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PART 5

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863

PART 5 -- CLOSING SUBMISSIONS, CONCLUSIONS, RECOMMENDATIONS

AND APPENDICES

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143. Closing Submissions -- -- -- -- -- -- -- -- -- 865

143. 1. Submission by Leshamstown Lane Residents -- -- -- - -- 865

143. 2. Submission by Mr. O'Donnell -- -- -- -- -- -- 866

143. 3. Submission by Alan Park, Bellinter Residents Association -- -- -- 873

143. 4. Submission by Brendan Magee, Meath Road Action Group -- -- -- 875

143. 5. Submission by Mr. Casey -- -- -- -- -- -- -- 876

143. 6. Submission by Peter Sweetman -- -- -- -- -- -- -- 888

143. 7. Submission by Mr. Butler -- -- -- -- -- -- -- 892

144. Application for Costs -- -- -- - -- -- -- -- -- -- -- -- 899

145. Issues Required to be Addressed under Sections 50 (2)

and 50 (3) of the Roads Act, 1993, as amended -- -- -- -- -- 899

146. Comments on Written Objections and Submissions

made to An Bord Pleanala, prior to Hearing -- -- -- -- -- -- 918

147. Comments on Submissions made on Legal Aspects of Council's Proposal -920

148. Comments on Submissions made on Route Selection, Consultation

and Information Aspects of Council's Proposal -- -- -- -- -- 927

149. Comments on Council's Application for Confirmation of

Motorway Order and Approval of Road Development -- -- -- -- - 931

150. Recommendations on Confirmation of

Motorway Order and Approval of Road Development -- -- -- -- 996

Table 1. Modifications to be attached to any Approval of the

Motorway Order under Section 49 of the Roads Act, 1993 -- -- 998

Table 2. Modifications to be attached to any Approval of the Road

Development under Section 51 of the Roads Act, 1993 -- -- 1002

Appendix 1. Names and addresses of Objectors

to Motorway Scheme Order -- -- -- -- -- -- -- 1008

Appendix 2. Names and addresses of Persons or Organisations

who made Submissions to the Road Development -- -- -- 1026

864

Appendix 3. Names and addresses of persons

represented by M/s Gaynor Corr -- -- -- -- -- -- -- 1030

Appendix 4. Documents handed in to Hearing -- -- -- -- -- -- -- 1036

Appendix 5. List of Wayleaves to be Acquired -- -- -- - - -- -- 1051

Appendix 6. List of Public Rights of Way to be Extinguished -- -- -- -- 1052

Appendix 7. List of Private Rights of Way to be Extinguished -- -- -- -- 1057

Appendix 8. List of Planning Permissions to be Modified -- -- -- -- -- 1059

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865

143. Closing submissions :

143. 1. Closing submission by Leshamstown Lane Residents :

This was made by Jimmy Finlay and Brendan Murphy on Day 23 of the Hearing and a

copy of their submission is listed at Day 23 in Appendix 4 of this Report.

Mr. Finlay said that they would like to focus on what they had been discussing with the

Council since their previous visit and said that arising from the Inspector's comment then

they had focussed on two issues. He said that the first issue was the costing of a bridge

over the M3 at Newalls and some traffic calming issues at Leshamstown Lane. He said

they were given sight of an outline sketch of a bridge but were told that it was

questionable if a two-lane road could be put in, due to the limitations of the CPO on the

land required there.

He said most of the discussions and communications with the Council had been about the

Leshamstown Lane issue and they had received certain documentation in the past week

which was an outline of what might be possible. He said that in fairness to the Council

officials who were trying to assist them in resolving the crux, the documentation was not

a definitive view by the Council but he said that it would be a sort of a carving up of

Leshamstown Lane in such a way that it might be able to accommodate the diverted

traffic from the Drumree Road after the road was severed. He said the proposals were to

have entrance ramps at the Drumree and Dunsany ends of the Lane with eight further

ramps spaced out along the Lane and with lighting at each ramp and that there would be

eight pull-in points as well.

Mr. Finlay said that at a meeting attended by over 100 residents of Leshamstown and the

surrounding Drumree areas on the previous Monday there was shock and horror at what

was being proposed as these proposals were a sort of mini-urbanisation in a rural setting.

He said while they might be suitable in a suburb of Dublin the residents did not see this

as something that should be tried out on their locality. He said they could not accept what

was the result of bad planning and a lack of consideration and said that the EIS made

virtually no mention of the impact this would have on their lives. He said the decision to

sever the road had severed a community and split a parish from its hinterland. Mr. Finlay

said that the Council were saying that they were going to force traffic up Leshamstown

Lane however difficult that was over 800 yards but were not going to give them a bridge

of 100 yards at Newalls which would restore the link between Drumree and

Dunshaughlin that had existed for hundreds of years.

He said that the people at the meeting were up in arms about what was being proposed by

the Council, that they had not opposed the M3 proposal, they had not opposed the

sewerage works and they had not opposed the roundabouts which would flyover the M3.

He said that if the Council thought the residents would accept a motorway in their back

866

gardens and a mini-O'Connell Street along their road, they had better think again. He said

they felt it was up to the Council to resolve the issue of how they were going to take the

rest of the traffic in.

Mr. Finlay said the traffic in their area was made up of people coming home from

Dunshaughlin through Batterstown to avoid the traffic jams in Dunshaughlin; people

from Trim used their road and locals who lived in Drumree Village used it. He said these

were three separate groups who used the Drumree Road and the new feeder link would

have no use for those except for people coming back from Dublin who came on the

motorway. He said there was no need for the people living around the Drumree area for

this link road as it was too much of a roundabout journey for people to use it as they

could be faced with bottlenecks coming across the motorway . He said that it would only

be the people from Trim that would use it and that it was a waste going ahead with a road

that two-thirds of the people would not use.

He said that if it was a farmer who had land on both sides of the motorway he would be

given an overpass and they as residents should get the same treatment when they wanted

to stay in contact with their mother town, Dunshaughlin. Mr. Finlay said they were

annoyed that sufficient land was not kept in the CPO to allow this bridge to be built and

he said they felt this was done deliberately so that there could not be a case made to have

a bridge built there in the future. He said that even if the bridge was only wide enough to

take one car at a time this would be only over 100 yards, when the Council were sending

them down 800 yards over a single lane road. Mr. Finlay said they hoped the Inspector

would take on board the unfairness of what had happened and said they were not asking

for the M3 to be stopped but were asking that the 100 yard span be kept open to keep

their communities alive. The Inspector said the points they had made would be taken into

account.

Mr. Finlay asked if they could engage with the Council in open debate at the Hearing on

some of their concerns and the Inspector said that, while there was nothing to prevent

them from having further discussions with the Council, they had been given a second

opportunity to make a submission and the Hearing was not going to become a mediation

forum at this stage for this matter. Mr. Murphy asked if the Council could give the

reasons why the bridge could not be put in and Mr. Keane said they would write to

Leshamstown about that.

143. 2. Closing submissions of Michael O'Donnell B.L.

on behalf of his various Clients :

Before making his specific submissions, Mr. O'Donnell referred to the issue of

accommodation works which he said was of concern to some of his Clients and said he

accepted the Council had some difficulties because of the nature of their proposal and

with some aspects being left to the contractor to design, but said he thought there should

be some degree of precision as to how mitigation works were to be included and that

these should be given to the Hearing so there would be some degree of certainty on what

867

formed part of the scheme. The Inspector intervened and said that the precise details of

accommodation works were not an issue for An Bord to decide on, but said that he

accepted there could be some more certainty in relation to what could be regarded as the

residential aspects of the frontage proposed to be acquired. He said this was part of the

reason he had sought clarification on that issue from Mr. Bergin.

Mr. O'Donnell said that in relation to the case of Mr. & Mrs. Peters, the Council had

fairly accepted the impact would be severe since the house would be located within 50

metres of the boundary of the works and said that, while this was not the actual

motorway, there would be severe disruption during construction for his Clients, and he

suggested this would almost make it impossible for them to live in their house for the

period while the road was being constructed. He said the house had been laid out to a

very high standard but that it was now going to be very susceptible to the road intrusion,

particularly from traffic noise, since the living rooms and bedrooms were at the front of

the house. He said that no mitigation measures were proposed either for during

construction when the impact of dust and noise would be very significant, or for the

operation of the road when noise levels would be a major intrusion on their quality of life

and the amenities they enjoyed in their property.

He said that he was not going to review the evidence given about the noise impact but

said that the appropriate levels were those imposed by the Council itself, by An Bord and

by the EPA for developments where they imposed noise conditions. He said that a

substantial stone wall should be included as a condition to mitigate the impact of noise,

dust and visual intrusion along the full frontage and said this should be constructed before

work commenced on the road development. He said that the landscaping works should be

time limited so that they were completed within the planting season after commencement

of the works so these could be in place to mitigate the impact on the house. He said that,

without meaning to be facetious, if a badger sett or bat colony were as close to the route

as the Peters house was then it was likely the route would have been moved and he said

the Peters were entitled to get at least the same degree of consideration and protection

when they would be continuing to live so close to the road.

Mr. O' Donnell the referred to the Tara Stud situation and said the Council witnesses

had also fairly acknowledged the major impacts there would be on the operations of the

stud which would seriously undermine its ability to continue since it was effectively

losing one third of its land between the 100 acres severed, the 70 acres taken and the

lands sterilised by being in close proximity to the motorway. He said that Mr. Osbourne

had acknowledged the status of the stud as a nationally important stud farm and Mr.

Bergin had given the example of the National Stud where there had been a bunding with

a wall and appropriate planting of mature trees provided along the full length of the

boundary. He submitted that a stone wall constructed along the full length of the

motorway should be required as a mitigation measure in the Tara Stud situation and said

that this would go towards mitigating the traffic noise and general construction impacts

which would be very inimicable to horse rearing and horses breeding activities.

868

He said that in the case of the Swans, both Mr. Osbourne and Mr. Guthrie had fairly

accepted that the planning permission there would be un-implementable since the

motorway would have an impact on the proposed house and stable block. He accepted the

issue was primarily one of compensation but said the impact would appear to be very

severe in terms of the Swan lands.

Mr. O'Donnell said that in terms of the McCarthy lands at Garlow Cross the impact on

that property was similar to that in the Peters case as the road would come very close to

their house but there was the addition of a major interchange being located in close

proximity. He said the construction works associated with the interchange would have

major negative impact on the house during both construction and operation and he

submitted that appropriate mitigation measures should be required to limit and, if

possible, eliminate those impacts. He said that the light pollution would have a serious

impact on the McCarthy lands at night and said that regard should be had to this in terms

of the amenity of the McCarthy family home and also on his stud farming operations.

Mr. O'Donnell said he was hopeful that some of the difficulties identified in the case of

Betty Newman Maguire could be resolved by the Council and that they might be able to

indicate before the end of the Hearing some proposals that might deal with some of her

concerns. He said that in the event that this was not possible, he submitted that her

requirements were reasonable, particularly her request that appropriate landscaping

would be carried out along both the new county road and along the embankments to the

proposed motorway and that appropriate noise mitigation measures be included on the

bridge. He suggested that these should include installing porous asphalt to reduce the

noise impacts.

Mr. O'Donnell then made an application for his Clients costs of the Hearing and said that

he was aware of the Inspector's position of this not being a matter for him to deal with,

but said he simply have it recorded that the application was made as none of the

submissions were frivolous and he suggested they might have provided some assistance

to the Inspector in making his recommendation to An Bord.

Note -- Mr. O'Donnell's submission on behalf of Dalgan Park was made on the

following day, Day 25, to those made on behalf of his other Clients.

Mr. O'Donnell commenced by saying that there was something unbelieveable about the

entire proposal for the Dunshaughlin to Navan Section since if you said to someone who

had no particular knowledge of the area that the Council and the NRA were proposing to

build a tolled motorway that crossed an internationally important river at a crossing point

where that internationally important river, the Boyne, and a similarly important river, the

Skreen, converged, they would find that extremely surprising. He said if you told them

the river system had species protected under the Habitats Directive and was a proposed

SAC and a major spawning ground for salmon, they would be amazed. He said that if

you then said that this immediately adjoined the lands of Dalgan Park, which had been

acknowledged as a landscape of outstanding beauty, with trees specifically protected by

the Council and used as a public park, it would be almost unbelieveable. He said that if

869

you then were told of the major educational and pastoral facilities, the retirement home

for old people and the range of facilities which would be adversely impacted in a major

way by noise, construction impacts, traffic, it would be scarcely believeable that this

could be possibly chosen by the Council to locate this roadway.

Mr. O'Donnell said that, as if that was not bad enough, on the other side of the lands was

a world famous site for archaeological reasons that the Council through Ms Gowan

accept the road would have a profound impact on and he said that, when all of that was

put together, this Dunshaughlin to Navan Section was all about the impact the road would

have on this "landscape" and he said he used the word "landscape" metaphorically for all

that was contained within it. He said there was the archaeology which was clearly an

international issue as it was the most sensitive site in the country and that proposing a

tolled motorway at the bottom of the hill within 1000 metres of what Ms Gowan called

the complex of Tara itself was an extraordinary proposal. He said that when this was

combined with the landscape, the river system, the public park in Dalgan Park, the sacred

nature of that place, the links of Dalgan with Tara, it was incomprehensible that a such a

design would be proposed. He referred to the Interchange at the bottom of the Hill of

Tara with its lighting giving constant light pollution, the noise and traffic, and said the

scale of what was being proposed was unacceptable.

He said that when you stood on the Hill of Tara and looked north or west, you looked

across a landscape that had remained unchanged for 2000, or perhaps 3000, years with

the link from Tara to Skreen, from pagan to early Christian and to modern Christianity in

terms of Dalgan Park. He said the landscape was a stunning, mythological,

archaeological landscape of great scientific and ecological value that was effectively

unchanged with the existing roads that had followed traditional pathways and changed

incrementally overtime. He said that what was now proposed would radically change the

entire context of Tara and the landscape and would destroy that landscape forever. He

said that it could never be the same and that when you stood on the Hill of Tara and

looked north to Skreen you would look across a major interchange and a tolled motorway

system, which would be the destruction of the landscape forever with no going back. He

said that this generation would have destroyed the landscape that existed unchanged for

3000 years by the construction of a tolled motorway system and a major interchange and

he submitted that this was not something that could easily be forgiven, if it were allowed

to occur.

Mr. O'Donnell suggested that no answer could be given if someone asked in 10, 15 or 20

years time "why was this motorway and major interchange allowed to be built within the

Tara complex to destroy that landscape" since it was simply unacceptable and he

suggested that now was the time to stand back and consider what was being proposed. He

said there was nothing to justify it when the scale of what was being proposed and the

landscape were considered. He said that there was not even a public service development

justification since it was a private profit making development that was being proposed to

be designed, built and operated by a private contractor, which would be designed for

profit and used as a parallel system to the existing road which would remain for those

who could not afford to pay the tolls. He said that it was for that type of a development

870

that we were willing to destroy the landscape along this location. He said it was clearly

not just a national question for this development because it was a world site and so was

an international question.

He said that Tara was for him the symbol of Meath and it was Meath County Council that

were now proposing this development, which would on their own evidence have a

profound impact on Tara. He said that not only would it destroy Tara but the Council's

answer for the monuments that had been identified as being connected to Tara was that

they would also be destroyed or, he said, by the euphemism quoted the previous day they

would be preserved by record. He said it was a wonderful answer for Tara that it would

be preserved by record and could then be visited in the library where there would be

drawings to show what had been removed and what had been destroyed. He submitted

that preservation by record was not an answer in this case and said that the Council had

prepared the EIS and purported to rely on that answer to some extent as the justification

for their case to proceed with this route.

Mr. O'Donnell said that in all of the Hearings he had been involved in, he had never seen

a submission that was so lacking, so inept and so inadequate. He referred to his

submission to the Inspector during the Hearing that he should go to An Bord Pleanala and

ask them to consider if they should proceed with the Hearing in view of the inadequacies

of the EIS as, he said, it was that bad. He said that it might not matter if the site and lands

were not so important but this was a critical site and he said that any flaws of deficiencies

were magnified because of the scale and the impact of what was being proposed. He said

that the inadequacies in the EIS were of crucial importance in this case and suggested that

Mr. Guthrie as the Project Engineer was not aware of the geographic, administrative or

legal context in which he was operating nor of the SPGs and said this level of ignorance

pervaded the EIS which accepted that the design had not yet been formulated and that it

was a matter for the contractor to agree the detail of the design.

He said that you could not accept a document for such a sensitive site where the design

was not yet formulated and where it would be left to the contractor to source the materials

for filling and the source of extraction and waste materials, where culverts and bridges

had not been formulated and where the height the road would be built was not even

known and said that was what was being proposed for this landscape of international

importance from at least five different criteria.

He said that the only part of the report that was generally immune from criticism was the

archaeological section since this clearly accepted the profound impacts that the

development would have, but he suggested that even here it was incomplete since Ms

Gowan had indicated that a major site, identified as part of the preliminary works, would

be destroyed as part of the development.

He said that for the built heritage Mr. O'Sullivan did not know the legal context within

which he was operating and was not aware of the need to consider the curtilage of a

protected structure, had no idea of what he was required to investigate and accepted that

871

he was simply sent to look at buildings without making any critical analysis of them

which, he said, gave a built heritage that was fundamentally flawed.

He said there was the ecology report on an internationally important river system where

the person preparing that report did not disclose the proposed SAC --- the highest

designation the EU could give to a site, he was not aware until it was put to him of there

being three separate species protected under the Habitats Directive in the river system,

and all of that was within the area where there was, he said, a major intersection of a

county road with the motorway being constructed at the confluence of two rivers.

He said there was a noise report by a person who had never visited the site until after the

EIS had been published. He said that when the impact of noise on the context of Tara

was considered and that Mr. Summers had never visited Tara and did not know what it

looked like, never visited Dalgan Park and did not know it was a public park before he

had prepared his report, and that this was what put in evidence as something to rely on to

justify the proposed route was unbelievable arrogance and contempt for a landscape and

for the people that lived there and for the heritage the EIS was required to protect.

He said there was a discrepancy in the air pollution report of about 20 times difference

between the modeled and measured air pollution levels with no explanation of how this

could have occurred from Mr. Crawford, the air pollution expert. He said the landscape

expert argued he could screen or landscape away a major interchange which was again a

contempt for the ordinary common sense view of what the likely impact was. He said that

there was a socio-economic report by Mr. Prendiville who accepted that he had no

sociological or economics expertise yet purported to give evidence on socio-economic

impacts.

Mr. O'Donnell suggested that for each category of evidence there was a huge inadequacy

and discrepancy with huge holes in what had been submitted and said that if a script were

to be written for ineptitude and inadequacy, a more disparate and inept number of people

could not have been chosen. He submitted that when the Inspector looked at the evidence

he had heard, then he could not rely on what had been stated in this section of the EIS. He

said that of all the landscapes possible, this one was the most critical for such mistakes to

be made and that to have prepared and relied on such a document made it not surprising

that they chose to build an intersection in this particular site in an EIS that was so

fundamentally flawed. He submitted that it was simply not possible to allow the damage

that would happen in this case to occur and said that of the range of experts, and he

named them all, not one could stand up and say that their report was complete and

accurate and free from flaw. He said the contrary was the case because each one was

hugely deficient, inadequate and had been shown to be such.

Mr. O'Donnell then said that there was an alternative and that it had been said on

numerous occasions to the Hearing that for this section of the route you looked at the

proposal to the east of Skreen. He said that he had deliberately chosen to compare these

two routes and that on each heading they were either equal or the road east of Skreen

was better. He said that for air pollution they were probably equal but that it would be

872

better not to cause air pollution to a world heritage site or a public park so the route east

of Skreen was the better choice. He said that in archaeological terms it was accepted the

road east of Skreen would be less damaging than a road through Tara and that in terms of

built heritage there were no protected structures east of Skreen. He said that for ecology

while you would have to cross the Boyne, this would not be at the confluence of the

Boyne and Skreen and that spawning would be protected, which made east of skreen

better. He said that in landscape terms Mr. Burns accepted both were attractive but

clearly a world archaeological site had a particular impact and should be avoided in

landscape terms. He said that in terms of noise and vibration a public park and a world

heritage site and a centre like Dalgan Park were places to avoid in terms of excessive

noise levels.

He said that the only section that sought to be relied on in providing a negative impact in

the Tara to Navan section was the socio-economic impact and, he said, this was by a

person who had no expertise in this area at all and his evidence must be discounted

because of this. He said that it had been shown to the Hearing that the entire basis of the

approach was fundamentally flawed and he submitted that if the two routes were looked

at objectively in the terms set by the Council then the road east of Skreen was the

preferred option. He said there had never been a satisfactory explanation given why that

route had not been selected and said that it came down to whether the EIS could be

depended on and said it was his submission that it could not be given reliance. He said

that even if reliance were to be given then the route in the EIS was not the optimum

because he said it could never be the case that you could build a motorway through Tara

and a major interchange at the bottom of the hill where Tara begins and that it could

never be right to build a motorway through a public park.

Mr. O'Donnell suggested the answer for that was because the public park and the uses

within Dalgan Park were never identified in the EIS and said that nowhere within the

EIS were the range of activities and public nature of the facilities in the uses of Dalgan

Park ever identified, so they were not had regard to. He said that if the Council had

directed its mind to those uses he had no doubt that they would not have chosen the route

they did as they would have been aware of the significance of the Boyne and Skreen

rivers. He said that had they been aware of the full extent of the archaeology and its

impact on Tara, he had no doubt that they would not have chosen that route and he said

the EIS was so flawed that it was not surprising they chose to proceed with that route. He

said the Council's solution was to destroy Tara because, quoting from the McGarry v.

Sligo County Council Supreme Court judgement, he said destroying a monument likc

Tara was not just the monument but its context and if its context was destroyed, you

destroyed the monument.

Mr. O'Donnell said that if a motorway was run through a public park at a place used by

the public then this effectively destroyed the public park, that if you built a major

intersection across a river spawning area you put that to an unacceptable level of risk and

that if you put all of these together you had a recipe for disaster. He said that could never

be confirmed by An Bord Pleanala if they were to properly direct their mind to what had

been proposed here. He said the Council might reply that they would destroy significant

873

amounts of landscape, archaeology and ecology but that they would preserve these by

record and he said he would conclude by saying that if the record was anything like the

record contained in the EIS, then it would bear no relationship to what was, in fact, there.

He submitted that having regard to the evidence there was only one solution for An Bord

Pleanala and this was to refuse to confirm this section of the road and he further

submitted that this was the appropriate recommendation for the Inspector to make.

143. 3. Closing Submission by Alan Park on behalf of

Bellinter Residents Association :

Mr. Park said that the main thrust of the BRA position regarding the proposed motorway

was, and remained, their disagreement and dissatisfaction with the Route Selection

process as they believed this process did not fairly assess the various options and that the

wrong conclusion had then been reached. He said they had demonstrated that the

preferred route of those who had attended the Public Consultation process was ignored

and that the EPR was the second least preferred and he said the Corridor Selection

process was never put to Public Consultation which, he said, meant that the process was

not correctly followed.

Mr. Park said there were many areas in the Summary Matrix in Table 4.2 in Vol. 2 of the

EIS that were not correctly rated. He gave details of these which included :-

1. The impact on "minor roads" rated as "slightly positive" which they disagreed with

and referred to the extra length for his neighbours in walking to Dalgan Park from

their homes or to the shop at Garlow Cross, where a longer round journey of 5.1 km

compared to 3.9 km would now apply.

2. He said that the Landscape & visual impact for the EPR (Blue Route 2) had been

wrongly entered in Table 4.2 and that the value given was understated and referred to

the values shown in Table RSR/6.6.1 as being the correct ones, and he said that Mr.

Guthrie's response in cross-examination was erroneous.

3. He said that both Consultant Archaeologists had clearly reported that any route

between Tara and Skryne Hills was not a desirable option and that this was supported

by Conor Newman and he suggested that Duchas were also opposed to a route

through the Tara/Skryne valley and said that they believed the EPR was Route P. He

referred to the failure to include the geophysical survey images in the EIS and

suggested that this could only have been done to conceal the full facts. He said that

the BRA believed a route through the Tara/Skryne valley should be avoided at all

costs.

4. He criticised the impact on private properties in the Residential/Private Property

category in Table 4.2 of "moderately positive" saying that there was no positive

impact on the properties in Bellinter, Ardsallagh or Cannistown and said this entry

was erroneous.

5. He said it seemed the Community Impacts were almost forgotten with no mention

being made of Dalgan Park or Dowdstown demesne in the socio-economic section,

nor of the impact on the walks in Dalgan Park by the Rivers Boyne and Skane, nor of

874

the work and courses carried on in Dalgan Park and Dowdstown House and said that

part of the EIS was not adequately addressed.

6. He said that they were as confused by the Noise section as the expert, Mr. Summers,

seemed to be. He said that some of the figures presented were incorrect, that the

manner in which readings were taken was open to doubt, that Mr. Summers only

visited the site for the first time in August 2002 after the EIS had been published and

that the Council were now saying that a new noise criteria would be adopted to assess

the noise impact. He said that the BRA saw no alternative to a complete reassessment

of the entire noise section in the EIS to provide correct values for Table

4.2 of Vol. 2.

He said that the BRA found Table 4.2 of Vol. 2 of the EIS was not a true and accurate

assessment of the impacts and submitted that the values in that table should be corrected,

which could then change the conclusions of the selection process.

Mr. Park said they were not satisfied that the provisions for the railway line at

Cannistown had been adequately provided to meet the requirements of Iarnrod Eireann

and said that the railway line should not be economically disadvantaged by having to

construct a bridge over the motorway. He said the railway connection was an important

part of the CDP and the SPGs and deserved to be considered as part of an integrated

transport plan for the County and not as a sort of optional extra that might be taken up in

the distant future.

Mr. Park referred to the response given by the Council to the BRA objection to the EPR

and said that the only issue of substance in it was a description of the bridge crossing the

River Boyne, with every other aspect of the issues they had raised being ignored. He said

they considered Mr. Harold O'Sullivan's response inadequate; that of Mr. Burns was still

awaited; that they had problems with Mr. Summers credibility; that the MC O' Sullivan

response on Blundellstown & Cannistown Interchanges failed to mention Blundellstown

and said that the Halcrow Barry response described the topography of Blundellstown

without explaining the rationale for that Interchange.

Mr. Park concluded the submission by saying that the BRA had found the experience to

be less than satisfactory; that they had found it most difficult to get full and proper

information about their queries and fears; that they had found many answers to be

economical of the truth and that they had not been given full and free access to

information they had legitimately requested and they felt advantage had been taken of

their inexperience and lack of knowledge in this field. Mr. Park said that to defend their

own interests, property and environment they had been forced to spend considerable time,

effort and money in pursuing their case and he asked that An Bord Pleanala would look

sympathetically at their right to recover costs and expenses incurred with the Hearing. He

said that the BRA appreciated the Inspector's forbearance relating to their presentations

and cross-examinations as they were made to feel at ease in an area where they were

inexperienced.

