The following is the submission made by the Terenure Residents' Association to the NTA relating to the latest BusConnects proposals. You are invited to make your own submission before 16 December by email to cbc@busconnects.ie. More information about making a submission can be found at www.busconnects.ie
Introduction
Terenure Residents’ Association (TRA) represents approximately 800 households covering an area that includes much of Terenure Village, surrounding estates, main roads and side roads (Fig 1). We are established over 30 years. This submission will relate to the plan as it affects our area and the households we represent.
Figure 1. Terenure Residents Association Catchment We have engaged with the consultation process for Bus Connects from the outset. Due to the pandemic, we requested a deferment of the submission deadline however this was refused. As many of our members do not have internet access or skills, we also requested that all households receive hard copies of corridor brochures. However, we did not receive any response. We consulted with our members within the constraints of COVID-19 public health guidelines.
The overwhelming response from residents was that these proposals are TOTALLY UNACCEPTABLE AND TOTALLY UNJUSTIFIED.
Our members are seriously affected by proposals for Corridors 10 and 12 directly, and indirectly by Corridor 11. Proposed land acquisition for Corridor 12 affects approximately 55 properties on Rathfarnham Road and Terenure Road East, and 1 property on Rathdown Park. Resultant road widening of up to 4 metres would create a hostile corridor through the community with serious impacts on the amenity, ambiance, environment and heritage, and effective shrinkage of the village footprint. Construction of a second bridge over the Dodder is unnecessary and impacts the Dodder environment.
Rerouting from corridors 10 and 11, together with Bus Gates in Rathmines and other local restrictions, will generate significantly increased traffic levels on Terenure Road West, Terenure Road North, Rathfarnham Road and Bushy Park Road and impede local circulation. No public realm enhancements whatsoever have been proposed for Terenure.
The proposals for Terenure are disproportionate in comparison to other areas. For example, proposals for Merrion Road, Crumlin Road, Lower Kimmage Road, Rathgar Road, Templeogue Village, Mobhi Road and Grattan Crescent all include treatments that conserve the built environment, do not involve road widening, incorporate traffic reduction strategies, and enhance local public realm. The opposite approach is contained in the proposals for Terenure and instead include road widening, significant traffic increases and destruction of the village.
The pandemic restrictions brought many changes including increased opportunities for remote shopping, working and learning. Mobility will always be critical but probably less focused on city centres. We believe these changes have not been adequately reflected in the current proposals.
The Transport Strategy for the Greater Dublin Area (2016) ignored the transport requirements of current and future populations in the south west of Dublin. It is likely that during the upcoming review transport solutions will be reassessed including a metro to the south west. This review will also reflect changing commuter practices and we suggest that Core Bus Corridors project is postponed until the review is complete.
Road Widening
Unsuitable Road Design
TRA rejects proposals to widen Rathfarnham Road and Terenure Road East. Widening the carriageway by up to 4 metres will create a hostile corridor through the heart of our community and constitute an unsuitable road design for a village and residential area. The Department of Housing, Planning and Local Government’s Design Manual for Urban Streets 2019 (DMURS), sets out the modern, sustainable approach to treatment of urban streets. It highlights how urban street design should shift from the conventional traffic conduit approach and should instead be framed by viewing the street as a place with a social function, putting sustainability, multimodal movement, pedestrians and accessibility at the heart of street design. The proposals presented for bus corridors in our area are the complete antithesis of these fundamental principles and only serve to obliterate Terenure.
The NTA did not properly consider or analyse any alternatives to road widening in their background feasibility study and it appears that the outcome was predetermined.
Zoning -Z2
Dublin City Council has zoned much of Terenure as Z2 i.e. with the objective “to protect and/or improve the amenities of residential conservation areas…” The current proposals appear to completely disregard, and are in breach of this objective.
Heritage
The proposed road widening will destroy the irreplaceable historical streetscape, fabric and character of Terenure and will breach the objectives of Dublin City Council Development Plan with regard to our built heritage (Chapter 11, Built Heritage and Culture). On Rathfarnham Road, 30 properties are impacted by road widening, the majority of which date from a century ago. Much of the road still has original boundaries, and the castellated walls of Stringer built houses form part of the distinct architectural heritage of Terenure. Preservation of the setting of Stringer houses in Terenure has previously set precedent in planning decisions. Memorial Hall is also listed as a protected structure.
