behaviour. It is envisaged that the additional use of the canal will also enhance passive security.

7.15 The pathway may not be fully accessible during winter – Given the proximity to water the path is likely to freeze in the winter making it inaccessible to the majority of people and would be a hazard. Traditional methods to combat freezing would pollute the canal and surrounding vegetation.

The towpaths will continue to drain into back ditches. The proximity of water has no bearing on the likelihood of freezing water on the towpath.

7.16 The construction of the pathway appears to be more relevant to supporting services related to the underground cable than facilitating the recreational uses of the towpath and canal bank.

This project incorporates ducting for 110kV electricity supply to the southwestern region of Dublin. This supply is essential to strengthen the existing ESB network and provide resilience of supply. Alternative ducting routes would cause widespread and severe disruption to existing routes in the vicinity of Clondalkin and Nangor Road. This route is incorporated in the approved “Green Routes in South Dublin County” report and the installation of the ducting provides an ideal opportunity to develop the enhancement of the canal towpaths as an amenity for public use.

7.17 We would like the following considered:

The enhancement of the canal towpath must provide accessibility for all, including those with impaired mobility, without compromising the heritage and wildlife value. Softer path designs are not suitable for this objective.

7.18 The protection of the aesthetic and heritage value of the existing towpath.

It is considered that the aesthetic value of the towpath is significantly enhanced by the scheme. The scheme will also enhance the heritage value of the towpath by virtue of its goal of attracting more people to the canal.

7.19 A census of current use and proposed future use – Have all users been identified, is there a need for such a wide path etc.

Existing use of the towpath is widely known. It would be desirable for the paths to be wider and to include cyclist / pedestrian separation measures, however the existing towpath width does not allow for this.

7.20 Alternative path routes fully investigated.

This route forms part of the planned network of green routes in the South Dublin County and opens up the canal as an amenity for all.

7.21 It is felt that along with the proposed pathway litterbins will also detract from the aesthetic value of the area.

Litterbins have been included to reduce littering of the towpath. Their location will be reviewed and maintenance measures by South Dublin County Council and Waterways Ireland will be agreed before implementation of the scheme.

7.22 If bins are used they should be sensitively designed to fit in with the environment and designed to reduce vandalism and litter falling out of them.

Bins will be designed to a high specification, to enhance the appearance of the scheme and discourage vandalism.

7.23 Interpretation boards detailing wildlife and built heritage.

Interpretation boards will be included.

7.24 Use of area for education (school and community).

The project enhances the ability for the use of the towpath for education.

7.25 Lighting should be designed to provide the minimal illumination required. Light pollution may affect the many nocturnal species present, as the physical structures from being imposing. Lighting has also been shown to effect the behaviour cycles of birds.

Lighting will be designed to minimize light pollution. Lighting may also be dimmed and / or switched off during core nighttime hours.

7.26 Use of sustainable energy to power lights, or at least reduce the conventional energy required.

Energy for lighting will be supplied from sources available within the area.

7.27 Low energy design.

Low energy is a criterion for the design.

7.28 Assessment of impacts on species such as moth and bats, as well as birds in the area,

An impact on moths and bats has been considered. Lights may be dimmed and/or switched off during core nighttime hours to minimize impacts.

7.29 Suitable design and construction material of lights to fit in with surrounding environment.

Lighting will be selected to be aesthetically pleasing.

7.30 The constructing of Bridges crossing over the canal should bear the following in mind:

Bridges will take account of future developments in the area. All bridges will be constructed in accordance with Waterways Ireland’s navigation and maintenance requirements. The scheme will provide access for the mobility impaired.

7.31 The ducting should be constructed with minimal impact on the environment. There did not appear to be any conclusive evidence on how these pipes will be laid. As well as habitat damage, we would also have concerns as to whether the construction would weaken the bank and cause structural damage or leaks. Given the proximity to water is this the safest route for an electrical cable.

