The Secretary,
An Bord Pleanala,
Marlborough Street,
Dublin 1
17 November, 2005

Observation on a Planning Appeal.

ABP Ref. No. 214700
Planning Authority: Galway County Council
Ref. No. 04/5402
Date of Consent Notification: 26 September 2005
Applicant: J. J. Mehan, Shannon Ferry Group Ltd.

Re: installation of a cable link car ferry, capacity 24 cars with associated on-board and on-shore facilities including a 0.2 hectare carpark, a 114 sq.m. service building containing an office and a store/workshop area, two new access roadways and associated link spans, relocation of a group water supply intake pipe, pump sump and pump house and for the redevelopment of small boat berthing and service facilities and access channels.

Dear Sirs;

Friends of the Irish Environment respectfully request An Bord Pleanala to consider this observation on the grant of permission for this proposed development in a previously undeveloped sensitive rural area designated for its natural habitats.

It is clear from the EIS and the planning file for this development that it is a major commercial proposal with a widespread impact on the environment of this remote area designed for scenic protection in the County Development Plan ['Highly Scenic'] and habitat protection through Irish implementation of European Natura 2000 designations. The site of the construction of the car park and building are grasslands at Illaunavee, Knockferry, and according to
the EIS, 'this grassland is part of an important orchid site and there is no obvious mechanism for compensation'.

The developer's contention that the project is in accordance with the National Spatial Strategy, the Galway County Development Plan, and the Guidelines for the West Region are not borne out by an examination of the premise of the development.

According to the developers, the premise 'aims to address the existing infrastructural bottleneck that is Galway city as a route between east and west Galway'. 85% of the demand is projected to come from this diversion. This would require r edirecting traffic onto a total of 18 kilometers of the N84 and N59 in each side of the river.

Redirecting national traffic to a local road network is contrary to standard traffic management practices. This is augmented by the lack of clarity about the nature of the proposed limitations on cargos, if any, in relation to HCVs, articulated trucks, and buses, for which no parking facilities have been proposed.

A platoon of cars released onto these road, interspersed with HCVs, would create both a capacity problem and a danger to public safety, given that the local authority itself identified the roads serving the proposed development as 'below standard in width, sightline, capacity, and structural strength to cater for the traffic associated with the proposed development'. No evidence is provided that the NRA and Galway Co. Council are satisfied that the road quality is appropriate for the proposal and the NRA made no comment [12 May 2005].

The initial Planners Report has been interjected with a comment suggesting that 'the issue of the road infrastructure has been addressed' through the EIS and Additional Information. But in fact it is not possible to address the issue of road alignment and improvement as it does not lie within the boundaries of the planning application. In order to raise the standard of the road to the level that would be required to meet national standards, an enormous disruption of the rural road network would be required and the investment is not reflected in any of the current National, Regional, or County Plans and Guidelines.

Further, the issue of the infrastructural bottleneck in Galway is to be addressed, as appropriate, through Galway City Outer By Pass, including a proposed bridge at Menlo 6 miles to the south of the proposed turn off for this ferry. Given that the Quinncentenial Bridge carries 40,000 vehicles a day, the impact of the proposed ferry with a capacity of 96 cars per hour does not seem even relevant.

In fact, An Taisce quotes a 1996 feasibility study for a bridge at this location which concluded that the volume of traffic diverted even by a proposed bridge crossing would be 'very low'. Yet the EIS for this project states that 'alternative locations were not considered.'

According to another appellant, this study makes the following points:

' Average journey time saving compared with existing overland routes would not be significant
' Access to the main routes in the west Region is not obstructed Lough Corrib and it is difficult to see how the proposed crossing would make a significant difference.
' Galway City and Connemmara are the main tourists destinations it the Region and the proposed crossing would not improve access to either.

And finally:

' It is most unlikely that the proposed crossing would generate any additional economic activity in the area.

Leaving aside the flawed premise of the development, the proposal directly contravenes the Galway Development Plan's restrictions on developments in areas of outstanding natural beauty which requires maintenance of the existing views and requires that developments close to lake shores are restricted to that associated with essential housing needs. The infill required for the 150 metre from the shoreline for parking does not comply with the Council's own guidelines and is contrary to proper planning and development. Infill of lakeside or coastal sites for parking can not be justified.

The amenities of the area and in particular the use of the river and existing piers will be radically impacted by the proposed ferry crossing. The EIS itself states that the 'tranquil character of the landscape will be altered'.

The 105 metre pier leading to the link span will be extraordinarily dominant, as the EIS informs us that the length of the roadways as proposed is the minimum length required to ensure safe operation of the ferry and prevent the otherwise 'high likelihood of the ferry colliding with the existing piers.'

The laying of the cable, its use and maintenance in fact require planning permission in themselves. Neither the Planning Application Notice nor the application informed the pubic of this aspect of the proposal. The omission from the Planning Application notice is all the more critical as the ferry will be licensed under the Merchant Shipping Act 1992 which is not listed in Annex II of the 1997 Habitats Regulations and thus not subject to an appropriate assessment. An assessment that does not consider alternatives is not appropriate.

The entire file shows questions that have been asked, both by the Planning Authority and the objectors which, despite assurances to the contrary, have never been answered and in spite of which the Local Authority intended to grant development consent.

The Board should be aware through the appeals and referrals it receives of the many developments that are eroding the core values of the landscape, habitat, and amenities of Ireland. Some of these are critical to Ireland's development and growth. But the dramatic piece-meal development of the Irish countryside, particularly those areas with remote amenity values, has left a dwindling number locations at which the experience of Ireland itself can be experienced unfettered.

Our organisation is constantly approached by individuals in previously unspoiled rural locations who are experiencing unregulated intrusions even in areas designated for nature conservation. Sand dunes, estuaries, rivers, and lakes are all virtually under siege from a new class of affluent leisure seekers with quad bikes, water and jet skies, power boat schools and even, on the Blackwater River, an 'Air Boat'.

The Galway Development Plan calls Lough Corrib 'possibly the single most significant natural asset in the County'. Given this development's flawed premise and wide-spread potential environmental disturbance, the national gain arising from this development is so small and the environmental lose so great that we urge your Board to refuse consent in the clearest terms.

Yours, etc.,

Tony Lowes

Enc: Fee of €50.00
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