Metro South West Group
Submission to the Review of the Greater Dublin Area Transport Strategy
https://www.nationaltransport.ie/consultations/greater-dublin-area-transport-strategy/?fbclid=IwAR1_hy1ZTdWkHmL_ZrTYozXvu06AgpIiYGJU6ZeQ0OMxFzXWRT4N9Ybl7S4
January 2021
Introduction:
The Metro South West Group (MSWG) is supported by 37 Residents’ Associations and Community Groups, which represent some 50,000 people in the area between the Red and Green Luas lines. This area contains approximately a fifth the population of the Capital. We welcome the Programme for Government’s commitment to improve the quality of life of citizens and the fundamental change in the nature of transport. The aims of prioritising the needs of pedestrians and cyclists, the delivery of Metrolink, prioritisation of light rail expansion and associated development, and implementation of park and ride stations align with our own. We particularly welcome the incentivisation of modal shift from car use to active commuting and public transport.
The MSWG proposal is to continue MetroLink to South West Dublin, rather than have it terminate north of Beechwood in Ranelagh1. This proposal has the capacity to transform commuting patterns2, take congestion off our roads, realistically reduce pollution and offer a cleaner, greener environment with the capacity to prioritise safer community life in our region. It would support positive development of distinct neighbourhoods and urban villages, while providing equality of access to public transport for this long neglected quadrant. It is likely that the Benefit to Cost ratio of the proposal would be strongly positive3
The MSWG envisages a multi-modal, integrated and flexible public transport system, which delivers efficient, versatile and interconnected services that contribute to the social and economic regeneration of the city centre, outer towns and townlands.
While being in line with national and European ‘Just Transitions’ proposals, our proposal is consistent at policy level with the Programme for Government with the European Green Deal, and with the spirit of Project Ireland 2040. It is also consistent with the NTA vision to ‘provide high quality, accessible, sustainable public transport connecting people across Ireland’. It aligns Dublin with other European cities of comparable population size with complementary public transport systems meeting the needs of all citizens, where underground METRO has been part of the mix for more than a century, overcoming both heritage and geological challenges successfully.
We welcome the commitment to a feasibility study for a metro service to the south west region, but have significant concerns as to its terms of reference which are outlined in the attached Appendix. In this context, we urge the NTA and government to ‘re-examine assumptions, and re-prioritise solutions’ as outlined in the NTA’s Issues Paper for this process. An underground metro service to South West Dublin is essential as a catalyst to reduce public transport access disadvantage, provide a foundation of sustainability and accessibility and be a support for people with mobility impairments in these communities.
1The Case for Continuing MetroLink to South West Dublin, Metro South West, August 2020. https://documentcloud.adobe.com/link/review?uri=urn:aaid:scds:US:eb90ca39-fff8-4acd-9fe5-c1e92f4fb93e
2 South West Dublin and the Continuation of MetroLink: Improvement in Commuting Times, Metro South West, October 2020.
https://documentcloud.adobe.com/link/review?uri=urn:aaid:scds:US:4013503d-9fe7-4f65-b8d1-a380eafdb0c7
3 Indications for an Economic Appraisal of MetroLink from Estuary to Firhouse: Would Estuary to Firhouse be Good Value for Money, Metro South West, October 2020
https://documentcloud.adobe.com/link/review?uri=urn:aaid:scds:US:4fd7a227-2e08-4c40-94ba-272842eb1aca
“Nothing is more powerful than an idea whose time has come”
– Victor Hugo
Reasoning and Discussion:
Dis-enfranchisement of South West Dublin communities:
The Triangle between the Red and Green LUAS lines has long been neglected from the perspective of a rapid rail transport service. Given the nature of the old streets from Stephens Green to the outer city suburbs, LUAS is not an option here. This has resulted in Bus being the only public transport option available in this area.
Combined current passenger carrying capacity of multiple modes of public transport for the population in the South East quadrant (Luas, DART and Bus) is 24,600 compared with 5,680 (bus only) for Dublin South West. Our analysis shows that even if BusConnects meets all its objectives, it will deliver only a handful of additional buses going into the city from South West Dublin in the peak morning hour[1]. Thus, a bus only solution will NOT make it easier for people in Dublin South West to get around, which is a core aim of the Greater Dublin Transport Strategy.
136,000 people live in the South West catchment area prescribed by the MSWG’s proposal and analysis compared with 129,000 in the area served by the LUAS Green line
Population Expansion in the Dublin South West area:
As the Greater Dublin Transport Strategy issues paper acknowledges, more people will be living and working in the region and the distribution of population will change. The following will further add to the burden on public transport demands in this quadrant, with:
480 hectares of residential land development zoned for development (SDCC) – Equivalent to an increase of 50,000 in the population of this quadrant;
554,554 people live in Dublin City under DCC and this is expected to rise by 58,000 by 2026.
