Thank you for the opportunity to make a submission on this active travel scheme. This submission represents my own views and not those of my employer or any other organisation.

I’d like to generally welcome this scheme which seeks to achieve a more balanced allocation of road space. The project report correctly identifies the current car-dominated road layout in the village as dating from when this road through Birdhill formed part of the N7. I am making this submission from the perspective of someone who has walked, cycled and driven through Birdhill on many occasions.I have a few specific comments on aspects of the scheme below.

Removal of left and right turning lanes

I welcome the removal of the left and right turning lanes in the village. The level of car traffic through Birdhill nowadays is extremely low and the removal of the turning lanes is entirely appropriate and in line with recommendations in the Design Manual for Urban Roads and Streets (DMURS).

Continuous footpaths and cycle tracks with bevelled kerbs

I particularly welcome the design elements of continuous footpaths and bevelled kerbs in this scheme. This design approach is only starting to be used in Dublin and it is welcome that Tipperary is at the forefront of modern urban road design: I hope this will be a benchmark for future active travel schemes in the county. The continuous footpaths will particularly make it more comfortable for wheelchair users, people pushing buggies and prams and others who will benefit from flat walking and wheeling surfaces.

In the detailed design stage it is important that the footpath and cycle track are not slightly dipped at entrances – the bevelled kerb shown on the design drawings will be enough to facilitate the drop in levels.

Moving of bus shelters

The moving of the bus stops closer to the junction is to be welcomed: it will improve the interchange between the 323/72 bus and the train station.

R445/R504/R466 junction

While the layout of the junction between the R445 and R504/R466 roads is much improved in this design, I have some concern about traffic turning on to the R504 and R466: specifically the lack of passive traffic calming for vehicles travelling in these directions. Two elements that could be considered at detailed design stage are the partial set back of the cycle lane and footpath across the R504 and R466 that would allow provision of a ramp so that the cycle lane and footpath would be raised on both sides crossing the R504 and R566; and the second is the tightening of the corner radius to slow down cars turning left off the R445 to the R504 and R566. Every effort should be made to slow vehicle traffic down as much as possible at this junction as it is the site of many conflicting movements and these passive measures would improve safety at the junction.

Crossing point for cyclists travelling from Ballina towards Birdhill

The scheme design requires cyclists coming from the Ballina direction to cross over the R445 to continue westwards. This crossing is in a 60 km/h zone and consideration should be made to extending the 50km/h zone to before this crossing point, and making sure that the crossing is raised with a significantly high and steep ramp that will provide some passive protection for vulnerable road users. It could be argued that the crossing could be moved further away from the roundabout as a safety measure.

Tidy Towns group collaboration

As Birdhill has a significantly successful Tidy Towns group, I wonder if greater provision could be made in the scheme for planting and other amenities that could be managed by the Tidy Towns group and whose feedback might be sought at design stage to support the vision of the Tidy Towns group.

Link to Birdhill Active Travel Scheme

Thank you for the opportunity to make a submission on this development. This submission is made in a personal capacity and does not represent the views of any organisation, including my employer.

It is suggested that further information is needed to adequately assess this application, particularly in relation to traffic and climate.

Page 7-49 in the Traffic and Transport chapter notes that the traffic model used is a fixed demand type, that is “additional trips or changes in trips (demand responses) that might be generated by a particular scheme are not considered. The only response considered by standard traffic models is change of route within the modelled area”.

Section 7.4.3 in the EIAR does attempt to apply a primitive variable demand model by applying “sensitivity parameters” derived from UK WEBTAG guidance. The resulting 1.5% modelled increased demand is assessed as being “at a very low level” and is not considered further.

The phenomenon of induced demand from new road schemes is well-established. A meta-analysis of the international evidence for induced demand was carried out for the UK Department of Transport in 2018 to update the concepts and methods for the treatment of induced traffic used in WEBTAG [1] found significant induced demand effects from new road schemes in various countries around the world.

In Ireland, a study commissioned by the National Roads Authority [2] to detail the inputs, outputs and operation of the Variable Demand model in the National Transport Model examined the evidence for induced demand from new road schemes to calibrate its model (note: there is no evidence in the EIAR that the National Transport Model was used to assess the impact of the Slane by-pass scheme). It found that the actual induced demand was 35% for the M1 Airport to Balbriggan scheme and 32% for the M4 Kinnegad to Galway scheme. In addition, the M4 Kinnegad to Galway scheme was found to have reduced passenger demand for rail services on the corridor by 20-30%. All of these effects were adequately modelled by the National Transport Model in the report.

