Metro South West Group Submission to the Oral hearing of An Bord Pleanála

into the MetroLink proposal from Transport Infrastructure Ireland

MSWG engaged ProfessoR Austin Smyth to review the flawed Feasibility Study by NTA of Metro from City Centre to Knocklyon.  This review was part of our submission and cost 30000€.  We need your help in raising this money. It is an important part of our campaign to get Metro to South WEst Dublin where you live.  It is for you and future generations.  Subscribe here.  https://gofund.me/c61d21c3

Good morning Inspector.  I am Seán Ward and I am joined by our transport expert, Professor Austin Smyth to my immediate left, and by Brendan Heneghan and Pauline Foster to my right.

The Metro South West Group represents over 40 residents’ associations between the Red and Green Luas lines.  This area has a population of 355,000 according to the 2022 Census, but no fixed rail link[1].

We welcome the opportunity to make this presentation to An Bord Pleanála about the southern part of MetroLink.

South West Dublin is characterised by a large population and narrow streets.  The three bus corridors which have been identified by the NTA each have long narrow stretches with room for only one vehicle in each direction.  The contrast with South East Dublin is significant, where there is not only a Coastal DART and Green Luas but also two wide roads with room for four lanes of traffic all the way into the city.

It is a serious concern to us that TII simply failed to address many of our points in its reply to our submission.  This will become clear today in our oral presentation.

The Metro South West Group presents two core propositions to An Bord Pleanála, together with some other observations.

First is that the Southern stump of MetroLink should not be pointed towards Charlemont, Manders Terrace and South East Dublin.  Rather, it should come no further south than St Stephens Green to facilitate possible future extensions, including a future extension to South West Dublin.

Second is that, once the continuation of MetroLink to Sandyford was shelved, TII should have evaluated all the feasible options for a south city terminus, rather than simply going as far as they could along the Green Luas Line.

1          Our first core proposition:

MetroLink should come no further south than St Stephens Green

In support of our contention that the future continuation of MetroLink to the South West should have been examined, we explained in our submission why buses and Luas could not provide the solution for South West Dublin and we highlighted the numerous flaws in a metro feasibility study which was conducted by the NTA.  Accordingly, our submission to An Bord Pleanala included:

  • Firstly, an analysis which showed that buses on their own would fall far short from being able to provide sufficient public transport capacity in South West Dublin due to the narrow road infrastructure[2].
  • Secondly, our submission also included the results of previous studies of Luas On-Street solutions, which reported that the narrow streets in South West Dublin made Luas On-Street impractical[3].

None of this analysis has been disputed by TII in their response to our submission.  Moreover, our analysis is consistent also with that produced by the Dublin Transportation Office in a document entitled A Platform for Change, that was published in 2001.  That report recommended a metro solution for South West Dublin.   Why has all of this analysis been ignored?

In advance of the Transport Strategy for the Greater Dublin Area 2022-2042, the NTA carried out what the Metro South West Group have always considered a very poor quality feasibility study.  In our submission to An Bord Pleanála, we listed several flaws in the NTA/Jacobs Metro to Knocklyon Feasibility Study[4]Remarkably, all of these flaws had a similar effect –  of reducing the estimated Transport User Benefits and the Benefit to Cost Ratio.  None of our critique has been disputed by TII in their response.  A key deficiency is that the NTA failed utterly to consult with any of the local interest groups, despite being fully aware of our desire to participate.  It is clear from other witnesses here that, like the NTA, TII has also failed to engage with communities.

Notwithstanding the flaws in the Feasibility Study, however, TII has persisted with its plan to point the southern stump of MetroLink towards Charlemont, Manders Terrace and South East Dublin.

We believe that the flawed Metro to Knocklyon Feasibility Study has played an important role in diminishing the perceived importance of continuing MetroLink to South West Dublin in the eyes of TII.  It would appear that the dismissal of a metro to South West Dublin has been central to the TII decision not to ‘future proof’ its plans.  To address the indifferent approach of TII towards the possible continuation of MetroLink to South West Dublin, the Metro South West Group felt obliged to ask Professor Austin Smyth to carry out an audit of the Metro to Knocklyon Feasibility Study.  Profesor Smyth has confirmed our concerns about serious flaws in the Feasibility Study.  Professor Austin Smyth will now address the Bord.