We have the following observations;

There are various existing electrical cables within the canal banks and there is no issue with the proximity to water. Canal banks will be supported during construction and their long-term structural stability will be enhanced as a result of these works. Pollution during construction will be prevented as required by existing law and there is no danger of pollution from the cables themselves. There will be no risk of flooding or electric shock from the cables.

7.32 While CCTV will help reduce and capture anti-social activity it will only work if fully operational and with a response:

CCTV will be monitored and the appropriate authorities notified. Access to footage, to facilitate the Irish Wildlife Trust can be considered if specific requests are made.

7.33 More consultation with a greater number of the community to develop the best use of this area. This would also include a census of use and traffic through the area.

Consultation has taken place in line with the Part 8 planning process.

7.34 Given the status of the Grand Canal as a pNHA a full environmental impact study should be completed.

A thorough ecology report which covers environmental issues including impacts on flora and fauna has been carried out and has not reported any significant environmental impact. An archaeology study has also been completed to Environmental Impact Study guidelines in order to highlight any archaeological or heritage issues along the route. A full Environmental Impact Study is not required under the European Communities (Environmental Impact Assessment) Regulations, 1989.

7.35 Promotion of cultural and natural value of canal through interpretation and awareness raising activities.

This project will facilitate such activities in future.

7.36 We would also be concerned that this is a further step towards reducing the natural heritage value of the area and being a stepping-stone towards development of what little green, natural space remains within the area.

This project will enhance the existing green space which is currently considered unsafe and antisocial by many. It will allow use of the canal by those with impaired mobility and provide a green alternative commuter route.

8. Submission from National Roads Authority

8.1 The Authority would like to be circulated with proposed details of cycle, pedestrian and 110kv ducting in the vicinity of M50 Bridge at Nangor Road for review.

This will be provided.

9. Submission from Department of Communication, Marine and Natural Resources

9.1 The Department of Communications, Marine and Natural Resources have no comment to make at this time, however it is suggested that Waterways Ireland who are the competent Authority for the maintenance and upkeep of the Royal Canal should be involved in the consultation process. The above is without prejudice to any comments that the Eastern Regional Fisheries Board may have in the matter at this time.

Waterways Ireland is a partner in this project.

10. Submission from the Dublin Transportation Office

10.1 Policy context: The DTO Strategy as set out in A Platform for Change (2001) states that the principal objectives for the cycling mode are the completion of the strategic cycle network and the development of links to public transport. Other objectives include the provision of additional cycle parking, promotion of the cycle mode, and provision of facilities for leisure cycling. The overall objective for cycling in the strategy is to increase the proportion of short trips (less than 6 km) to 30% by 2016.

10.2 In 2006 the DTO published a Cycle Policy for the Greater Dublin Area to facilitate the achievement of the targets set in A Platform for Change. This includes objectives to improve the physical infrastructure for cycling, to promote cycling through marketing and training and to develop and monitor cycle programmes to support the policy objectives.

This project will improve infrastructure for cycling and encourage more cycling in the adjacent areas. The route forms part of the network of pedestrian and cycle ways throughout South Dublin County.

10.3 DTO position: The DTO would be supportive in principle of developments aimed at improving conditions for cycling, subject to their compliance with the policy objectives outlined above.

This route forms part of the network identified in approved report “Green Routes in South County Dublin” This scheme will connect to routes within the city and provide a continuous green route from the 12th Lock to Ringsend Basin. The route provides a green, safe alternative mode of transport for business, school and leisure users.

10.4 Design of Pedestrian/Cycle route: The design of the proposed route comprises a 2.0m footpath directly adjacent to the canal with a cycle path of 1.5m alongside the footpath, widening to 2.0m where possible. It is intended that the cycle path will cater for two-way cycle traffic for its entire length. Fishing areas and seating areas with CCTV have been proposed at various locations along the route. As detailed in Provision of Cycle Facilities – National Manual for Urban Areas, the DTO considers 1.5m to be insufficient to cater for two-way traffic in a canal towpath setting, particularly in the presence of potential hazards such as fishing stands.