875

143. 4. Closing Submission by Brendan Magee on behalf of

the Meath Road Action Group :

Mr. Magee said that the MRAG objection to the proposed M3 was based on their

assertion that the wrong route had been chosen. He said that the EIS was a very well put

together document and that, taken at face value, it was difficult to find fault with it. He

said it was their contention that it was a flawed document, since it dealt only with the

Preferred Route, and that of deliberately hid the fact of another route option being more

viable from an environmental and cost point of view. He said that, in spite of the

Council's efforts to prevent the MRAG getting information about the proposal, they had

managed to get enough to be able to prove that the wrong route had been chosen and said

that he would now summarise this proof, which had been exposed during the crossexamination

of all of the Council's experts.

Mr. Magee said that the MRAG instinctively knew that the wrong route had been chosen

when it was proposed to be located between the Hills of Tara and Skryne through the area

with the highest concentration of known archaeological sites and said that this had been

proved when they got copies of the Route Selection Report, The Archaeological

Assessment Paper Survey by Valerie Keeley and the N3 Navan to Dunshaughlin Route

Selection by Margaret Gowan. He referred to neither of the archaeological reports

recommending the Preferred Route and Ms Gowan's evidence under cross-examination

of Route P being the most viable from an archaeological perspective. He also referred to

Conor Newman's presentation, the geophysical survey results and his opinion of the

archaeological dimension of the EPR going to be hugely expensive in time and money.

He then referred to the various expert witnesses for the Council and the Ecology, Air

Quality and Landscape & Visual sections in the EIS and said that a reading of their EIS

reports would give the impression that the Preferred Route was the "right" option but

when the same experts report in the Route Selection Report was read you found that

another conclusion was reached and that the preferred route was not the best option from

the perspective of that discipline. He said that there was no assessment made of the Built

Heritage in the Route Selection Report and that Mr. Guthrie had not disagreed with the

quotation from that Report which said that route P did not come close to structures in the

area. He said that the Noise figures in the EIS were admitted to be wrong by the noise

expert and asked what legal standing had an EIS when it had been proved some of its

information was wrong.

Mr. Magee submitted that none of the environmental experts employed by the Council

had recommended the Preferred Route and said that 5 of them had recommended another

route, Route P. He submitted that the decision to ignore all of the experts advice was

taken by Mr. Alan Guthrie as the Project Co-ordinator, and said that Mr. Guthrie had

justified his decision by saying that the primary reason was that the Preferred Route

affected fewer people. Mr. Magee submitted that the Assessment Matrix used to assess

all route options was proven not to have given any serious consideration to the effect on

people in the selection process, with the rating being shown as " slight positive" for all

options.

876

Mr. Magee said that Mr. Guthrie's only stated reason for not choosing Route P was its

remoteness from the N3 and he said that was not true, since the P route crossed the N3

only 2 miles from Navan, while the proposed junction at Blundellstown was 4 miles from

Navan. Mr. Magee questioned the location of a junction at Blundellstown on safety

factors because of the history of fatal accidents on the existing N3 between

Blundellstown and Navan which, he said, would also be added to from the increased

traffic using that section of the N3 to access the motorway.

Mr. Magee said there were a number of questions to be answered by Mr. Guthrie which

included why the NRA guidelines for Public Consultations were not followed ? ; why

were the Public's views expressed at those Consultations ignored ? ; why was

information not made freely available to the public ? ; why were documents changed and

edited before being made available to the public ? and why was false information given

to the public.

Mr. Magee said that, having heard the evidence, the MRAG believed that the Inspector

could not recommend that the route be approved, particularly the section going through

the Hill of Tara area. He said that the MRAG were not against a motorway but were only

against the proposed location and he said that they had put forward a credible alternative

that had many advantages over the present proposal. Mr. Magee concluded by asking that

a full feasibility of the MRAG Alternative Route Proposal be undertaken by the

NRA/Council before any final decision was taken.

( Note -- A hard copy and CD of the previous MRAG submission on Day 17 was handed

in by Mr. Magee and are listed in Appendix 4 of this Report at Day 25. )

143. 5. Closing Submission by Greg Casey, Solicitor,

on behalf of Sarah Maher, Ardbraccan House, Navan :

Mr. Casey said that he would start with what he would loosely call the Facts and that Fact

No.1 was the requirements for assessing needs for motorway schemes in the NRA

Guidelines which, he said, were quite strict. He said he would outline the chronology of

events that followed from when they had made a telephone request to the Council on 12

November for the completed Phase 1 & 2 questionaires returned to the NRA for this

scheme as required under the 1999 version of those NRA Guidelines and were told they

would be faxed to them. He said that by 18 November when no FAX had appeared they

again phoned the Council and spoke to Nicholas Whyatt and were then told that they

could not have these questionaires since " They" whoever, he said, "They" were had met

and decided the public were not entitled to see these under the Freedom of Information

Act due to commercial sensitivity. He said that on being reminded that access to

Information on the Environment under 90/313/EC and the Irish Regulations SI 125 of

1998 applied here, Mr. Whyatt had replied that this had also been debated and the request

was still being resisted but had requested a written application. Mr. Casey said they sent

off their written request on 18 November and repeated this at the Hearing on 19

877

November and that, in fairness to Mr. Whyatt, he supplied a letter to them on 20

November that explained the 2000 NRA Guidelines were in Draft form and the NRA did

not require that Phase 1 & 2 questionaires to be completed. He said they reminded Mr.

Whyatt that the 1999 guidelines were quite specific and would have applied at route

corridor stage, and said that Mr. Whyatt doubted these existed but had returned at 6.30

pm yesterday (20 Nov.) with those 1999 Guidelines.

Mr. Casey then read the Council letter of 20 November 2002 "--- I resume the

questionaires you referred to are those contained in the NRA Project Management

Guidelines (PMG), March 2000. You should note that these non-statutory guidelines

were not in place when the consultants were originally appointed to design and develop

the section of the scheme relevant to Ardbraccan House. Generally the PMG were

published when the majority of the sections of the scheme had reached the constraints

study, Phase 2, and route selection, Phase 3, stages of development. After publication of

the PMG, the Council consulted the NRA about their use in this scheme including the

completion of the questionaires. The NRA informed the Council that on the M3 Clonee

to North of Kells scheme they only required formal submission of the questionaires for

approval for route selection Phase 3 and that there was no need to get retrospective

approval for Phases 1& 2. Therefore there are no completed Phase 1& 2 questionaires for

any section of the scheme that were submitted to the NRA for formal approval. The one

exception to this is the Kells to Carnaross section which lagged behind the remainder of

the scheme. When the PMG were published, formal approval was needed to proceed to

route selection. Phase 3 for this section of the scheme was obtained from the NRA.

Notwithstanding the foregoing, our file does contain a completed Phase 2 questionaire

from MC O'Sullivan for the Navan by-pass section and from Halcrow Barry for the

Dunshaughlin to Navan section. I attach a copy of the Navan By-pass Phase 2

questionaire for your information. However, I would reiterate that neither of the Phase 2

questionaires for the Navan By-pass or the Dunshaughlin to Navan section were

submitted to the NRA in accordance with the PMG."

Mr. Casey said he was proposing that the Road Scheme Development Guidelines of May

1999 be submitted to An Bord to peruse at their leisure since Phase 1 as set out in the

guidelines was a pre-planning questionaire that set out in outline what the Local

Authority wanted to build, be it a motorway or whatever, and then, he said, the NRA

responded to that and sanctioned the Local Authority to go to Phase 2. He said they knew

these were non-statutory guidelines but they were guidelines that the NRA imposed

stringently relating to road planning. He said that the purpose of the Phase 1 questionaire,

which he said would only take about 10 minutes to complete, was to allow the Council to

proceed to Phase 2 and that was not funded by the NRA. He said Phases 2, 3 & 4 were all

funded by the NRA and that it was clear this particular scheme would be funded in its

entirety by the NRA, whether that was by a PPP or otherwise.

Mr. Casey then discussed the Phase 2 questionaire for the Navan By-pass which, he said,

had not been approved by the NRA but mirrored the Phase 2 questionaire set out in the

May 1999 guidelines and said that the questions answered mirrored largely the concerns

that Ms Maher had been enunciating to the Council and the NRA throughout the year and

878

this Hearing. He referred to the questionaire having been signed by Ms Joyce and said

that the questions covered were " field checked, streams, rivers, canals etc having regard

to drainage systems, local knowledge" both ticked yes; " springs, wells, watertables,

turloughs " it said "no information on wells". He said it said something relating to

turloughs, something about farm walkover aerial photography and preliminary site

investigation undertaken and otherwise no. He said that in relation to ground water the

answer was no and that written after that was " preliminary investigation undertaken". He

said that at "R" was asked " Has a review of Irish /EU legislation/ regulations relating to

infrastructure/funding/regulations been carried out, ie to include issues relating to

licensing requirements during construction, quarries, tips, mobile plants etc" and said the

answer was no. He said the answer to a question " are there known areas of special

designation within 10 kms. of the study area at B" was yes and that it referred to the NHA

on the Boyne and archaeological sites at Tara and he referred to the Navan By-pass as

not going near Tara.

Mr. Casey then said that from the 1999 Guidelines once the NRA gave the go-ahead, that

the first thing to be done was to draw up a Constraints Report; that the second thing was a

Corridor Selection Report; that the third thing to happen was the Route Options Report;

that the fourth thing was there should be a Route Selection Report and the fifth thing was

that the Emerging Preferred Route (EPR) should be produced. He said that it would be at

that point that the Members of the Council would approve the EPR which then went to

pre-planning stages and EIS and on the a Hearing like this one. He said that having set

out what was the correct chronology, he would now look at what the actual chronology

was which, he said, had been dug out during the course of the Hearing. He said that the

first thing considered appeared to have been in February 2002 (as he said it) and was

called Route Options; that the second thing appeared to have been considered in May

2000 and was the Constraints Report with Archaeology February 2000 and Architecture

April 2000; that the third thing considered appeared to have been a powerpoint

presentation to the Meath Councillors where the EPR popped up on the screen; that the

fourth thing, which he said was in its right order, was the Route Selection Report in

December 2001 and that the fifth thing was the Corridor Selection Report that arrived in

January 2002.

Mr. Casey said that as he understood it the Corridor Selection Report should have arrived

before the Route Selection Report and that the Corridor Report was dated January 2002

which was after the date of 19 December 2001 when the Council had advertised their

intention to vary their CDP and the Navan Environs Plan to allow for the construction of

a motorway incorporating the route west of Navan through Ardbraccan up to Kells. He

said that the Corridor Report arrived after the variation was advertised and that the Route

Selection Report, which was dated December 2001, should have arrived after the

Corridor Selection Report but said that by the time the Corridor Selection Report was

there it was already a fait-accompli as far as the 2001 CDP was concerned. He said that

the Route Selection Report of December 2001 and the Corridor Selection Report of 2002

had only been made available at the Oral Hearing.

879

Mr. Casey said this juxta-positioning of the planning such a project defied all logic and

had placed members of the public in County Meath and in particular, his clients the

Mahers, in a material disadvantage which he would now deal with. He said that the

Meath CDP of 2001replaced the 1994 CDP, which had been allowed an extension of time

by the Minister to allow for debate and for the public to be consulted, and that Plan

became operative in March 2001. He said that March 2001 was ten months after the EPR

for the motorway had been shown to the Members of the Council at their meeting on 8

May 2000 and that a Matrix ( which he showed to the Hearing) had been shown to the

Councillors at that meeting. He said he believed that the matrix shown to them was a

simplified version of the actual matrix for what reason he did not know, but suggested it

was to keep them "in the dark".

He said that between May 2000 and March 2001 when the CDP was adopted nothing had

been done to incorporate the EPR into the CDP and that this required the advertising of

the Variations on 19 December 2001, both to the Meath CDP which was 8.5 months old

then, and to the Navan Environs Plan and he said that the people of Meath deserved an

explanation for why that happened. He said the advertisements allowed for submissions

to be made up to 26 January 2002, but that reports had been prepared on 30 and 31

January for circulation to Councillors on the Friday, 1 February, to vote on the Variation

at their meeting on Monday, 4 February.

Mr. Casey said there was a curious matter relating to those variations of the Meath CDP

of 2001 and the Navan Environs Plan of 1997 and he referred to Mr. Killeen's evidence

that the 1994 CDP and 1997 Navan Envirions Plans were important documents to be

considered regarding their objectives together with the 2001 CDP and the Variations as

being the cause of some curiosity for him. He said that he could not see what relevance

was the 1994 CDP now and could not understand what the Navan Environs Plan had to

do with it after the adoption of the new CDP in March 2002 but that he now realised that

the Navan Environs Plan of 1997 was produced as an Area Plan by the Council under the

1963 legislation as part of the infrastructure of the 1994 CDP. He said that when the 2001

CDP kicked in, then everything that had to do with the 1994 CDP was cut off and that

you started with a new fresh clean sheet. He said that he could find no reference in the

2001 CDP of a carryover into that Plan of the Navan Environs Plan of 1997 and said that

if anyone could point him to the carryover into that Plan, he would be delighted.

Mr. Casey then said he would theorise that if there was not a carryover into the 2001

Plan, that there was then a significant and material lacuna in Part 2 of the 2001 CDP

where there was no mention of Navan and its Environs in relation to various County

plans around the County contained in that document. He suggested that at this stage the

lacuna was so gaping that it undermined the viability of the 2001 CDP and said that, at

any rate, the variation proposed to the Navan Environs Plan 1997 on 19 December 2001

was adopted on 4 February 2002. He said that Variation allowed specifically for the

development of a motorway from South Navan up to beyond Ardbraccan and allowed for

the construction of feeder roads from the centre of Navan out in a southerly and

southwesterly direction to the Athboy Interchange and that that was what the Navan

Environs Plan allowed for. He said that it seemed to him that you could not vary a Plan

880

that did not exist and that he was submitting to An Bord that it was highly questionable as

to whether there was any variation of the Navan Environs Plan of 1997 on 4 February

2002, because he was saying no such Plan existed which left a gaping hole in the middle

of the 2001 Meath County Development Plan, and said he was signaling this to everyone.

Mr. Casey then referred to the Consultation processes and to the case of Attorney General

and the relation of Frank McGarry, Paddy O'Hara, Patricia Mulligan,Niamh Crimin, John

Hamilton in their own right re Sligo County Council, Supreme Court 1985, no.118/133,

Walsh, Hedderman,and McCarthy J.J. of 17 February 1989 commonly known as the

Carrowmore Graves case and he quoted from the judgement which, he said, was well

known to An Bord. One part of the extracts he quoted reads " The Plan is the statement

of objectives. It informs the community in its draft form of the intended objectives and

affords the community the opportunity of inspection, criticism and, if thought proper,

objection. --- The private citizen refused permission on such grounds ( ie material

contravention of the CDP) based upon such objectives may consloe himself that it will be

the same for others during the currency of the plan and that the Council will not shirk

from enforcing those objectives on itself."

He said the EPR was adopted by the Councillors on 8 May 2000 with the CDP not

adopted until the following March and asked why, given Mr. Justice McCarthy's words,

the citizens of Meath and his Client, were not given an opportunity to ascertain

essentially what was now adopted by the variation to the Development Plan 8.5 months

after that EPR came into being, which allowed for the motorway to go past Ardbraccan,

and why that was never in the consultation process and the drafts of the Plan prior to its

adoption. Mr. Casey said he would put on the record that the variations were adopted on

4 February 2002 and that the newspaper advertisement of the fact of the variation to the

Meath CDP and Navan Environs Plan was dated 29 May 2002, almost four months later.

He said he could find no explanation why there was such an extendcd period of time

between the adoption of the variation, which took effect immediately, and the notification

to the people of Meath that it had come into being. He said that in April and May 2002

Ms Maher had sent two people to the Council Office in Navan seeking an up-to-date

version of the CDP and that the professional representative was given Volumes 1, 2 and 3

of the 2001 Plan without the Variation and the person who went in on her behalf from

Ardbraccan was given the same. He said that again on instructions a representative of Ms

Maher was sent into the Navan Offices of the Council during the course of this Hearing

in August looking for the current version of the CDP and was again given Volumes 1, 2

and 3 without the Variation.

Mr. Casey submitted that if the chronology he had given was correct, then there had been

a denial of the rights to participate in the process of (a) the routing and positioning of the

road, (b) the CDP, (c) the variation because the variations were published long after the

time had elapsed in which the public and those affected by CPO notices could make their

submissions and objections to the EIS and CPO as the documentation was not available.

He submitted that you could not make a reasoned submission which would be technically

correct in law or in fact unless you were in receipt of, and aware of, the passing of the

variations of 4 February 2002. He said that, to him, amounted to a denial of public rights

881

of participation in the process leading to the Oral Hearing and on to An Bord and any

adoption by An Bord of this scheme.

Mr. Casey said he now wanted to come to the scheme itself and said that the statutory

basis for there being a Hearing was to look at and have an Oral hearing into the CPO and

to participate inn a fact-gathering exercise in connection with the EIS and the EIA. He

said he wanted to remind An Bord that the concept of EIS and EIA was not a creature of

Irish domestic law but was a creature of Europe by reason of the various votes in favour

of further European integration over the years. He said that the Directives relating to EIA,

Habitats and Ecology, Water Quality and Air Quality emanated from Europe and were

binding on us here. He said that we were sometimes good at transposing the requirements

of European Law particularly in the areas of agriculture and such matters, and were

particularly strict in their enforcement, and said that we were not so good in other areas

and were not very good at it in terms of the area of EIA.

He said that some questioning had arisen the previous day relating to data and whether

there was a requirement to furnish data or not as part of an EIS. He said the relevant

directives were 85/337/EC as amended by 97/11/EC on the assessment of certain public

and private projects in the environment. He said the recent Directive updated the original

EIA legislation and amended a number of articles of the 1985 Directive. He read Articles

3 and 5 sections (1), (2) and (3), with section (3) saying in part "The information to be

provided by the developer in accordance with paragraph (1) shall include at least : ---- (3)

the data required to identify and assess the main effects which the project is likely to have

on the environment" and he said that he emphasised that section (3) required the data to

identify and assess the main effects, not the adverse effects but the main effects. He read

the next section as " An outline of the main alternatives studied by the developer and an

indication of the main reasons for his choice taking into account the environmental

effects" and the last section as " A non-technical summary of the information mentioned

in the previous sections". Mr. Casey said he was tendering this to An Bord for

consideration in the context of the EIS before the Hearing for consideration.

Mr. Casey said that the 1997 EIA Amendment Directive was implemented into Irish law

by the 1999 EIA Regulations and that in Schedule 6 it set out the information to be

contained in an EIS and that it mirrored the amendments in the 1997 Directive which he

had referred to above. He quoted the equivalent passage from the 1999 EIA Regulations

and said this included for the inter-reaction between all of those matters including water,

culture and heritage, landscape, soil, air, material assets, flora, fauna, human beings,

climate. He said that if he took the EIS that had been furnished to the public and assumed

that was the only information available to them, until documentation started coming out

of the Council during the Hearing, he would submit to An Bord, who had already allowed

the Hearing to go to Oral Hearing, that if An Bord considered the contents of the EIS

furnished to the Hearing and made available to the public they could not possibly come to

the conclusion that the EIS and the information contained therein complied with the

requirements of either the 1997 EU Directive or those of the 1999 Regulations

implementing that Directive.

882

He said he would give one example of this and said that Ms Joyce might have been

wondering why he had been asking her questions about the conclusions set out in the EIS

at Volume 5A relating to soil, water, geology and hydrogeology and why he was harking

on about the Report of April 2002 which post-dated the EIS and which appeared to

review the question of water, geology and hydrogeology at the Ardbraccan area. He said

that he was not present for the balance of the Hearing on the other Sections all the way

from Clonee but, he said, all the borehole logs, trial pit logs and core hole logs and results

and all the data relating thereto should have been included with the EIS, so that the main

effects of the project on the environment could be identified. He said he had sight of the

borehole test results, Mr. Finlay had a quick glance at them, Ms Maher had the

opportunity of examining them and so had Mr. Sweetman but that no other person

affected by the line of the project from the Durhamstown Road Overbridge to the start of

the Navan By-pass section had been given any opportunity to examine the data referred

to or contained in those Reports. He said that it appeared to him that those borehole logs

were nowhere to be found and that it appeared to him to be a gaping hole in the middle of

the EIS. He submitted to An Bord that it rendered the EIS unacceptable and unworthy of

description with the term of EIS.

Mr. Casey said that Ms Joyce had said that the part on hydrogeology and geology and

other related matters in the EIS were an assessment by someone who was no longer with

the Company and that it was conclusions drawn by him from data that were put in the

EIS and that people were simply supposed to accept a conclusion that he had come to as a

fact. He said that they could not do that, and said that any conclusions posited along the

entire route that were not backed up by the data could not be regarded as sufficient

statements of fact to be assessed so as to (a) identify and then (b) to assess the main

effects on the environment, and then to go on to consider whether they had any adverse

impacts on the environment.

Mr. Casey said that Ireland had a peculiar record with Europe in its track record on EIA

and that Ireland had a peculiar record before the European Commission and before the

European Courts of Justice and was being regularly hauled before the Commission and

the Courts of Justice for failure to implement environmental directives and regulations.

He said he would refer An Bord to the judgements of the European Court of Justice

against Ireland in that regard, including one of the Court Fifth Chamber of 21 September

1999 relating to Directive 85/337/EC for Case C/392/96, which related to thresholds and

matters of that nature. He said that Ireland's defence against that action was that it was

pulling up its socks and that it was improving its EIA regulation and domestic legislation

to enable it to apply the 1985 Directive and said that while this was going on, the 1997

Directive was coming into force with the 1999 EIA Regulations. He said that contrary to

what Ms Dempsey thought, these regulations applied equally to road building projects as

much as they did to any other project and that there was no waiver for road projects. He

said there were no lessor thresholds for roads than there were for dumps, for water

extraction, for airports, for gas terminals or for anything else, with the same rules

applying.

883

Mr. Casey said that in a recent opinion of the Commission addressed to Ireland in, he

thought, September 2001 which An Bord already had from another Hearing, the

Commission, under Article 226 of the Treaty, addressed Ireland's failure to fulfil its

obligations under Directive 85/337/EC and Amending Directive 97/11/EC regarding the

requirements of an EIA and he quoted from page 3 of that Opinion as "The information

to be provided by the developer in accordance with paragraph (1) shall include at least a

description of the project, a description of the measures envisaged in order to avoid ---

the data required to identify and assess the main effects -- etc." He said that the Opinion

dealt with specific cases where the Commission believed that Ireland had been in breach

and that one of those was a road project, complaint P1998/4307, which concerned the

environmental impact of a motorway project in Co. Kildare called the Kildare By-pass

which was given development consent on 22 January 1996 following an EIA. He said

that project involved constructing a motorway below the level of the surrounding land

which required the constant removal of large amounts of water from an acquifer, or a

natural reservoir, to keep the motorway dry and said that everyone present would be

aware of the Pollardstown Fen. He said he was tendering this to An Bord as he thought

that An Bord knew the comments of the Commission in relation to that complaint and he

said that the instigator of that complaint was Mr. Sweetman.

Mr. Casey said that the net effect was that before development consent could be given, all

of the data must be furnished and made available to the public for the public consultation

process and that the public must be consulted and that al of the data in the fact-gathering

exercise would then be assessed by An Bord. He said that it was okay for the EIS to set

out the likely effects on the environment of a particular plan or project, and said that as a

matter of good practice both positive and negative impacts should be set out, and that

then to proceed to come up with whatever the types of remediation or mitigation that

were capable of objective assessment. He said that in the case of this EIS he believed that

it did not contain fact, because the data was not provided, but only the Consultants views

on the merits of this particular project and he said these were saying it was great but we

are not going to give you any of the information which would allow you to question any

of the conclusions reached. He said that Ms Maher had referred to a rather peculiar

statement made to the Hearing which, in effect, said that if it was not put into the EIS

then they could not be blamed for being wrong and he said that the execution of an EIS

with such an attitude did not comply with the legal regulatory framework.

Mr. Casey again referred to the adoption by the Council on 8 May 2000 of the motorway

route and said that was done on the basis of a matrix that was simplified so that they

could understand it and that the effect of that simplification was to merge the boundaries

between the weighted criteria across a number of areas. He said that the crossexamination

had borne that out and that it had been their intention to analyse the matrix

in Table 4.3 and to try and draw a fresh matrix which would be accurate but said that the

ESB power cut had prevented them from doing this. He said that if the matrix presented

to the Councillors for the EPR on 8 May 2000 was examined, there were a number of

areas where the rankings did not make sense and that he would refer to the evidence for

this and would analyse Table 4.3.

884

Mr. Casey then said that when looking at Table 4.3, the summary matrix of the Navan

By-pass in Volume 2 of the EIS and at Routes A to H, it had to be remembered that at 8

May 2000 the 1997 EIA Directive and the 1999 Regulations were in force. He said that

for "landscape and visual" every route was ranked as neutral which he concluded meant

no impact at all and said that seemed strange since Route B went straight through the

front garden, a wing of the House and the stables and trees at Ardbraccan and on towards

the Durhamstown section and the toll plaza. He said that if Route A, which was the Route

now being examined in more detail than the others, was looked at it also said hat

"landscape and visual" was neutral and he asked that An Bord when looking at these two

matters would exercise common sense in seeing if there was any reality to those two

weightings. He said that in terms of "air quality" there was a major negative impact

found for Route A and a moderate negative impact for Route B and wondered how that

difference could have arisen. He said that in terms of "planning and development" the

matrix said Route A was extremely positive and wondered how that could be given the

CDP of 1994 and Navan Environs Plan of 1997 on 8 May 2000. He said that may well be

so in terms of the varied Plan and he suggested it flew in the face of logic that there was a

big blue blob there and that Route B was a major positive since that went through

Ardbraccan House itself. He said he was only analysing Routes A and B at that time to

show how ridiculous that summary matrix was and said that if geology was looked at,

which was neutral across the board, you could not even come to a conclusion whether it

was correct or not on the basis of all that they had heard and been given.

Mr. Casey said that there were a number of items in the Powerpoint presentation to the

Councillors on 8 May 2000 relating to Routes A , B and even H that beggared belief in

logic and he said they would be submitting that to An Bord later on when the ESB was

back on line for them to complete their fresh analysis. He then referred to the Conor

Newman response to Margaret Gowan's written response which had been submitted to

the Hearing by FAX that morning ( See Section 82.2 of this Report) and he read Mr.

Newman's response to Ms Gowan's point 6. He said that it appeared Mr. Newman was

making the point that the favoured route from the archaeologist in the Constraints Report

of February/March 2000 was to go from north of the Hill of Skreen and not to turn

northwest between Skreen and Tara and head to south Navan via Dalgan Park and head

for Ardbraccan south and west of Navan. He said that would mirror the experience of

Valerie J.Keeley in their recommendations of February 2000 when they said if they had

to choose a preferred route, they would say that a route east of Navan and around the

north of the town and to Kells would be the preferred route.

