Comments about the approach taken on this project:
Re. Kildare Meath Grid Upgrade Project Consultation; Step 4
TII welcomes consultation on the proposed options for the Kildare Meath Grid Upgrade Project. TII acknowledges this non-statutory consultation is framed within on-going productive and collaborative liaison between TII and Eirgrid at a national level.
In relation to the specific route options for the proposed Kildare Meath Grid Upgrade Project, TII notes extensive interactions with the existing national road network in the area, identified in the consultation documentation as crossings of the M4, N7 and M7, national roads. Crossings are identified as by trenchless construction methods to avoid any physical impact.
Motorway Crossings With respect to grid connection routing proposals crossing the motorway network, Eirgrid should observe the following;
• A third party seeking to cross a motorway will require Works Specific Deeds of Indemnities, arrangements for third party access or consent from TII in accordance with Section 53 of the Roads Act, 1993. Arrangements for third party access are also likely to be required. Contact should be made to ‘thirdpartyworks@tii.ie’ to progress this element when proposals for the crossings have been developed.
General requirements for directional drilling under a motorway include;
• The launch and reception pits for the Pipeline are located outside the Motorway boundary,
• The Pipeline will be installed at such depth so as not to conflict with the drainage for the Motorway,
• Neither the Works nor the Pipeline will damage or interfere with the Motorway,
• There are no bolted joints in that part of the Pipeline within the motorway fence-line,
• Specific requirements may also arise for these proposed works.
National Road Scheme Planning In addition to the proposed crossings of the existing M4, N7 and M7, national roads, consultations should be had with the relevant Local Authority/National Roads Design Office with regard to locations of existing and future national road schemes in the area, as follows;
• M4 Leixlip to Maynooth included in the National Development Plan, 2021 – 2030, and
• Leinster Orbital Route, included in the NTA Transport Strategy for the Greater Dublin Area, 2016 – 2035.
TII would highlight in relation to the above national road projects, as outlined in the DoECLG Spatial Planning and National Roads Guidelines (2012), that policies and objectives, including rezoning of lands, should not compromise the road planning and route option evaluation process, in circumstances where road scheme planning is underway and potential routes have been identified and brought to the attention of the planning authority, including schemes that may currently be suspended.
Similarly, development strategies, for example, the Kildare Meath Grid Upgrade Project, should not have the effect of altering the function of these routes or importantly, increasing the cost of land to be acquired or under active consideration, as a route option for a national road scheme.
HV Cable Routing on National Roads
Eirgrid will be aware of TII concerns in relation to the laying of high voltage cabling in the national road reservation and the implication such works have on ability to implement national road network maintenance and improvements, including safety works. TII welcomes that the current options on display do not propose the laying of any cabling in the national road reservation.
As previously advised, a number of significant implications for TII and road authorities in the management and maintenance of the strategic national road network resulting from the laying of high voltage electricity cabling in the national road reservation have been identified, including;
• Impacts on embankments, bridges, drainage and road furniture infrastructure leading to future maintenance liabilities,
• Impediments to future maintenance and operations activities, such as safety barrier repair and roadside drainage renewal,
• Impediments to future routine network improvements such as pavement overlay and strengthening, installation of new verge-side signs and other road furniture,
• Impacts on network traffic flows during installation,
• Impediment to future on-line upgrades of national roads because of the implications to road authority / TII in relation to both the technical challenges and the additional costs of moving underground cables in order to accommodate the road improvements.
EIAR Scoping
In addition to the above, with respect to additional EIAR scoping issues, the following recommendations provide general guidance for the preparation of an EIAR, which may affect the National Roads Network;
• The developer should have regard to any Environmental Impact Statement and all conditions and/or modifications imposed by An Bord Pleanála regarding road schemes in the area. The developer should in particular have regard to any potential cumulative impacts,
• The developer, in preparing EIAR, should have regard to TII Publications (formerly DMRB and the Manual of Contract Documents for Road Works),
• The developer, in preparing EIAR, should have regard to TII’s Environmental Assessment and Construction Guidelines, including the Guidelines for the Treatment of Air Quality During the Planning and Construction of National Road Schemes (National Roads Authority, 2006),
• The EIAR/EIS should consider the Environmental Noise Regulations 2006 (SI 140 of 2006) and, in particular, how the development will affect future action plans by the relevant competent authority; see Guidelines for the Treatment of Noise and Vibration in National Road Schemes (1st Rev., National Roads Authority, 2004),
• It would be important that, where appropriate, subject to meeting the appropriate thresholds and criteria and having regard to best practice, a Traffic and Transport Assessment be carried out in accordance with relevant guidelines, noting traffic volumes attending the site and traffic routes to/from the site with reference to impacts on the national road network and junctions of lower category roads with national roads. In relation to national roads, the Authority’s Traffic and Transport Assessment Guidelines (2014) should be referred to in relation to proposed development with potential impacts on the national road network. The scheme promoter is also advised to have regard to Section 2.2 of the NRA/TII TTA Guidelines which addresses requirements for sub-threshold TTA. Any improvements required to facilitate development should be identified. It will be the responsibility of the developer to pay for the costs of any improvements to national roads to facilitate the private development proposed as TII will not be responsible for such costs,
• The designers are asked to consult TII Publications to determine whether a Road Safety Audit is required,
• In the interests of maintaining the safety and standard of the national road network, the EIAR should identify the methods/techniques proposed for any works traversing/in proximity to the national road network.
• TII recommends that that applicant/developer should clearly identify haul routes proposed and fully assess the network to be traversed. Where abnormal ‘weight’ loads are proposed, separate structure approvals/permits and other licences may be required in connection with the proposed haul route and all structures on the haul route through all the relevant County Council administrative areas should be checked by the applicant/developer to confirm their capacity to accommodate any abnormal ‘weight’ load proposed.
Conclusion
National Strategic Outcome 2 of the National Planning Framework includes the objective to maintain the strategic capacity and safety of the national roads network. In addition, Chapter 7 ‘Enhanced Regional Accessibility’ of the National Development Plan, 2021 – 2030, sets out the key sectoral priority of maintaining Ireland’s existing national road network to a robust and safe standard for users. This requirement is further reflected in the publication of the Draft National Investment Framework for Transport in Ireland and also the existing Statutory Section 28 Spatial Planning and National Roads Guidelines for Planning Authorities.
It is important for Eirgrid to be aware that proposed crossings of national road motorways require adherence to established procedures and standards. Also, ongoing maintenance and future upgrades to the national routes within the study area will be required and TII recommends that the above observations are taken into account in the Kildare Meath Grid Upgrade Project.