The physical constraints of the canal dictate the achievable widths.

10.5 A further reservation about the route concerns its connections to the road network in its vicinity for the entire length. The current proposal has limited connections to adjacent lands and roads, located mainly at points where the route is crossed by major roads. From an examination of the drawings, it would appear that a number of opportunities exist for the route to be “plugged into” the existing network. This would facilitate its use by commuters wishing to travel to and from areas in the vicinity of the canal corridor, rather than the more limited leisure purpose the current proposal would serve.

This route forms part of the network identified in approved report “Green Routes in South County Dublin” Access points for schools, work and leisure provided by other bodies will be considered.

10.6 The DTO Cycle Manual also stresses the importance of a high level of design for junctions and other points at which cycle facilities adjoin or are part of the general road network. The existing documentation for the proposed scheme is not of a sufficiently detailed scale to allow an accurate appraisal of the detailed design issues arising at such points of potential conflict.

Junctions have a high level of design and have taken account of existing road networks. Toucan crossings will be provided at crossing points.

10.7 The DTO is in favour of the provision of cycle facilities to cater for a range of cycle trip types, including leisure trips for which this facility appears to be quite suitable. However, the provision of facilities designed primarily for leisure use should not be seen to obviate the need for other types of cycle route, such as the routes to stations, schools and local centres as advocated in the GDA Cycle Policy.

This route links with local road networks which provide access to local facilities. The route forms part of the network of pedestrian and cycle routes throughout South Dublin County for business, school and leisure users.

11. Submission from Concerned Residents of the Grange

11.1 However this proposal appears to be a method of facilitating using the canal bank as a service corridor for high tension electrical cables and other utilities.

This project incorporates ducting for 110kV electricity supply to the southwestern region of Dublin. This supply is essential to ensure development and employment in the area in line with all existing development plans. Alternative ducting routes would cause widespread and severe traffic disruption. . This route is incorporated in the approved “Green Routes in South Dublin County” report and the installation of the ducting provides an ideal opportunity to develop the enhancement of the canal towpaths as an amenity for public use.

11.2 While economically combined use makes sense, a previous situation arising from CIE’s Mini-CTC Signalling Project must highlight the need for caution and due diligence in planning this venture.

Every effort is being made to identify potential problems at detailed design stage. The works are being planned in conjunction with ESB and affected public bodies.

11.3 Provision of demarcation of usage for the various interests (i.e. pedestrians and cyclists) in your proposal does not include provision for motor vehicles, implying unacceptable liability when driving on the usage defined area.

Motor vehicle access will be provided for where it exists at present. The pathway will be shared use in the vicinity of the 12th Lock, to provide access to private dwellings and signed accordingly.

11.4 The photos show the proposed end of the cycle path in a cul-de-sac on the south bank. The towpath continues on the north bank from this point to Hazelhatch, causing safety concerns for cyclists crossing the canal.

A toucan crossing will be incorporated at this point in conjunction with the upgrade of the R120.

11.5 While a well intentioned development, the plans presented to the public consultation demonstrate a lack of cohesion and ‘joined up’ thinking in the planning area. This highlights yet again the need for a Local Area Plan.

This project forms part of the planned network of green routes within South Dublin County and conforms to the walking and cycling objectives of the South Dublin County Development Plan 2004-2010.

11.6 Existing alternative route via Grand Canal Way on northern bank of canal.

The northern bank will be developed in conjunction with lands to the north of the canal. The south bank provides a direct route with more frequent opportunities for access than the north bank.

11.7 Regarding public lighting the issues arising are:

South Dublin County Council will maintain lighting. Lighting will be designed to limit light pollution and may be dimmed / switched off during core nighttime hours. Lighting is provided to enhance the safety of towpath users. CCTV will be night vision capable with a minimum light quality.