He said that he could not find any reasoning that would upset that viewpoint between

February and May of 2000 because Mr. Breen in cross-examination admitted that the

field walking was only for Route A and was only commenced after 8 May 2000. He said

that Mr. Breen had been forthcoming and fair and that some of the things he had said

might be unpalatable when viewed by the NRA because of he confirming he only started

walking routes after May 2000 and then only route A. He referred to Mr. Breen's

statement that some site excavation including topsoil stripping might be required in the

area to the southwest of the Mound, south of the Bohermeen Overbridge and the corner

of the field that was being landlocked. He said that area was also referred to in Ms

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Rooney's Report they had tendered to An Bord and said that in the NRA Guidelines of

1999, which were non-statutory but nonetheless binding, it was stated that it would be in

order to conduct trial digs and matters of that sort. He said that in the document issued by

the Department of Arts, Heritage, Gaeltacht and the Islands issued in 1999, "Framework

and Principles for the protection of the Archaeology Heritage" it stated at paragraph 3.6.6

on page 27 that " EIA should, unless there is substantial grounds to show that it is not

necessary, involve the carrying out of archaeology assessment including, where

appropriate, test excavation". Mr. Casey said they knew from Mr. Breen that there would

have to be test excavation along the line of the route passing Ardbraccan and he said that,

not having been present for all of the other areas from Clonee to Kells, he could not say

whether similar excavations should have been carried out elsewhere as part of the EIS

process leading to the data to be contained in the EIS. He said there was nothing to have

prevented this and that it was recommended by Arts, Heritage, Gaeltacht and the Islands.

He said that it left them in an "Alice in Wonderland" situation in relation to how the

various matrices were arrived at for archaeology at Table 4.3 in Volume 2 of the EIS, and

in the matrix presented to the Councillors.

Mr. Casey referred to Ardbraccan itself and said that Mr. O'Sullivan, who had only

become involved long after the route had been adopted by the Councillors, did not really

disagree with all that they, and Mr. Shaffrey, were saying about Ardbraccan. He said that

while there might be slight differences in emphasis, both Mr. O'Sullivan and Mr. Breen

agreed that Ardbraccan was a very rich area in terms of its historical, archaeological,

architectural and landscape context. Mr. Casey said that he had already read into the

record the definition from the 1999 Act relating to national monuments and that

architectural heritage included the historical, cultural, social, archaeological aspects and

the setting and it included groups of sites which, by definition, must include the groups of

sites plus their settings. He said he would remind An Bord that that legislation of 1999

was in force in 2000 and that if any element of common sense was applied in looking at

the setting and the objectives of the CDP, then the placing of a motorway on the

landscape 650 metres away from Ardbraccan directly in its view, within its historical

demesne, that part of it which was no longer in the ownership of the present owners of

Ardbraccan who, at great personal expense, had managed to reclaim that area west of the

farm road, was something which in saying there would not be an effect on the setting by

the imposition of a 21st century superhighway was a ludicrous statement. He said the

Inspector had commented on he taking a quick trip around West Cork to give examples

of the juxtaposition of ridiculous edifices in the settings of some of our more important

historical and archaeological and architectural sites but he had done that to make people

think about what was being imposed on the landscape of Ireland and on those parts of the

landscape which were precious and immoveable and once destroyed could never br

restored.

He then read from Volume 5C at page 16, paragraph 7.3 in Appendix I where Mr.

O'Sullivan referred to the issues raised by Ms. Maher in her letter under four headings

and the letter from Mr. Starret CEO of the Heritage Council to Mr. Tobin CEO of the

NRA and then he read from paragraph 7.4 on page 17 where Mr. O'Sullivan referred to

matters not impinging on the House but on its settings and said that Mr. O'Sullivan was

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saying it would affect the settings. Mr. Casey submitted that it was a matter of law and

fact that the siting of the motorway with all of its intended environmental impacts,

including traffic, air, noise, water, visual impact, dust, pollution, and whatever affronted

the eye in having to look at it in the context of a richly endowed historic landscape

offended the law, offended the particularity of the objectives of the Meath CDP as

opposed to the general objectives. He said that particular objectives must be given greater

weight than general objectives since they had been made particular. He said the siting

offended against the sense of pride in our surroundings, in our countryside and in our

heritage whether that heritage came from pre-Christian, Christian or Norman times, from

the Protestant Reformation, the 800 year war with Britain or 100 years ago, it did not

matter as it was part of our heritage.

Mr. Casey said that he understood Ms Joyce to say that the Durhamstown road had been

moved off-line further north to facilitate Ms Maher at her request but he took from her

responses to the Inspector's questioning about overpasses being built off-line or on-line

that there was a general policy for overbridges to be built off-line because of mounding

and houses along the line. He said that if that was the case then it seemed to him the

present positioning of the Durhamstown Overbridge was in line with the general policy

of the NRA as opposed to being put there to accommodate the wishes of Ms Maher.

He said that he understood Mr. Searson had given evidence and had been cross-examined

about noise and that the outcome was that noise would present an adverse significant

impact on the House and settings of Ardbraccan and said that would escape onto the uses

of Ardbraccan in terms of noise pollution. He said that there was nothing in the EIS, or

before the Hearing, to suggest that the interactions between the noise and the uses of

Ardbraccan and its demesne were tested or that the interaction between noise and air

pollution, Ardbraccan, its landscape, its setting, its cultural heritage, its archaeology, its

water, effects on water, geology, hydrogeology or its landscape were considered in their

inter-relationships to one another in accordance with the EIA directive and the Irish

Regulations.

Mr. Casey said that the problem was that Ms Maher and her husband, who had lavished

time and money on the restoration and conservation of Ardbraccan, could not even deal

with the NRA and Council on the question of a deep cutting of the roadway to ameliorate

noise because the underlying ground conditions were not known. He said that it appeared

there was overburden of some nine metres from the borehole results for Durhamstown

and possibly further back the route for maybe 200 yards to the south where there

appeared to be four more boreholes near the location for the possible borrow pits. He said

that in the absence of any data or analysis of data relating to ground water, geology and

hydrogeology, it was not possible to assess whether it was possible to cut down into this

nine metres of overburden to try and remedy the noise, air pollution, visual impact and

visual intrusion on the landscape context and setting of Ardbraccan.

Mr. Casey said that even if they had tried over the last three years to deal with the

Council and the NRA and their various advisors, they would have had to try and amass

all of the data themselves to make an assessment of all the interaction between all of

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those matters. He said they could not have come to any conclusive view with the Council

since the Council simply had not given any of the data or looked at any of those

interrelations not alone for Ardbraccan but, he said, that nowhere in the totality of the EIS

for the motorway were those inter-relationships taken into account as required by law.

Mr. Casey said that in relation to the Durhamstown Road Overbridge they did not know

whether it could be put seven metres into cut, when it could have been up to 1.9 metres

above ground with the Durhamstown Road overpass underneath, 10 metres from the

surface of the motorway.

He said they did not know if a large mound, like that described by Ms Maher at her

family home in Buckinghamshire, could be put between the road and the House as

nobody had ever addressed that question. He said nobody had addressed the question of

looking west from Ardbraccan House along the route of the motorway between

Bohermeen Road Overbridge and Durhamstown road of whether mounding could be

done or if a deep cut could be put there, and he said that by deep he meant 7 to 10 metres

and not 3 or 4 metres, as an amelioration of the significant adverse impacts on

Ardbraccan.

He said that there had been various promises made during the Hearing relating to

lighting, screening and planting of trees and he referred to Mr. Evans comments about the

point where the tangential light started towards Ardbraccan. He said he understood that

was on an embankment and as his calculations showed this to be about 1 or 2 metres

above the surrounding ground, then it would require 10 metre trees to raise the trees to a

height of 8 metres over the roadway. He doubted the feasibility of a timber screening

along the side of the road there to try and divert the flash of headlights and said these

were matters that could not be dealt with since the people who were responsible for doing

so, ie the promotors of the project, never addressed it at all.

He said that Mr. Burns had told the Hearing, by reference to a photograph taken from the

Bohermeen Road looking north along the stonewall which incorporated tree screening

and the gate pillars, that these would have to be retained and he said that Mr. Burns had

indicated, even if not in formal words, that in the event of development consent being

given that 10 to 12 to 15 metres from the western edge of that wall boundary to the top of

the embankment leading down into the cutting would be planted and that was in the

nature of an undertaking. He said that the engineering drawings indicated that would

involve taking land from the eastern side of that wall which was not allowed for in the

CPO maps. Mr. Casey said that it appeared to him from these drawings that if screening

of 12 metres was to be kept the whole way up to Durhamstown, that it could not possible

be done within the landtake and also have two in one embankments, drains 1 to 1.5

metres, the median strip and the minimum carriageways as set out in Volume 2 of the

EIS. He suggested that the Inspector should "run his ruler" along that area from

Bohermeen to Durhamstown and do the same exercise as he had done. He suggested that

the Inspector would also conclude that the screening mitigation proposed for that section

could not be achieved within the landtake and also allow for the minimum design

requirements of Volume 2 relating to carriageways etc. He said that from his examination

it appeared as if the landtake from a point some distance to the north of Bohermeen

888

Overbridge, possibly after a few hundred yards, was 16 metres too little in terms of its

width and that shortfall continued for some distance northwards. He said that even if the

mounding to ameliorate noise as outlined by Mr. Searson was started at that point, the

bunding would require a greater landtake and said that unless that was taken from Ms.

Maher he could not see how the NRA, or the concessionaire, could possibly comply with

the kind of undertakings being suggested by Mr. Burns the other day.

Mr. Casey said there was an issue about the Farm Road and that the Inspector had invited

him to make a submission about this. He then submitted that if a dual carriageway was

being given sanction in this area, then the Farm Road should be closed off from the

Durhamstown road right down to the Five cross roads other tan for the people who lived

along the road and the people who owned Ardbraccan or, effectively, the landowners.

He said he had one final matter he wanted to refer to and that was about the public

questionaires handed out as the choice of questions used always puzzled him. He said

what puzzled him even more was the weighting given to various answers as they had

been told that 79% of people said that proximity to the motorway would be their biggest

issue. He said that the answer of "people living near the route 79%" to " what in your

opinion is the most important consideration" might be an Ibsenism but whether it was

that the people living near the route should be accommodated to allow then gain access to

the route or as in the people living in east or north of Navan. He said the second most

important weighting to" what in your opinion was the most important consideration" was

that 71% said archaeology and historical sites. He said that was part of Ms Joyce's

Powerpoint presentation to the Councillors on 8 May 2000 and that if indeed archaeology

and historical sites were so important to the people who filled in their questionaires and if

found to be an important consideration to put before the Councillors in terms of

weighting, then why was not more thought and more consideration given to it.

Mr. Casey concluded his submission by saying he would return to the Carrowmore

Graves judgement and that he wanted to quote from the final paragraph where Mr. Justice

McCarthy said " I would not like to end this judgement without paying tribute to the

courage of those who have at considerable monetary risk challenged the conduct of the

Local Authority in County Sligo, thereby going some way to answer the stated

observation of important archaeologists in the western world " Do the Irish have no

pride" ".

143. 6. Closing Submission by Peter Sweetman, on behalf of An Taisce :

Mr. Sweetman said that he would deal with the trees in Ardbraccan at the start of his

submission and said that one of the Beech trees in Ardbraccan had honey fungus which,

when it came into an estate, might stay dormant for a while or it might run rampant

throughout the estate. He said that no-one knew why it decided to do that but if it did

decide to run rampant, every tree around Ardbraccan House would die and that any

mitigation measures based on the survival of those trees were ill-founded. He said that

the Copper Beech, which was the most important screen at the back of the house, had

bracket-fungus and was at the end of its life and had to be assessed whether to take it

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down now or wait for next year. He said that the small Beech in the middle of the view

had a forked leader at about 15 feet and would not grow into a substantial tree and that

the large Beech on the left as you looked from the house was mature to over mature and

might fall in the next storm. He said that if it happened that those three trees went, the

entire house and the view, which was the view used for the light in the photograph,

would then be exposed to the road from the toll plaza.

Mr. Sweetman said that the Ash trees at Durhamstown were overgrown hedgelings and

were growing on a bank, were inadequately supported and would be extremely prone to

constructionitis and he said that they had now discovered that movements of the

watertable were certain to take place on that site and said the trees could not be relied on

for any manner of screening. He said these trees also appeared to have a certain amount

of cavities in them and that Ash trees with cavities were the normal habitat of Bats. He

said that Mr. Burns was relying of the trees already in the landscape to mitigate the

impact on the landscape without doing any survey.

Mr. Sweetman said that they had heard on numerous occasions how the Council had

deliberately set out to obstruct throughout this development. He said that when Mr.

Keane could magically produce documents off the Material Contravention File which

were not on it 12 hours previously and refused to answer where he got it from or whose

possession it was in was an example of this obstruction. He suggested that Mr. Keane's

reason for refusing to answer was because the document had been deliberately suppressed

from the public. He said that the Council had worked on a need to know basis all the way

through and that this was abusing the public as it was a fundamental requirement of the

EIA process that the public be consulted. He said that Fr. Pat Raleigh had given similar

evidence of abuse by the Council to that of Ms Maher and he said that there had been

others who had also complained.

He said that An Taisce believed that some route improvement was required from Clonee

to Dunshaughlin and that Dunshaughlin needed to be by-passed and they accepted that

Navan needed some relief. He said that he had been going to say that An Taisce saw

nothing wrong with the Clonee to Dunshaughlin section and said that he really had not

looked at that section. He said that in view of the incompetence and deception in the

other sections they had looked at from Dunshaughlin to Navan and the Navan By-pass,

he could not recommend to even accept that part of the road since he saw no reason why

it should have been more competently looked at than the sections they had looked at in

detail.

Mr.Sweetman said it was absolutely clear from the evidence put before the Hearing that

the wrong route was chosen for that the Dunshaughlin to Navan section. He said the

Council continually relied on the socio-economic survey by someone who knew

absolutely nothing about socio-economics. He said that everything pointed to the Navan

By-pass going east of Navan and that the only reason for not putting it east of Navan

appeared to be that there was some clay east of a tailings pond that might be used to build

a tailings pond extension at a future time. He said that clay to build this tailings pond

could be sourced anywhere in Meath as Meath was basically deep clay soil. He said that

890

it was not a reason to destroy our heritage because the Navan mines might or might not

want to extend the tailings pond. He said he was one of the objectors to the tailings pond

and that it turned out that everyone was happy and that the conditions were basically

agreed and greatly improved the process. He said that it was a consultation process with

Tara Mines rather than a confrontation process with everything put on the table. He said

that the grass grew on one half of the tailings pond because they had spread mushroom

compost on it and planted grass and that while there was an element of cadmium

pollution there at two parts per million, the tailings pond was absolutely safe and without

any substantiation from the Council.

Mr. Sweetman said that the route selection of these two sections was fundamentally

flawed and that if the route selection from Dunshaughlin to Navan had been done

properly and proper alternatives looked at, it would have been impossible for it to come

out with the route that they now had come out with. He said that he and An Taisce

supported everything that Mr. Casey had said about the EIS, and he was just going to

extend that to the rest of the route. He said that the EIS was fundamentally flawed in law,

that it did not comply with th 1999 Regulations and did not comply with the NRA's own

road design guidelines.

He said that Ms Dempsey had said on Day one or two that the 1999 Regulations did not

apply to road designs and said he wanted to draw attention to the NRA's Project

Guidelines at page 38 and chapter 4. 3.1where the particular topic outlined were the EC

EIA Regulations SI 93 of 1999. He said one of these was archaeology and the NRA

version said that archaeology should include the necessary exploratory investigations. He

said that Ms Dempsey, Ms Gowen and Ms Joyce all said they did not do it that way but

did it afterwards. He said that was what happened at Carrickmines and was why the

Commissioner wrote once again to the Irish Government for not complying with the EIA

Directive. He said permission was given to a road without assessing the ground water and

massive problems arose and that the Glen of the Downs suddenly became an SAC and

this had not been looked at. He said that roads were no different to any other

infrastructure and were in the First and Second schedules requiring full EIA. He said that

this was also stated in the NRA guidelines which Mr. Whyatt said were in draft and said

that there were previous guidelines, version 1.0 of May 1999 which said much the same

thing including the 1999 Regulations, and there was no mention of draft on version 1.1 of

March 2000. He said this was another case where the Engineers in this project said they

knew best and did not need rules, they did not need to tell the public and did not need to

consult as they knew best and would talk down at people.

He said that the assessment of the ecology at the Boyne Valley crossing was non-existent

and that the same document said that where you were crossing an SAC detailed

mitigation measures should be put in place. He said that the "fumbled" mitigation

measures proposed at the site did not actually fit into the site relevant to the construction,

so they could not be implemented. He said that the EIS contained no details of the source

of the raw materials or of the deposition of waste and that the interactions of these was

something that was considered in the EIS and that nobody could answer questions on it at

the Hearing because everybody was passing the buck. He said that the micro-climate

891

relative to the road was not considered and there were fog patches in places and the

relevance of the Tara Mines shaft was not considered but that the mud for the tailings

pond was considered as very important. He said that there was no data for ground water

and that construction traffic was averaged over the entire route. He asked what was the

construction traffic at Ardbraccan and said nobody knew because no-one assessed it and

it was not in the EIS. He said that they said something would be done about it but that it

never was unless it was pinned down and that it could not be said what the mitigation

measures were on any point on the road because they were not in the EIS.

Mr. Sweetman said that he had to repeat what Ms Dempsey had said at the very

beginning which was that they did not put things in the EIS which they did not think were

necessary because if it was not in the EIS they could not be questioned on it and he said

that was very arrogant, but said that it might not be the exact wording but was something

on those lines and that the Inspector would read it for himself in the transcript. He said

that the information contained in the EIS relevant to the toll plazas was not, as he had

said previously and would say again, adequate to build a one-room cottage with the

information supplied and not adequate for a toll plaza. He said that he was convinced that

the 2001 Development Plan was a document that deliberately set out to deceive trhe

public and no evidence had been produced to convince him of anything else. He said they

had heard no mention of the White Quarry or Ardbraccan Quarry which was a late 17th or

early 18th century quarry out of which the stone came for some of the most important

buildings in this country such as Leinster House, Carton, the Customs House and

Ardsallagh. He said that the White Quarry had been flooded and filled in for many years

and that a cursory glance at the aerial photograph would have told the Engineering Team

that they had serious groundwater problems in that area because of its high watertable.

He said there had been evidence of PM10s and that the baseline levels of PM10s

presented was below the naturally occurring level so that they were not going to appear to

high when the evidence came in. He said that the noise data which had been collected on

the site was going to be ignored because the Engineering Team decided it did not fulfil

the criteria they had set themselves. He said the object of an EIS and assessment was that

all the relevant data be presented by the developer and that where the developer refused

to produce relevant witnesses, then it could only be stated that the relevant data was

either highly suspect or the developer was embarrassed at what might the answers might

be. Mr. Sweetman said that the no-show by Duchas at the Hearing on both ecology and

natural environment showed the sorry state this country was in relevant to its

implementation of the Habitats Directive. He said he welcomed the fact, and hoped it

would be soon, that the European Commissioner would be sending a European civil

servant to run Duchas because they were incapable of running it themselves.

Mr. Sweetman said that Mr. Perkins had his name on every document presented at the

Hearing but was nowhere to be seen as he was embarrassed at what had been put forward

and that so he should have been. He said that Mr. Murphy, who really was a developer,

was hiding under some stone because he was perpetuating a con-trick in planning terms

since this was a development by a private company looking to transfer an exemption

from the Planning Authority, and said that he did not want to tell the Hearing that

892

because he was embarrassed by it. He said that point 9 of Mr. Newman's submission

clearly stated what Mr. Lumley was trying to point out to Mr. Keane, while Mr. Keane

was being aggressive to him. He said that no-one looked at the electricity line that

crossed the Deer Park ( at Ardbraccan) and how it would cross the road and he would

love to have known.

Mr. Sweetman concluded his submission by saying that he hoped and was confident that

this road project would be the second road project in the country that would be refused

permission because it was outrageous.

145. 7. Closing Submission by Pat Butler S.C. for the Council :

Mr. Butler said that the exercise commenced on 21 August and now concluding on 21

November was, as had been restated several times, a fact finding exercise to give An

Bord all of the relevant information to allow them to make an assessment of the

environmental impacts of the development and to decide whether the scheme should go

forward. He said that his comments would only deal with facts insofar as they were

relevant to illustrate the legal issues raised by the objectors and that he would leave it to

the Inspector to balance the arguments made throughout the period of the Hearing. He

said there were two issues that he wanted to deal with at the end of his submission and

these were the route selection issue, which had been raised by various parties, and the

relationship between the Council as Road Authority and the promoters of the scheme and

the NRA.

He said that he would deal with the issues in the order they had been raised and,

commencing with the EIS, he said that Section 50 of the 1993 Roads Act as amended by

the 1999 Regulations set out what was required in an EIS and that Section 50 started off

by saying that an EIS must be prepared by a road authority for the types of development

set out in Section 50, including a motorway, in respect of the likely effects of the

proposed road development. He said that was absolutely critical in dealing with many of

the criticisms made by the objectors since it had been constantly stated and put to

witnesses appearing for the Council that what they were doing was justifying something

that they had already decided on. He said that it had frequently been explained to the

objectors that the Act specifically said that a project, the proposed road development,

must exist before the EIS was done and that therefore the EIS must by its nature and in

accordance with law deal with that road project. He said that the EIS must also look at the

alternatives that were considered but that it was not an EIS of these alternatives. Mr.

Butler said that that was the fundamental error many of the objectors had been making

throughout the Hearing when they had constantly asserted that what a proposer of a

scheme like this should do was not alone an EIS relating to the project, but one for every

alternative and he said that was not what was required.

He said that there must be a proposed road development and it was the likely significant

effects of that development that were to be considered. He said that the evidence that had

been put before the Hearing, throughout its entire length, had displayed that the likely

893

significant effects had been inquired into and that the required mitigation measures had

been set out and he submitted that was the position. He said that in the end it was still a

matter for An Bord to decide.

Mr. Butler said that much time had been spent putting the Project Engineers, and some of

the other witnesses for the Council, through extensive cross-examination relating to

matters which had led up to the decision to carry out this development and to propose the

scheme. He said they were undoubtedly entitled to go back and look at the Constraints

and other studies that had been carried out but that once the project was decided on then

it was that project which was the subject of the EIS. He said that brought up again the

proposition that the EIS was prepared to justify a proposal and insofar as that proposition

had been made, he said that he rejected it and he said that it was quite clear from the

legislation that this could not possibly be the basis on which the EIS was prepared.

Mr. Butler said that Mr. Casey in his submission had echoed some of the criticisms made

throughout the Hearing by various bodies or objectors but not to the same extent as those

made by Mr. Sweetman. He said that Mr. Sweetman seemed to have a paranoid view of

anything carried out by a public body and saw conspiracy at every turn. He said that there

had definitely a view taken by some objectors over the period of the Hearing that, in

some way, the Council had been hiding documents and had not been open. He said he

wanted to reject that view and said that it was quite clear, whatever the perception of

objectors, from listening to each of the witnesses for the Council that every attempt had

been made on their part to be open and explain and to be helpful.

He said that there had been criticism of the EIS as to its content and clarity in its function

of informing the public and said that it was interesting to note that a number of

professional witnesses appearing for objectors had invariably praised the EIS. He referred

to Mr. Conor Newman's first submission where he had stated that " Indeed the carc that

has gone into the preparation of this section of the various EIS statement is itself a

reflection of the standing of Tara." He referred to Mr. Terence Reeves Smyth's report for

Ms Maher which said " I have now read through Dr. O'Sullivan's contribution to the EIS

and feel that on the whole his report is quite good. Indeed it is superior to many other EIS

reports I have seen." He said that Mr. Peadar Creagh had made a presentation on behalf

of Raynestown when he said " The EIS is very well put together, it is hard to find fault

with it." He said those were examples where an objective view had been taken of the EIS

which found it to be a comprehensive, detailed and efficient report. He said that it was

also notable when Mr. Sean Finlay was called as a witness for Ms Maher and was asked

about the EIS that he did not say that any significant effect had not been set out in

relation to the geology, and that he had not criticised the EIS nor was a suggestion of a

criticism put to him.

Mr. Butler said that the issue of whether the traffic figures justified a motorway had been

raised at the early part of the Hearing by Mr. Frank Burke on behalf of his clients and he

said that the debate which had ensued on the previous day between Mr. Burke and Mr.

Evans had finally nailed that issue and said that Mr. Evans had made out,

comprehensively, the case for the motorway.

894

He said that the context of the Strategic Policy Guidelines (SPGs) was an issue that

concerned many people in the locality relating to the probable or possible provision of a

rail link from Navan to Dublin and why that was not considered as alternative. He said

that the legislation was quite clear and that the two words used relating to alternatives in

the Regulations were "what alternatives (if any) were considered". He said there was no

requirement to consider an alternative if that alternative had no bearing on the project in

hand and that, in any case, the SPGs themselves said in relation to rail that, until a proper

feasibilty study was carried out regarding the provision of a rail link, it was not an issue.

Mr. Butler submitted that it was quite correct that the alternative of a rail link balanced

against the provision of the motorway was not a proper matter to be taken into account.

He said that, additionally, the SPGs themselves in providing for a strategic transport

corridor clearly included the provision of a motorway and said that word was used in the

SPGs. He said it was clearly envisaged by the SPGs that, whatever about the other type of

transport links, a motor way would be provided.

Mr. Butler said that the issue of public participation had been repeatedly raised and said

that this had to be put in the context of the legislation which, in the case of Section 50,

required the specific publication of certain notices about the making of the scheme, times

for objection etc. He said that there was no requirement in law for what had now

developed as public consultation. He said there was provision in the Directive 85/337/EC

for the competent authority, in this case Ireland, to set out within its own legislation

provision for written submissions, public inquiry and time scales within which that

inquiry took place but said nothing about public consultation. He said that the system

developed in this country had gone further than the requirements, both Statutory and the

Directive, and had put public consultation into being and said that those public

consultation processes were carried out. He said that insofar as an argument was made by

the objectors that the public consultation process was not in accordance with the NRA

guidelines, he submitted that guidelines were guidelines and were not strictures or

statutory requirements. He said the guidelines were a template and an aid to help

individual local authorities to direct their affairs and said that if they diverted from them

this was not an infirmity in law, giving the example where the High Court so held in the

case of Smith and McEvoy v. Meath County Council.

He said that Mr. Sweetman had again raised the issue of the import of materials which

had been raised on a number of occasions in the Hearing and said that he was not going

to go through this in any great detail as the Inspector had heard submissions on that issue

at a very early stage of the Hearing. Mr. Butler said that the 1999 Regulations provided

for the promoter of a given scheme to be able to supplement the information during the

Hearing process and also provided that the information contained in the EIS need only be

such as was required to identify the project at the stage at which the Hearing process had

reached. He submitted that for all of those reasons and the reasons relating to future

processes dealing with planning applications etc, the EIS had adequately identified the

volumes and the effects of the import of materials.

895

He said an issue had been raised of "project splitting" and that issue had been raised in

the context of the reasoned opinion from the EC quoted by Mr. Casey and said that a

fundamental misconception had arisen about that whole concept and was constantly

reiterated by objectors. He said that the reasoned opinion was directing the Irish

Government's attention to particular issues and gave, as an example, the case of the

Ballymun Development Regeneration Scheme where the developer divided that scheme

up into 15 separate applications instead of applying for permission in one project. He said

that the purpose of dividing it was to make each application below the threshold requiring

an EIS and the Commission rightly pointed out that was not within the spirit or letter of

the Directive and should not have been allowed. He said that in the case of the M3

Scheme there were five projects merged into one big scheme and said that how this could

be argued to be project splitting was inconceivable and that, in any case, an EIS had been

prepared whereas the EC was complaining about splitting of projects to avoid preparing

an EIS.

