I wish to submit the following observations regarding the current proposal plan (Part VIII Development: Mill Road, Corbally – Sustainable Transport Improvement Scheme) and the information, research and documentaton available to the residents prior/ in the related files.

1. Insufficient preliminary analysis complete

The preliminary data, research and reports available in relation to Part VIII are missing from the proposal plan files: there is not sufficient data available to assure of the benefits, improvements and safety of this proposal plan.

The following reports are unavailable in the Part VIII public files:

i) Landscape Plan: no long-term landscape plan available regarding the replacement of the trees to be removed. No information regarding the removal of the century-old wall or Corbally Palace gateway. No field studies completed regarding the diocesan land intended for removal made available to the residents. This information is required to assure the residents of the long-term environmental sustainability, historical preservation and the unique character of the area. (see: http://www.limerickcity.ie/media/Media,4042,en.pdf)

ii) Traffic & Transport Studies: no audits, analysis or data is available regarding the scheme proposed for the area and any positive or negative impacts the proposal will have on the flow of traffic/pedestrians/cyclists and the safety of the residents commuting on the Mill Road, most importantly, at peak times at the proposed pinch-points. The following reports/audits are unavailable for this current proposal:

a)Transport Audit

b) Safety Audit

c) Pedestrian/Footfall Analysis

d) Cycle Network Case-Study*

*An in-depth analysis and expansion of the previous Limerick Metropolitan Cycle Network Study (2019) for the proposed area to empirically assess the requirements of the local residents of the Mill Road: (https://www.limerick.ie/sites/default/files/media/documents/2019-04/Limerick-Metropolitan-Cycle-Network-Study.pdf)

(Note: MHL Consultant Engineers representing the Limerick City and County Council (LCCC) in this scheme for the Mill Road have previously carried out traffic and transport studies in the Mungret area for their client and are capable of carrying out traffic and safety audits – if these audits were previously completed for this plan, this information should be made available for the residents to examine.)

Other (optional) relevant data:

e) Reports for Woodlands, Mill Road, Corbally development: as the proposal plans for Part VIII intersect with the Woodlands development Inspector’s Reports, these reports should be included in the files to ensure all residents are fully-informed regarding the future developments of the Mill Road: https://www.pleanala.ie/en-ie/case/307632

https://www.pleanala.ie/anbordpleanala/media/abp/cases/reports/307/r307632.pdf

f) School survey/footfall/potential-user analysis

iii) Land Acquisition: it is unclear whether all the residents along the main road have been approached regarding the acquisition of the possible land available to facilitate this construction, thus the opportunity to explore further options of widening and improving the consistency and continuous structure of the road have not been publicly confirmed as fully-investigated in this regard. (Note: disclosure of financial cost and personal identifiers are not required as in accordance with GDPR).

2. Community-lead construction: further public consultation required

While it is appreciated that previous concerns regarding initial plans have been noted by the LCCC, engagement with the local community in accordance with the recommendations with Smarter Travel Guidelines (2009) is not present currently in the files for this proposal (Part VIII of the Sustainable Transport Improvement Scheme) for the local area: (http://www.rmo.ie/uploads/8/2/1/0/821068/design_manual_for_urban_roads_and_streets_2013.pdf). There are no reports or documentation (e.g. feedback, previous consultations, meeting minutes etc.) regarding the collaborative working and co-ordinated decision-making involving the residents of the Mill Road to examine the changes made throughout the process and deductions to finalise the present proposal plans. No quantitative or qualitative/content analysis has been completed, or if so, made available to the residents living in the Mill Road to assess the requirements of the community the plan intends to serve. As there is no statistical or content analysis completed, or available in the files regarding pedestrian/cycle flow, consequently, were are unable to ascertain the needs and requirement for the residents of the Mill Road in the Part VIII proposal plan.

Understandably, the current Covid-19 measures have impacted the ability to meet in large groups to discuss the plans proposed. All possible efforts should be explored to consult with the local residents prior to any commencement of the scheme with the relevant data and research that can be analysed and are available to the residents to view to ensure that the community’s needs are meet.

I wish to acknowledge the Mill Road Resident’s Group’s enormous efforts in representing, informing, conducting walking-tours and outdoor one-to-one meetings (abiding by Covid-19 guidelines), communicating with the local residents and providing feedback for the LCCC in relation to this plan. All efforts should be made by local authorities involved to liaison and to continue to establish the most effective communication channels for residents with these representative bodies in the local communities.

No involvement or data of the potential users

i) Primary, Secondary and Montessori school initiatives

There has been no inclusion of Scoil íde National School, St. Muchin’s College or Sunnyside Montessori Preschool regarding the proposals; potential benefits in collaboration with the local community have not been identified as a result.