It is clear from Profesor Smyth’s report that there is a need to revisit continuing MetroLink to South West Dublin before a decision is made by An Bord Pleanála to allow MetroLink to head towards Charlemont and Manders Terrace and thereby compromise the economic benefits of subsequently continuing MetroLink to South West Dublin.

As Professor Smyth has reported, the optimum route for serving South West Dublin – subject to further evaluation –  would serve Portobello/Rathmines to Tallaght.  However, TII proposes to send MetroLink to Manders Terrace in Ranelagh.

Looking at this map, we say that any sensible metro route to the South West should serve Portobello/Rathmines.  The red ‘X’ on the right is Manders Terrace, below which TII proposes to park the Tunnel Boring Machine.  The red ‘X’ on the left is the clock on the Rathmines Town Hall, in the middle of Rathmines.

If MetroLink goes to Charlemont and the Tunnel Boring Machine is entombed under Manders Terrace, it may well be possible in a Phase 2 project to continue MetroLink to Terenure and beyond.  However, it would not be possible in the future to ‘double back’ and serve Portobello and Rathmines.

The importance?  Portobello and Rathmines are densely populated and they have many attractions, including third level colleges, schools, library, cinemas, swimming pool, etc.   A feasibility study for the conversion of Cathal Brugha Barracks to housing is currently underway.

Duplicating the Luas Green line – by bringing MetroLink to Charlemont – would provide negligible Transport User Benefits, as residents in that area already have the Luas.  Moreover, the Charlemont area has few trip attractors.  However, bypassing Portobello/Rathmines (as is now proposed by TII) would reduce significantly the potential Transport User Benefits of continuing MetroLink to South West Dublin as a Phase 2 project.

Our submission explained how continuing MetroLink to Charlemont and entombing the Tunnel Boring Machine under Manders Terrace would deplete the benefits of the future continuation of MetroLink to South West Dublin[5].  TII has not disputed this analysis.

We wholly reject the contention that a Charlemont terminus keeps all the options for the south city open. Indeed, TII might explain to An Bord Pleanála how connectivity to Portobello, Rathmines or Harold’s Cross can be achieved from Manders Terrace.

2          Our second core proposition:

Once the continuation of MetroLink to Sandyford was shelved, TII should have evaluated all the feasible options for a south city terminus.

It has been argued by persons in their submissions to An Bord Pleanála that a city centre terminus should not be at Charlemont. Various alternative solutions have been proferred:  terminate at O’Connell St North, Tara Street, St Stephen’s Green East, St Stephen’s Green West.

We believe all of these should have been examined in great detail along with the proposition of terminating at Charlemont, a place which is not in the city centre. We believe that the Aarhus Convention applies to this project, and that it requires the assessment of alternatives; this simply has not been done.

We would like to address one particular variant.  In assessing the city centre, particular attention should have been given to the Metro North configuration for the South City terminus.  Call this the Metro North Option.

Deputy Jim O’Callaghan stated, that the Metro North O’Connell Street station Option,

located under O’Connell Bridge, had the significant advantage of having been previously

approved by An Bord Pleanála; accordingly, it deserves – and did deserve prior to the

application for a Railway Order – particular attention and scrutiny, as it would provide an

entry and exit north and south of the quays, on Bachelors Walk and Aston Quay

The Metro North Business Case concluded that the interconnection with DART would involve a ‘a ‘short walk’ of around 200m to the Tara Street DART station. However, this ‘short walk’ would require passengers to cross three busy streets, Westmoreland Street, D’Olier Street and Tara Street.