Mr. Butler said that the position of the Elected Members had been raised and raised again

in his submission by Mr. Casey and he said he was surprised at Mr. Casey asserting that

the Elected Members had adopted the scheme, since he should know what their position

was. He said that the Elected Members did not adopt the scheme as the drawing up and

proposing of a scheme was an executive function and that Mr. Casey should know the

distinction between a reserved and an executive function. He said that the drawing up of

the scheme under the 1993 Act was not a reserved function of the Members but that the

County Manager had properly kept them informed of progress with the scheme and that it

had been presented to the members for their views. He said that the Elected Members had

voted for the provision of the County Development Plan 2001which included the

provision of a motorway in accordance with the scheme, as presented, and with a map

attached to the Plan which showed the motorway passing Ardbraccan. He said that the

Elected Members also passed the resolution amending the 2001 Plan and the Navan

Environs Plan specifically to take account of changes that had been made to the route. He

said that even if it could be said that there was some imperfection in the part played by

the Elected Members in bring forward the scheme, it was clear that they knew what was

provided for in the Plan and in the amendment.

He said that the issue relating to the Tree Preservation Order at Dalgan Park had been

raised and said that the Inspector should be satisfied from Mr. Killeen's evidence that the

Tree Preservation Order was provided for in both the 1994 plan and in the 2001 Plan.

Mr. Butler then referred to the argument made on Ms Maher's behalf about the variation

and said that the scheme and the indicative route were set out in the 2001 Plan at Section

3.5.2. (ii) at page 51 and bullet point 3 and provided specifically for a motorway from

Clonee to Kells. He said that Ms Maher had brought proceedings relating to the variation

of that Plan on the basis that she was not informed and did not know that a motorway was

to pass her property when, he said, that was quite clearly stated in the 2001 Plan. He said

that whatever arguments Mr. Casey had made in relation to what he perceived as

infirmities in the way the variation was brought in, that had no bearing on the fact that Ms

Maher and everybody in the Navan area was on notice from the 2001 Plan of March 2001

896

that a motorway was passing in the area as indicated. He said a further issue raised out of

the Plan in Ms Maher's submissions was that a Planning Application was refused in the

Ardbraccan area, with six reasons given, and that because one of those reasons was that

the setting of Ardbraccan would be affected, it had been argued from this that the placing

of the motorway in the setting of Ardbraccan was a breach of the Development Plan. He

said that argument could not have any substance when the provision of the motorway was

a specific objective in the CDP.

He said that Mr. Galligan, Ms Maher's then Counsel, had raised an issue at the start of the

Hearing about the notice published in the newspaper that the variation was about to be

debated and said that Mr. Galligan had argued the that the notice was defective as the

reason and description were not set out in the notice. Mr. Butler referred to Section 13 (3)

(a) of the Planning and Development Act 2000 and said that this simply said the

requirement for the notice was to have the reason or reasons set out and said nothing

about a description and he said the notice was perfectly valid.

Mr. Butler said that Mr. Guthrie had been criticised for not knowing the provisions of the

SPGs and he had said that he knew of the guidelines but not their content. Mr. Butler said

the criticism had no foundation since Mr. Guthrie's function was as the Project leader and

said that the "planning" elements of the scheme were matters for the Planning Authority

and were dealt with by the Planning Officer who provided guidance for Mr. Guthrie and

other persons involved with the scheme. He said that the Planning Officer had given his

evidence relating to where the scheme sat within the context of the SPGs.

Mr. Butler referred to the matter of illegal camping raised by Mr. Laurance Ward and the

possibility of this developing along sections of the motorway and said that Section 69 of

the Roads Act provided specific machinery to deal with such situations and that there

were definitions in Section 59 for temporary dwellings which included those in carparks.

He said that Ms Ryan had raised the issue of access at Lismullin and her difficulty came

from her concern about an access being provided for, as she said, just one person and she

wanted that closed. He said that it was only in circumstances where the scheme would

deprive a person of their only access that the Council were obliged to provide an access

and that where it was stopped when that was not the only access, then it was a case for

compensation.

He then referred to Mr. Prendiville's evidence and his qualifications being called into

question and said that he accepted the Hearing was an informal one but said that

nonetheless, Mr. Prendiville's qualifications were questioned. Mr. Butler said that Mr.

Prendiville had given his evidence and the weight to be attached to that was a matter for

An Bord. He said he was drawing to the attention of An Bord that no countervailing

evidence was given that would contradict anything that Mr. Prendiville had said.

Mr. Butler said issues had been raised about the Habitats Directive and the proposal to

designate both the Boyne and Blackwater Rivers as SACs. He said that the legal

requirements for such designation were that there must be publication and there must be

confirmation of boundaries and while both Rivers had been put forward as candidates for

897

designation, neither publication nor designation of boundaries had been decided and

therefore, at present ( Note - as at 21 Nov.2002), they did not have a status in that regard.

He said that Mr. Nairn had given evidence that, even if they were SACs or had that

status, nothing that this scheme would do would affect those Rivers.

He said that the issue of Planning Permission for roads had been raised and he said that

Meath County Council were the proposers of this scheme, that they were the statutory

body entitled and required to propose such schemes and that the Council had the

Exempted qualification under Section 4 of the 2000 Act for roads in their functional area.

He said that Section 4(f) provided that any development carried out by or on behalf of the

local authority was also exempted. He said that an issue had been raised with the

Dunboyne By-pass relating to its location in the CDP and said that it was quite clear on

the Development Plan that an indicative line showing the By-pass of Dunboyne was

shown. He said that there could be no question from that of the Dunboyne By-pass being

something that the Council could not carry out.

He said that Mr. Casey had raised an issue about the Navigation Rights on the River

Boyne and said this was related to the issue on the importation of material. He said that in

the decision in Keane v. An Bord Pleanala, the Supreme Court had set out in great detail

the distinction that must be drawn between different forms of planning or licensing

regimes and gave as an example the case of someone applying for planning permission

for a public house. He said that permission did not entitle them to operate the public

house until they had obtained a liquor license. He said that it was a misconception which

had been stated throughout the Hearing that in the future some other license might not be

available to the Authority to enable the scheme to go ahead and that An Bord could not

go through with this function until that other license had been obtained. He said that in

the same way as the person proposing to build a public house might not have his liquor

license at the time he applied for planning permission did not mean that the application

could not be dealt with, the same applied for this application to An Bord. He said that all

of these licensing regimes were separate in their own right and that the same applied to

common law rights. He said that in the case of Mr. Casey's Clients owning navigation

rights that might interfere with the ability of the Council to carry out this scheme, that

was a matter that the Council would have to deal with in its own time and he said that it

was not a matter that rendered the ability of An Bord to make a decision on this scheme

redundant.

Mr. Butler said he wanted to deal with the Route Selection argument which had been

raised particularly by the Meath Road Action Group and in various guises by other

objectors and by Ms Maher. He said that Mr. Guthrie had, on several occasions, set out in

detail the chronology that had lead to the making of the scheme and that he had been

repeatedly cross-examined on why the Corridor Selection Report had followed the Route

Selection Report, with it being put to him that the NRA Guidelines said it should have

been in a different sequence. He said that Mr. Guthrie had set out in great detail why that

was so, but it seemed that no matter how often it was said that the objectors just did not

want to hear.

898

Mr. Butler said that, as had been set out in some considerable detail, there had been a

number of schemes proposed in the late 1990s and that it had then been decided these

should be upgraded into one overall scheme. He said that it was decided logically and for

economic reasons that all of the preparatory work done on individual schemes should not

be dumped and go back to square one, and that for similar logical reasons it was decided

to validate the selections which had already been made by carrying out a Corridor

Selection Report. He said that was the chronology followed and that, despite repeated

explanations, the objectors refused to accept that explanation. He said it was logical and

reasonable and that Mr. Guthrie had set out in his evidence that the Corridor Selection

Report had validated the selection process. Mr. Butler said that the entire scheme was

founded first on Government policy, second on the policy in the CDP which followed

from that, third on the Needs Study carried out in 1998 and updated and had a sequential

foundation in policy that justified the need to build and gave a legal sound base to the

building of this scheme on the route as selected.

He then referred to the relationship between the Council and the NRA which, he said, had

been brought up frequently during the Hearing and again by Mr. Sweetman in his

submission. He said that the NRA had been set up by legislation in 1993 when it was

given specific functions to oversee the implementation of the road program on National

Roads and that it was also decided that funding for that program should be directed

through the NRA. He said the fact of the Legislature doing this and setting up an

Institution to oversee the implementation of these schemes by the Local Authorities was

not a mythical structure, as it had been developed into by the objectors, but was a simple

and very obvious legal structure. He said there was a conduit called the NRA that had a

supervisory role over the development of that program, its implementation and its

funding. He said that the people given the power to carry out the scheme under that Act

were the Meath County Council. He said that in relation to contracting out of that work,

that was no different than for any other public scheme in the Country and said that if a

Local Authority wanted to build Sewage scheme or a Landfill scheme they normally

contracted this out and it was the same for this Motorway. He said that the constant

sniping at the NRA and the relationship between the Council and the NRA had no

substance, no validity and was a red herring at the scheme and the Hearing.

Mr. Butler said that there were two elements to the Hearing, the first being the

recommendation of the Scheme to An Bord Pleanala and he said that he did recommend

it to them. He submitted that the Scheme was fully in accordance with law, as being

carried out in accordance with the requirements of law, and was a proper scheme to be

approved by An Bord. He said that in relation to the EIS he also recommended that, and

submitted that it fully accorded with the requirements of law, the requirements of the

Directive and of the Regulations made thereunder. Mr. Butler concluded by referring to

the comments that Mr. Sweetman had attributed to Ms Dempsey and said that he had no

recollection of her making any of the comments she was supposed to have made. He said

that he noted Mr. Sweetman himself had now admitted that it was not an exact quote

from what she had said and he said that he thought the quality and substance of what Mr.

Sweetman had said stood by that remark.

899

(Note -- The comments attributed to Ms Dempsey appear to have been based on her

replies when being cross-examined by Mr. Burke, see Section 23.7 of this Report, and

seem to have been given a meaning that was out of context for the line of questioning

being pursued in that cross-examination.)

144. Applications for Costs :

During the course of the Hearing applications for Costs to be awarded to their clients

were made by Mr. Anderson, Solicitor on behalf of Mr. Basil Brindley, Rathbeggan

House; Mr. Comyn, Solicitor on behalf of Mr. Michael Kieran, Knockmark; Mr. Paul

Brady, Solicitor, on behalf of his Clients and Mr. Declan McGrath B. L. on behalf of

Gerrardstown Stud. Mr. Michael O'Donnell B. L. on behalf of his Clients and Mr. Alan

Park on behalf of Bellinter Residents Association made a similar application during their

closing submissions and applications were made by Mr. Brendan Halligan of Raynestown

Residents Association and Mr. Ron Pagan of the Ardbraccan/ Boyerstown N3 Group also

applied for Costs.

It had been made clear at the early part of the Hearing, when Mr. Anderson made his

application, that the issue of costs was not something which would be dealt with in the

Inspectors Report, other than to note that an application had been made, and that a

separate application would have to be made to An Bord if the matter of costs under

Section 219 of the Planning and Development Act were to be considered. This comment

was repeated by the Inspector when subsequent applications were made during the course

of the Hearing.

145. Issues Required to be Addressed under Section 50 (2) and 50 (3)

of the Roads Act, 1993, as amended :

Section 50 (2) (a) : A description of the proposed road development, comprising

information about the site, design and size of the proposed road development.

Details of the background to the proposed road development is given on pages 1-13 of

Volume, with a more detailed description given on pages 13-16 and in Volume 2 of the

EIS. The design details were expanded on by the Project Engineers in their evidence and

cross-examination.

Descriptions of the proposed development are also given on pages :-

Vol.3A -- 3-13, 194-195, 202-209

Vol.3C -- A 1-2, D 2-7, E 1& G Section 1

Vol.4A -- 2-10, 77-78, 136, 145, & 165

Vol.4C -- A 3-4, D 5-6, E 3-5

Vol.5A -- 2-8, 128- 129, 137-138

900

Vol.5C -- A 1-2, & G 5

Vol.6A -- 1-8, 93, 143-144

Vol.6A -- C 1-2

Vol.7A -- 1-5 & 109

Note -- The differences in details that arise in the Untolled Scenario for each relevant

environmental effect are given at the end of each "A" Volume and for each Report in the

Appendices in the "C" Volumes. These details are not being listed in this commentary on

Sections 50 (2) & 50 (3) since they do not affect the issue of compliance with those

Sections and would extend the commentary unnecessarily.

50 (2) (b) : A description of the measures envisaged in order to avoid, reduce and, if

possible, remedy significant adverse effects.

Amelioration measures designed to reduce significant adverse effects of the proposal are

discussed in pages 22-27 of Volume 1 and in Chapters 15 each "A" Volume of the EIS

where the mitigation measures proposed are outlined. Mitigation measures are described

on page 4 in Volume 2 and on pages :-

Vol.3A -- 14-15, 37-38, 71, 117-119, 127- 128, figs. 5.1.4 - 5.1.8, 151-153,

168-172, 183-185, 197-200, figs. 8.1-8.2, 211-213, 217-224, 233, 247, 256-258,

285-295 and shown in each "B" volume on the appropriate drawing.

Vol.3C -- A 42-46, B 8-9, C 10-15 & 26, D 18-23, figs. SLM 101-103, E 18-20, F

44-48, G Section 5 & Table 6A, I 51-62.

Vol. 4A --14-15, 35, 51-54, 82-85, 96, figs. 5.1.5-5.1.8, 105-106, 116-118, 131-

133, 139-140, 148-149. 154-157, 177-179, 191-201.

Vol. 4C -- A 19-23, B 18-22, C 9-11, D 4, E 33-34

Vol. 5A -- 15, 22, 35, 51-54, 82-85, 95-96, figs. 5.1.4-5.1.6, 104-106, 115-116,

126, 130-131, 139-140, 166, 171-176, 180, 182, 184-196.

Vol. 5C -- A 43-44, 46-47, B Section 3.7-3.9, C Section 4.7- 4.9 & 4.14, D17-21,

figs. 101-103, E 121-14, F 40-47, G 13-28, H 51-54, I 20-21.

Vol. 6A -- 13, 56-57, 75-77, 100-102, 111, 122=123, 131, 135-137, 147-148, 161,

165-178, 179-180, 2010205, 209-210, 215-222.

Vol. 6C -- A 42-46, B Section 3.7-3.9, C Section 4.7- 4.9 & 4.14, D 16-18, E 18-

20, F Table 6, G 50-51 & 53-54.

Vol. 7A -- 23-24, 40, 55-57, 74-76, 91-93, 98-99, 111-112, 128-136, 179-186.

Vol. 7C -- A 35-39, B Section 3.7-3.9, C Section 4.7- 4.8,D 14-16, E 10-12 & 19-

22, F Table 6, G 25-27, H 12-14.

Section 50 (2) (c) : The data necessary to identify and assess the main effects which

the proposed road development is likely to have on the environment.

The data necessary to identify and assess the main effects which the proposed road

development is likely to have on the environment is scattered throughout the various

chapters of the EIS :-

901

Traffic volumes --- Vol.1 -- pages 1& 13; Vol.2 -- pages 19-25 & Maps 26-31

Vol.3A -- pages 29-30; Vol.3C -- pages A 19-29;

Vol.4A -- pages 22 & 32; Vol. 5A -- pages 20-21;

Vol.5C -- pages A 5 &21, C Section 4.2;

Vol.6A -- pages 22, 25-26, 3, 87-89; Vol. 6C A 21 & 27

Vol.7A -- pages 16, 18-19, 29; Vol.7C -- pages A 20 & 25.

Flora/Fauna impacts --- Vol. 2 -- page 4; Vol.3A -- 141-149 ( bat survey 146-147),

156-157, figs. 6.1.1- 6.1.4, 163-167, 174-181, figs 7.3.1-7.3.4;

Vol. 3C -- E pages 1-12 ( bat survey E10-11);

Vol. 4A -- pages 98-104, ( bat survey 103);

Vol. 4C -- B pages 2-15, C 3-8, (protected acquatic species C 6)

Vol. 5A -- pages 98-103, 112-113 ( bat survey 102)

Vol. 5C -- E pages 1-9 ( bat survey 8 & appendix 4)

Vol. 6A -- pages 115-120, figures 6.1-6.4, 128-129;

Vol. 6C -- E pages 3-16 (protected acquatic species 14)

Vol. 7A -- pages 85-90, ( bat survey 89), figs. 6.1-6.4, 128-129

Vol. 7C -- E pages 1-8 & 13-19 (bat survey 7 & protected

acquatic species 17)

Noise impacts ------- Vol. 1 -- page 22; Vol. 3A -- pages 92-94, 101-106;

Vol. 3C -- C pages 4-7; Vol. 4A -- pages 49-51, 60-65

Vol. 5A -- pages 64-69, 74-76: Vol.5C -- C Section 4.3-4.5

Vol. 6A -- pages 69-73; Vol. 6C -- C Section 4.3- 4.5;

Vol. 7A --pages 49-55; Vol. 7C -- C Section 4.3 - 4.5.

Pollution impacts ---- Vol. 3A -- pages 65-70, 195-196; Vol. 3C -- B pages 3-8;

Vol. 4A -- pages49-51, 60-65; Vol. 4C -- C page 7;

Vol. 5A -- pages 44-47; Vol.5C-- B section 3.3-3.4; F pages 9-26

Pollution impacts ---- Vol. 6A -- pages 49-53, 62-64, 146;

Vol. 6C -- B Section 3.3 -3.4; E4 &15;

Vol. 7A -- pages 33-36; Vol. 7C B Section 3.3-3.4.

Visual impacts ------- Vol. 1 -- page 23; Vol. 2 -- pages 42-43, 45-46;

Vol. 3A -- pages 113-116, 123-126, figs. 5.1.1 - 5.1.4

Vol. 3 C -- D pages 8-17.

Vol. 4A -- pages 78-81, 89-95, figs 5.1.1-5.1.4; Vol.4C -- A 3-7

Vol. 5A -- pages 82-84, 91-94.

Vol. 5C -- D pages 9-16, figs. IMP 101-103.

Vol. 6A -- pages 97-100, 105-110, figs. 5.5-5.8; Vol.6C -- D 9-12

Vol. 7A -- pages 74-75, 79-82, figs 5.4 -5.6; Vol.7C -- D 9-12

Landscape impacts --- Vol. 1 -- page 23; Vol. 2 -- pages 42-43, 45-46.

Vol. 3A -- pages 113-116, 121-122, figs. 5.1.1-5.1.4.

Vol. 3C -- D pages 8-17.

Vol. 4A -- pages 78-81, 89-95, figs. 5.1.1-5.1.4.

902

( VP 1, Tara on fig. 5.1.3; Central core Dalgan Park

and TPO on fig. 5.1.4); Vol. 4C -- A pages 3-7.

Vol. 5A -- pages 82-84, 91-94; Vol.5C -- D p 2-9, figs 5.1-5.4.

Vol. 6A -- pages 93-97, figures 5.1-5.4;

Vol. 6C -- D pages 3-9 & 12 ( VP 32 & VQs 3 &11)

Vol. 7A -- pages 69-73, figs. 5.1-5.3; Vol.7C -- D p 3-8 & 13.

Archaeology impacts -- Vol. 1 -- page 27; Vol. 2 -- pages 42-43, 45-46.

Vol. 3A -- pages 252-256; Vol. 3C -- I pages 5-36, 63-75.

Vol. 4A -- pages 166-175; Vol. 4C -- E pages 3-30

Vol. 5A -- pages 168-170; Vol. 5C -- H pages 3-50

Vol. 6A -- pages 191-200, figures 13.1-13.4

Vol. 6C -- G pages 1-21; H pages 2-5

Vol. 7A -- pages 147-160; Vol.7C -- G pages 1-21.

Architectural impacts -- Vol. 1 -- page 27; Vol. 2 -- pages 42-43, 45-46.

Vol. 3A -- page 121; Vol. 3C -- D page 4, J pages 1-9.

Vol. 4A -- pages 186-187; Vol.4C -- A page 5, Appendix F.

Vol. 5A -- pages 90, 178-180;

Vol. 5C -- D page 6, I pages 2-21 and Appendices ( Ardbraccan)

Vol. 6A -- pages 104, 207-212; Vol. 6C -- D page 4, G p 22-48.

Vol. 7A -- pages 167-172, 175; Vol. 7C -- H pages 1-11

Community impacts -- Vol. 1 -- pages 21-22; Vol. 2 -- pages 42-46

Vol. 3A -- pages 27-36, 40-54; Vol. 3C -- A pages 30-41

Vol. 4A -- pages 23-25, 30-31.

Vol. 5A -- pages 17-20; Vol. 5C -- A pages 9-20.

Vol. 6A -- pages 2-34, 38-41; Vol. 6C -- A p 4-20 & App. A7

Vol. 7A -- pages 15, 321-32; Vol. 7C -- A pages 4-19.

Material Asset impacts -- Vol. 1 -- pages 26, 42-43, 45-46

Vol. 3A -- pages 196, 208-209, 232-235; tables 10.2- 10.5

figures 10.1.1 - 10.1.4

Vol. 4A -- pages 138, 146-147, 158, 162-163,

tables 10.2-10.5, figures 10.1.1 - 10.1.4

Vol. 5A -- pages 129, 136-138, 160-161, tables 10.2-10.5

Vol. 5C -- G pages 3-7.

Vol. 6A -- pages 144-145, 157-159, 179, 181-183,

tables 10.2 - 10.5; Vol. 6C -- F pages 1-5

Vol. 7A -- pages 110-111, 121-123, 137-140, 141-143

tables 10.2 - 10.5; Vol. 7C - Appendix F (no nos.)

Climatic impacts --- Vol. 1 -- page 25; Vol. 3A -- pages 201-303.

Vol. 4A -- pages 141-143; Vol. 5A -- pages 132-114.

Vol. 6A -- pages 151-153; Vol. 7A -- pages 115-117.

903

Water (Drainage) impacts --- Vol. 3A -- pages 180-183, 188, figures 7.3.1 - 7.3.4

Vol. 3C -- F pages 9-42

Vol. 4A -- pages 134-135;

Vol. 4C -- B pages 14-16, 18; C pages 7-8

Vol. 5A -- pages 113-114, 122, 124-125, figs. 7.1.1 - 7.1.3

Vol. 5C -- F pages 9-24

Vol. 6A -- pages 134-135, 138-140; Vol. 6C -- E p 4, 15.

Vol. 7A -- pages 97, 101-102, 105-106.

This data was also referred to at various stages during the evidence and crossexamination

of witnesses.

Section 50 (2) (d) : An outline of the main alternatives studied by the road authority

and an indication of the main reasons for its choice, taking into account the

environmental effects.

The alternatives considered are given on pages 13 to 19 of the Non Technical Summary,

Volume 1, of the EIS and are detailed in Volume 2 on pages 32 to 56 with Summary

Matrices for the alternative alignments assessed on user, engineering and environmental

aspects in each of the five Sections shown in Tables 4.1 to 4.5 on pages 57 to 59.

The locations for the initial alternative routes considered is described on pages 32 to 42

and shown on Figures 4.1 to 4.5 on pages 65 to 69, with up to 10 possible routes being

considered for the Clonee to Dunshaughlin Section; 6 possible routes in the

Dunshaughlin to Navan Section; 8 possible routes for the Navan By-pass Section; 6

possible routes for the Navan to Kells Section plus 2 links to the N52 and 5 possible

routes for the Kells to North of Kells Section. Four broad Corridors were identified for

each Section and these were also assessed to identify possible constraints on route

alignments within those corridors, with details given on pages 42 to 46 and shown on

Figures 4.6 to 4.10 on pages 70 to 74 and a summary of that assessment given in Table

4.6 on page 60 in Vol. 2. This suggests that the preferred corridor combination would be

Orange/Blue /Orange/Orange/Orange from Clonee to North of Kells. A further

assessment of the route option comparisons on engineering, environmental and economic

grounds is given on pages 46 to 52 from which the location of the Preferred Route

alignment is identified for each Section and this is shown on Figures 4.11 to 4.15 on

pages 75 to 79 in Volume 2 and the reasons for selecting that Preferred Route are given

in pages 46 to 52 in Vol. 2.

The Preferred Route for the M3 starts from the end of the Clonee By-pass, follows the

existing N3 to the junctions with the Trim and Ratoath roads and then swings to the west

of the existing N3, bypasses Dunshaughlin to the south and west, crosses over the N3 at

Roestown, north of Dunshaughlin, and continues northwards to the east of the N3,

passing between the Hills of Tara and Skreen, and re-crossing the N3 at Blundellstown to

the south of Navan. The M3 route continues to the southwest of Dalgan Park, crosses the

River Boyne and by-passes Navan to the south and west and stays west of the existing N3

in bypassing Kells, crosses the N52 and from there continues northwestwards as a single

904

carriageway road, still to the west of the existing N3, which it rejoins at the Meath /

Cavan County boundary north of Carnaross

Details of the alternative locations considered for the southern and northern toll plazas

are given on pages 61 to 64 in Volume 2.

Section 50 (2) (e) : A summary in non-technical language

This is contained in Volume 1 of the EIS and the summary corresponded generally with

the more detailed sections that followed in Volumes 2 to 7. However, the section on

Potential Construction Impacts at 5.5 did not contain the details of the quantity of

imported fill required to construct the embankments or of the expected consequential

truck movements to transport this fill, both of which are given at Section 3.6 in Vol. 2.

There were also short non-technical sections given in Vol. 3A on page 1; in Vol. 3C on

the first page of Appendix B, in Appendix F on pages 72-76 and in Appendix I on page

3; in Vol. 4C in Appendix D on pages 3-4 and in Vol. 5C in Appendix F on pages 49-51.

Section 50 (3) (a) ( i ) : A description of the physical characteristics of the whole

proposed road development and the land-use requirements during the construction

and operational phases.

The comments under Section 50 (2) (a) above are also applicable here with further details

given in :-

Vol. 1 -- pages 3-5, 23, 27; Vol. 2 -- pages 13-16,

Vol. 3A -- pages 3-12, 113, 194-195, 207-211, 246; Vol. 3C -- D pages 2-4

Vol. 4A -- pages 78, 136, 146-147; Vol. 4C -- D pages 9-14.

Vol. 5A -- pages 14, 137-138, 165; Vol. 5C -- D pages 3-5, G pages 6-7.

Vol. 6A -- pages 12, 143-144; Vol. 6C -- D page 3, F pages 2-3.

Vol. 7A -- pages 6, 110, 126-127; Vol. 7C -- D page 3, Appendix F

Section 50 (3) (a) (ii) : An estimate, by type and quantity, of expected residues and

emissions resulting from the operation of the proposed road development.

Details of the expected residues and emissions are given in the EIS under the relevant

requisite headings as follows:-

Water pollution --- Vol. 1 -- pages 24-25

Vol. 3A -- pages 167-171, 182-185, 195-196; Vol.3C -- F p 4-64.

Vol. 4A -- pages 130, 133, 137, 139; Vol. 4C -- B page 18, C page 8

Vol. 5A -- pages 115-118, 125-126; Vol. 5C -- F pages 22-39.

Vol. 6A -- pages 139-140, Vol. 6C -- E page 17.

Vol. 7A -- pages 97, 102, 105-106.

