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Submission to Bus Connects Public Consultation

16th December 2020


Submission to Bus Connects Public Consultation



By way of general comment, I wish to make these overall points.

  • The proposals will, if implemented, very severely impact non-bus traffic in the form of lorries, vans, cars and motorcycles.


  • If implemented, there will be wide-spread and very severe peak-time non-bus traffic congestion on major traffic arteries.


  • This severe congestion will be seriously damaging to Dubliners for whom improved bus transport does not meet their needs.


  • No proper research is evident in the published proposals of the collateral damage to non-bus transportation


  • Specifically, in relation to the route 12 proposals, it makes no sense to have a single lane one-way traffic regime for Rathgar Road, funnelling into the narrow squeeze point at the junction of Lower Rathmines Road and Castlewood Avenue.


  • I do not accept that the transportation needs of Dublin city require or justify the Route 12 proposals.


  • Likewise, the suggestion that most Rathgar non-bus traffic to the city centre be diverted onto Castlewood Avenue/Belgrave Square/Charleston Road is a recipe for complete congestion and chaos


  • The envisaged reduction of traffic to two single lanes with no filter left lane at the Ranelagh/Chelmsford Road junction is utterly counter productive and will cause massive delays for the 18 bus route (an important east-west bus connection)


  • The proposed traffic gate at Lower Rathmines Road is wholly unjustified and unnecessary


I attach a digested version of public and resident’s association reaction to the Route 12 and other Bus Connects proposals and I endorse these observations.





Senator Michael Mc Dowell


Rathgar Residents Association has made the following observations

  • The significant proposed increase in the number of buses travelling through Rathgar.
  • Removal of the main Village bus stop at Christ Church will reduce access to the Village.
  • That Bus Connects plans are based on data that is now well out of date, as such data does not account for the huge changes brought about by Covid-19.
  • The impact of the Rathgar changes will cause massive changes for residents on smaller roads which will see greatly increased traffic.
  • There has been no environmental impact assessment of the increased frequency of buses.
  • That Rathgar Road is to be made one-way inwards towards Rathmines for cars, meaning all outward car traffic will be redirected along the Upper Rathmines Road and Palmerston Road. It is proposed that traffic will turn right at the top of Palmerston Road and Upper Rathmines Road onto Highfield Road, and that no assessment of the impact on those roads has been carried out.
  • Terenure Road East and Rathgar Road will be greatly impacted by the Core Bus Corridor 12 while Highfield Road will be greatly impact by the proposed Orbital Bus Route.
  • The NTA is proposing to remove the main Village bus stop at Christ Church – the inward bus stop on Terenure Road East will move closer to the 5-road junction and will add to congestion by being positioned directly across the outgoing bus stop.
  • The widening of Terenure Road East will result in a permanent loss of the historic fabric of the village due to the homes there still being under threat of CPO.
  • They maintain that the NTA should perform traffic counts and junction analysis on all roads in the area, and that the combined impact of BusConnects and the increased bus frequency must be considered and will be detrimental to the community.


  • Residents of Rathmines Road Upper have concerns that replacing the 140 bus (with terminus in Palmerston Park) with the No. 14 from Dundrum would mean seating is unlikely to be available when it reaches Rathmines Road Upper. This area is home to many elderly people, as well as many students from Trinity College Dublin who live in the complex on Dartry Road. The 140 bus is essential for these people to get further into Rathmines and the city.


  • Business owners in Rathmines have highlighted that proposed cycle lanes will block kerbside road access to shopfronts for loading and unloading. It used to be the case that vehicles could deliver between 10am – 12pm weekdays but the proposed cycleway will be 24/7, rendering deliveries impossible as delivery drivers must cross two lanes of traffic and park illegally to gain access.



The Ranelagh Village Improvement Group has a number of concerns:


  • That new and extended planning and review processes are needed due to the project being based on outmoded information bases and conceptual frameworks.
  • That further traffic counts are needed in the light of changed work patterns.
  • That plans arising from the 2019 consultation report envisage ‘City Bound Buses’ 86, 87 and 88 travelling along Sandford Road and through Ranelagh Village to Mountjoy Square, while S2 Orbital buses will travel via Castlewood Avenue and Charleston Road through the Triangle, crossing the village and on to Chelmsford Road and Appian Way. These proposals are not feasible or practical given the already pressurised nature of this urban environment.
  • That a massive increase in traffic passing through Ranelagh will arise from the proposals that all non-bus and taxi traffic that currently travels into and out of the city centre via Lower Rathmines Road will be diverted along Castlewood Avenue and Charleston Road. (alongside the proposed S2 Orbital bus) join Ranelagh Village and Ranelagh Road in order to enter and exit the city. This is as a result of a proposed ‘Bus Gate’ on Lower Rathmines Road.