It is important that the Board has adequate evidence of the likely impact of the proposed scheme in order to make a decision on the scheme. The EIAR presented assumes that the proposed scheme will have no effect on traffic volumes, or the mode share of public transport, compared with a do-minimum scenario.

The OECD, in its 2022 report Redesigning Ireland’s Transport for Net Zero [3], noted that the large public investment in the road network in Ireland has the effect that “the attractiveness of driving…compared to other modes increases. This results in fewer users of shared, micro and active modes…a higher number of cars in the region…and longer average distance driven by car per day…all of which increases traffic volume…congestion and travel time by car”. It further noted that the pattern of road building, combined with spatial planning approaches has resulted in dispersed land use, with population growth in car-dependent outer urban and suburban areas as inner-city populations declined. The report concludes that “both these dynamics (induced car demand and urban sprawl) erode the attractiveness of sustainable modes”.

It is not sufficient for the well-understood effects of induced demand to be ignored, and if induced demand effects were adequately modelled, it is possible that a different scheme design would have been chosen: section 3.3.6 does not account for the increased induced demand that a Type 2 carriageway would cause, because the fixed demand modelling assumes that demand will be the same in all cases.

I would like to suggest that the Applicant is requested for further information to adequately model the induced demand that will be caused by this scheme. Such modelling should be calibrated against actual induced demand that has been caused by the construction of previous road schemes in the State. If induced demand effects are successfully modelled, it would require many sections of the EIAR to be updated, including the chapter on climate.

I would suggest that significant induced demand effects could be mitigated by a lower capacity and design speed, for example a single rather than a dual carriageway with a lower speed limit.

Thank you for considering my submission.

[1] https://www.gov.uk/government/publications/induced-travel-demand-an-evidence-review 
[2] https://www.tii.ie/tii-library/strategic-planning/project-appraisal-guidelines/Unit-20.8.pdf
[3] https://www.oecd.org/ireland/redesigning-ireland-s-transport-for-net-zero-b798a4c1-en.htm

Link to scheme page on the An Bord Pleanála website

I would like to make a submission on the proposed Section 38 scheme at Abbey Street, Nenagh. This submission is made in a personal capacity.

I’d like to welcome the proposal to restrict vehicles from this section of Abbey Street. I have had a number of close calls with cars while walking through the arch, especially coming out of the laneway onto Kenyon Street. This measure will have a positive impact on the town centre, and will make Abbey St a nicer place to walk and to shop. Vehicles will still have access to Abbey St from the Martyr’s Road side, but this measure will stop the street being used as a shortcut for private vehicles.

I would like to make one suggestion, that consideration be made to adding a supplementary P050 EXCEPT CYCLISTS plate to the RUS 011 NO STRAIGHT AHEAD sign so that people on bikes would be legally permitted to use the archway, as per the Traffic Signs Manual Chapter 5 pages 17 and 50. An alternative sign could be RUS 058 (Ch 5 p 41).

The reason I make this suggestion is that I take the 7 year-old swimming every Saturday morning. Sometimes we walk but sometimes we cycle, and it would be helpful to be able to go through from Kenyon street on the bike on the way to the leisure centre. Our alternative route via Pearse St is quite dangerous for a young child on a bike.

Link to scheme consultation page

Thank you for the opportunity to make a submission on this scheme, which is made in a personal capacity. The scope of this submission is limited to the footpath upgrades proposed as part of this scheme.

The Design Manual for Urban Roads and Streets (DMURS) is the principal design manual for urban roads and streets and is mandatory when providing new or modifying existing urban roads and streets within the 60 km/h urban speed limit zone.

DMURS states that the absolute minimum for footpath width is 1.8m, and that wider footpaths should be provided where pedestrian activity is higher (for example 3.0m for areas of moderate to high pedestrian activity.)

It is unacceptable that footpath widths of less than 1.0m are proposed on Emmet Place and Silver Street as part of this scheme, as is illustrated by the drawing extracts below:

This will result in an unsafe environment for users of the street, especially for people using wheelchairs, mobility aids and buggies.

There is no need for such substandard and unsafe footpath widths. This Part 8 scheme could easily be amended to reallocate road space away from vehicles to provide footpath widths that are safe and conform to the relevant design standards. 