European Countries without a Metro
It makes environmental sense:
Ireland has one of the worst records of dependence on the car in Europe and nowhere is this better illustrated that in Dublin South West, with 73% of the population here choosing cars as their primary mode of transport – only 9% choose to use bus, which is currently the ONLY public transport choice. The NTA anticipates that 23% of all trips in the Greater Dublin Area will use public transport by 2035, while the number of car trips is also forecast to increase. Without a metro, the population of South West Dublin will remain wedded to the car.
Underground metro is widely accepted as being the safest, most reliable and environmentally friendly form of public transport. This is why it is a central pillar of public transport in almost every European city. It is the most effective way to reduce unsustainable car use in the South West Dublin region and there are indications that the proposal would have a high economic benefit to cost ratio4. This would result in a significant reduction in traffic congestion, leading to:
reduced air pollution and improved health benefits for the population at large
facilitating more efficient over-ground bus and tram services
more road space to re-configure in favour of pedestrians, cyclists and active transport modes
opportunity for significantly improved public realm environments and quality of life
re-vitalisation of the city centre and local villages and communities creating a capital region that works.
4 Indications for an Economic Appraisal of MetroLink from Estuary to Firhouse: Would Estuary to Firhouse be Good Value for Money?, Metro South West, October 2020
https://documentcloud.adobe.com/link/review?uri=urn:aaid:scds:US:4fd7a227-2e08-4c40-94ba-272842eb1aca
Appendix
Metro South West and the NTA Feasibility Study: January 2021
A1 Between the Red and Green Luas lines, the National Transport Authority has identified 4 bus corridors. However, under BusConnects, the projected increase in the number of buses going into the city in the peak morning hour is very small.
A2 19 years ago, the Dublin Transportation Authority conducted research, carried out transport modelling and published A Platform for Change. This found that a ‘bus only’ solution would not work in South West Dublin and that a metro would be required. Yet ‘buses only’ is the ‘solution’ which the NTA proposes.
A3 The Metro South West Group has carried out a lot of research into continuing MetroLink to SW Dublin. This also showed that buses alone would not be sufficient to serve the transport needs of South West Dublin5. It recommended to the NTA (in April 2019) that a feasibility study be carried out into continuing MetroLink to South West Dublin. Further analysis was carried out into savings in commuter time if metro stations were located at Spawell and Dodder Valley Park. This showed that significant time savings could be achieved throughout the outer suburbs by cycling or driving to these metro stations and taking the metro into the city. However, the Group said that the location of stations is best left to consultants6. The likely costs and benefits were also explored and it was concluded that the benefit-cost ratio would most likely be strongly positive7. The proposed feasibility study was supported by all 3 political parties at the recent General Election.
A4 The continuation of MetroLink to SW Dublin would be of great benefit to everyone in the area and for people visiting the area. Metro would not only give access to the city centre. For example, at St Stephens Green, you could transfer to Cross city Luas and go to the Technological University of Dublin in Grangegorman; or the Green Luas Line and go to Sandyford. At Tara Street, you could transfer to DART and go to Malahide or Bray. At O’Connell St., you could transfer to the Red Luas Line and go west to St James Hospital or East to the IFSC. Or you could stay on board and go the Airport or Swords.
A5 It is now important that a proper feasibility study is carried out into continuing MetroLink to SW Dublin. On 26 November, the NTA announced that feasibility studies would be carried out into two metros: to Terenure, Rathfarnham, Knocklyon and to UCD, Sandyford. However, there are serious issues regarding the scope of these studies. A6 Prior to the NTA announcement, the South West Metro Group met twice with an official and Ministerial advisor from the Department of Transport. Following are our takeaways from the meetings:
5 The Case for Continuing MetroLink to South West Dublin, Metro South West, August 2020. https://documentcloud.adobe.com/link/review?uri=urn:aaid:scds:US:eb90ca39-fff8-4acd-9fe5-c1e92f4fb93e
6 South West Dublin and the Continuation of MetroLink: Improvement in Commuting Times, Metro South West, September 2020
https://documentcloud.adobe.com/link/review?uri=urn:aaid:scds:US:4013503d-9fe7-4f65-b8d1-a380eafdb0c7
7Indications for an Economic Appraisal of MetroLink from Estuary to Firhouse: Would Estuary to Firhouse be Good Value for Money, Metro South West, October 2020
https://documentcloud.adobe.com/link/review?uri=urn:aaid:scds:US:4fd7a227-2e08-4c40-94ba-272842eb1aca
a) The feasibility study, which is underway in the NTA, is concerned with a ‘stand-alone’ metro from South West Dublin into the city rather than a continuation of MetroLink to South West Dublin. (A stand-alone metro would be much more expensive than a continuation of MetroLink to South West Dublin (c. €500m+ more expensive8); furthermore, a proposal to build a stand-alone metro which would start in South West Dublin and proceed into the city has, to the best of our knowledge, not been proposed anywhere to date.)