905

Air pollution --- Vol. 1 -- page 22; Vol.2 -- page 22

Vol. 3A -- pages 68-71, 73-78, figures 3.1- 3.5

Vol. 3C -- B pages 5-8, 23-26, figures 3.1- 3.4 & 17.1-17.2.

Vol. 4A -- pages 35, 41-43

Vol. 5A -- pages 49, 60-63, figures 3.3 - 3.4;

Vol. 5C -- B tables 3.12 -3.19

Vol. 6A -- pages 53-54, 65-67, figures 3.7 - 3.9

Vol. 6C -- B tables 3.12 - 3.16, figures 3.3 - 3.6

Vol. 7A -- pages 47-48, figures 3.6 - 3.7;

Vol. 7C -- B tables 3.11 - 3.13, figures 3.3 - 3.4

Soil pollution --- Vol. 1 -- pages 25, 27; Vol. 3A -- pages 196-198

Vol. 4A -- pages139; Vol. 5A -- pages 128-130

Vol. 6A -- pages 146-148; Vol. 7A -- pages 110-111

Noise pollution --- Vol. 1 -- page 22;

Vol. 3A -- page 97; Vol. 3C -- C pages 15-15, 20-27

Vol. 4A -- pages 55-56

Vol. 5A -- page 78; Vol.5C -- C section 4.6.8 - 4.8

Vol. 6A -- pages 74-75, 86; Vol.6C -- C section 4.6.8 - 4.8

Vol. 7A -- pages 54, 65; Vol.7C -- C section 4.6.8 - 4.8

Vibration --- Vol. 1 -- page 22; Vol. 3A -- pages 98-99; Vol.3C -- C p 18-19

Vol. 4A -- pages 80-81;

Vol. 5A -- pages 80-81; Vol. 5C -- C section 4.10 - 4.14

Vol. 6A -- pages 79-80; Vol. 6C -- C section 4.10 - 4.14

Vol. 7A -- pages 59-60; Vol. 7C -- C section 4.10 - 4.14

Light pollution -- Vol. 2 -- page 16; Vol.3A -- page 247.

Vol. 4A -- pages 80, 162; Vol. 4C -- A page 19.

Vol. 5A -- page 165.

Vol. 6A -- page 95, 185-186; Vol. 6C -- D page 7

Waste pollution --- Vol. 3A -- page 196; Vol. 4A -- page 139; Vol. 5A -- page 130

Vol. 6A -- page 147; Vol. 7A -- page 111

In my opinion, these are adequately addressed in the EIS and these issues were also

discussed in the evidence and cross-examination of the Council witnesses, where the

predicted emission levels and mitigation measures proposed where required, were further

expanded upon.

906

Section 50 (3) (b) : A description of the aspects of the environment likely to be

significantly affected by the proposed road development, including in particular :-

1. Human Beings, Fauna and Flora :

The effects of the proposal on Human Beings arise under a number of headings:

Traffic Volumes -- Safety issues

Details of traffic volume changes from the provision of the M3 motorway and their

effects are discussed in the following pages :-

Vol. 1 -- pages 1, 13; Vol. 2 -- pages 3-4, 19-3, 80-104

Vol. 3A -- pages 27-36; Vol. 3C -- A pages 19-23, 33-37

Vol. 5A -- pages 18-22; Vol. 5C -- A pages 23-32

Vol. 6A -- pages 30-34; Vol. 6C -- A page 21

Vol. 7A -- pages 16-20; Vol. 7C -- A page 20

The most significant impacts identified is the reduction in traffic flows on the existing N3

and in through traffic flows on the Main Street area of Dunshaughlin by 75%, in Navan

by 78% and in Kells by 90% on 2004 traffic flows and in a reduction predicted for

accident statistics of between 30% and 50%

Traffic Noise and Vibration

Details of predicted Traffic noise are discussed in the following pages :-

Vol. 1 -- page 22; Vol. 3A -- pages 92-106; Vol. 3C -- C pages 7-10, 22-25.

Vol. 4A -- pages 48-51; Vol. 5A -- pages 64-68; Vol.5C -- C section 4.6

Vol. 6A -- pages 70-75; Vol. 6C -- C section 4.6

Vol.7A -- pages 52-55; Vol. 7C -- C section 4.6

These were based on a target noise criterion of 68 dB LA10 18hour for determining

where mitigation measures involving the provision of noise barriers were required.

Details of the possible impacts of Vibrations from traffic both from construction and

operation of the road are discussed in pages :-

Vol. 1 -- page 22; Vol. 3A -- pages 98-99; Vol.3C -- C p 18-19

Vol. 4A -- pages 80-81

Vol. 5A -- pages 80-81; Vol. 5C -- C section 4.10 - 4.14

Vol. 6A -- pages 79-80; Vol. 6C -- C section 4.10 - 4.14

Vol. 7A -- pages 59-60; Vol. 7C -- C section 4.10 - 4.14

907

These indicated that during construction all practicable means, as in BS 5228, would be

used to limit vibrations from construction plant, and that when the road was in operation

ground vibrations would be very much less than those required to cause disturbance.

Air Pollution :

The impacts on Air quality are discussed in the following pages :-

Vol. 1 -- page 22; Vol. 2 -- page 4

Vol. 3A -- pages 68-71, 212; Vol.3C -- B pages 4-8; Vol.4A -- pages 34-35,41-43

Vol. 5A -- pages 47-50; Vol. 5C -- B section 3.5-3.9 & appendix 1

Vol. 6A -- pages 55-56, 65-66; Vol. 6C -- B section 3.5-3.9 & appendix 1

Vol. 7A -- pages 33-36; Vol. 6C -- B section 3.5-3.9 & appendix 1

The predictions showed that air quality in the vicinity of the motorway would be in

compliance with known future air quality criteria, and that air quality on the existing N3

would have increased concentrations of pollutants if the motorway was not constructed.

Severance :

The effects of Severance for communities and on agricultural lands are discussed in the

following pages :-

Vol. 1 -- pages 21, 26; Vol. 2 -- pages 42, 44-46

Vol. 3A -- pages 32, 207, 212, figs. 2.3-2.3.6; Vol. 3C--A p 30-37, G sects. 1 & 4

Vol. 4A -- pages 24, 148, 154-157; Vol. 4C -- D pages 16-17

Vol. 5A -- pages 20, 139; Vol.5C -- A pages 23-24, G pages 9-12

Vol. 6A -- pages 41-43, 160; Vol. 6C -- A page 21, F page 5

Vol. 7A -- pages 29-30, 124; Vol.7C -- A page 20, Appendix F

Fauna and Flora :

Both Aquatic and Non- Acquatic Fauna are affected :-

The impacts on Acquatic Fauna are discussed in the following pages :-

Vol.1 -- page 24; Vol.2 -- page 4;

Vol. 3A -- pages 164-165, 175-179; Vol. 3C -- F page 17( protected species)

Vol. 4A -- pages 113-116 ( protected species page 114)

Vol. 4C -- C pages 3-8 ( protected species page 6)

Vol. 5A -- pages 112-114; Vol. 5C -- F pages 2-39

Vol. 6A -- pages 127-129; Vol. 6C -- E page 17( protected species page 126 )

Vol.7A -- page 95-98 ( protected species page 96-97)

908

The Protected species referred to are listed in Annex 11 of the Habitats Directive and are

Salmon, Lamprey, White Clawed Crayfish and Freshwater Pearl Mussel. Evidence was

given that the construction of the bridges and culverts crossing the habitats where these

protected species existed would be arranged so that there would be no direct impact on

the habitat at those crossings.

The impacts on Non-Acquatic Fauna including Birds, Badgers and Otters are discussed

in the following pages :-

Vol.1 -- page 24; Vol. 3A -- pages 146-150 ( Bat survey page 146-147)

Vol. 4A -- pages 103-104, 112 (Bat survey page 103, 112); Vol. 4C -- B p 1-16

Vol. 5A -- pages 98-103,111(Bat survey page 102, 111); Vol. 5C -- E pages 1- 9

Vol. 6A -- pages 115-122; Vol. 6C -- E 16-17

Vol. 7A -- pages 85-90 (Bat survey page 89); Vol.7C -- E pages 3-8

In the the EIS it was stated that there were no NHA's, SAC's or SPA's affected by the

proposed road, but this was amended by the Council during the Hearing in the context of

the submission by Duchas of 22 April 2002 to An Bord Pleanala that the Rivers Boyne

and Blackwater were now proposed candidate SACs. This is discussed in more detail at

several sections of the evidence and cross-examination of Council witnesses ( See

Sections 57.8, 91.1& 110.2 ). The Council gave evidence that the construction of the

river crossings for both Boyne and Blackwater would not directly impact on the proposed

candidate SACs.

See also the reference to the Annex 11 species of the Habitats Directive referred to at

Acquatic Fauna above, which were also detailed in the EIS.

The effects on Flora arises under two headings :

Plants :- The flora along the route is discussed in the following pages with no rare or

protected species being found in the surveys along the route of the proposed road and no

NHAs, SPAs or SACs affected :-

Vol.1 -- page 4; Vol. 3A -- pages 141-146, 148-149; Vol. 3C -- E pages 2, 7.

Vol. 4A -- pages 103-104; Vol. 5A -- pages 98-100; Vol. 5C -- E pages 2-5.

Vol. 6A -- pages 115-118; Vol. 6C -- E pages 3-7.

Vol. 7A -- pages 85-87; Vol. 7C -- E pages 3-6.

Trees :- No specimen trees would be affected by the proposed road but 2402 mature

trees, 1406 of which are Ash trees would have to be removed. It is considered that the

residual impacts on hedgerows would be minor. The effects on trees are also dealt with

in the following pages :-

Vol. 3A -- pages 114, 122, 142, 145, 156; Vol. 3C -- D pages 3, 9; E pages 9, 17.

Vol. 4A -- pages 79, 81, 98, 103-104, 111; Vol. 4C -- A pages 4-5, B page 7.

909

Vol. 5A -- pages 82, 85, 100-101, 110; Vol.5C -- D page 4; E pages 5-6, 18.

Vol. 6A -- pages 94, 118, 125; Vol. 6C -- D page 3; E page 8-9, appendix 3 p 4

Vol.7A -- pages 70, 88, 94; Vol.7C -- D page 3; E page 5, appendix 3 page 25

2. Soil, Water, Air, Climatic factors and the Landscape :

Soil :

No areas of contaminated ground were identified in the assessment of Soil along the

route. Substantial quantities of soil would have to be excavated in cuttings along the route

and it is anticipated that there would be a substantial shortfall in the quantities of suitable

fill material to form the embankments, which would require over 4.5 M cubic metres to

be imported from borrow pits elsewhere from the figure given in Volume 2 of the EIS.

The figures given in Section 8.4 of Vols. 3A to 7A suggest this could be a higher

quantity but more accurate figures, based on more up to date calculations, were given in

their evidence by the Project Engineers at Sections 25.1, 50.1, 86.1 & 102.1 in this

Report.

The location of these external borrow pits and the transport of material from these to the

site and the location of possible disposal sites and transport of waste material to them was

questioned and discussed at the Hearing and is commented on further on at Sections 147

& 148 of this Report. See also comments at Section 50 (3) (d) below.

The effects on soils are discussed on the following pages :-

Vol. 1 -- page 25; Vol. 2 -- pages 16, 23; Vol. 3A -- pages 194-198, 213, 247.

Vol. 4A -- pages 137, 146; Vol. 5A -- pages 130, 137,

Vol. 6A -- pages 144-146, 158. Vol. 7A -- pages 110-111, 122

Water :

The impacts on Water are discussed in the EIS with the use of Attenuation ponds

proposed at several locations to mitigate outflow rates where this was considered to be

necessary in particular storm conditions. A Flood study using the HEC-RAS model was

undertaken for the part of the Tolka River catchment upstream of the proposed route

where there is a history of flooding in the Dunboyne and Clonee areas and mitigation

measures are identified to minimise the impact from the proposed road development on

this flooding.

The effects on Water are discussed in the following pages :-

Vol.1 -- pages 24-25.

Vol. 3A -- pages 149, 167-168, 182-187, 196; Vol. 3C -- F pages 44-60.

Vol. 4A -- pages 104, 116, 130-131; Vol. 4C -- C pages 7-8

Vol. 5A -- pages 112-114, 124-126, 130; Vol. 5C -- E pages 6, F page 11-21

910

Vol. 6A -- pages 127-129, 138-140; Vol. 6C -- E pages 12-13, 17

Vol. 7A -- pages 95-98, 102; Vol.7C -- E pages 15-16

Air and Climatic factors :

The impacts on Air quality are discussed on the following pages :-

Vol.1 -- page 25; Vol.3A -- pages 67-70; Vol. 3C -- B pages 4-8

Vol. 4A -- pages 32-35.

Vol. 5A -- pages 46-50; Vol. 5C -- B sections 3.5- 3.6, appendix 2.

Vol. 6A -- pages 55-56; Vol. 6C -- B sections 3.5- 3.6, appendix 2.

Vol. 7A -- pages 34-40; Vol. 7C -- B sections 3.5- 3.6, appendix 2.

The results of the predicted air quality impacts indicate that worst-case pollutant

concentrations would comply with the relevant EU and Irish limit values along the route

of the proposed road development and that there would be significant reductions in

pollutant concentrations in NO2, particularly in Dunshaughlin, as a result of the proposed

motorway

The effects on Climatic factors are reported in section 9 of Vols. 3A to 7A the EIS and

were not considered to be significant.

The Landscape :

Details of the visual impacts of road on the Landscape and on adjoining properties are

discussed in the following pages:-

Vol. 1 -- page 24; Vol.3A -- pages 113-117; Vol. 3C -- D pages 8-17, 23.

Vol. 4A -- pages 81-82, 89-95, (TPO impacted at Dalgan Park) Vol. 4C--A p 3-7

Vol. 5A -- pages 82-84; Vol. 5C -- D pages 3-8

Vol. 6A -- pages 93-99; Vol. 6C -- D pages 3-15.

Vol. 7A -- pages 69-75; Vol. 7C -- D pages 3-13.

Visual Quality zones in the County Development Plan at VQ 3 - River Valleys, VQ 9 -

Tara and Dunsany and VQ 11- Rural and Agricultural are affected as well as Views and

Prospects at VP 1- Tara, VP 27 at Skreen and VP 32 Blackwater Valley but there are no

areas described as Sustainable Recreational Use of Natural Assets (SRUNAs) in the

Development Plan directly impacted on by the proposed motorway.

The visual impacts are also discussed in the evidence and cross-examination of the

Council's Planning Officer and Landscape expert witness, see Sections 21.1 and 62. 1 &

62.4 of this Report.

911

3. Material assets, including the architectural and archaeological heritage, and the

cultural heritage :

Material assets :

These arise under two headings, Agricultural and Non-Agricultural including Natural

Resources.

The effects on Agriculture are discussed in the following pages :-

Vol. 1 -- page 26; Vol. 2 -- pages 42-46

Vol. 3A -- pages 207-211, figs. 10.1.1- 10.1.4; Vol. 3C -- G sections 3 & 4.

Vol. 4A -- pages 145-148, figs. 10.1.1- 10.1.4; Vol. 4C -- D pages 5-14

Vol. 5A -- pages 136-138; Vol. 5c -- G pages 3-12.

Vol. 6A -- pages 157-161; Vol. 6C -- F pages 2-6.

Vol. 7A -- pages 121-125; Vol. 7C -- Appendix F ( unnumbered)

The effects on Non-agriculture and Natural Resources are discussed in the following

pages :-

Vol. 1 -- page 26; Vol. 2 -- pages 42-46

Vol. 3A -- pages 232-233, 246-247, figs 11.1.1-11.1. 4

Vol. 3C -- A pages 38-41; D page10.

Vol. 4A -- pages 23, 158, 161, figs 11.1.1- 11. . 4

Vol. 5A -- pages 160-161, 165-166, figs. 11.1.1 - 11.1.3

Vol. 6A -- pages 179-183, 185-187. Figs. 11.1 - 11.4

Vol. 7A -- pages 137-140, figs 11.1 -- 11.3

Architectural Heritage and Cultural Heritage:

The effects on the Architectural and Cultural Heritage are discussed in the following

pages :-

Vol. 1 -- page 27; Vol. 2 -- 42-46.

Vol. 3A -- pages 121, 277-279, photos 14.1-14.2; Vol. 3C -- D page 4, J pages 1-9

Vol. 4A -- pages 88, 186-187; Vol. 4C -- Appendix F ( no. pg nos.)

Vol. 5A -- pages 178-180; Vol. 5C -- H pages 9-10, I pages 2-21 & appendices

Vol. 6A -- pages 207-212; Vol. 6C -- G pages 21-49

Vol. 7A -- pages 167-174; Vol. 7C -- H pages 12-16.

In their submission to An Bord Pleanala of 25 April 2002, Duchas referred to the

interpretation of the definition of "architectural heritage" as defined in the Architectural

Heritage( National Inventory) & Historic Monuments Act 1999 used in the preparation of

the EIS as being too restrictive and suggested that those parts, particularly in Volumes 3

to 6, should be reviewed. Duchas suggested that, with the exception of Volume 7, the

items considered in the EIS were confined largely to country houses and some bridges

912

and that no reference had been made to vernacular structures, existing village complexes,

items of industrial heritage such as corn mills etc, bench marks, farm structures and

complexes, demesne grounds, walls, entrance gates and structures of the latter part of the

19th and all of the 20th century. The Council responded to these suggestions by Duchas

and this is detailed in Sections 60 and 60.1 of this Report. Duchas did not attend and

were not represented at the Hearing. The effects on the settings of demesnes, particularly

for Ardbraccan and Dowdstown House, were extensively discussed in the crossexamination

of the Council witnesses on this aspect.

Archaeology:

This is discussed in the following pages :-

Vol.1 -- page 27; Vol. 2 -- pages 42-46.

Vol. 3A -- pages 121, 252-256, 260-263, figs. 13.1.1 - 13.1.4, photos 13.1 -13.8

Vol. 3C -- I pages 5-36;

Vol. 4A -- pages 165-175, figs. 13.1.1 - 13. 1. 4; Vol. 4C -- E pages 3-30.

Vol.5A -- pages 168-170; Vol.5C -- H pages 3-50

Vol. 6A -- pages 191-200; Vol. 6C -- G pages 1-21

Vol. 7A -- pages 147-162; Vol. 7C -- G pages 22-31

The effects on Archaeology by the proposed route would involve the excavation and

preservation by record of a number of archaeological sites, some of which had been

identified as potential archaeological site or complexes by a Geophysical Survey

undertaken for the Council along the proposed route in the Dunshaughlin to Navan

Section and at Nugentstown on the section from Navan to Kells. The number of sites

identified as requiring to be excavated totals 20 with one of these located in the valley

between the Hill of Tara and the Hill of Skreen. The potential impacts of the route being

placed in the valley between the Hill of Tara and the Hill of Skreen from and

archaeological, cultural and historical perspectives was extensively discussed in the

cross-examination of the Council's expert witnesses, particularly Ms Margaret Gowan at

the Hearing and a verbal submission was made by Mr. Conor Newman, the former

director of the Discovery Programme on the potential impact of the route on the Tara

landscape. The Council submitted proposals for pre-construction archaeological

investigations along the route in response to the Inspector's request arising for the

concerns expressed about the potential impacts on archaeological sites both known or yet

to be identified.

4. The Inter-relationships between the above factors :

While there is no specific chapter on the appraisal of the interactions in the EIS, the Interrelationship

between aspects of the environment and their potential impact on one another

is discussed in several parts of the EIS with inter-relationship matrices being given in

Tables 1.1 and 1.3 in Volume 2. There are also descriptions of the interactions between

913

the various aspects given at the start of several of the sections within each of Volumes 3A

to 7A of the EIS. The interactions were also referred to by a number of witnesses during

evidence and cross-examination at the Hearing. The details of where the interrelationships

are discussed in the EIS are given in the following pages :-

Vol. 1 -- pages 21, 23, 27.

Vol. 2 -- pages 4, 56-54, Table 1.1 page 4, Table 1.3 page 9.

Vol. 3A -- pages 25, 115, 139, 205, 249; Vol.3C -- A 47-49; D pages 2-5.

Vol. 4A -- pages 21, 97, 144, 164. Vol. 5A -- pages 16, 97, 135, 167.

Vol. 6A -- pages 19, 113, 155, 189. Vol. 7A -- pages 11, 83, 119, 145.

I am satisfied that the inter-relationships between the various factors at 1 to 3 of Section

50 3 (b) above were adequately dealt with, between the details given in the EIS and the

evidence presented at the Hearing.

Section 50 (3) (c) : A description of likely significant effects (including direct,

indirect, secondary, cumulative, short, medium and long, permanent and

temporary, positive and negative ) of the proposed road development on the

environment resulting from :

1. The existence of the proposed road development :

The aspects of the environment affected by the existence of the proposed road

development are:-

Humans with regard to Safety, Noise, Visual Effects, Community and Severance and the

degree to which they are affected are outlined in the EIS on the following pages :-

Vol. 3A -- pages 64,70, 92-94, 116;

Vol. 3C -- B pages 8-12, 23-26; C pages 10-14, 22-25.

Vol. 4A -- pages 35, 49, 51, 75, 85.

Vol. 5A -- pages 20-22, 32, 34-40, 50, 66-67, 91-94

Vol. 5C -- A pages 25-31; B sect. 3.5-3.6; C sect. 4.7 - 4.9; D pages 9-16; G p 12.

Vol. 6A -- pages 28-34, 55-56, 74-77, 97-99.

Vol. 6C -- A pages 22-28; B sect. 3.5 - 3.6; C sect. 4.7 - 4.9; D pages 10-14.

Vol. 7A -- pages 12-22, 39-40, 54-55, 79-82.

Vol. 7C -- A pages 19-20; B sect. 3.5 - 3.6; C sect. 4.7 - 4.9; D pages 9-13.

Flora / Fauna, and the degree to which these are affected are discussed in the EIS on the

following pages :-

Vol. 2 -- page 4. Vol. 3A -- pages 149-150, 167-172, 175-179

Vol. 3C -- E pages 14-20; F pages 49-70

Vol. 4A -- pages 103-104, 116; Vol. 4C -- B pages 16-22; C pages 8-1.

Vol. 5A -- pages 103-104; Vol.5C -- E pages 10-11; F pages 2-39.

914

Vol.6A -- pages 121-122; Vol.6C -- E pages 16-17

Vol. 7A - pages 90-92, 98-99; Vol. 7C -- E pages 2-8.

Protected aquatic species, such as the salmon, lamprey, white clawed crayfish and

freshwater pearl mussel, and protected non-acquatic species, such as the otter and bats,

are discussed in the above pages.

Landscape, Archaeology and Cultural Heritage and the degree to which these are

affected are outlined in the EIS in the following pages :-

Vol. 1 -- pages 23, 27; Vol. 2 -- page 4.

Vol. 3A -- pages 115-119, 252-269, 277- 279;

Vol. 3C -- D pages 8-17; I pages 12-36, figs. 1-8 and photos 1-33

Vol. 4A -- pages 80-82, 175-177, 180-187;

Vol. 4C -- A pages 8-18; E pages 31-32; Appendix F ( unnumbered )

Vol. 5A -- pages 84-88, 91-96, 168-170, fig.5.1.3 ( Ardbraccan)

Vol. 6A -- pages 95-99, 200-202, 209-210; Vol. 6C -- D pages 7-15; G page 1-49

Vol. 7A -- pages 71-74, 161-163, 172-174;

Vol. 7C -- D pages 7-13; G pages 1-31; H pages 1-16

2. The Use of Natural Resources :

The aspects of the environment affected by the use of Natural Resources are outlined in

the following pages :-

Vol. 1 -- page 26; Vol. 2 -- pages 16, 23.

Vol. 3A -- pages 13, 196, 246-247; Vol. 3C -- G section 4

Vol. 4A -- pages 12, 138-139, 163-163; Vol. 4C -- D pages 14-19

Vol. 5A -- pages 130, 143; Vol. 5C -- G pages 8-15

Vol. 6A -- pages 144-146, 185-187; Vol. 6C -- Appendix F (unnumbered)

Vol. 7A -- pages 110-111, 141-143; Vol. 7C -- Appendix F (unnumbered)

3. The emission of Pollutants and the creation of Nuisances and the elimination of

wastes:

The aspects of the environment affected are Noise, the Air Quality and the Receiving

Waters and Receiving Soils and these are discussed in the following pages :-

Noise :

Vol. 1 -- page 29.

Vol. 3A -- pages 92-94, 96-98, 106; Vol. 3C -- C pages 7-12, 22-27.

Vol. 4A -- pages 51, 67-75; Vol. 5A -- page 78; Vol.5C -- C section 4.6 - 4.8.

915

Vol. 6A -- pages 74-75, 86; Vol. 6C -- C section 4.6 - 4.8

Vol. 7A -- pages 53, 65-67; Vol. 7C -- C section 4.6 - 4.8.

Air quality :

Vol. 1 -- page 28. Vol. 3A -- pages 68-78; Vol. 3C -- B pages 4-9.

Vol. 4A -- pages 35, 41-43;

Vol. 5A -- pages 60-63, Vol. 5C -- B tables 3.12 -3.19, figs. 3.3 -3.5.

Vol. 6A -- pages 55-56, 63-67; Vol. 6C -- B tables 3.12 -3.16, figs. 3.3 -3.5.

Vol. 7A -- pages 47-48; Vol.7C -- B tables 3.11 -3.13.

Receiving Waters :

Vol. 1 -- pages 24-25.

Vol. 3A -- pages 149, 170-171, 183-185; Vol. 3C -- F pages 58-60, 69-71.

Vol. 4A -- pages 113-114; Vol. 4C -- C pages 7-8.

Vol. 5A -- pages 114-115, 121-123, 125-126; Vol. 5C -- F pages 27-39.

Vol. 6A -- pages 129, 134-135, 138-140; Vol. 6C -- E pages 12-13, 15.

Vol. 7A -- pages 98, 102, 105-106; Vol.7C -- E pages 9-10.

Receiving Soils :

Vol. 1 -- pages 25, 27; Vol. 3A -- pages 196-197; Vol. 4A -- pages 137-138.

Vol.5A -- pages 130-131; Vol. 6A -- pages 146-148; Vol.7A -- pages 110-111.

4. Forecasting methods used to assess the effects on the environment:

These are described for Traffic effects, for Noise pollution, for Air pollution and for

Water pollution on the following pages :-

Traffic :

Vol. 1 -- page 13 and Vol. 2 -- pages 19-22, 24-31, 80-104.

The forecasting methods used for Traffic effects were further discussed in the evidence of

M/s Guthrie & Richardson in Sections 17.1 and 20.1 and in their cross-examination by

Mr. Burke in Sections 17.2 and 20.2 and in Mr. Burke's cross-examination of Mr. Evans

in Section 134.1 all of this Report.

Noise :

Vol.1-- page 22; Vol. 3A -- pages 93-94, 101-103; Vol.4A -- pages 48-49, 60-65.

Vol. 5A -- pages 74-75; Vol.5C -- C section 4.3-4.6, tables 4.3-4.6, appendix A

Vol. 6A -- pages 73-75; Vol.6C -- C section 4.3-4.6, tables 4.3-4.6, appendix A

Vol. 7A -- pages 61-64, 66; Vol. 7C -- C section 4.3-4.6, tables 4.3-4.6, app. A.