No DMURS quality audit was published for either this Part 8 scheme or the earlier Section 38 scheme introducing a two-lane one-way system for motorised traffic. It should be noted that such an audit is mandated for works on public roads (ref: Department of Transport National (Infrastructure) Guidelines and Standards Group, Circular 2 of 2022 and Circular 3 of 2022).

It is also unfortunate that in the public consultation report for the Section 38 scheme it was noted that road space reallocation would be considered as part of this public realm scheme. I cannot see any places where this reallocation of space has been made, or even where it was considered. The result of the two schemes, if implemented, will be streets dominated by the private car, and unsafe for other users of the street.

Nenagh deserves better than two lanes for cars and footpaths narrower than one metre, where you will struggle to walk side by side. This is contrary to DMURS, the national Sustainable Mobility Policy, and the Tipperary County Development Plan, which states “10G: Through Council own development, such as public realm upgrading and regeneration programmes, seek to encourage the following principles; (a) Implement improvements to facilitate pedestrians and cyclists and to improve access for people with mobility needs”.

Welcome for the scheme

I would like to welcome the proposal to bring the Rialto cinema back into use. The planned refurbishment is sensitive to the building’s heritage and the enterprise centre will be a fantastic addition to Nenagh.

Road safety audit

The road safety audit is inadequate. The audit does not take into account the place functions of the streets adjacent to the development, and represents a vehicle-centric approach which is inappropriate for a development of this kind in an urban centre like Nenagh. It is unfortunate that a DMURS quality audit was not undertaken.

Poor frontage on to Emmet Place

There is poor frontage onto Emmet Place with just an entrance to the car park and a long wall.  it is unfortunate that this project does not do more to activate the street. Further opening up of the Emmet Street side could enhance the environment of the street, especially if combined with pedestrian permeability measures outlined below.

Car parking

The application outlines the multitude of off-street car parking spaces within a few minutes’ walk of the site and it is unfortunate that a decision was made to provide private car parking spaces within the footprint of the site. This compromises the Emmet Place side of the scheme. One or two disabled parking spaces and a loading bay should have been sufficient for a development of this type in this location.

Opportunity missed to provide permeability through the site

There is a natural desire line between St. Mary’s Secondary School and Kenyon Street that runs through the site as an alternative to walking through Hanly’s Place. Although there is a pinch point at the corner of the building with an adjacent property, it should still be possible to open up the site so that it is permeable for pedestrians coming from Ashe Road to Emmet Place.

Thank you for taking the time to consider this submission, which is made in a personal capacity.

Link to Part 8 application

Our greenhouse gas emissions in Tipperary are staggeringly high. We have higher per capita emissions than any other country in the EU, higher than China, Russia and the USA. If Tipperary were a country, our per capita emissions would be one of the highest in the world, ranking alongside the worst-polluting petrostates:

Country	Per capita emissions (tonnes/person 2018)
Kuwait	31.34
United Arab Emirates	29.03
Kazakhstan	23.33
Co. Tipperary	22.09
Saudi Arabia	21.81
USA	18.88
Estonia (highest in EU)	17.36
Russia	15.96
Ireland	11.26
Germany	9.98
China	8.74
EU-27	8.19
Africa (whole continent)	3.62

Country data from Our World in Data and includes LULUCF. Co. Tipperary per capita emissions derived by dividing the total emissions (3 703 400 tonnes) by the preliminary population for 2022 noted in the draft Climate Action Plan (167 661).

The publishing of total emissions for County Tipperary in the draft Climate Action Plan is welcome, however it is difficult to understand the figure of total emissions of 3,703.4 kt of CO₂eq (the unit of kilotonnes is missing from page 32) without providing some context. I would like to suggest that some more context is given in the final version of the plan, possibly with international comparisons like in the table above, illustrating that if the rest of the world was as polluting as our county, the world would have a few short decades left before most of it became inhabitable.

Agriculture

The 7,404 farms in Co. Tipperary (CSO, 2022) are the source of 1,849 kilotonnes of CO₂eq emissions. 90% of Irish beef and dairy produce is exported. I would like to suggest that actions be developed with the Local Enterprise Office and other agencies to support greater value-added processes in Tipperary, perhaps following the success of products such as Cashel Blue cheese, to encourage a shift away from exporting internationally-traded commodity products such as Skimmed Milk Powder, and towards a more premium product that can potentially provide a better return to farmers. There are currently over 100 organic farms in Tipperary (Farmers Journal) and I would like to suggest that a market development programme for organic produce be developed in the county to help existing organic farmers to find a market for their produce which may also encourage conventional farms to convert to organic (and which would result in a reduction in agriculture emissions due to lower stocking rates on organic farms).