b) The geographical area of the study is Corridor E, as described in the Transport Strategy for the Greater Dublin Area 2016 to 2035, rather than the triangle between the Red and Green Luas lines. (The Corridor E geographical area is far smaller than the triangle between the Red and Green Luas lines.)
c) No change is possible to the Terms of Reference.
d) There is no opportunity for community engagement with the consultants carrying out the feasibility study.
e) The possible continuation of MetroLink from St Stephens Green to South West Dublin is outside the scope of the study. (However, the email from Anne Graham, NTA, seems to qualify this – see paragraph 7 below.)
f) The possible continuation of MetroLink from Charlemont/Beechwood to South West Dublin is outside the scope of the study. (However, the email from Anne Graham, NTA, seems to qualify this – see paragraph 7 below.)
g) If we have any observations on MetroLink, including its possible continuation to South West Dublin, the place to make these observations is An Bord Pleanála, when the NTA applies for a Railway Order in the middle of 2021.
h) The “Metro to Knocklyon” feasibility study, which is underway is one of series in preparation for the (legally required) updating of the Transport Strategy for the Greater Dublin Area 2016 to 2035. These studies will be used to prepare a draft updated text for the Strategy. At that stage, all of the underlying studies will be published and the draft Strategy will be subject of public consultation.
A7 We put certain queries to Anne Graham, CEO of the NTA. Here is her reply, dated 19 December 2020, and her responses to the queries: “Dear Ms. Foster, We refer to your email and attached letter of 8th December in relation to the Metro to Knocklyon Feasibility Study currently being undertaken. The overall scope of the study is “to undertake a feasibility study for a possible Metro line along the city centre to Knocklyon corridor. This study should include an assessment of an indicative route, including indicative stations, and investigate its feasibility from a technical, environmental, transport planning and economic point of view. This study should culminate in the production of a Feasibility Study Report for the possible Metro scheme.
A8 The Case for Continuing MetroLink to South West Dublin, Metro South West, August 2020, paragraph 3.4.. https://documentcloud.adobe.com/link/review?uri=urn:aaid:scds:US:eb90ca39-fff8-4acd-9fe5-c1e92f4fb93e
The brief for the study is attached. In setting out their approach to the study, the design team state that “the purpose of this feasibility study is not to identify the preferred route for a possible Metro line on the corridor nor is it to suggest the preferred design on any section of the alignment considered. Instead, it is to investigate the technical, environmental, demand, and economic feasibility of a Metro along this corridor. Should the proposed Metro be considered feasible and worthy of advancement, a further route option selection and design process would be required to advance specific proposals. A feasibility study is the first step in a process of assessing as to whether a Metro type system should be pursued further. This step precedes the identification of an emerging preferred route from a set of feasible route options, as part of a route slection process.” In relation to your five specific queries, the responses are below.
1 Where is the city end of these hypothetical metro lines situated? Response: The exact termination point has not been prescribed for the study.
2 Would these potential Metro lines involve the MetroLink Tunnel Boring Machine continuing towards Terenure, Rathfarnham, Knocklyon or UCD, Sandyford? Response: The feasibility study is predicated on a possible metro extension being a separate project from MetroLink. It may be that the same Tunnel Boring Machine could be used on such extension, but to include such extension project into MetroLink would delay the commencement of the MetroLink project by a number of years.
3 If so, from which proposed MetroLink station would the TBM proceed towards Terenure or UCD? Response: Refer to responses to queries 1 and 2.
4 Is it within the scope of the study to possibly include the very populous suburban area of Firhouse-Bohernabreena? Response: The exact location of the southern terminal point has not been prescribed for the study,
5 Is it within the scope of the study to possibly improve connectivity by continuing the line to the Square Tallaght and thus connect with the Red Luas? Response: This would be a significant change to the study and would only be considered, if deemed appropriate, as a follow-on study. We trust that the above information is of assistance. Yours sincerely, National Transport Authority”
A8 Our concerns with the Terms of Reference of the feasibility study
A8.1 The whole geographical area between the Red and Green Luas lines should be within scope. We have been informed that the feasibility study would be required to exclude geographical areas which lie outside Corridor E – see paragraph A6(b) above. However, some locations which are east of the Red Luas Line and within the ‘Triangle’ lie outside the E corridor. These areas include:
Bancroft, Tymonville, Balrothery, Greenhills, Cypress, Limekiln, Mountdown, Perrystown, Kimmage, Whitehall Road, Wainsfort, Fortfield, Walkinstown, Crumlin, Lower Kimmage Road, Stannaway Road, Clogher Road, Larkfield, Clareville, Sundrive.
