Caibidil:
Dear Sir/Madam,
TII welcomes consultation on the proposed options for the East Meath – North Dublin 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.
As a general principle at the outset, TII is concerned to note that routing principles applied to the route option development includes the principle to maximise the use of national, regional and local roads. While TII has no remit in relation to regional and local roads, Eirgrid will be aware that TII is responsible for the provision of a safe and efficient national road network. TII has consistently identified 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, 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. Having regard to the foregoing, TII would welcome Eirgrid updating route option development principles to omit reference to maximising use of the national road network in the interests of adherence to the provisions of official policy relating to safeguarding the capacity and safety of the national roads network.
- In relation to the specific route options for the proposed East Meath – North Dublin Grid Upgrade Project, TII notes extensive interactions between the 4 proposed route options and the existing national road network in the area, identified in the consultation documentation as follows;
- A crossing of the M1, in the vicinity of Junction 2 (Dublin Airport) on a section of M1 maintained under a Motorway Maintenance and Renewal Contract (MMaRC).
- Two crossing options of the M2, located between Junction 2 (Cherryhound) and Junction 3 (Ashbourne South) on a section of M2 maintained under a MMaRC Contract.
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Two crossing options of the M3, either in the vicinity of Junction 5 (Dunboyne) or in the vicinity of the R154/M3 crossing. Both crossing options are proposed on a section of the M3 that is maintained by a Public Private Partnership (PPP) Concession Company. Crossings are identified as likely to be by Horizontal Directional Drilling (HDD). 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,
- Any maintenance and/or future planned upgrades of the Pipeline at the crossing location can be carried out without access to the motorway boundary
- There are no bolted joints in that part of the Pipeline within the motorway fence-line,
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A pre and post construction survey shall be required along the length of the pipeline over the extents of the motorway boundary
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Specific requirements may also arise for these proposed works. Consultation with the relevant maintaining organisations (e.g. MMaRC Contractor and PPP Concession Company) should also be undertaken and any access requirements agreed with them through their 3rd party protocols. National Road Scheme Planning In addition to the proposed crossings of the existing M1, M2 and M3, 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. 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. Examples of impacts are outlined above. TII welcomes that the current options on display do not propose the laying of any cabling in the national road reservation. 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 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. In relation to national road structures, early engagement with TII Structures Section should be undertaken to ascertain requirements.
- 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 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 East Meath - North Dublin Grid Upgrade Project.