Transport

Tipperary County Council is the roads authority for all public non-national roads in the county, in addition all the permissions for the recent expansions of the national road network in the county – for example the M7, M8, N24 and N52 – were applied for by Tipperary County Council and its predecessors, despite being funded by Transport Infrastructure Ireland and predecessor agencies.

The Environmental Impact Statements for the major road schemes in the county presented by the Council all showed a ‘steady state’ volume of traffic, the new roads schemes, many of which bypassed towns, were predicted to simply divert traffic away from the towns with little or no net increase in traffic. Unfortunately this did not turn out to be the case and volumes have significantly increased on the road network, especially on motorways, far in excess of national roads elsewhere in the country that did not see improvements. This has been a contributor to the rise in transport emissions in Tipperary.

I would like to suggest that an action be added to the Climate Action Plan that Tipperary County Council perform a retrospective evaluation of all major road schemes developed in the name of the council over the past few decades, including the road schemes mentioned above, to evaluate the climate impact of these schemes (by comparing the increase in traffic volumes along the corridor of the schemes with other national roads elsewhere in the country that were unimproved), which appears to have been significantly underestimated in the Environmental Impact Statements produced by Tipperary County Council in ‘support’ of the schemes. Such a retrospective evaluation could improve future Environmental Impact Statements and better inform the development of future road programmes. An example of such an evaluation on the carbon impact of new road schemes in the UK is available from Transport for Quality of Life (PDF).

I would also like to suggest that a fresh analysis of the induced demand potential of all road schemes proposed in the county development plan and local area plans be performed to evaluate the negative climate impact of facilitating more traffic in the county, preferably assisted by the analysis suggested above. Recent urban traffic schemes, for example the recent Section 38 permission obtained by Tipperary County Council to expand capacity for private cars in the centre of Nenagh with a two-lane one-way system was not published with any analysis of traffic or emissions impact, and suggestions in the public consultation process to change the scheme to allocate space for more sustainable transport modes such as walking and cycling were not taken up.

Finally, I would like to suggest an amendment to the action on transport hubs: to change the wording from Support the delivery of an ‘Integrated Transport Hub’ in the Key Towns of Clonmel, Nenagh and Thurles to incorporate and support multi-modal services… to Support the delivery of an ‘Integrated Transport Hub’ in the Key Towns of Clonmel, Nenagh and Thurles to incorporate and support multi-modal services while supporting the maintaining of the existing public transport stops in the centre of these towns… in order to make sure that current and prospective public transport users are not inconvenienced by the moving of bus stops to more peripheral locations to facilitate private car traffic, as has recently been proposed in Nenagh.

While I think there are other areas worthy of inclusion in the Climate Action Plan, in particular around settlement patterns and one-off housing and the greater facilitation of solar and onshore wind, the main point I would like to make is that there is a lack of urgency in the draft. This year the World Health Organisation said that Life-threatening hunger caused by climate shocks, violent insecurity and disease in the Horn of Africa, have left nearly 130,000 people “looking death in the eyes” and nearly 50 million facing crisis levels of food insecurity. We need to acknowledge that Tipperary is contributing to the problem of climate change far in excess of Irish, European and global norms and we need to take real action to reverse some of our mistakes and to take responsibility as a wealthy and prosperous county to right some of the wrongs we are inflicting on the world.

Thank you for the opportunity to make a submission on the draft climate action plan. This submission is made on a personal basis and does not represent the views of any other organisation, including my employer.

Local Area Plan

I have a general comment about the pattern of development of Nenagh, and that is that the focus of development in Nenagh appears to be at the edge of the town. Recent housing developments in Drummin Village and the Fiserv building on the Limerick Road are two examples of recent developments that, while welcome from the perspective of housing and employment respectively, are located quite a distance from the town centre and are designed to be primarily accessed by private car. The traditional layout of Nenagh is compact and sustainable, but these recent developments have served to undermine this. I worry that the pattern of zoned lands in the Local Area Plan will continue to support sprawl at the edge of town, especially as Greenfield development will be cheaper for property developers than building on any of the brownfield sites identified in the Local Area Plan.