The following could be a solution. On exiting Tara Street DART station, there could be al METRO signage above an escalator – bringing passengers below street level, to a pedestrian tunnel leading directly to the MetroLink station under O’Connell Bridge.  This 200m pedestrian tunnel could be located under Burgh Quay.  If a 200m walk underground is considered to be too long, travellators could be installed. This pedestrian tunnel could also facilitate switching from both DART and MetroLink to the Luas Green Line on Westmoreland Street and vice versa.

From a passenger perspective, this type of pedestrian underground interconnection is comparable to many interconnections, to be seen in metro systems across Europe.

Furthermore, as proposed under the approved Metro North Scheme, MetroLink would continue to St Stephens Green West, where the station would be adjacent to the Green Luas stop.  An Bord Pleanála has previously given its approval to both the Metro North station at St Stephens Green West and the route to it. The interconnection between MetroLink and the Green Luas stop would be very straightforward at St Stephens Green West.  A short ‘run off’ beyond this MetroLink station for the trains would mark the end of the project – pending a full review of the options for the south of Dublin, including continuing MetroLink to South West Dublin via Portobello/Rathmines.

Again, for passengers, this simple interface between MetroLink and the Green Luas Line would be far superior to the proposed interchange at Charlemont.

Benefits from a passenger perspective

We say that this Metro North Option has many benefits from a passenger perspective.  The substitution of the previously approved and modified Metro North proposal would offer passengers the following six interchange benefits:

  • A good interchange with the Luas Red Line on Abbey Street, with a 100m walk on the surface; this is currently sadly lacking in the present plan and is an obvious defect.
  • Good interchange with DART at Tara Street (c.200m uninterrupted walk underground).
  • Good interchanges with numerous buses along both quays and O’Connell Street – lacking in the current plan.
  • Good interchange with the Green Luas Line on St Stephens Green West.
  • Good interchange with the Green Luas Line on Westmoreland Street and O’Connell Street.
  • Eliminate the cumbersome and convoluted proposed interchange with the Green Luas at Charlemont.

Other benefits

There are many other benefits from the Metro North Option:

  • It eliminates the demolition of apartments etc. and other disruption adjacent to Tara Street.
  • It avoids the disruption and damage at Trinity College.
  • It avoids the disruption along the route from St Stephens Green to Manders Terrace, including around Charlemont.
  • Locating the MetroLink station at St Stephens Green West would facilitate its future integration with DART Underground.

Cost reductions

 The additional capital cost of the proposed 200m pedestrian tunnel under Burgh Quay and a short escape shaft would be far outweighed by:

  • Two fewer stations to be excavated, at Tara Street and Charlemont.
  • Saving on tunnelling, tracks etc. due to reducing the length of MetroLink by c. 1.2kms.
  • The proposed demolition of apartments adjacent to Tara Street, and subsequent compensation, is avoided as are all other landowner issues south of the Liffey.

Conclusion

 This variant of the Metro North proposal would:

  • Be much better for passengers,
  • Be much less costly for the Exchequer,
  • Entail less damage and disruption, and
  • Ensure that the future extension of MetroLink towards South West Dublin is not compromised without proper evaluation.

Accordingly, this variant of the Metro North Option should have been considered and evaluated by TII and the results of this evaluation should have been presented to An Bord Pleanála.

 3          Other issues which have not been addressed adequately by TII’s response      

We outline now two other issues of concern which are contained in our written submission to An Bord Pleanála and which have not been addressed adequately if at all by TII in their response:

  • The precise location of a station in St Stephens Green, and
  • The serious drawbacks with Charlemont.

The adequacy of St Stephens Green as an interchange

Our submission argued that locating a MetroLink station at Tara Street would not preclude having a final terminus at St Stephens Green West.  We disputed the NTA assertion, which was made to the Oireachtas Committee on Transport, that:

“The curves involved in coming through Tara Street Station, which was a critical connection for us, and then getting down to Charlemont would not allow us to go to the other side of St. Stephen’s Green” 

but without giving any measurement for this curvature[6].  In its submission to An Bord Pleanála, TII stated that:

“The eastern side of St. Stephen’s Green was identified as the optimum location for the MetroLink station as it would best serve passenger demand from the retail, commercial and cultural trip attractors in the vicinity. Further, the alignment from Tara Station (where MetroLink interchanges with DART and Irish Rail services) towards its terminus at Charlemont imposes turning constraints on the tunnel boring machine (TBM) that favour the eastern side of St. Stephen’s Green as an appropriate location.”[7]

But, TII has continued to avoid providing their estimate for the radius of this curvature from Tara St to St Stephens Green West.