916

The use of the CRTN method for predicting Traffic Noise was discussed in the crossexaminations

of the Council's expert witnesses and in particular during Mr. Dilworth's

evidence and his cross-examination by Mr. Searson in Section 108 of this Report.

Air pollution :

Vol. 1 -- page 22; Vol. 3A -- pages 64-71; Vol. 3C -- B pages 1-8.

Vol. 4A -- pages 33-34, 38-40.

Vol. 5A -- pages 54-59; Vol. 5C -- B section 3.5, tables 3.6 - 3.11.

Vol. 6A -- pages 53-56; Vol. 6C -- B section 3.5, tables 3.6 - 3.11.

Vol.7A -- pages 44-46; Vol. 7C -- B section 3.5, tables 3.6 - 3.11.

Water pollution :

Vol. 3A -- pages 180-183, figs. 7.3.1 - 7.3.4. Vol. 3C -- F pages 9 - 42.

Vol. 4A -- pages 121-129. Vol. 5A -- pages 121-122, figs. 7.1.1 - 7.1.3.

Vol. 6A -- pages 128-129, 134-135, figs 6.1 - 6.3.

Vol. 7A -- pages 100-101, 105-106, figs. 6.1 - 6.3.

Section 50 (3) (d) : An indication of any difficulties (Technical deficiencies or lack of

know-how) encountered by the road authority in compiling the required

information :

In Section 8.4 on "Impacts of Development" in each of Volumes 3A to 7A of the EIS a

difficulty in identifying, at the time the EIS was written, the exact locations from where

the material to be imported to make up the shortfall in filling required to construct the

embankments would be sourced. A difficulty in identifying where unsuitable material

would be disposed of off-site was also identified. It was stated that these difficulties arose

since the decisions on these sources would largely be commercial decisions for the

contractor, who would be constructing the scheme, to make. It was suggested that local

existing licensed quarries or local borrow pits would be used. It was also stated that

where borrow pits and disposal sites were used, their use would be subject to compliance

with all relevant legislation under the Planning and Development Acts and Waste

Licensing Regulations. This matter was discussed at the Hearing on several occasions,

particularly at Section 18 of this Report. ( See also pages 922 & 923 in Section 147

below)

Difficulties are also noted in the following pages of the EIS where access disputes

prevented site access for certain inspections. An off-site inspection was then used in these

cases :-

Vol. 3C -- E page 8; F page 8; G table 6b.

Vol. 5C -- G page 1; Vol. 7C -- H page 11.

917

Section 50 (3) (e) : A summary in non-technical language of the above information :

The Non-Technical Summary, Volume 1 of the EIS, referred to in the commentary on

Section 50 (2) on page 904 of this Report also contains the relevant data from Section 50

(3) above, with the exception of the details referred to at Section 50(3) (d) above.

Comments on compliance of the EIS with the requirements of Section 50 (2) and

Section 50 (3) of the Roads Act, 1993, as amended.

During the Hearing the validity of the EIS was questioned on a number of occasions for a

variety of reasons and there were several requests for an adjournment of the Hearing on

the basis that the information available in it was inadequate or that certain matters that

should have been addressed in it had not been included. There were also questions raised

about the methodologies used in compiling some of the data, such as the noise

measurements in Dalgan Park, and on the assessment of some of the impacts in the route

selection matrices for the Dunshaughlin to Navan and Navan By-pass Sections, which it

was suggested undermined the credibility of the EIS. Questions were also raised in

relation to the availability of data so that a proper appraisal could be made by objectors of

what was being proposed and suggestions were made that the Consultation process used

in the route selection was flawed which undermined the validity of the EIS.

Another issue that was raised, principally by the Bellinter Residents Association, the

Meath Road Action Group and by Mr. O'Donnell on behalf of Dalgan Park, and to an

extent by Mr. Casey on behalf of Ardbraccan House, was that the wrong route had been

selected and that, because of this, the EIS presented by the Council should not be

approved.

These issues, as well as others, were referred to in their Closing Submissions by M/s

O'Donnell, Casey, Magee and Park and responded to by Mr. Butler in his Closing

Submission, see Section 143 above. My comments on these issues follow in Sections 147

& 148.

With regard to the section on "interactions", these were discussed at a number of stages

during the evidence and in the cross-examination of Council witnesses during the

Hearing and this was raised specifically with Ms Dempsey in the context of queries

raised by objectors, see Sections 23.7, 23.13 and 51.2 of this Report. I am satisfied, as

referred to previously on pages 912 & 913 of this Report, that the details given in the EIS

in the section on inter-relationships were adequate the and that the requirements of the

Act in respect of inter-relationships, as required in 50 (3) (b), have been complied with.

There were a number of comments made during the Hearing about the lack of references

to range of activities and the amenities available in Dalgan Park in the EIS. Specifically

there is no reference to the Conference facilities available in Dowdstown House or to the

riverside and woodland walks in the Dalgan Park grounds in the section on Socioeconomics

in either Volume 4A or 4C. There is, however, a reference to the use of

918

Dowdstown House as a Conference centre in the section on Cultural Heritage at page 186

of Vol. 4A and the SRUNA area in Dalgan Park is noted in Appendix A in Vol. 4C and

shown on figs. EIS-BSM-EX 103 / IMP 103. Mr. Guthrie stated in evidence that the route

through Dalgan Park had been assessed principally from the effect it would have on the

farming operations since the route passed through the farmland of Dalgan Park and that

both Dowdstown House and Dalgan Park had been fully assessed for the Noise, Air and

Landscape and other effects while not being specifically referred to in the socioeconomics

section. Mr. Prendiville, in his direct evidence to the Hearing, also referred to

the Conference Centre and the walks in Dalgan Park and in his cross-examination

accepted that Dalgan Park should have been assessed in both the Agricultural and Socioeconomic

section in Vol. 4A. ( see Section 56.1 & 56. 4 of this Report )

The absence of a reference to some of the local community facilities in the Ross Cross/

Collierstown/ Skryne area from Table 2.6 in the Socio-economic section in Vol. 4A was

also raised at the Hearing and these were acknowledged by the Council. (see Section 56.5

of this Report)

For the reasons which I outline in Sections 147 and 148 I am satisfied that the arguments

advanced in questioning the validity of the EIS are not well founded. I am also satisfied

that the omissions referred to regarding Dalgan Park and Dowdstown and in the

Collierstown area do not materially affect the overall assessment of the effects of the

proposed road development on the environment.

Having regard to the evidence on EIS content outlined in the commentary on the subsections

of Section 50 (2) and 50 (3) above, I am satisfied that the EIS submitted to An

Bord Pleanala presented sufficient information to comply with the requirements of

Section 50 of the Roads Act, 1993, as amended.

146. Comments on Written Objections and Submissions made to An Bord Pleanala

prior to the Hearing :

As outlined in Sections 6 and 13 of this Report, there were effectively 311 objections

made to An Bord Pleanala in respect of the Motorway Order, and 76 submissions in

respect of the Environmental Impact Statement for the Road Development were received

within the prescribed time, with One late submission. 22 of those who made objections to

the Motorway Order related more to the environmental impacts of the Road Development

in the content of their objections and 7 of the submissions made in respect of the Road

Development were more appropriate to the Motorway Order. During the course of the

Hearing 124 of the objections to the Motorway Order were withdrawn on the basis of

agreements having been reached with the Council and the names of the landowners

involved are listed in Section 9 of this Report.

919

1. Written Objections against Land Acquisitions :

A summary of the objections received against the Land Acquisition is given in Section 13

of this Report but only for the Plots for which the objection was not withdrawn, either at

the opening of or during the Hearing. An examination of the Written Objections indicated

that the main issues were :-

· Alternative route available / Wrong route selected

· Proposal contrary to Law and Development Plan

· Motorway near Tara not justified

· Impacts of Interchanges / Roundabouts

· Closure of R125 ( Leshamstown Lane issue)

· Scale of Dunboyne By-pass

· Excessive land take

· Severance and access issues

· Animal Disease issues / Shared underpasses

· Drainage issues

· Flooding issues

· Effects on services, e.g. water supplies, utilities etc.

· Screening of property

· Concerns about problems from roads being left as cul-de-sacs

· Effects on driveways

· Inadequate Boundary treatment proposals

These issues are discussed in the evidence and cross-examination of Mr. Guthrie, Ms

Joyce and Mr. Evans, the Project Engineers as well as that of Mr. Killeen, the Council's

Planning Officer, particularly in Sections 17, 19, 21, 25, 50, 86 and 102 of this Report as

well as in the evidence and cross-examination of the Council's other witnesses. I am

satisfied that from the evidence at the Hearing all of the issues raised by the objectors to

the Motorway Order were adequately addressed. I am also satisfied that the Council

presented sufficient evidence to justify all of the acquisitions that were included in the

Order.

2. Written Submissions on Environmental Impact Statement :

76 submissions were made to An Bord Pleanala within the prescribed time before the

Hearing and there were 22 submissions included in the objections made to the CPO that

related more to the environmental impacts. A summary of these submissions is given in

Section 13 of this Report. An examination of the written submissions indicated that the

main issues were :-

· Alternative route available / Wrong route selected

· Proposal contrary to Law and Development Plan

· Adequacy of the EIS

920

· Noise levels

· Air Pollution

· Light Pollution

· Archaeological effects

· Cultural Heritage effects

· Effects on Dowdstown/ Dalgan and Tara/Skryne

· Effects on Ardbraccan / Boyerstown

· Inadequate provision for Alternative Transport modes

· Provisions for Pedestrians and Cyclists

· Effects on services, e.g. water supplies, utilities etc.

· Effects on Businesses

· Need for a Bat Survey

· Screening of property/ Privacy issues

Some of the issues raised in respect of the EIS were also raised in respect of the

Motorway Order. I am satisfied that all of the issues referred to in the submissions made

prior to the Hearing were adequately addressed during the evidence given at the Hearing,

and in the cross-examination of the Council witnesses at the Hearing.

147. Comments on Submissions made on Legal Aspects of Council's proposal :

As was referred to in the commentary on the compliance of the EIS with the requirements

of Sections 50 (2) & (3) of the Roads Act 1993, as amended, the validity of the EIS was

questioned on a number of occasions during the Hearing both from legal or quasi-legal

aspects and also on the basis of the wrong route having been selected. There were also

concerns expressed about aspects of the Public Consultation and suggestions that these

perceived "defects" had an effect on the selection of the preferred route. In this Section

the submissions relating to the legal or quasi-legal aspects are dealt with and the issues

raised relating to route selection, public consultation and information are dealt with in

Section 148.

At the outset of the Hearing and as detailed in Section 14 of this Report Mr. Galligan

S.C., appearing then of behalf of the owners of Ardbraccan House, sought an

adjournment on the basis of a challenge that had been made in the High Court to the

validity of the County Development Plan (CDP) of 2001 and submitted that, as this had

not then been ruled on by the High Court, the Hearing should be adjourned as he

contended that An Bord could not determine the application in the event of the Court

ruling that the CDP was invalid. Mr. Galligan further submitted that there was no

reference in the CDP to the M3 Scheme being a tolled motorway and that should have

been referred to as an objective in the CDP itself. He also referred to there being no

reference to a tolled scheme in the copy of the CDP purchased by his Client, Ms. Maher,

on 19 August 2002 from the Council Offices and that that copy did not contain the

variation adopted in February 2002. He also referred to the newspaper advertisements of

December 2001 for this variation which did not contain a specific reason for the variation

which, he submitted was a breach of the requirements of Section 13(3) of the Planning

921

and Development Act 2000 and he subsequently handed in a copy of this advertisement

which is listed in Appendix 4 of this Report at Day 4 during his cross-examination of Mr.

Killeen, the Council's Planning Officer.

My ruling rejecting Mr. Galligan's request is given in Section 14.9 of this Report and

followed from Mr. Galligan's admission that he had failed in his application to obtain

injunctive relief in the High Court. From a recent Notification on the outcome of Legal

proceedings ( 06/06/03 ) it appears that this application to the High Court challenging the

validity of the CDP has now been determined by the action being withdrawn. It should

also be noted that another challenge to the validity of that CDP, but based on somewhat

different grounds -- Smith and McEvoy v. Meath County Council -- was dismissed by

the High Court in October 2002.

As will be described subsequently in Section 149 of this Report, the CDP of 2001 clearly

makes provision for a motorway between Clonee and North of Kells and the EIS in the

Non-technical summary, Vol.1, and in Vol. 2 refers to the intention of the M3 scheme to

be progressed as a Public Private Partnership (PPP) with the concessionaire being able to

recoup some or all of the construction / operation costs through the collection of tolls.

The EIS goes on to point out that the making of a Toll Scheme would be determined in

accordance with the procedures in the Roads Act 1993 and the Planning and

Development Act 2000 which would be a separate procedure and this, in my opinion,

removes any necessity for a reference to tolling having to be included in the CDP itself.

The other issue he raised, that of the lack of a reason for the Variation on the

advertisement, was discussed in detail in Mr. Galligan's cross-examination of Mr. Killeen

in Section 21.8 of this Report when Mr. Killeen stated that the reason was given in the

detail in block capitals on the advertisement dated 19 December 2001. In my opinion this

complies with the requirements of Section 13 (3) (a) of the Planning and Development

Act 2000

Mr. Casey of Casey & Co. Solicitors, who appeared for Ms Maher at the later part of the

Hearing, also referred to the same Variation of February 2002 to the CDP and to the

advertisement of its adoption in both his Preliminary Submission, detailed in Section

121.1 and in his Closing Submission, detailed in Section 143.5, both in this Report.

In his closing submission Mr. Casey submitted that the time lapse between the adoption

of the Variation on 4 February 2002 and the advertisement to that effect on 29 May 2002

amounted to a denial of rights for the public to participate (a) in the routing and

positioning of the road, (b) in the CDP and (c) in the Variation; that it was not possible

for the public to make reasoncd and technically legal submissions against the CPO/EIS

in the absence of they being aware of the passing of the Variation and that this amounted

to a denial of public rights of participation in the process leading to the Hearing and any

adoption by an Bord of the scheme. It should be noted that the CDP of 2001 was adopted

in March 2001, some 12 months before the Motorway Order and EIS were published and

this identified the Council's intention to construct a motorway from Clonee to Kells,

including By--passes of Dunshaughlin, Navan and Kells.

922

Mr. Casey submitted that the Navan Environs Plan of 1997 was an "Area Plan" made

under the 1963 Planning and Development Act which lapsed when the 2001 CDP Plan

was made since it was part of the infrastructure of the 1994 plan. He submitted that there

was a material lacuna in Part 2 of the 2001 CDP where there was no mention of Navan

and its Environs in that document and that it was questionable in there was any variation

of the Navan Environs Plan of 1997 made on 4 February 2002 as he suggested a

variation could not be made to a Plan that did not exist. While Mr. Casey's contention

might be an arguable point, it should be noted that the CDP Rural Detail Map of the

Navan Area Infrastructure Map for Variation no. 2 to the CDP of 2002, adopted on 4

February 2002, clearly shows the route of the M3 extending from the Roestown crossing

on the N3 to the north of Dunshaughlin to the N 52 By-pass of Kells. Since this is part of

the 2001 CDP as Varied, in my opinion that overcomes whatever "lacuna" might exist

about the 1997 Navan Environs Plan as suggested by Mr. Casey.

In his preliminary submissions and as detailed in Sections 121 to 125, Mr. Casey

suggested that a number of statutory bodies, specifically Navan, Kells and Trim UDCs

(as they then were), were not circulated with details of the proposed variation to the 2001

CDP and he submitted that this lapse questioned the validity of the CDP and that the

Council could not propose a scheme that was materially in contravention of their own

Plan. It transpired that this notification had been issued and that the details were on a

computerised record and not in a hard copy format on the public file. Mr. Casey went on

the submit that since the motorway scheme was a tolled scheme and that a letter to the

Council from the NRA of 28 February 2001 showed it as being driven by the NRA, that

in the absence of a Five Year Plan by the NRA under Sections 17/18 of the Roads Act

1993 made the scheme ultra vires to both the NRA and the Council. Mr. Casey drew

attention to an application pending in the High Court for judicial review relating to the

powers of the NRA and Councils in respect of road schemes proposed by them, Joan

Finlay v. Laois County Council and the NRA.

Arising from questions raised during the Hearing about the role of the NRA in the

proposed motorway scheme, Mr. Butler had already stated that the scheme was being

promoted by the Council in its own right as the Roads Authority and in his closing

submission Mr. Butler repeated this since Mr. Sweetman in his closing submission had

also raised the issue of the NRA/Council relationship. On the basis of the situation

outlined by Mr. Butler it appears that the issue of the Motorway Scheme being ultra vires

to the Council does not arise.

Mr. Sweetman sought an adjournment of the Hearing on the issue of the sourcing of

imported fill material and off-site disposal locations and submitted that there was

inadequate information in the EIS to allow the public to assess the implications of traffic

movements and other effects. He suggested that An Bord Pleanala had previously ruled

that such additional information had to be provided in a similar situation to this. Mr.

O'Donnell and Mr. Galligan supported this application with Mr. Galligan suggesting that

it was project splitting to exclude the extraction of materials for the construction from the

EIS. This issue is detailed in Sections 17.9 and 18 in this Report.

923

The case referred to by Mr. Sweetman was that of the "Waterford By-pass Scheme and

N25 Waterford By-pass (No.1) CPO 2002" about which An Bord wrote to Waterford

Corporation on 11 March 2002 regarding a number of matters where additional

information / clarification was required, one of these relating to the quantities of surplus

material generated and general proposals for its disposal. As outlined in Section 18.3, in

the light of the information outlined at section 8.4 in each of Vols. 3A to 7A of the EIS

on the likely quantities of imported fill and the need for further legislative procedures in

relation to non-licensed sites and that the Council were assembling information on this

issue, I ruled that there was sufficient information available in the EIS, as presented, to

allow the Hearing to proceed.

A map identifying possible locations for borrow pits along the proposed route and the

locations operational quarries and gravel pits and of licensed waste sites was submitted

by the Council on Day. There were discussions about this issue in Ms Dempsey's crossexamination

by M/s. McGrath and Burke in Sections 23.3 and 23.7 and later in her crossexamination

by M/s. Sweetman and O'Donnell in Sections 51.1and 51.2 and concerns

were raised by other objectors about possible locations near them. The issue was not

raised in any of the closing submissions. Mr. Bergin, Consulting Engineer, giving

evidence on behalf of Dalgan Park questioned the transportation implications and

suggested it could take up to 313 return trips daily for a period of 30 X 6 day weeks using

10 cu. metre lorries to transport the 1.2 M cu. metres of fill and 0.49 M cu. metres of

disposed material for the Dunshaughlin to Navan Section. Mr. Lumley giving evidence

on behalf of An Taisce said that the landscape impacts of the quarrying and extraction

sites should have been addressed.

Each of the Project Engineers when giving evidence about their sections gave details of

the most recent calculations for quantities for those sections which total circa 5.33 M cu.

metres of imported fill being required and circa 1.46 M cu. metres of unsuitable material

being disposed of off-site. The Council gave an undertaking that the access routes for this

material into and out of the site of the proposed M3 would be generally restricted to the

use of either the National roads, N3/ N51/ N52 and Regional roads with only certain

specified sections of Local (County) roads being used.

Having regard to the fact that any off-site location for use as either a source for filling or

as a disposal site for unsuitable material that is not already licensed under either the

Planning Acts or the Waste Licensing regulations will be required to go through a

regulatory procedure which provides for input by the public; that the "development site"

extends from Clonee in the south of the county to the Cavan border over a distance of

some 60 kms; that the issue and the difficulties of identifying locations in the context of

the PPP type contract was set out in the EIS, and to the extent of the submissions and

discussions on the issue at the Hearing, I consider that matter has been adequately

addressed and that further information is not required to enable a decision to be taken on

the Application for Approval of the Road Development.

924

On completing his cross-examination of the Council's witnesses and before presenting

any evidence on behalf of his Dalgan Park Clients, Mr. O'Donnell sought an adjournment

of the Hearing and submitted that the Council should go back and prepare the various

headings in the EIS in a manner that would, he said, allow for a proper assessment to be

carried out on an appropriate EIS. In his submission, which is dealt with in Section 63 of

the Report, Mr. O'Donnell questioned the competence of the various witnesses that had

given evidence for the Council on the Dunshaughlin to Navan Section in relation to the

approach taken, the level of detail addressed and the conclusions reached and suggested

that, in most of the areas discussed, there had been a more appropriate route considered at

the route selection stage. Mr. O'Donnell referred particularly to the expert witness on

noise and to the witness on the socio-economic section where, having identified that thc

latter witness did not have either sociology or economics qualifications, then declined to

ask him any questions. Mr. Butler accepted that Mr. O'Donnell was entitled to criticise

the evidence being put before the Hearing but rejected the submission that the evidence

presented by the Council did not conform to the legislative requirements or was

insufficient to allow An Bord to make an assessment. Mr. O'Donnell repeated much of

these criticisms in his Closing Submission.

At the time and as set out in Section 63 I stated that neither Mr. O'Donnell or Mr.

Sweetman, who had supported his submissions, had offered any rebutting evidence and

that until all sides had been heard the points being raised could not be properly

considered. On that basis and in equity to the other objectors who wished to make

submissions and to cross-examine the Council witnesses, Mr. O'Donnell's request for an

adjournment was not acceded to.

As can be seen from the list of Council witnesses in Section 7 of this Report, different

expert witnesses appeared for the Council in some of the specialist environmental

disciplines in the Dunshaughlin to Navan Section as compared to the other Sections and

this gave rise to some concerns being expressed by objectors about consistency in the

responses to their queries. Some witnesses were better able than others to respond to the

questions posed and as Mr. Summers, the noise expert who dealt with the Dalgan Park

area, had not personally been present when the noise measurements were taken for the

Dunshaughlin to Navan Section and from which the noise model used to predict future

noises levels was developed, he had some difficulty in dealing with the questioning he

received on the noise criteria and levels being predicted. Mr. Dilworth, who was the noise

expert that dealt with the other Sections, subsequently gave evidence of having reviewed

the Dunshaughlin to Navan predictions with Mr. Summers and, other than for a revision

for the effects of local traffic on the Ardsallagh Road itself as detailed in the document

handed in by the Council on Day 28 for Tables 4.7 and 4.8, found these to be correct.

The section on Socio-economics in the EIS in Vol. 4A sets out the basis for the

assessment which gives particular attention at local level to the areas of journey time,

access to community facilities and effects of the development on the existing road

network and indicated that the methodology used in the assessment was broadly based on

the guidelines given in Chapter 11 of the UK DMRB of 1994 and the EPA advice notes

and draft guidelines of 1995. It would seem from the basis given for the socio-economic

925

in the EIS that Mr. O' Donnell's requirement for a witness to have either sociology or

economic qualifications to deal with what are, generally, the effects from possible

severance of access to community travel patterns appears to have been an un-necessary

criterion and could be likened to using a sledge- hammer to crack a nut. While Mr.

O'Donnell called a number of witnesses on behalf of Dalgan Park, no specific evidence to

rebut either the details in the socio-economic section in Vol. 4A or Mr. Prendiville's

direct evidence were given other than for references to the lack of inclusion of the

activities and facilities within Dalgan Park / Dowdstown house by Fr. Pat Raleigh SSC

and Mr. Ger Clarke. While Fr. Sean McDonagh SSC made a submission on " Motorway

Madness", see Section 24 of this Report, this was aimed more at national policy issues

and did not address the local community access impacts.

I am satisfied that, notwithstanding the views expressed by Mr. O'Donnell about the

competence of the Council witnesses in his submissions, and the concerns expressed by

the Bellinter Residents about the lack of references to the activities and facilities within

Dalgan Park in the EIS and their concerns about the noise measurements taken there, the

data presented in the EIS and supported by the direct evidence offered by the Council is

of sufficient detail and its conclusions are sufficiently clear so that a decision can be

made on the likely effects on the environment by the proposed road development.

Mr. Casey, supported by Mr. Sweetman, referred to the supporting data by way of

borehole logs, trial pit logs and corehole logs with the results and data relating thereto

and said that this was information required to be provided as part of the EIS to comply

with the content of Article 5(3) of Directive 85/337/EC as amended by 97/11/EC which

refers to "data required to identify and assess the main effects -- likely -- on the

environment". Mr. Casey submitted that the absence of this data from the EIS and the

lack of details on the interactions made it impossible for An Bord to come to the

conclusion that the EIS and the information contained therein complied with the

requirements of the 1997 Directive or 1999 Regulations. Mr. Lumley for An Taisce and

Mr. Conor Newman made similar comments about the absence of the Geophysical

Report and Data Images from the EIS with only the interpretative drawings ( which are a

form of summary ) being given there.

The requirements of Directives 85/337/EC and 97/11/EC are incorporated into the

amended Roads Act 1993 by SI 93 of 1999 and the requirements for "data" are set out in

Section 50 (2) (c) which reads " the data required to identify and assess the main effects

which the proposed road development is likely to have on the environment" . I would

draw attention to the proviso that is given at the end of Sections 50 (2) and (3) which

reads " to the extent that such information is relevant to a given stage of the consent

procedure and to the specific characteristics of the proposed road development or type of

road development concerned, and of the environmental features likely to be affected, and

the road authority preparing the environmental impact statement may reasonably be

required to compile such information having regard, inter alia, to current knowledge and

methods of assessment."

926

As referred to in the commentary at Section 143 of this Report, the data required in

Section 50 (3) (c) is scattered throughout the EIS and these locations are listed in this

commentary. Details of the number of boreholes and trial pits with a summary of the

findings appears in Section 8 on Soil, Geology and Hydrogeology in each of Vols. 3A to

7A and more extensive details on the possible effects on wells and watertables is given in

Vols. 3A and 5A. The area at Bohermeen, which gave rise to Mr. Casey's questioning of

Ms Joyce, is specifically referred to in Vol.5A at 8.4.4 and 8.5. Having regard to the

content of Section 50 of the Roads Act 1993, as amended, I am satisfied that it would not

be reasonable to require that the records of the individual borehole, trial pit or corehole

logs from the site investigations carried out, or for the detailed results of the geophysical

surveys, would be included in the EIS for a road development of this nature. I am also

satisfied that there would be no difficulty in identifying and assessing the main effects

likely to impact on the environment without having sight of these individual records. It

should be noted that the borehole logs were available at the Hearing from August to the

end of October and that the details of the Geophysical survey were available, if requested,

from the Project Archaeologist.

Mr. Sweetman had referred to the requirements of the Habitats Directive and that the

effects of Articles 6 in the context of the Boyne and Blackwater rivers being designated

as proposed candidate Special Areas of Conservation brought them into consideration as

Natura 2000 sites and that this required the mitigation measures to be detailed. The

notification of this designation was made after the EIS had been published and is

contained in the submission from Duchas to An Bord in their letter of 22 April 2002. This

letter did not appear to have come to the Councils attention until August. This issue was

discussed on several occasions during the Hearing, see Sections 57.7, 57.8 and 110.2.

The Council submitted proposals for specific mitigation measures for the River Boyne

crossing in documentation submitted on Day 28 which appear to meet the requirements

for such sites, similar arrangements applying to the Blackwater crossing. Mr. Butler also

referred to this matter in his closing submission. I am satisfied that the construction

methods proposed for the road crossings of both rivers will have no significant impact on

the habitats at those locations and there would appear to be no impediment in granting an

approval in terms of the requirements of Article 6 of the Habitat Directive for Natura

2000 sites.