Our analysis shows considerable time savings for commuters throughout the outer suburbs of South West Dublin between the Red and Green Luas lines by cycling or driving to a metro station9.
A8.2 The proposed metro line should be evaluated as a continuation of the MetroLink line to South West Dublin, probably as a Phase 2 of that project, when the Tunnel Boring Machine would continue from the city to South West Dublin. If the metro from South West Dublin to the city is seen as separate from a continuation of MetroLink, the capital cost would be far higher10.
A8.3 The option of continuing MetroLink from St Stephens Green (rather than Beechwood) to South West Dublin should be within scope. When MetroLink comes south to St Stephens Green, it could be directed either to South West Dublin or South East Dublin. Thus, the Terms of Reference should provide that these two options be considered from that location. If MetroLink were to go almost as far as Beechwood (the current NTA proposal) it would still be possible to continue MetroLink to the outer suburbs of South West Dublin by guiding it towards Terenure and beyond; however, important inner suburbs of South West Dublin would have been bypassed due to the Terms of Reference. The figure below shows that if MetroLink must go nearly as far as Beechwood, the opportunity of serving Harolds X and Rathmines would be lost.
9 South West Dublin and the Continuation of MetroLink: Improvement in Commuting Times, Metro South West, September 2020
https://documentcloud.adobe.com/link/review?uri=urn:aaid:scds:US:4013503d-9fe7-4f65-b8d1-a380eafdb0c710 The Case for Continuing MetroLink to South West Dublin, Metro South West, August 2020, paragraph 3,4. https://documentcloud.adobe.com/link/review?uri=urn:aaid:scds:US:eb90ca39-fff8-4acd-9fe5-c1e92f4fb93e
A8.4 The Consultants should be required to analyse Census 2016 Place of Work School and College (POWSCAR) data to establish for all commuters in South West Dublin (the ‘Triangle’):
o Current destination, mode of travel and commuting time;
o The opportunities to walk, cycle or drive to a metro station and use the metro and the connection opportunities (with Cross-city Luas, Luas Green Line, DART, Luas Red Line, Buses, Dublin City Bikes) to complete the journey and the time savings (if any) that would be involved over current arrangements.
A8.5 The Terms of Reference should require the consultants to analyse the potential of the continuation of MetroLink to take traffic from the M50 and the N8111.
A8.6 The Terms of Reference should require the consultants to report on the costs and benefits of Estuary to Sandyford via UCD vs. Estuary to South West Dublin. There is no published Cost-Benefit Analysis for Estuary-Beechwood. If Beechwood is regarded as a possible ‘interim’ end-point for MetroLink (with a station at Charlemont) en route to South East Dublin, the equivalent interim end-point for MetroLink, en route to South West Dublin could be Cathal
11 See South West Dublin and the Continuation of MetroLink: Improvement in Commuting Times, Metro South West, October 2020., paragraphs 7.1-7.4.
Brugha Barracks (with a station at Portobello)12. The Terms of Reference should also require the consultants to compare the costs and benefits of:
Estuary to Charlemont/Beechwood
vs
Estuary to Portobello/Cathal Brugha Barracks.
A8.7 The Terms of Reference should make it clear that the consultants, rather than the NTA, make the final decisions regarding the findings and conclusions in the Feasibility Study Report. This is particularly important as there is an apparent partiality in the NTA regarding continuing MetroLink to South West Dublin13. The consultants should present their draft findings and conclusions to public and community representatives prior to their finalisation by them. Of course, it will remain with the NTA to decide which analysis and proposals they wish to bring forward to the updated Transport Strategy.
A9 Conclusion
A9.1 There are several serious flaws in the Terms of Reference, which have the potential and likelihood of producing unreliable findings and conclusions. It appears to us that the effect of the NTA’s Terms of Reference would be to increase the costs and reduce the benefits of providing a much-needed metro service to South West Dublin.
A9.2 Note that there is no need to delay the MetroLink. Project preparation for MetroLink from Estuary to St Stephens Green is well advanced and should proceed without delay. However, the options for the South of Dublin – from St Stephens Green – have not yet been evaluated and compared with each other. It will take some years before the Tunnel Boring Machine approached St Stephens Green: this affords time to plan the ultimate configuration of MetroLink in the southside.
Metro South West Group
January 2021