Terenure Road East has a historical streetscape with houses originating from mid 19thcentury. Current proposals for Terenure Road East will impact 25 properties, many of which are listed on Dublin City Council’s Record of Protected Structures (Nos 61,63, 65, 67, 74,76,78). Destruction of protected curtilage comprising of historical cut stone and old brick walls, pillars and railings is totally unjustified and unacceptable.
Trees /Environment
Terenure is a firmly established area with mature trees and greenery. Road widening will result in extensive loss of greenery and mature trees on both public and private land. Up to 20 mature trees will be lost on Rathfarnham Road and a similar number on Terenure Road East – some of which are centuries old and irreplaceable. Removal of these trees, together with gardens and greenery will have a significant impact on the environment and amenity of the area.
Health and Safety
Widening roads encourages speeding and poses a significant health and safety risk for all road users. Widening roads in Terenure will also shorten driveways, necessitating reversing out onto the carriageway. This will also involve reversing onto cycling lanes in many cases which is extremely hazardous. We suggest that proposals aim for minimum carriageway widths (at most, current widths) to discourage speed and engineer safety of all road users and residents.
Gradient
Road widening on Rathfarnham Road will increase the gradient within many properties (Nos 55, 57,59, 61, 63, 65, 67, 71) and gravely impact safe access and egress. There are also road safety concerns for residents who will be forced to reverse blindly onto the carriageway, particularly onto sloped areas with restricted visibility to oncoming traffic. Residents have not been provided with full details of proposed land acquisition to date and therefore cannot fully assess the resultant impact and breach of building regulations. This is unacceptable.
Pinch Points
The proposed road widening on Rathfarnham Road is unreasonable and unnecessary, particularly as all traffic flow will be restricted in any event at the pinch point of Terenure Cross and to a lesser extent at Rathdown/Rathfarnham Road/Bushy Park Road junction. Similarly, road widening proposals on Terenure Road East are unreasonable as, again, all traffic will be restricted at the same pinch point at Terenure Cross where 4 sets of bus signalling will compete for priority.
Recommendations
Terenure Road East:
We recommend that the Bus Priority Signal on the outbound carriageway is moved eastwards from St Joseph’s Church to the position of the current, underutilised bus priority signal. There is absolutely no need to acquire land and destroy an historic road when the solution is cheap, simple, signal-controlled traffic management.
Rathfarnham Road:
These recommendations relate to Rathfarnham Road between Pearse Bridge and Terenure Cross.
We recommend that current road space is allocated to 3-lane configuration with priority signal management. This solution can provide a high degree of bus priority and incorporates an alternating bus lane design. This layout was proposed by Eamonn Ryan TD, Minister for
Transport, during the first consultation and is similar to schemes proposed for other corridors in the Bus Connects Project e.g. Crumlin Road, Merrion Road.
Inbound
o 1 bus lane and 1 general traffic lane between Dodder Bridge and Rathdown Park. 30KPH speed limit to facilitate sharing of road surface. Alternatively, alternating bus lanes could be used here.
o Maintain proposed arrangement with Bus Priority Signalling between Rathdown Junction and Memorial Hall.
o Move bus lane 50 metres north of Memorial Hall – this balances with commencement of outbound bus lane (alternating bus lanes). Inbound cycle track from Memorial Hall to Terenure Cross.
Outbound
o Move commencement of bus lane 50 metres south (alternating bus lanes). Outbound cycle track from Terenure Cross to Memorial Hall.
o Bus Priority signals as proposed at Memorial Hall to facilitate bus priority. Outbound, from Rathdown Park to Pearse Bridge, provide 1.5 metre cycle track.
Footpaths
o Between Rathdown Park and Terenure Cross, provide 2 metre footpaths with increasing width towards the village area. Between Rathdown and Pearse Bridge, provide for footpath of varying widths of 1.5 -2.00 metres which is in line with current layout.