Mr. Sweetman referred on several occasions to the proposer as being "an animation of the

State" and that because of being this, the Directive had direct effect and that the EIS had

then to be assessed in terms of European law. It was not clear if he was referring to

Meath County Council in this context since he had also referred to the NRA as being the

driver or promoter of the scheme on several occasions as well. Mr. Butler, on several

occasions during the Hearing and in his closing submission, made it quite clear that this is

a scheme being promoted by Meath County Council in its own right as a Road Authority.

It would seem from this that the "direct effect" suggested by Mr. Sweetman does not

apply since Section 47 of the Roads Act sets out the powers of a Road Authority to make

a motorway scheme and Sections 49 and 50 set out the procedures to be followed

thereafter, including the requirements for an EIS.

927

148. Comments on Submissions made on Route Selection, Consultation and

Information aspects of Council's proposal :

The Route Selection process dominated much of the cross-examination of the Council

witnesses for the Dunshaughlin to Navan section and was also discussed in the Ardbracan

module of the Navan By-pass Section. Mr. Park, in his closing submission for the

Bellinter Residents Association, said that the main thrust of their position was their

disagreement and dissatisfaction with the Route Selection process and their belief the

process did not fairly address the various options and that the wrong conclusion had been

reached. This dissatisfaction had previously been outlined in their main submission, see

Section 70 of this Report, and in the cross-examination of Council witnesses, principally

of Mr. Guthrie in Section 50 of this Report. The Meath Road Action Group both in their

main submission, see Section 71, and in Mr. Magee's closing submission stated that their

objection to the proposed M3 was based on their assertion of the wrong route having

been chosen.

The National Roads Project Management Guidelines, NRA/8, version 1.1 of March 2000,

in which a phased approach to the planning of projects is outlined, was first referred to by

Mr. Galligan when appearing on behalf of the owners of Ardbraccan House when he

asked why those Guidelines had not been followed ( See Section 17.7). and this aspect

was, later on, also raised by Mr. Magee (See Section 50.6) Mr. Casey in his closing

submission also referred to these Guidelines but used the 1999 version.

The Guidelines themselves form an extensive document and cover all stages of the

project planning and management of major road projects, including financial

management, from inception to the completion of the Final Account. The guidelines set

out a program of events that commences with a "Constraints Study" period which

includes a "First" Public Consultation followed by a "Route Selection" period that

includes a "Second" Public Consultation. It should be noted that there are Four further

"periods" described in the Guidelines including details of Statutory procedures to be

undertaken, Contract Document procedures and Financial Reporting.

As part of the preparatory work for each of the Section, which initially was undertaken as

a series of discrete schemes that could be linked in the future, a Constraints Report and a

Route Selection Report were produced, these Reports being produced in 1999, 2000 and

2001for the various Sections. ( Copies of these were handed in and are listed at various

Days in Appendix 4 of this Report). When it was decided to propose single scheme from

Clonee to North of Kells, which followed from the NRA letter of June 2000, a "Corridor

Selection" Report was produced which is dated January 2002 but seems to have been

available in draft form before this. This Corridor Selection Report is referred to at Section

4.3 in Vol. 2 of the EIS where there is a description of the analysis and comparison of

four broad corridors, Orange, Green, Blue and Pink for each Section and from this the

conclusion was drawn that the preferred "Corridor" combination from Clonee to North of

Kells was Orange/Blue/Orange/Orange/Orange. Mr. Guthrie was cross-examined at

length by Mr. Magee ( See Section 50.6 ) and others about the reasons for producing and

928

publishing this Corridor Selection Report in January 2002, which came after all of the

individual Route Selection reports for the separate Sections during 2000 and 2001, and on

the apparent non-compliance with NRA Guidelines. Mr. Guthrie had accepted Mr.

Galligan's suggestion that these Guidelines had not been followed (See Section 17.7).

Mr. Butler in his closing submission referred specifically to the argument advanced by

objectors of the Corridor Selection Report following the Route Selection Report when the

NRA Guidelines suggested a different sequence should have been followed, and he set

out the reasons for the chronology followed by the Council which are logical in the

context of the way the scheme was developed over 1999 to 2002. The details of the

alternative options that were considered are set out in Chapter 4 in Vol. 2 of the EIS, and

these include the comparison of corridors and of routes. However, it is apparent from the

content of the cross-examination on this issue that the timing of the Corridor Selection

Report created a perception for residents along parts of the route to which the Council

had some difficulty in responding to their satisfaction.

The other aspect of the Route Selection process criticised was the Summary Matrices

used from which the Preferred Route was selected both in Tables 4.1 to 4.5 in Vol.2 of

the EIS and in the Route Selection Reports for the Sections themselves, which are not

part of the EIS. As can be seen from the cross-examination by the Bellinter Residents

Association, Meath Road Action Group and Mr. O'Donnell on behalf of Dalgan Park, this

followed from the reports and recommendations on individual environmental aspects in

the various route options considered for the Dunshaughlin to Navan section where a

number of these indicated that a route to the east of Skreen would have a lessor impact,

from the point of view of that environmental aspect only, than that of a route between

Hill of Tara and the Hill of Skreen. ( See Sections 50. 14, 50.22, 57.5 and 61.8 as

examples of this). In their closing submissions both Mr. Park for Bellinter Residents and

Mr. Magee for the Meath Road Action Group highlighted again their criticisms of these

Matrices, which they suggested were incorrectly used to select the wrong route.

At an early stage of the Hearing Mr. Guthrie was asked if there had been a weighting

applied to the different elements in the route selection process and he had replied that it

would have been difficult to produce a uniform ranking or weighting system across a

range of environmental impacts that would be acceptable to everyone. Nevertheless much

of his cross-examination by the Bellinter Residents members was aimed towards

establishing that some form of ranking had been used, incorrectly in their view, in the

selection of the Preferred Route. Mr. Guthrie accepted that there was an element of

ranking or weighting for the same factor as between the different route options being

considered in a particular Section. However, he did not accept that the use of such a

ranking had the same effect as placing a numeric value on each factor and then adding

these up across the summary matrix to get the preferred option. ( See Section 50. 22 of

this Report).

The considerations used in determining the Preferred Route for each Section are set out in

Vol. 2 of the EIS at Section 4.4 and was also outlined in Mr. Guthrie's direct evidence at

Section 17.1 and each summary matrix has a footnote stating that it is only indicative of

929

possible impacts. However it is clear from the concerns expressed, particularly from

residents in the areas from Collierstown to Dalgan to Bellinter/ Ardsallagh and also in the

Boyerstown /Ardbraccan area, that the pictorial representation conveyed by the matrices

shown in Vol. 2 of the EIS did not adequately convey the intent of what the authors of the

Vol. 2 matrices meant them to represent.

Mr. Guthrie explained in his direct evidence and in cross-examination the context in

which the route corridor alignments had been assessed and how the decision by which the

preferred route was selected came from a balancing of the various factors involved. The

Dalgan Park, BRA and MRAG objectors submitted that since Archaeology, Ecology, Air

Quality and Landscape impacts as identified in the Route Selection Report were all of a

lessor impact on a route to the east of Skreen than those for a route to the west of Skreen.

They also pointed to the route to the west of Skreen passing between Tara and Skreen

and submitted that the eastern route, or the Pink route, should have been the route

selected. Mr. Guthrie pointed to the fact of the Pink route being closer to more properties

than were on the Blue route, with consequentially more potential for noise, air and visual

impacts. He said this was the principal factor that outweighed the apparent advantages of

the Pink route, but had difficulty in convincing the objectors that the Blue 2 route was the

better option selected. A somewhat similar argument was made by Mr. Casey that a

route to the east and north of Navan should have been selected, again based on factors

identified in the Route Selection Report for the Navan By-pass, which would have taken

the motorway well away from Ardbraccan House. Ms Joyce outlined the factors for that

Section that had been balanced against those he had advanced.

A further source of contention raised by the Bellinter Residents Association about the

Route Selection process related to the interpretation placed by the Council on the

preferences expressed in questionaires returned by people who attended the public

Consultation exhibitions. In cross-examination by Mr. Park, see Section 50.14, Mr.

Guthrie said that about 30% favoured a route east of Skreen, 30% favoured west of Tara

and 40% favoured a central route and that when these were further analysed, some 56%

favoured a Blue or Pink route. In the BRA submission, see Section 70, Mr. Parks set out

their analysis of the returns which showed that the Pink route or eastern was the least

opposed and that the Blue or central route was the second most strongly opposed. Mr.

Hamill, also of the Bellinter Residents Association, gave figures to indicate that the

number of first preferences from those who favoured the eastern routes was double any

other option, see section 50.23. Mr. Guthrie submitted a written comment on the project

teams statistical analysis of the preferences, which was handed in on Day 28 and is listed

in Appendix 4 of this Report. This followed from his cross-examination by Mr. Park and

the Project Team concluded that the public favoured a central corridor of either the Green

or Blue options and since the Green option had a direct impact on Tara, the Blue corridor

of D for a western bypass of Navan or E for an eastern bypass of Navan became the more

favoured option. Their analysis showed the eastern or Pink corridor to be the next most

favoured choice.

While it is clear from the submissions made by objectors from the Dalgan Park, Bellinter/

Ardsallagh and Boyerstown/ Ardbraccan areas that they considered the wrong route had

930

been selected, it is equally clear that alternative routes were fully considered by the

Council in the process that lead to the "Preferred Route" being proposed as the road

development for which the EIS was prepared. I am satisfied from the evidence in the

documents and given at the Hearing that the requirements of Section 50 (2) (d) of the

Roads Act 1993, as amended, were fully complied with for this proposed road

development.

It is evident from the cross-examination of Council witnesses by objectors from several

of the areas along the route from Clonee to Kells that the Public were not satisfied they

had been adequately informed on the decision to construct a motorway as the

improvement for the N3. The Public Consultation Exhibitions for the various Sections

took place as follows :-

First Second

Clonee to Dunshaughlin June 1999 December 1999

Dunshaughlin to Navan December 1999 May 2000

Navan By-pass February 2000 May 2000

Navan to Kells February 2000 May 2000

Kells to North of Kells September 2000 May 2001

At the May 2000 exhibitions the proposals as shown in the brochures for the N3 referred

to an off-line route and to a dual carriageway situation and with possible locations for

interchanges also being shown. With the exception of the exhibitions for the Kells to

North of Kells Section, all of the other exhibitions pre-dated the NRA letter of June 2000,

which designated the N3 as one of the projects being considered for a PPP scenario and

that such schemes would be developed as motorways or high quality dual carriageways

and that tolling would also be considered.

As Mr. Butler pointed out in his closing submission, there is no specific requirement in

the Roads Act 1993, as amended, for Public Consultation, per se, in the preparation of

Motorway Orders, CPOs or EISs. However, a system of Public Consultation has been

developed for these type of major projects where an EIS is required and this was what

was followed in the case of the M3. The NRA Roads Project Management Guidelines

previously referred to also includes for Public Consultation Exhibitions in the steps the

Guidelines set out to be taken as part of the planning phases.

The Council would say that the County Development Plan adopted in March 2001 and

the Variation adopted in February 2002 did provide for a consultation procedure on the

motorway proposal and evidence was given that the footprint for the M3 was generally

similar to that envisaged for the N3 dual carriageway with interchanges and limited

access that was shown at the May 2000 exhibitions. However, a number of people at the

Hearing made the point that they had been consulted about a dual carriageway proposal

and not about a motorway and suggested that the motorway was a very different concept

to what had been shown, as they perceived it.

931

A further exhibition in the latter part of 2001 when the adjustments to the route had been

incorporated, and when the Corridor Selection Report was apparently available, could

have provided for some of the concerns expressed at the Hearing to be ventilated, and

might possibly have satisfied some of those queries. It would also have provided an

opportunity for residents adjacent to the route, but whose property was not being included

in the Order, to become informed of any adjustments being made to the route alignment

as "design refinements". Some of those who made submissions to the Hearing referred to

adjustments in the route that were made to minimise or avoid impacts elsewhere after the

exhibitions of May 2000, and which they did not become aware of until the Scheme was

published in 2002. Adjustments to the line adjacent to the Trevet road and Lismullin

areas are examples of this where comments were made at the Hearing.

The issue of availability of documentation and information from the Council was raised

by a number of people, particularly at the early stages of the Hearing. Mr. Butler in his

closing submission referred to this and pointed out that the Council's witnesses had made

every effort to be open and helpful in providing details of what was being proposed. It

was apparent at the Hearing that that was so, but many of the points made about the

perceived difficulty in obtaining answers to queries raised with the Council related to the

period while the scheme was being prepared and before the Hearing commenced.

This issue is not a matter for consideration in relation to the Road Development itself.

However, from the frequency it was raised at the Hearing it is something that the Council

might wish to consider in the context of the procedures used when responding to queries

from the public, and as a part of their focus on customer service.

149. Comments on Council's application for Confirmation of Motorway Order

and Approval of Road Development :

1. Motorway Order :

The Council's evidence in relation to Planning issues referred to the Transportation

policies in the 1994 County Development Plan at 2.4 which included the provision that

the Council would implement the relevant road development proposals that formed part

of the programs submitted to the Commission of the European Communities to facilitate

regional and national development. This was further detailed in the Roads Program

objective at 3.7.2 which stated that National Primary and Secondary roads would be

improved and Motorways provided in locations in line with national road policy and

programs submitted to the Commission of the European Communities.

The Transportation policies in the 2001 County Development Plan are set out at 2.7.1 and

aim to create compact and self-sustaining urban structures to minimise transport needs; to

permit the efficient movement of goods and persons in the interests of commerce and

enterprise and to check commuting patterns that were dependant entirely on the use of

the private car by providing high quality public transport alternatives as promoted in the

Dublin Transportation Initiative (DTI) Report and by a spatial policy based on the

932

Strategic Policy Guidelines (SPGs). In relation to Roads, the objectives in the 2001 Plan

included specifically for the an extension of the Clonee By-pass to the end of the

proposed Dunshaughlin By-pass, by-passes for Dunshaughlin, Navan and Kells, the

realignment of the N3, on an off-line route, between the ends of the Dunshaughlin and

Navan by-passes, the ends of the Navan and Kells by-passes and from a point on the N52

to a point on the N3 north of Carnaross, as well as a by-pass of Kells for the N52. The

locations for proposed Interchanges and Link roads serving Dunshaughlin, Navan and

Kells are also referred to in this objective. There is also a specific objective at 3.5.2 (ii)

under Roads and Parking which provides for a new motorway on the N3 to Kells

including bypasses of Dunshaughlin, Navan and Kells and, separately, for a western

relief route on the R157 for Dunboyne.

The need for improvements to the N3 as a dual carriageway from Clonee to Kells with

dual carriageway bypasses for Dunshaughlin and Navan and as a wide two lane from a

bypass of Kells northwards was identified in the Roads Needs Study published by the

NRA in 1998. The National Development Plan 2000-2006 includes a reference at 4.12 to

the N3 being a route where further major improvements formed part of the development

strategy for national primary roads.

Under the heading of Public Transport, the 2001 County Development Plan provides for

a detailed feasibility study into the provision of a rail link between Dublin and Navan via

the former MGWR Clonsilla/Kilmessan route or with possible linkages to the south

Meath fringe and at 3.5.2(i), there is an objective for the provision of a heavy rail link

between Navan and Dublin and co-operation with CIE to identify a preferred alignment.

The Strategic Planning Guidelines (SPGs) published in 1999 identifies the Dublin to

Navan corridor as a future Transportation Corridor, both in the text at page 7 and on Map

2 at page 9 in the Executive Summary and the then proposed N3 dual carriageway to

Navan was listed as "essential to strategy" in Table 9.5 in the principal road infrastructure

requirements on page 104 in Chapter 9 of the main report. The N3 Clonee to North of

Kells is also referred to as a strategic route of national importance at pages 15 and 24 of

the summary report of the DTO report "Platform for Change".

In giving evidence on behalf of Dalgan Park, Mr. Jack O'Sullivan, Environmental

Consultant, quoted extensively from the 2001 County Development Plan on the proposals

outlined therein to enhance public transport and develop a high quality rail link in support

of the proposals in the SPGs and said there was no reference to an upgrading of the N3 to

motorway status in Section 2.6.5.1 which deals with " Development Corridors and their

Management" as a transportation objective. ( See Section 64.1 of this Report) He also

suggested that the Variation to the Development Plan adopted in February 2002 was

inconsistent with the other transportation policies in the Development Plan and said that

An Bord should consider this as an isolated and out of context reference which should

get far less attention than the remainder of the Plan. However, in subsequent crossexamination

he accepted that the reference to the motorway at Section 3.5.2 (ii) was an

objective in its own right and that it was not necessary for this to be repeated elsewhere in

the Development Plan.

933

Mr. Casey also referred to the Variation adopted in February 2002 and suggested that

there was a lacuna in part 2 of the 2001 Development Plan coming from his suggestion of

a lapse of the 1997 Navan Environs Plan, and said that this left a "gaping hole" in the

2001 Development Plan. ( See his Closing Submission).

It should be noted that the Variation to the 2001 Development Plan, adopted in February

2002, was made to take account of minor adjustments to the route of the motorway which

was itself already included in the 2001 Development Plan adopted in March 2001. Mr.

O'Sullivan's suggestion of inconsistency seems to have come from a misunderstanding of

the intent of this Variation, since the fact of the motorway objective already being in the

Plan makes it part and parcel of the overall Development Plan policies. Mr. Casey's

questioning of the viability of the 2001 Plan also appears to be groundless for the same

reason, with the motorway already being an objective of the 2001 Plan and the route fully

described therein, and with the Variation being made only to reflect some adjustments in

the location of the route at Dunshaughlin and at Navan.

Mr. Killeen, the Council's Planning Officer, in his direct evidence ( See Section 21.1)

referred to the provisions in Section 3.5.2 in the 2001 County Development Plan which

highlighted that the development of transportation networks in the county would require

an approach that was fundamentally based on the principles of sustainable development

and that there would be a coincidence between the Development Plan policies, the

strategies of the DTO and the SPGs He referred to the policy in Section 3.5 for Roads in

the 1997 Dunboyne Development Plan to reserve a routes as indicated on Map 2 for the

Dunboyne relief road with a specific objective for this bypass and relief road to the west

and north of Dunboyne at 4.1 in Section 4 of that Plan. He explained that the line of the

relief road as it affected the property in Plot 326, where an objection had been made by

the owners M/s Henshaws, was altered slightly from that shown in Urban detail Map 13

of the 2001 County Development Plan but this was not a material alteration and it was

not necessary to include this in the Variation made in February 2002. He referred to the

Navan Environs Development Plan of 1997, which was varied in February 2002, as a

having a specific development policy and objective for a bypass route to the south and

west of Navan and he referred to the policy and objectives in the Kells Development plan

of 1995 as varied in 1996 and again in the 2001 Kells Development Plan to provide for

bypasses of both the National Primary and Secondary routes around the town.

Mr. Killeen also referred to the Rural Detail Map in the 2001 County Development Plan

that showed the "Areas of Visual Quality" with the landscape classification for the county

with the Eleven areas of visual quality (VQs) as identified in the 2001 Plan. The proposed

M3 traverses areas designated VQ 3-- River Valleys; VQ 9 -- Tara and Dunsany district

and VQ 11 -- Rural and Agricultural. Mr. Killeen said that both VQ 3 and VQ 9 were

very sensitive to all categories of development and that the location of the proposed

motorway route in the low-lying areas as it traversed VQ 3 and VQ 9 was, in his opinion,

the optimum location. The route of the proposed motorway and its associated link roads

was superimposed on this Map at my request and the locations of affected Listed Views

and of the Tree Preservation Order at Dowdstown were also marked on this Map and

934

those aspects will be dealt with in the comments on the Road Development. This Map is

listed at Day 10 in Appendix 4 of this Report.

It is clear from the objectives in the various Development Plans referred to above and, in

particular, in the Meath County Development Plan of 2001 as varied, and to the

strategies outlined from the National Development Plan 2000- 2006, in the Strategic

Policy Guidelines and in the DTO "Platform for Change", that the proposal to construct

an off-line roadway as an improvement for the N3 as a Motorway from Clonee to Kells

and to continue as a new off-line road from Kells to rejoin with the existing N3 at the

county boundary north of Carnaross, including a Bypass of Kells on the N52, conforms to

the Transportation Policies and Objectives of the Development Plan. Having regard to

this and to the Certificate submitted by the Council's Planning Officer that the proposal

was consistent with the proper planning and sustainable development of the area, and

having inspected these lands myself, I am satisfied that the acquisition of the lands set out

in the Motorway Order conforms to the objectives of the Meath County Development

Plan.

In the 1998 Roads Need Study it was stated that the Clonee By-pass section of the N3

was already at motorway standard and the Study suggested that a dual carriageway was

required from the Clonee By-pass to Navan, a dual carriageway by-pass of Navan and a

dual carriageway from Navan to Kells, with a wide two lane road northwards from Kells.

As stated in Mr. Guthrie's evidence traffic counts taken by the Project Team subsequent

to their appointment in 1999 showed that the traffic predictions used for the N3 in the

Roads Needs Study had been overtaken by increased growth in traffic, and that the levels

now justified a motorway from Clonee to Navan . The relevant traffic flows, taken from

Vol. 2 and from the document handed in by Mr. Guthrie on Day 5 ( as listed in Appendix

4 of this Report) are set out below :-

AADT in 2024 Motorway capacity

Clonee to Dunshaughlin

(a) Clonee to Pace 64400*

(b) Pace to Dunshaughlin 54700 56500 (commuter)

Dunshaughlin to Navan

(a)Dunshaughlin/ Blundellstown 44000 56500 (commuter)

(b)Blundellstown/Kilcarn 53100 56500 (commuter)

Navan By-pass 30200 43500 (rural )

Navan to Kells 30300 43500 (rural )

Kells to north of Kells 14600** 13800 (rural for LoS D)

*The section from Clonee to Pace is a dual carriageway with an additional weaving lane,

and from ** Kells to North of Kells it is a wide single carriageway.

From the Pace Interchange to the Kilcarn Interchange, south of Navan, a motorway is

proposed providing a Level of Service C with a capacity of 56500 AADT when

considered as a commuter road, (Note that as a rural road its capacity for LoS C is

43500) and the provision of a motorway there is justified by the predicted traffic flows.

935

The predicted design year flows of 30200/30300 AADT for the section from Kilcarn

Interchange to Kells could be accommodated on a grade separated dual carriageway since

they are 30% below the capacity of a rural motorway at level of service C and this was

the thrust of the argument advanced by Mr. Frank Burke, Consulting Engineer, in his

submission on behalf of Ms Maher, Ardbraccan House and in his cross-examination of

Mr. Evans, see Section 134.1 of this Report and he had also raised this in his earlier

cross-examination of Mr. Guthrie, see Section 17. 2. of this Report. I also raised this issue

with Mr. Evans, see Section 115 of this Report.

In his evidence on behalf of Dalgan Park, Mr. Healy questioned the absence of an

assessment for induced traffic in the modeling undertaken for the proposed M3 and

quoted from the procedures used in the UK where the impact of induced traffic was

required to be assessed for all major road proposals and suggested that variable demand

methods should have been used in the traffic forecasts made for the M3, see Section 69.1

of this Report. Mr. Burke, when giving evidence on behalf of Ardbraccan, suggested that

there had been an over-estimation in the growth factors used in the Dr. O'Cinneide

Report, on which Mr. Richardson's forecasts were based, which lead to a 15% overestimation

in the base year model for the Kells area. Mr. Burke also suggested this overestimation

could allow for induced traffic to develop, see Section 134.1 of this Report.

While no specific assessment for induced traffic was included in the traffic forecasts

developed by either Dr. O'Cinneide in his reports or by the Project Team, the SATURN

model used by the Project Team allowed for a more extended network to be modeled

than was in Dr. O'Cinneide's model and it also took trip distribution changes into account,

which was not possible in Dr. O'Cinneide's model. The SATURN model is a robust

model that has been used extensively for traffic forecasting on many recent road

proposals in Ireland and the map showing the area modeled for the proposed M3, at

Figure 3 in Mr. Richardson's Brief of Evidence, includes the N2 from Dublin to Ardee to

the east of the route as well as areas to the west of the proposed route. In crossexamination

Mr. Healy accepted that the area modeled was more extensive than he had

thought initially. Having regard to the evidence provided in the EIS and given at the

Hearing, I am satisfied that traffic forecasting methods used by the Project Team, on

which their recommendations for a motorway were based, are sufficiently robust and that

the traffic predictions can be accepted without requiring a specific assessment for the

possible effects of induced traffic in this proposal.

Mr. Evans pointed out that the cross-section width used for the motorway was 27 metres

which was slightly less that the width of 27.5 metres proposed for a reduced width dual

carriageway in the Roads Needs Study; that there were driver behaviour issues in having

a "standard" dual carriageway following immediately from a "standard" motorway where

the only difference was in the colour of the road signs and that having a consistency in

road type as far as the N52 junction, where a clear division was being provided with the

twin roundabout junction was a more sensible and safer solution rather than follow the

options being advocated by Mr. Burke. The continuation of the motorway to Kells also

facilitated the decision of the M3 project as a PPP but Mr. Evans said that was a

secondary reason with the issue of driver safety as the primary reason.

936

Having regard to traffic flows predicted for the various sections of the N3/ M3 and to the

reasons outlined at the Hearing, particularly in the discussion between M/s Evans and

Burke, I am satisfied that the designation of the proposed road from Pace Interchange to

the N52 Junction as a motorway is justified on road design, traffic safety and capacity

grounds.

The predicted flows in 2024 for the Link roads are as follows :-

Dunboyne By-pass (R157) 9700 AADT

Trim Road Link at Dunshaughlin R125 18700 AADT

Kilcarn Link at Navan 22800 AADT

Athboy Road Link at Navan (N51) 33500 AADT

Kilmainham Link at Kells 4600 AADT

N52 Bypass of Kells 10700 AADT

The link roads at R157 and R125 are both wide single carriageways with a level of

service C (10000) on the R157 and level of service D ( 17900) on the R125, both for

commuter road scenarios. In the case of the Kilcarn and Athboy N51 Links to Navan,

dual carriageways are being provided where a level of service of C ( 34600) for a rural

road applies. Level of service D applies on the Kells N52 bypass in a rural road scenario.

Objections to the concept of a motorway were made by a number of objectors to the

Motorway Order and included in many of the submissions to the Road Development.

Some of these were to the concept itself such as that from George & Mary Begley,

Collierstown; the Columban Missionaries, Dalgan Park (Plot 1094); An Taisce and

Seamus Farrelly, Hill of Skryne. Others objected to the general location of the proposed

M3, including the above named as well as the following :- Bellinter Residents

Association (BRA) and individual residents from Bellinter/Ardsallagh areas; Canavans,

Collierstown (Plot 1067); John Wilkinson, Baronstown (Plot 1074/1075); Mahers,

Ardbraccan; John Delaney, Grange, Bective and Brian Smyth, Tankardstown, Navan.