A recent local newspaper article about the proposed digital hub on the Rialto cinema site quoted a local authority official saying “It had been planned for Stereame but that had been shot down by the Department as it was not town centre”. The bias towards out-of-town development has worrying implications for the future sustainability of the town and goes against many national, regional and county-level policies on consolidating our town centres and the principle of compact growth. I do not know what specific measure in the Local Area Plan could help counteract this bias, but perhaps it would be helpful to engage with local authority officials who view locations like Stereame as suitable for digital hubs and software development companies, to see what guidance would encourage them to site (and encourage others to site) such developments in the town centre. Certainly the descriptions of the Stereame and Lisbunny sites in the Local Area Plan leave the reader with the impression that the development of large-scale employment is not encouraged within the town centre (or in locations where employees could comfortably walk into town on their lunch break), notwithstanding the principle stated that new offices should have easy employee access.

A lot of land in Nenagh is given over to car parking, both on-street and off-street. I would like to propose a specific opportunity site in the Kenyon St car park. The car park already has recently-built commercial units at its far end, and replacing the car parking with a mixed housing/employment development, with additional permeability for active travel towards Silver St and Stafford St, would be a positive development for the town. Any need for more parking displaced by the closure of Kenyon St car park could be accommodate on sites further out of town.

Local Transport Plan

It is difficult to see the rationale for the “Nenagh Traffic Management Plan” which was submitted as a Section 38 development four months before the Local Transport Plan was released. No traffic modelling, road safety audit, or any other narrative document was made available with this traffic management plan, it was just a set of drawings. The Local Transport Plan just seems to accept the introduction of this plan, accompanied by a statement “Over the longer term horizon of the LTP, further enhancements to the proposed one-way system may be feasible through reallocation of road space for public realm upgrades and further provision for active modes”, which is a relatively weak commitment compared to other measures proposed in the plan.

The problem with this traffic management plan is that it creates a severance in the middle of Nenagh for active travel users. Some footpaths covered by this management plan will be under the DMURS minimum of 1.8m in width, and cyclists will have to navigate dangerous two-lane one-way streets. I live on Sarsfield Street, we have two boys aged 7 and 10. The new traffic management plan will negatively impact on our ability to encourage independent mobility for these kids. For example, I take the 7 year-old to swimming lessons in the council swimming pool by the town park. We were just getting to the stage where we were able to cycle on the road for part of the journey to the pool. I don’t think it will be safe for me to cycle with him in the new layout: we would be forced to try and navigate two lanes of cars going the same direction, with no facilities at all to help him make his journey through the town centre. Equally I was hoping that it would be possible for the boys to cycle themselves to the train station in the future: that journey will be made much less safe as a result of the traffic management plan, and may prevent them making this journey at all.

Furthermore, the aim of the Nenagh Traffic Management Plan is stated in the Transport Plan to “reduce congestion” which is another way of saying “increase capacity for the private car”. I don’t believe this is compatible with the national, regional and county-level commitments to reduce emissions and reduce dependency on the private car.

I would like to suggest a new measure to try and ensure that the redesign of this facility is encouraged as a priority:

ATx: Priority reallocation of road space on the new Nenagh Traffic Management Plan towards active modes to provide safe segregated routes for active travel users and to mitigate against the increased capacity for private cars being introduced in the town centre.

Active travel network

Aside from the severance in the town centre caused by the Nenagh Traffic Management Plan, I would like to welcome the active travel network proposed. If implemented over the period of the plan it would have a positive effect on the town, especially for the 1 in 5 households in Nenagh who do not own a car (Census 2016). Some of the visualisations in the Plan are excellent with bevelled entrance kerbs and no height change for pedestrians and cyclists crossing side entrances. It might be worth incorporating these design elements as a specific action for any new measures built, to avoid the usual ‘dipping’ of footpaths at side entrances and severance of cycle facilities at junctions.

Public transport network

The transport plan does not propose to remove the town centre bus stops and I would like to welcome this measure. The narrative in local media from council meetings quoting local authority officials that I have read emphasised that buses were getting in the way of cars. I never saw any discussion reported on how more people can be encouraged to use public transport. I have reservations about the proposed mobility hub, in light of the above, but as long as buses are stopping in the middle of town where services are accessible to more people, some additional rail/bus integration may be helpful.

Roads

The proposed roads do not seem to meet the criteria for new roads outlined in the local transport plan. I could not see any specific mitigating measures being proposed that would counteract the induced demand for more traffic as a result of such schemes. I would support the HGV ban, although I do not see the building of additional roads as necessary to facilitate this ban.