This is just one possibility. There are numerous other alternatives that could be considered that utilise combinations of reduction of bus and traffic lanes widths, Bus Priority Signalling, Bus Gates, and even One-Way Systems that would achieve a high level of bus priority and avoid land acquisition. However, these have not been properly considered to date by NTA. We propose that a comprehensive assessment is undertaken to identify which combinations would best avoid land acquisition, reduce traffic burden and conserve the environment, and these alternatives are then presented for further non-statutory consultation.
Traffic Redirection and Restrictions
Modelling
Terenure is already substantially impacted by heavy traffic and will be further impacted negatively by these proposals. TRA members are concerned at the inadequacy of traffic modelling to date. It is incomplete, treats corridors as silos and not as interconnected pieces and ultimately prohibits our consultation. We are concerned at the advancement of this project before full data is available. We are also concerned that traffic counts and their positioning did not accurately measure true levels of traffic and due to inaccurate data, the model cannot be relied upon.
Rerouting from Corridors 11 and 10:
Restrictions of traffic in Kimmage (Corridor 11), Templeogue Road (Corridor 10), and Rathmines (Corridor 12), together with reopening of Springfield Avenue, mean that Terenure (accessed via Terenure Road West and Rathfarnham Road) and onwards via Terenure Road North, provides the only direct connection to the city centre from the south west. The NTA has acknowledged that traffic levels will significantly increase on Rathfarnham Road, Bushy Park Road, Terenure Road North and Terenure Road West. This escalation is unacceptable.
24/7 Bus Gate Inbound on Templeogue Road;
This 24/7 Bus Gate is unnecessarily restrictive and has the knock-on effect of overloading alternative routes e.g. Terenure Road West and Rathfarnham Road. It will also make it very difficult for residents living on and off Templeogue Road to access Terenure and beyond. We suggest that the bus gate is time
restricted for morning peak hours only. As there will only be one bus using this road every 5 minutes during rush hour (12 buses maximum), it would appear to be a wasted resource of road space and outside of peak hours, a bus priority signal could be employed instead.
24/7 Right Turn Ban into Rathdown Avenue and Rathdown Park:
A 24/7 ban at these turns severely restricts access for local residents as well as access to Bushy Park. It also places additional pressure on other routes – Rathfarnham Road, Terenure Road West, Bushy Park Road. We recommend that the restrictions are time-plated following assessment of the optimum times.
24/7 Left Turn Ban from Olney Crescent and 24/7 Right Turn Ban from Fergus Road onto Templeogue Road:
These restrictions are unnecessarily harsh for residents. Removal of these restriction would only generate a small number of car movements therefore we recommend moving the bus gate westwards to allow residents of Olney Crescent/Grove and Fergus Road to access Terenure Village without an excessively circuitous journey. A second option is to apply restrictions for morning peak hours only.
24/7 Left Turn Ban onto Terenure Road East from Greenmount Road
A 24/7 ban is unnecessary and severely restricts Greenmount residents accessing the village area. Removing these restrictions would only generate a small number of car movements therefore we recommend removing this ban, or time-plating it for peak evening hours only.
Environmental Considerations:
Increased traffic with increased exposure and proximity to air pollutants has serious implications for the health of residents. There have been no environmental impact studies performed along impacted routes in Terenure to measure either noise or air quality despite requests from residents. It is very disturbing that proposals have progressed to this extent without the proper environmental input and controls.
Cycling Arrangements
We welcome improved cycle facilities and the introduction of ‘Quiet Streets’ which will have low traffic levels and encourage safe sharing of road space.
We welcome the provision of a cycle track along Terenure Road North with the proviso that adequate loading, disabled and car parking is provided for, and greenery, pavement widths and public realm is improved.
We note that the alternate Rathfarnham cycle route may not appeal to all cyclists and some may prefer to take a more direct route. We therefore recommend that Rathfarnham Road is designated a 30KPH zone to allow for safer sharing of road space.