As mentioned above, School survey/footfall/potential-user analysis would assess the true scale and impact of the proposal and the community, ensuring synthesis could occur regarding cycling facilities available to the pupils and identifying potential users of the carriageway as a result of this preliminary analysis and the impacts they will have on the local residents.

ii) Nursing Home and additional needs initiatives

We are aware that the Mill Road is not safe cuurently for all residents to access, most notably, the elderly, wheelchair users, people with additional physical needs and parents using prams/buggies are prevented from being kept safe due to the narrowing of the pathways. We are unaware of the possible impacts of the road alterations on the local nursing home, as currently shuttle and emergency services are impacted due to the width of the road. As the road is unable to accommodate for a regional bus/shuttle service, this denies the inclusion of the elderly and residents with additional needs from equal access to the road and services. Without any data available, we are unable to conclude the percentage of the population which can only rely on one mode of transport (i.e. private car, public bus etc.). and address the needs of all the residents who share the Mill Road.

Visual Communications:

Many residents relayed in discussion that the plans and materials available to them were difficult to visualise, thus impeding their ability to assess the proposal. A model-version of the plans would be beneficial in assisting the residents to evaluate the proposal as clear and comprehensive as possible, which could be viewed in controlled environments (such as Scoil íde hall or City Hall) to ensure Covid-19 guidelines are adhered to.

3. Transport-mode viability for the community – no data present

In accordance with Smarter Travel Guidelines (2009, p.4) the guidelines:

“recognises the importance of assigning higher priority to pedestrians and cyclists, without unduly compromising vehicle movement, in order to create secure, connected places that work for all members of the community. “.

No research or statistical data has been acquired regarding the specific residential demographic of the Mill road and the mode of transports used or would potentially use as a result of the proposed infrastructure. As no traffic or safety audits have been conducted, or that have been made available in the files, we are unaware of the percentages/ potential percentages of each mode of transport and the impact the plan will have of the commuters living in the Mill Road.

While the guidelines available to prioritise pedestrians and cyclists where possible , the access and flow of vehicles (according to the Smarter Travel Guidelines), the option of a bus or shuttle service has been denied to the Mill Road as a result of no investment in an upgrade of the road prior to the significant dwelling-increase and developments since the late 1980’s.

Pinch Points and flow- impact

The pinch-points in the proposal plans downgrades and decreases the flow of the road: these are not welcomed features and all options should be explored fully before compromising for such options which resort to their inclusion (see part 1.iii Land Acquisition).

It is paramount that any upgrades need to serve the people living here and the consequences of any changes. Currently as we are aware, the road is dangerously narrow as it stands to accommodate any large and/or emergency vehicles in contraflow, the footpath is not safe for the disabled, elderly, or parents with babies and infants in prams, the top of the Mill Road has a dangerous blind-bend and there is no alternative route out/emergency exit if the road gets blocked. This has denied the residents safe and equal access travelling on the Mill Road, with the long-term effects of this oversight of the upgrading of the Mill Road has denied the residents services such as a bus route like the surrounding areas (e.g., Westbury and Shannon Banks) as a result. While is truly appreciated that the LCCC are investing in the Mill Road and upgrading the facilities, we need to ensure that all possible options have been explored with residential consultations as so all are informed and understand the drawings and plans and all relevant information comprehensively.

If the flow of traffic, access and safety can be improved by helping to equally serve all residents, this is the plan which should be approved of. Does this plan reflect and enhance the community it intends to serve? If we had the necessary data available, we might have a clearer picture of the benefits or impediments which this current plan will have, such as peak-traffic times at these points of concern, again significant information which is missing to make a fully- informed decision.

In summary, more information is required in order to properly assess the positive or negative impacts this particular proposal (Part VIII) will have on all the residents of the Mill Road, as currently there is not sufficient information or preliminary data available in the files to assure and evaluate potential impacts accurately on the residents. Qualitative and quantitative content analysis is required for the traffic, safety, heritage, the demographic needs of the residents and their means and modes of transport in the area. A landscape plan, transport audit and safety audit have not been conducted/ made available for this proposal and the impact it will have on the residents of the Mill Road - this information is necessary for such major works and the long term impacts they may have. The plan as it currently stands is not quite at a fully investigated stage as a result.

Any research, surveys and data in relation to the Mill Road, the possible future development plans and the population demographic should be made publicly available in in the proposal plan files on the LCCC website/portal (if they were previously completed). The Mill Road is in dire need of upgrading for many years. Now that this transport development scheme has been put forward by the Limerick City and County Council, I am very grateful that there is focus for a much-needed upgrade: however, the LCCC have to ensure that it is functionable for the residents it intends to serve and again, include them in each step of the proposed upgrade. Further residential/community consultations would be most beneficial going forward to ensure this is the most comprehensive and workable proposal plan after ruling out all possible alternatives available to the residents in upgrading the road. Unfortunately, without the adequate research and data available, the residents are unable to make comprehensive observations and evaluations at this stage with the materials available.

Part VIII - Mill Road, Corbally - Submissions

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