11.8 Questions regarding CCTV surveillance are:

The CCTV cameras will be monitored by South Dublin County Council on a continuous basis. Antisocial behaviour will be notified to the relevant authorities.

11.9 Provision of ducting for public lighting, CCTV, 110kv power cables and communication cables together with associated connection and pulling chambers:

The cabling will connect to existing networks and is essential for ensuring security of supply. This project will not affect the stability of the canal bank and there are no radiation risks from the cables.

11.10 This proposal transforms the canal bank into a service corridor with the attendant risks. We request that an environmental impact assessment be carried out regarding the following:

A thorough ecology report which covers environmental issues including impacts on flora and fauna has been carried out and has not reported any significant environmental impact. There will be some unavoidable disturbance during construction however the canal structure will not be weakened. The cables are not oil filled and the ducts will be rubber jointed to avoid flooding. The ducts will connect to Grange Castle Business Park and to Adamstown Residential area and other existing and proposed 110kV substations. Two way 110kv ducting will be installed.

11.11 Loss of Amenity and added risks:

There is no danger from electro-magnetic fields or electrocution. There are various other existing electrical services in the towpath in the Dublin City area and maintenance, if any, does not cause a major disturbance.

11.12 Construction of Designated Fishing Points along the Route

It is proposed to facilitate fishing points along the route. There is no danger from electro-magnetic fields or electrocution.

11.13 The provision of toucan pedestrian and cycle crossings at Ninth Lock Road and Killeen Road

Toucan Crossing and access will be incorporated in the R120 upgrade and in advance of the upgrade works if necessary.

11.14 The construction of access ramps to allow impaired access to and from the route from Park West Avenue, Fonthill Road and the Grange Castle Road. Access will be maintained and improved at Killeen Road, 9th Lock Road and 12th Lock Road.

Toucan Crossing and access will be incorporated in the R120 upgrade. No existing residential access will be removed by this scheme.

11.15 The provision for future pedestrian bridges at key points along the route to link to future developments on lands to the north of the canal.

Waterways Ireland will maintain the towpaths, with assistance from the relevant Local Authorities in their area.

All bridges will be constructed in accordance with Waterways Ireland’s navigation and maintenance requirements.

11.16 The provision of upgraded landscaping with native planting

This scheme only affects the southern towpath. The northern towpath may be upgraded in future.

11.17 Provision of the appropriate directional signage and markings.

The route will be named in due course by South Dublin County Council.

11.18 Summary

The proposal will link with the upgrade of the R120 as details for this scheme are developed. Existing rights of way will not be extinguished.

12. Submission from John and Beverley Power

John and Beverley Power support the Concerned Residents of The Grange in opposing the above proposal in its current form particularly for the following reasons:

12.1 Any interruption of our usage of our legal right –of-way beside the 12th Lock from the barrier to the R120 would be unacceptable.

Existing rights of way will not be extinguished.

12.2 It is unclear from this proposal if high tension cables will also be adjacent to our property.

Ducting will be installed within the boundaries of Waterways Ireland property approximately 1.5m from the canal. Cabling may be installed at a future date.

12.3 Concern for the structural integrity of the canal bank during construction and after completion.

The structural integrity of the canal bank will not be compromised during the works.

12.4 Lack of reference to other SDCC proposals (e.g. R120 – Option 7A)

The project will link with the R120 as details of this scheme develop.

12.5 Traffic Management/traffic calming is currently necessary on the R120 and will become more acute with population explosion due to Adamstown New Town and the increased industrial developments in the Grange Castle Business Park area. No traffic safety improvements are indicated as part of this proposal at the 12th Lock.

Any necessary traffic calming measures will be incorporated in the R120 works.