In our submission, we quoted an eminent railway engineer who estimated that the radius of curvature from the proposed MetroLink station at Tara Street to a possible location on the west side of St Stephens Green would be approximately 500m, which would be completely unremarkable as many metro systems around the world have stretches of tunnel with a radius of curvature much smaller than this.  The BART in San Francisco and the Central Line of the London Underground (between White City and Shepherds Bush) are just two examples[8].

In its response to our submission, TII still has not given An Bord Pleanála its estimate for this radius of curvature.

The drawback of Charlemont as an interchange for passengers

Our submission to An Bord Pleanála went into great detail regarding the unsuitability of Charlemont.  In our view the response of TII is entirely inadequate.  In the short time available to us here, we will deal with only one aspect: the TII proposal that 30 North-bound Luas trams will arrive in Charlemont, but only 24 will proceed to St Stephens Green, due to a lack of road space in Adelaide Road and Harcourt St.

In our submission, we queried the necessity for this arrangement and pointed out that TII had supplied insufficient detail as to how this arrangement could operate safely, if at all.  We set out hypothetical ways in which the turn back of 6 trams per hour could be implemented[9].   In their response, TII still has not provided any detail as to how or where the turn back is proposed to occur.  As well as practical problems with this proposal, there are very serious safety issues, which are set out in our submission.  For example, if 6 in-bound trams per hour simply reverse southwards from Charlemont, they will be departing from the wrong platform.  Many south-bound passengers transferring from MetroLink will surely seek to cross the Luas tracks to access these empty trams.  Similarly, many south-bound Luas passengers on crowded trams may elect to leave the crowded tram at Charlemont and transfer to a reversing and empty south-bound tram.  These are highly dangerous prospects.

Several other contributors to this oral hearing will deal with the TII response to other shortcomings in the its proposal to bring MetroLink to Charlemont.  We will not detain you Inspector, save to say that we support the analysis of these contributors.

I now hand you back to Seán, who will speak about the possible decisions which are open to An Bord Pleanála.

4          Different decisions which are open to An Bord Pleanála

We would finally like to address what you, the Bord, can consider.  There are many different decisions which are open to An Bord Pleanála.  Either grant or refuse a Railway Order for the MetroLink proposal as submitted; or alternatively, approve the project with modifications.  We are absolutely clear that all of this project should proceed largely as proposed on the North side of Dublin.  Therefore, we believe that An Bord Pleanála should neither approve nor reject the MetroLink proposal in its entirety.  Rather, it should approve the project with modifications to the southern end of MetroLink.

Three possible decisions on modifying the southern end of the MetroLink proposal are outlined as a hierarchy, starting with the most flexible and finishing with the least flexible.  All of these would enable early Government approval to commence the project at Estuary.

  1. Grant a Railway Order as far south as Parnell Square East. In the meantime, TII could then review all the options for the southern end of MetroLink, including reaping the benefits of incorporating most of the Metro North Option, which we have alluded to earlier.  Continuing to Portobello/Rathmines or Charlemont could also be examined.
  2. Grant a Railway Order as far south as Tara St. Similarly, TII could then review all the options from Tara St., including terminating at Tara St., and either St Stephens Green, West or East.  Continuing to Portobello/Rathmines or Charlemont could also be examined.
  • Grant a Railway Order as far south as St. Stephens Green East. In the meantime, TII could then review all the options from St Stephens Green East, including terminating at St Stephens Green East, Portobello/Rathmines or Charlemont.

Thank you, Inspector, for your attention.