 A number of residents of Rathdown Park are strongly opposed to the revised route


  • This incorporates a proposal to put a cycleway down their cul-de-sac and requires the compulsory acquisition of part of a garden in Rathdown Park and the construction of a bridge from Dodder Park Road over the Dodder. This bridge is a second bridge to be constructed on this stretch of the Dodder resulting in unnecessary duplication of infrastructure by the NTA


Representatives of the Terenure West Residents Association have made the following observations which merit due regard:


In relation to the overall process it is accepted that there have been issues on: 

  • Consultation - Poor information, detail impacting community not easily accessible, no right of reply
  • Flawed Traffic Modelling - deficiencies in studies. unstable and incomplete data
  • The designs chosen for the corridors e.g. our area has been unfairly impacted by 3 corridors  

There are significant impacts on our community 

  • Kimmage Corridor -  Bus gate on Lower Kimmage Road at Poddle Park severing the community from Sundrive services, Schools (Scoil Mologa, HS National, school at Greyhound stadium), church and cemetery and creation of rat runs for people trying to avoid Wainsfort  
  • Tallaght Corridor - Bus gate will cause traffic diversions through Fortfield down to Terenure West/KCR, access to Bushy for recreational purposes  
  • Rathfarnham Corridor - Effect of additional traffic sequencing on Terenure Road West. 

Note that the Garda station is located on Terenure Road West, these proposals will  have a serious impact on response times


Mr. Brendan Heneghan who represents resident’s groups in Terenure and Rathgar has made submissions on various Bus Connects routes. A summary of the issues of concern as expressed at a recent meeting with elected Oireachtas members is below:


We are all concerned about

  • The inadequate period for consultation to expire 16 December. Most of this was during a "lockdown". There are many people who are as yet unaware of major changes proposed for our area. This particularly affects people who are not users of technology. We would all plead that this be extended.
  • Inadequate traffic modelling. While this has been promised many times over, all that is available are models for the AM peak and these are done "silo style" corridor by corridor. Models for other times of the day need to be produced urgently and the combined effect of 4 local corridors needs to be assessed.
  • A local plan which disimproves cycling facilities (by removing existing lanes) and pedestrian facilities (by narrowing pavements).
  • We are all in favour of measures which improve public transport, cycling and pedestrian facilities and reduces the use of private cars; however, this plan does not do this.


Terenure West issues

  • Terenure West is wedged between the Tallaght-Terenure corridor and the KCR where the Kimmage corridor starts. There are bus gates close by. We are concerned that traffic trying to avoid the bus gates will come into the residential roads in substantial numbers. While NTA at a meeting in 2019 promised to address this without inconvenience to local residents, they have not done so
  • Terenure West people naturally gravitate to services on the Kimmage corridor such as shopping and schools. The bus gate proposed close to the KCR will make these difficult to access by car; car access is necessary for certain types of persons and trips. We believe that the time of operation of bus gates should be the AM peak only.


Rathgar issues

  • The scheme has major environmental impacts on Rathgar, on Terenure Road East and Rathgar Road in particular. There is great concern that no environmental assessment has been undertaken to date. Particular concerns arise with the sheer number of buses an hour (72 per hour according to the frequency tables) and related pollution and the road widening proposed at the Terenure end of Terenure Road East. Some 19 trees are to be felled along Terenure Road East, including a magnificent specimen at the entrance to Argus House.
    • Four A spines, and the S4 circular route, all of which are high frequency, as well as several subsidiary services, are to go through Rathgar.  (The equivalent current service in many cases accesses the city via Harold's Cross Road.)  No other corridor will have to cope with that many buses.  The NTA has claimed that its new hybrid buses "are expected" to be 30% more energy efficient that diesel-only buses.  It has not released the data and more worryingly bought an extra 200 hundred diesel buses before the ban came into effect in July 2019.  Those buses will be on our roads until after 2030.  The NTA has refused to switch to electric buses, arguing that the routes - its routes - are too long.  Hybrid buses are not "green".


  • The selection of the route for CBC12 (and CBC10 which feeds into CBC10) and the network design which put four A spines plus additional routes through Rathgar are plans and/or projects for which an EIA and/or SEA ought to have been undertaken.  Residents will continue to fight to protect their environment and health.  They were comforted by the Chief Justice's comments in the Friends of the Irish Environment case when he said: "I do acknowledge that, in an appropriate case, it may well be that constitutional rights might play a role in environmental proceedings. I would not rule out the possibility that the interplay of existing constitutional rights with the constitutional values to be found in the constitutional text and other provisions, such as those to be found in Art. 10 and also the right to property and the special position of the home, might give rise to specific obligations on the part of the State in particular circumstances."


  • The planned frequency of buses cutting through Rathgar under BusConnects is disproportionate and will permanently destroy the fabric of this historic area.  (Terenure Village will also be unable to cope.) The homes and buildings along both Rathgar Road and Terenure Road East are in the main protected structures; a high frequency bus corridor of this nature will affect the character of area.  No reliable figures have been provided by the NTA to show what element of claimed shorter journey times will be attributable to the destruction of so many mature trees rather than to the use of priority lights or cashless fares, for example.  Road-widening at a time of climate crisis rather than introducing congestion charges or park and ride is a serious error and unnecessary and will be challenged.