12.6 Lack of a Local Area Plan continues to produce piecemeal changes without ‘joined up’ thinking.

This project forms part of an approved South Dublin County Council report entitled “Green Routes in South Dublin County” and conforms to the objectives for walking and cycling in the South Dublin County Development Plan 2004-2010.

13. Submission from Norah C. Carlson

13.1 I note that neither the Watery Lane (Clondalkin) access point to the Canal, nor that known to me as Grand Canal Terrace, have been indicated on your maps, (sheets No. 24 (Watery Lane) nor No. 31 (Grand Canal Terrace).) I sincerely hope there is no intention to close these. They are from my own observation, widely used – in the case of sheet 24 this can be clearly seen from the aerial photograph of the Watery Lane access.

There is no intention to close existing accesses. Additional accesses may be added where feasible.

13.2 On sheets number 31 & 35 (Kylemore Road) the proposed seating area will be facing Labre Park. I would suggest it be sited on the city side of the Kylemore Road Bridge, where it would have a better aspect, and could accommodate those who might be accompanying anglers using the proposed fishing points in the area.

Seating locations will be adjusted during detailed design to the most suitable location at each point.

13.3 Reference sheets numbers 26 & 35 – the proposed access from Park West Avenue to the Canal at the 8th Lock is to be welcomed, as the section between the 7th and the 9th Locks has only the Watery Lane exit (widely used by Clondalkin Residents) at present.

14. Submission from Henry and Timothy Crowley

14.1 We are landowners of the lands as indicated on the map enclosed, on both sides of the Canal from after the Newcastle Road Bridge at the Twelfth Lock to lands above the Gollierstown Bridge. We farm these lands on both side of the canal. The farm enterprise consists of a beef and tillage operation. The lands are connected by Gollierstown Bridge. At present the towpath is located on the north side of the Canal from the Newcastle Road to Hazelhatch. On the south side of the canal there is no towpath and no public access and we farm right up to the canal on this side.

This section of the project would form Phase 2 of the scheme. Landownership issues will be considered as part of the design process for this phase and agreement reached with landowners concerned before any works commence.

14.2 If the project goes ahead on the south side of the canal then we would need South Dublin County Council’s proposals on the securing and fencing of the route from our lands. If the project goes ahead on the north side (the towpath side) as indicated by an official of South Dublin that we met on the 30th September then the fencing does not apply. However we would be interested to cooperate on the security and safety of the route.

This section of the project would form Phase 2 of the scheme. Fencing will be considered as part of the design process for this phase in consultation with landowners and agreement reached before works commence.

14.3 Which ever route is used we wish to point out that we will need to cross the route at Gollierstown bridge to access our lands on the South side of the Canal. We presently access these lands with heavy machinery involved in the tillage operation and we also need access for the movement of farm animals to and from the fields. Here again we would need to know South Dublin County Council’s proposals for our safe access across the route taking into account Health and Safety procedures.

Access arrangements will be considered as part of the design process for this phase in consultation with landowners and agreed before works commence.

The proposal will be carried out on a phased basis, phase 1 from Inchicore to a point after the 12th Lock, Clondalkin and phase 2 from the 12th Lock, Clondalkin to Brownstown. (as indicated on drawings presented to the meeting) The proposal will form part of an overall route from Inchicore to Naas in the future.

As the proposal is in accordance with the proper planning and sustainable development of the area having regard to the provisions of the South Dublin County Development Plan 2004-2010 and the recently adopted it is recommended that the proposal be proceeded with.

The recommendation of the Area Committee will be brought to the County Council for decision.”

Following consideration of the report it was Agreed to recommend the proposal to the County Council for decision.

The proposed works are consistent with the proper planning and sustainable development of the area having regard to the Development Plan 2004-2010 and the recently adopted Green Routes in South Dublin County Report. http://www.sdublincoco.ie/sdcc/departments/econdev/publications/pdf/GreenRoutesInSouthDublin02102007.pdf

Accordingly, it is now proposed to proceed with the development works as proposed.