New Dodder Cycle Bridge
We are concerned at the scale, impact and cost of the new Dodder cycle bridge opening into the cul de sac in Rathdown Park. This structure is unnecessary as it duplicates an existing cycle bridge some 400 metres away. Due to the elevation, it will be overwhelming in size, require extensive ramping and will impact significantly on the Dodder amenity, environment and ecology. Land acquisition significantly impacts one property. We suggest that plans for this bridge are abandoned and acceptable alternatives considered.
Village Area
Public Realm enhancement have been proposed for many other areas as part of the Core Bus Corridor project. e.g. Kimmage, Ballsbridge, Rathmines, Stoneybatter. However, no public realm or indeed any improvements have been proposed for Terenure Village. We therefore recommend that the NTA immediately engage with Dublin City Council, TRA and local business and community groups to generate a Village Improvement Plan. This plan should function as a critical pillar of this transport project.
We recommend that there is provision for largescale enhancement of the central village area. We recommend introducing a textured, coloured, paved road surface with an appealing aesthetic that would denote the village area, discourage speeding, offer definition to the commercial, social and community centres and give a sense of ‘place’. A similar scheme is to be found along George’s Street in Dun Laoghaire.
We recommend maximising footpath widths throughout the central village area. We note that there is an effective reduction of pavement width around the southern end on Terenure Road North due to allocation to road width and bicycle track. As this is one of the busiest village areas, we recommend increasing pavement widths and adjusting the bicycle track position and road dimensions accordingly. We recommend developing significant public realm improvements and active greening and tree planting the length of Terenure Road North as this road forms a significant part of the village area.
The increased pavement widths proposed along a short section of the western end of Terenure Road East will merely act as a safety buffer on this hostile, heavily trafficked section. For health and safety, it is essential that additional protective bollards are erected along this section to prevent vehicular traffic deliberately or accidently mounting the pavement.
Terenure has recently benefited from erection of heritage style street lighting. It is important that should any of these be relocated, they are replaced with identical structures.
Car parking:
Removal of a significant number of on-street designated car parking spaces as well as loss of informal parking outside of bus lane hours will be a critical loss to local business. Indeed, this is a ridiculous situation where Terenure Village has significantly less public parking provided than Templeogue, an urban village a fraction the size of Terenure. No alternative car parking has been sought by the NTA to date and we suggest that they proactively secure a site for parking within the village area. All options must be explored — surface, multi storey, or underground —and should be integrated with the Village Improvement Plan. Additionally, there are no obvious allocations for disabled parking or loading bays on the plans and we require further detail and information.
Cycle parking
There are no provisions for bicycle stands/racks in these proposals. We suggest an appropriate location is incorporated into the proposals and into the Village Improvement Plan.
Pedestrian crossings
We welcome the addition of signal-controlled crossings at Terenure Cross — on Terenure Road East and Rathfarnham Road crossings. We welcome the improved crossing positionings and reduction to single phase.
Speed Limit Reduction
In addition to the speed limit reduction proposed for Templeogue Road, we also recommend extending the 30KPH zone south to Pearse Bridge, north to Ashdale Road/Terenure Road North Junction, east to the entire length of Terenure Road East and west to Greenlea Road. Reduction of speed limits would improve safety and reduce noise pollution.
Bus Stop Locations
Residents are concerned at the removal of bus stops at Memorial Hall and on either side of Templeogue Road at the Library. This represents a significant inconvenience for many.
Summary:
o We reject all proposals for road widening and land acquisition to create a hostile corridor through Terenure.
o We reject proposed traffic management plans and diversions that are designed to significantly increase traffic levels through our streets, prioritising through traffic over residents.
o We recommend abandonment of plans for a second Dodder cycle bridge and consideration of acceptable alternatives.
o We recommend the generation of a Village Improvement Plan with input from all relevant stakeholders. This should form one of the essential pillars of the Bus Connects project in Terenure.
o We recommend the NTA prepare revised proposals that work with current road space as well as revised traffic management plans, and engage in further in-depth consultation with all residents and impacted groups.
o We recommend deferment of the corridor project until review of Transport Strategy is competed, particularly in view of changing commuting and working practices.