Terenure village/ Rathfarnham Road issues


  • Terenure is being treated unfairly and disproportionately by the NTA Bus Corridor Project in comparison to many other similar areas - eg Mobhi Road, Crumlin Road, Merrion Road, Rathgar Road. All these areas have been offered alternatives to road widening, together with traffic reduction strategies. However, in Terenure, the NTA proposes to widen roads with the express purpose of increasing traffic volumes which will be rerouted from Templeogue Road and Kimmage due to BUS GATES there. This objective has been clearly stated and acknowledged by the NTA. They have failed to consider any options whatsoever to reduce traffic burden, traffic chaos and road widening.


  • If it proceeds, the design will result in Terenure Village footprint effectively being reduced. Terenure will become a hostile corridor, with generation of traffic chaos and destruction of our amenity, our environment, our heritage streetscape, our commercial and social activity and ultimately our community.


  • Serious consideration needs to be given to using the existing roadway to the maximum extent possible, rather than any widening.


Rathdown issues


  • The "offline cycle route" to the west of the Rathfarnham Road proposes a new bridge across the Dodder accessing a cul de sac in Rathdown Park. This bridge will require significant ramping work (to manage the height difference) in the green space on the county side of the Dodder and will cut through an extensive forested environmentally protected area. The proposed bridge seems to be at a considerable height over the Dodder. The proposal wholly ignores another cycle bridge under construction a few hundred metres away. The various cycling groups have indicated that they do not want this extra bridge. There is also extensive opposition on the county side of the Dodder where it disturbs the Owendoher River valley.


  • The proposed bridge does not make sense. it is a waste of money, an eyesore, unnecessarily damaging to the local environment and will not be used. It is hard to believe that the NTA did not realise the scale of this bridge. Drawings, a proper EIA and a cost estimate should also have been prepared and disclosed.


  • It is imperative that the final schemes for corridors address these serious issues.


The Terenure Residents Association in its comprehensive submission of 13th December 2020 included the following 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.


Residents of Castlewood Avenue / Belgrave Square / Charleston Road made a detailed submission and alternative recommendations to Bus Connects proposals as follows:


  • The current draft preferred route for the Rathfarnham to City Centre Core Bus Corridor disproportionately impacts Castlewood Avenue, Belgrave Square, and Charleston Road by funneling city bound traffic from Rathmines Road down the residential road of Castlewood Avenue.


  • The projected increase in traffic flow along Castlewood Avenue is shown at page 108 of the Transport Modelling Report


  • Castlewood Avenue/Belgrave Square/Charleston Road is already gridlocked at morning and evening rush hour. It simply does not have the capacity to take any increase in traffic.


  • It is a residential area and the residential character of the area is being sacrificed in order to take traffic away from the urban village area of Rathmines. This does not make any sense: traffic is being diverted from an urban area (which has capacity to take it) to a residential area (which does not have the capacity to take it).


  • Furthermore, any increase in the traffic congestion on Castlewood Avenue, Belgrave Square, and Charleston Road will make the proper functioning of the Number 18 Bus impossible. The Number 18 Bus travels along this stretch of road and the Dublin Area Bus Network Redesign Choices Report commissioned by the NTA specifically highlighted the necessity of improving “orbital” routes such as the Number 18. The current proposal does the very opposite of this and threatens the very viability of the Number 18 Bus Route. Developing radial routes at the expense of an orbital route such as the Number 18 goes against the stated policy objective of the NTA.


  1. 2.      The Proposed Solution:


  • Consideration must be given to developing the measures currently in place for cyclists on Rathmines Road and Mountpleasant Avenue so as to achieve a sensible system that allows general traffic use Rathmines Road in both directions (albeit limited by the operation of a bus gate in the outbound direction as currently proposed).


  • One option is for an inbound only cycle lane along Rathmines Road to be complimented by an outbound only cycle lane up Mountpleasant Avenue. Rathmines Road would thereby have the following lanes:

(i)               an inbound cycle lane;

(ii)              an inbound bus lane;

(iii)            an inbound general traffic lane, not subject to a bus gate;

(iv)            an outbound general traffic lane (subject to a bus gate, as currently proposed under Route Option RM3).


  • There is no difficulty with space on the road for this, as this is the same lane set up as currently operates, but with the cycle lane currently being outbound rather than inbound.


  • We consider such an alternative to achieve the best of all worlds:

(i)               It allows general traffic use Rathmines Road, thereby avoiding funneling traffic down adjacent residential roads such as Castlewood Avenue.

(ii)              It is in keeping with the NTA’s stated policy of developing orbital bus routes such as the Number 18.

(iii)            It provides cyclists with safer routes into and out of the city.

(iv)            It ensures a bus lane into the city centre is reserved for buses only, as opposed to the current Route Option RM3 of sharing the lane with general (local access) traffic.

(v)              The outbound lane, involving the operation of a bus gate, remains unchanged as per Route Option RM3.


  • The Mountpleasant Avenue cycle lane could continue along Belgrave Square and join up with Rathmines Road via Belgrave Road/Church Avenue. This would be an invaluable facility both for commuters leaving the city centre, and for school children attending Scoil Bhride, Lois na nOg, and Kildare Place School. It would encourage cycling to school thereby reducing local traffic considerably.



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