There were also an alternative route suggested by the Meath Road Action Group

(MRAG) and this was supported by Mahers of Ardbraccan; R. Pagan of the Ardbraccan/

Boyerstown Group and the BRA. There were references to an "alternative being

available" from the following which, while not followed up by evidence at the Hearing,

appears to be the alternative suggested by the MRAG :- SERLA Print Ltd.(Plot 308);

P.Yorell, Dunboyne (Plot 293); Bective GFC (Plot 1138); J. Wilkinson, Baronstown,

(Plot 1074/1075); Tara Mines (Plot 2221); Sean Murtagh, Boyerstown (Plot 2181);

P.Carry, Drumbaragh (Plot 4016); M. Muldoon, Ballylist ( Plot 4039).

The Bellinter Residents Association referred to a possible alternative that would run to

the east and north of Dalgan Park which they had previously suggested to the Council

and I asked Mr. Guthrie about the investigation of the alternative, see Section 115 of this

Report. In a response submitted with other documents on Day 28. Mr. Guthrie confirmed

that no specific study of that suggestion had been made but said that it was similar to the

alignment assessed as part of route B3 in the route selection process. This would have

required a crossing about 16 metres above the valley floor, where the river valley is

937

relatively wide, and would require a substantial cutting east of the N3 to limit the height

of the river crossing which would be at grade on the west bank where it would cross the

main access to Ardsallagh House. The bridge crossing itself would be some 300 metres in

length and would be a prominent structure, with a significant visual impact, and would

require substantial approach embankments and cuttings on both sides of the valley.

Alternatives in the Ardbraccan area were referred to in Ms Joyce's direct evidence at

Section 86.1. and I subsequently questioned her on these, see Section 115. Ms Joyce

confirmed that they had examined a number of alternatives which are shown on the maps

included in the book of additional drawings which she had handed in, with other

documents, on Day 20 to the Hearing ( These are listed at Day 20 in Appendix 4 of this

Report). Some of the alternatives examined were suggested by Mr. & Mrs. Maher of

Ardbraccan House, some were suggested on their behalf by Mr. Frank Burke Consulting

Engineer and some were suggested by other residents in the Ardbraccan area. The

conclusions reached were that the Preferred Route impacted significantly less on houses

with only 5 houses within 100 metres while all other routes had higher numbers of houses

adjacent to them and there were also lessor impacts on flora/fauna habitats and potential

archaeological sites on the Preferred route by comparison to the alternatives considered. I

am satisfied that possible alternative locations for a route for the motorway in the vicinity

of Dalgan Park and of Ardbraccan were given adequate consideration by the Council in

the selection process for the route.

All of those who objected to the concept of a motorway also objected or made

submissions about the effects of the Road Development and their objections/submissions

will be dealt with in more detail in my comments on the Road Development. However, I

am satisfied, from the evidence presented by the Council and as referred to above on the

levels of traffic predicted, that the upgrading of the N3 by an off-line motorway along the

route proposed is justified. I am also satisfied, from the evidence presented and from the

cross-examination of the Council's witnesses, that possible alternative locations to the

route finally proposed were given careful consideration. In addition to the details of

alternatives presented in Vol. 2 of the EIS, evidence was given by the Project Engineers

-- Mr. Guthrie in Section 17.1 & 50.1, Ms Joyce in Section 25.1 & 86.1 and Mr. Evans in

Section 102.1 -- on the various alternatives considered in their respective Sections, both

for the mainline and, where appropriate, for the Link roads. I am satisfied, as previously

referred to in Section 145 on the requirements of Section 50(2)(d), that possible

alternatives were adequately considered.

The Meath Road Action Group in their submission to the Hearing, see Section 71 of

this Report, outlined their proposal that there should be a new route which combined the

N3 and N2 routes to provide for through or long distance traffic as an alternative to

upgrading the N3 by the M3 proposal of the Council. They did acknowledge that even

with their proposal some upgrading from Clonee to Dunshaughlin on the N3 and to

Ashbourne on the N2 would still be necessary and were, essentially seeking that their

proposal be fully investigated/assessed before a decision was made on the M3 proposal.

They said that the NRA response of this combination of the N2/N3 not being in the

938

Roads Need Study was not a valid objection as the Roads Needs Study was now

outdated.

There is no provision in the Meath 2001 County Development Plan for such a proposal

which contains proposals at Section 3.5.2 (ii) for improving both the N3 and N2 as

separate schemes. At my request, the Council made inquiries with Fingal County Council

whose response was referred to in a document handed in by the Council on Day 25. This

confirmed that there was a study in progress on how lands at Abbotstown might be

accessed from the M50, as part of the Campus Stadium Ireland Project, and this was

considering the possibility of a grade separated junction on the M50 between the existing

N2 and N3 junctions but only as a means of accessing the Abbotstown lands and that

there were no plans to link such a junction with an additional radial route emanating from

Dublin. No separate study to investigate the provision of an interchange junction on the

M50 between the existing N2 and N3 junctions had been carried out. Fingal suggested

that it was doubtful there was sufficient space on the M50 between the N2 and N3

junctions to service a combined N2/N3 radial route if the Campus Stadium Ireland

proposal went ahead at some future date. Having regard to this information from Fingal

and the fact of there being no provision for such a combined route in the County

Development Plan, I do not consider that the MRAG proposal for a combined N2/N3

scheme can realistically be seen as a viable alternative to the M3 as proposed in view of

the uncertainties associated with a junction onto the M50. On that basis I am not

recommending that a decision on the application for Approval to the M3 proposal be

deferred pending a study of the MRAG proposal.

There were also objections to the location and scale of the proposed Dunboyne Bypass,

R157, from the following :- Newtown Bridge Residents Association; David Deasy,

Lorrha Lodge; Owen McBreen Summerhill Road and Bernard Walsh & Emer Ni.

Mhaoldoimnaigh, Newtown Cottage (Plot 331) all of Dunboyne. Ms Joyce in her

evidence in when cross-examined by M/s Walsh & McBreen outlined the reasons for the

use of a wide single carriageway road for the Dunboyne bypass, which has the 10 metre

wide road instead of the 7.5 metre width advocated by the Newtown Bridge residents, see

Sections 25.1, 25.7, 25.12 & 25.13 of this Report. As can also be seen from the details of

predicted traffic flows given above, the predicted AADT of 9700 is almost at the limit

for a Level of Service C on a wide single roadway and if their request for a reduction in

width were agreed to, there would be severe traffic congestion on the Bypass well before

the design year of 2024. I am satisfied that the proposal to construct the Dunboyne

Bypass as a wide single cariageway is justified.

The other objection by the Newtown Bridge Residents, including that of Deasys,

McBreens and Walshs, was to the size of the Roundabout proposed at the Newtown

Bridge junction of R 157 and R 156 which they wanted reduced from the 60 metre

diameter in the Motorway Order to a diameter of 30/32 metres, which would use less

land from adjoining properties. From the evidence given and cross-examination on the

roundabout issue it is clear that the smallest diameter roundabout that could be provided

here would be one of 50 metre diameter and that a reduction in diameter would not affect

the landtake from Plot 331, the nearest to the Roundabout. Having regard to the fact of

939

there being a relatively high Heavy Goods Vehicle content in traffic flows on the R157 I

consider that a Roundabout of inscribed circle diameter of 55 metres, instead of the 60

metres originally proposed should be adequate at the Newtown Bridge junction, which

would still permit for normal tracking of articulated vehicles and for the number of

acceses required off this roundabout.

Mr. Micheal Kieran, Knockmark (Plot 172), supported by an objection from Mr. Eddie

Bannon, Knockmark (Plot 174) proposed an alternative route for the R125 Link road to

Dunshaughlin. This proposed a new route from the roundabout at the Dunshaughlin

Interchange to link with the Trim road R 154 at a new junction on the eastern side of

Kilcooly village rather than at the existing Merrywell junction which is to the west of

Kilcooly. This is shown on a map prepared on his behalf by Mr. Frank Burke, Consulting

Engineer which was handed in by Mr. Comyn, Solicitor, when making a submission on

behalf of Mr. Kieran on Day 11, see Section 43 of this Report.

The benefits of this alternative for Mr. Kieran and his immediate neighbours would be to

remove the need for a shared underpass and service roads and would also reduce the

severance impacts. In Mr. Bannon's case it would remove his land from the Order. His

solicitor suggested their alternative would cost less to construct than the Council's

proposal and have less of an impact on a possible reopening of the disused railway line.

The Council suggested the alternative would increase the possibility of Leshamstown

Lane being used as a "rat-run", that it would increase journey time for those using it who

lived west of the Merrywell junction on the R154 and that it would bring more traffic

through Kilcooly where the houses fronted directly onto the R154 and where there was

very limited space for footpaths or widening. While not directly referred to, it also

appears from the map submitted to involve lands not included in the Order. Mr. Kieran's

alternative route has also to be considered in the context of the proposed closure of part

of the existing R125, and the objection by Residents in the Leshamstown Lane area to

this closure.

A number of residents along and in the vicinity of the Leshamstown Lane outside

Dunshaughlin objected to the proposed closure of part of the R125. These were Bridget

Bowens, Carmel & Patrick Carroll, Mr. & Mrs Caton, William & Bridget Crowley, Shay

Fitzpatrick, James Finlay, Ann & Anthony Devey, Paula & Alex Doyle, Colm & Mary

Murphy, Leo Lawlor, Paul Manck, Annete & Enda McDonough, Walter Smyth, Mary

Keane, Brendan & Dolores Murlphy, Jack Irwin, Frank Fitzmaurice, Andy Morgan, and

Barbara Finlay. During the Hearing a submission of their behalf was made by M/s Finlay

and Murphy on Day 7, see Section 40 and they also made a closing submission on day

23, see Section 143.1. Their objection is effectively an objection to the proposed

Extinguishment of the Public Right of Way listed at 4 & 5 in the Third Schedule of the

Motorway Order ( See Appendix 6 of this Report).

The Leshamstown Lane residents had three main points in their objection to the closure

the first being that the Lane would be used as a short-cut by people in the Warrenstown

and Drumree areas to get to Dunshaughlin rather than go around by the new link; that it

affect people who traditionally came from Dunshaughlin out to the GAA club in Drumree

940

which was a nursery for many other GAA clubs and that the Lane was too narrow for the

extra traffic that would be forced to use it. The Council in their response contended that

the new route would be well signposted and that people would find it generally shorter to

use the new link road to get to and from Dunshaughlin with test trips from Knockmark

crossroads showing that it was marginally shorter in travel time going by the new link to

Dunshaughlin and that the extra volumes of traffic that might use Leshamstown Lane

would not be significant. The Leshamstown Lane residents objected to traffic calming

measures that would involve speed ramps and wanted the existing R125 kept open even if

only by way of a single lane bridge.

When I questioned Ms Joyce on the traffic implications, see Section 115, she

acknowledged the Council's assessment was for a possible doubling in traffic from the

present flow of about 240 cars daily to a possible 500 cars daily assuming 10 movements

per day from houses in the locality and 80% of these going towards Dunshaughlin. These

levels are still relatively low and less than one car per minute on a 10 hour day. The

existing R125 through Drumree Village is not suited to the expected levels of traffic if

the road remained open and a bridge could cost up to € 900000 even for a reduced width.

There is no provision in the landtake for a bridge crossing the motorway and Ms Joyce

confirmed that there was a difficulty in the width being available for the approaches

within the existing road space.

Having inspected the existing R125 and Leshamstown Lane prior to the Hearing and

having revisited the locality after the initial submission by the Residents and Mr. Kieran

and having looked at Kilcooly village on the R154, I consider that if Mr. Kierans

alternative was adopted it would (a) cause a traffic problem in Kilcooly for which no

solution has been proposed and (b) increase the likelihood extra traffic using

Leshamstown Lane in the event of the alternative being adopted and the existing R125

being closed. I also consider that the increased traffic, which is likely to use the existing

R125 if the public right of way remains in place, would be detrimental to the existing

houses fronting onto the R125 particularly in the Drumree village area. Accordingly I do

not recommend that the alternative route for the R125 suggested by Mr. Kieran be

adopted. I recommend therefore that the Public Right of Way be extinguished on the

particular section of the R125 as set out in the Third Schedule of the Motorway Order and

as delineated on the Map attached to the Motorway Order. I accept that this will increase,

to some extent, traffic flows along Leshamstown Lane and will suggest some mitigation

measures for this in my comments on the Road Development.

Gerrardstown Stud (Plot 1056) proposed a modification in the route of the M3 where it

passed through their lands which is generally set out in the objections made on their

behalf to An Bord Pleanala and summarised in Section 13 of this Report. Detailed

submissions were made on behalf of Gerrardstown Stud to the Hearing on Day 21 and are

set out in Sections 73 to 78 of this Report.

The proposed route had been adjusted where it passes through the lands of Gerrardstown

Stud to minimise the impact on an area of archaeological importance known as "Area

26"which affected a part of the Studs lands used as breeding paddocks which are close to

941

the stud yard and thus convenient for their management. The stud had proposed a number

of alternatives to the Council prior to the Motorway Order being published but the

Council were not prepared to accept the modifications suggested as these impacted on

Area 26. The stud then developed Route D as an alternative route that was slightly west

of the Council's route referred to as Route A in the comparison. This alternative, Route D

was generally parallel to the Council Route A and at some 200 metres distance from it

and went through three "landscape features", which consist of tree covered enclosures

that the Council's archaeologist thought might be of some archaeological or historical

significance. The alternative route D made use of a number of reverse curves to shift the

route to its alternative location while maintaining the same skew while crossing the N3 at

Roestown. The alternative route increased the severance on an adjoining non-residential

holding and passed through five other land holdings, all of which were not included in the

Motorway Order, while greatly reducing the severance impact on Gerrardstown stud

itself. Mr. McGrath B. L. who appeared for Gerrardstown Stud gave details of written

consents from five of the six landowners affected by Route D to the proposed alternative

route and had correspondence from the sixth landowner who indicated they were not

objecting but had not given a written consent by Day 21 of the Hearing.

The Council's principal objections to the alternative Route D proposed by Gerrardstown

were its impact on the three "landscape features" and to the additional curves introduced

to gain the required shift giving the route a degree of sinuosity that they would prefer to

avoid if possible. While the geometric design of Route D was accepted as meeting the

required standards, the Council did not see it as providing a significantly better option

than their own route, Route A and suggested that in general terms Route D could have a

greater noise impact on a nearby house and that there would be a visual impact from the

noise barrier which Route D would require as mitigation.

In his final submission Mr. McGrath suggested that their alternative route could be dealt

with by way of a modification under Section 49(3) of the Roads Act 1993 and he

suggested that the absence from the Roads Act 1993 of the restrictions set out in Section

5 (3) (a) of the Third Schedule of the Housing Act 1966 which effectively was the

foundation of the provision where land outside a CPO could not be brought into a CPO.

Mr. McGrath submitted that this "absence" from the Roads Act 1993 removed the bar on

An Bord from doing what he was suggesting, namely, a modification to substitute Route

D in place of Route A in confirming the Order. In my opinion Mr. McGrath was mistaken

in his assumption that the lack of a reference in the Roads Act 1993 to the restrictions

outlined in the Third schedule of the Housing Act gave a facility to include lands that are

outside the original Order in any approval of that Order. The Housing Act 1966 is the

basis for all provisions for compulsory acquisition of lands by local authorities for the

purposes of works to be undertaken by them and it underlies the provisions for

compulsory purchase, whether by motorway or compulsory purchase order, in the Roads

Act 1993, as amended. It is also notable that the recital to the Motorway Order includes a

reference to section 86 of the Housing Act 1966. In my opinion it is not permissible to

include lands in an Approval of the Motorway Order that were not included in the

original Order and therefore, Mr. McGrath's submission can not be put in place.

942

The Council did not recommend the Route D be substituted in place of the route they had

proposed which affects Plot 1056 and gave evidence that they did not see Route D as

being a better route. I agree that the use of reverse curves on a section of motorway,

where a speed limit of 120 kph applies, should be avoided unless there is no alternative

available and this situation does not apply in this case. On that basis I recommend that the

Route as proposed by the Council should remain unaltered and in the circumstances I

consider this is a case where the effects of the Motorway Order on Plot 1056 are best

dealt with by monetary compensation.

The Farrellys of Woodpole (Plot 4035/4036) and Whelans of Calliaghstown (Plot 4003)

suggested that the Route could have followed the N3 north of Kells; Mr. Gavigan of

Kells (Plot 3075) objected to the location used for the N52 Bypass route to cross the R

163 and Mr. Ormiston of Blackwater House, Kells (Plot 3094) also objected to part of the

route used for the N52 while Mrs. Madden of Kilmainham (Plot 3039) objected to both

the M3/N3 Link and to the route for the N52 By-pass.

No further evidence was offered on their behalf at the Hearing and having considered

what was set out in their original submissions to An Bord I am satisfied that the route

proposed by the Council for both the new N3 North of Kells and the N52 Kells Bypass

are the most suitable and I am satisfied that the routes selected should remain unaltered. I

consider that the effects of the location of the road on the respective lands can be

mitigated by compensation.

At the end of the Hearing there were 195 objections to the Motorway Order that had not

been withdrawn, including some submissions made to the Road Development that were

more appropriate to the Motorway Order. A summary of the objections/submissions is

given at Section 13 of this Report and set out hereunder are the Plot numbers, names and

addresses of (1) those who cross-examined Council witnesses at the Hearing, (2) those

who made verbal or written submissions to the Hearing and (3) those whose original

objection/submission was left stand, or who did not attend or ask questions.

1. The following 34 objectors questioned or cross-examined Council witnesses :-

CLONEE TO DUNSHAUGHLIN

121 Tom & Mary Byrne, Ashling, Roestown, Dunshaughlin

149/160 Michael & Mary Morrin, Johnstown House Johnstown Dunshaughlin

172 Michael Kieran, Knockmark, Drumree

255 David Robinson, Rathbeggan, Dunshaughlin

294 Reps Patrick Peters --- Theresa & Colum Peters, Piercetown, Dunboyne

326 Peter & Edward Henshaw, Benettstown, Dunboyne

331 Emer Ni Mhaoldomhnaigh & Bernard Walsh, Summerhill Road, Dunboyne

470 Anthony J. McDonnell, Knockmore, Ballina & P. J. Roche, Glascarn, Ratoath

DUNSHAUGHLIN TO NAVAN

1056 Gerrardstown Stud, Gerrardstown, Dunshaughlin

1062 1074 & 1075 James Swan, Skryne, Tara

1063 James J. Swan junior, Skryne, Tara

943

1064 The Limestone Land Co. Ltd. c/o Tara Stud, Clowanstown, Tara

George & Mary Begley, Collierstown, Tara

Liam Doyle & Grace Martin, Branstown, Tara

1074 /1075 John Wilkinson, Barronstown, Tara

1083 Phillip & Margaret Ryan, Lismullin, Navan

1090 Reps Mary E. McCarthy, c/o Cathal McCarthy, Philpottstown, Garlow Cross

1094 Rev. Peter O'Neill, Missionary Society of St. Columbans, Dalgan Park, Navan

Bellinter Residents Association per Alan Park, Bellinter Cross, Navan

Represented by Paul Brady, Solicitor :-

1111 Brian & Jean Malone, Ardsallagh, Navan

1122 Emmet Clarke, Ardsallagh

Frank & Marie Clarke, Ardsallagh (shared entrance with Plot 1122)

1125 Joseph & Patricia Fitzsimons, Ardsallagh

1126 Robert Fitzsimons, Ardsallagh

1127 Thomas & Anna Farrelly, Ardsallagh

1128 John T. & Breda Connolly, Ardsallagh

1130 /1144 John Columba McEvoy, 34 Market Square, Navan

1136 Sean Carty, Cannistown

NAVAN BYPASS

2181 Sean Murtagh, Boyerstown, Navan

S.J. Maher, Ardbraccan House, Navan

NAVAN TO KELLS TO NORTH OF KELLS

3047 Henry Newman, Gardenrath Road, Kells

3053 Henry & Una Newman, Gardenrath Road

4019 Michael & Bernadette Meegan, Drumbarragh, Kells

4062 Ms Betty Newman Maguire, Castlekeeran, Carnaross

2. The following 30 objectors made additional verbal or written submissions at the

Hearing :-

CLONEE TO DUNSHAUGHLIN

*119 Joseph & Ann McKillen, Roestown, Drumree

*150 Derek Gray, Readsland, Dunshaughlin

*155 Valerie Sunner, Knockmark, Drumree

162 Michael & Maureen Duffy, Rath Hill, Dunshaughlin

*163 Sean & Bernadette Joyce, Rath Hill, Dunshaughlin

*166 Pat Summerville, Rath Hill, Dunshaughlin

183 Gerry & Catherine Carry, Crosskeys, Drumree

188 Thomas McManus, Derrockstown, Dunshaughlin.

*230 Peadar & Pauline Creagh, Raynestown

*257 Sylvester McAuley, Roselawn

*329 Tom & Loreto Doherty, Newtown, Summerhill Road, Dunboyne

340 Sean Boylan, The Bungalow, Dublin Road, Dunboyne

*342 Sean Delaney, Bracetown, Clonee

352. Vincent McDonnell, Knockmore, Ballina, Co. Mayo.

944

353 Anthony J. McDonnell, Knockmore, Ballina

371 Strandfair Holdings -- Finnian O' Cinneide, Loughsallagh, Clonee ( as occupier)

429 Mary Redmond, Barnaderg, Drumree

DUNSHAUGHLIN TO NAVAN

Geraldine Hennessey, Spearsview Cottage, Cooksland, Dunshaughlin

*1087 Patrick & Susan Meehan, Lismullin, Garlow Cross, Navan

NAVAN BYPASS

2103 Mark Corley, Grange, Bective, Navan

*2114 Nicholas & Kathleen Keogh, Rackenstown House, Dunshaughlin

*2117 Vitgeson Ltd., Moatlands, Navan

*2140 Maureen Foley, Macetown, Navan

2324 Eamonn Corley, Grange, Bective, Navan

*2325 Thomas & Maureen Hare, Williamstown, Navan

NAVAN TO KELLS TO NORTH OF KELLS

3018 Andrew Brooks, Febog, Kells

*3038 John Newman, Curragh, Kilmainham

*3071/ 4009 Thomas Duffy, Boolies, Balrath, Kells

*4000 /4002 Eamonn Duffy, Boolies, Balrath, Kells

*4063 Kieran & Martina Meegan, Drumbarragh.

3. The following 131 objectors, most of whom were represented by M/s Gaynor Corr,

did not add to their original objection or their representative advised that it was being

left stand as it was submitted :-

CLONEE TO DUNSHAUGHLIN

*118 John & Kathleen O' Connor, Roestown, Drumree

*120 Arthur & Elodie McFaul, Roestown, Drumree

*123 /124 Martin & Monica Kelly, Roestown, Drumree

*147 John Francis Morgan, Readsland, Dunshaughlin

*148 Peter Conlon, Readsland, Dunshaughlin

171 Christopher Lynch, Knockmark, c/o John Lynch, Augherskeagh, Drumree

*173 Drunree GAA Club, c/o Sean Walsh, Augherskeagh, Drumree

174/182 Eddie Bannon, Kilcoole, Drumree

All in Leshamstown Lane area

Bridget Bowens, Roestown, Drumree

Carmel & Patrick Carroll, The Haven, Readsland, Drumree

Mr. & Mrs. P. Caton, Meadowcroft, Leshamstown Lane, Dunshaughlin

William & Bridget Crowley, Leshamstown Lane Drumree

Shay Fitzpatrick, Breffni, Leshamstown Lane

James Finlay, Leshamstown Manor, Drumree

Ann & Anthony Devey, Almeida House, Leshamstown, Drumree

Paula & Alex Doyle, Tara House, Roestown Drumree

Colm & Mary Murphy, Leshamstown, Drumree

Leo Lawlor Watermeadows, Leshamstown, Drumree

945

Paul Manck, Birchlawn, Drumree

Patricia Murnane, Leshamstown, Drumree

Annette & Enda McDonagh, Leshamstown Lane, Drumree

Walter Smyth, Leshamstown, Drumree

*186 Louis & Mary Murray Fortfield, Derrockstown

189 Shane Cassidy, 119, Navan Road, Dublin 9

*213 Patrick & Mary Townsend, Raynestown,

*215 Thomas & Irene Reeves, Raynestown,

217 Raymond & Sheelagh Brennan, Raynestown

*218 Michael & Marion McCullagh, Raynestown

223 David & Patricia Crimmins, Raynestown

*229 Dermot & Philomena McGreal, Raynestown

*231 Frank Goodman, Raynestown

*232 Joseph & Noreen Sheridan, Bush Lane, Raynestown

*234 Patrick Ennis & Joan Burke, The Bungalow, Raynestown

*235 John & Marie Drake, Raynestown

*236 Declan & Ellen Collins, Raynestown

*237 Desmond & Anne Bellew, Raynestown

*238 Sean & Patricia Wynne, Raynestown

*239 Eamonn & Mary Halligan, Raynestown

*240 John & Joanne Duffy, Raynestown

*241/242 Thomas & Pauline Everard, Raynestown

256 Ronald Robinson, Rathbeggan, Dunshaughlin

264 Bucco Ltd., Suite 1, Westpoint Health & Fitness Centre, Blanchardstown,

293 Patrick Yorell jnr, 2, Old Fair Green, Dunboyne

308 SERLA Print Ltd, Serla House, Greenhills Road

*312 Hugh Mullally , Woodpark, Dunboyne

330 Mary J. Barden, Summerhill Road, Dunboyne

332 Richard, M.J., & Doris Bruton, Newtown, Dunboyne

346 John Connaughton (Ltd.), Ballybane, Killiney Avenue, Co. Dublin

*450 John & Pamela Conneely ,The Maples, Dunboyne

*467 Thomas O'Sullivan, Loughsallagh, Clonee

DUNSHAUGHLIN TO NAVAN

1052 Margaret Quinn, Westleigh Farm, Roestown, Dunshaughlin

1061 C.A.S Ltd., c/o Jones Engineering Ltd., Waterways House, Grand Canal Quay

1067 Captain Anthony & Catherine Canavan, Collierstown, Tara

1076 Vincent & Ann Murphy, Skryne, Tara

*1088 John & Maureen Meehan, Lismulin, Navan

1089 Noel McGuinness, Blundellstown House, Garlow Cross

1092 Liam Donohue, Darraugh, Garadice PO, Ballyconnell. Co. Cavan

James McCaldrin, Oak Lodge, Bellinter, Navan

Joseph Heery, Ardsallagh, Navan

*1109 Cormac Murray, Wood Lodge, Ardsallagh

1109 Thomas Wimesy, Gate Lodge, Ardsallagh (as occupier)

1124 Tony & Alison King, Tall Trees, Ardsallagh

*1130/1144 John Columba McEvoy, 34 Market Square, Navan

946

1133 Reps of Frank Foley, Cannistown, Navan

1135 Leslie & Mary Curtis, Cannistown

1138 John Moran, Secretary, Bective G. F. C., Cannistown, Navan

NAVAN BYPASS

*2113 Vincent Keating, Ardsallagh, Navan

*2116 Shiela O'Keefe St. Anne's, Balreask, Navan

*2117 Maurice & Joan Whelan, Balreask Old, Dublin Road, Navan

*2118 Daniel McCormack, Balreask House, Navan

*2131 Michael & Teresa Crowley, Balreask Old, Dublin Road, Navan

*2132 Noel & Josephine Hogan, Balreask Old, Dublin Road, Navan

2142 Stan & Bernadette Kennelly, Knockanure House, Macetown, Navan

*2151 Patrick & Monica Sherlock, Gainstown, Navan

*2151 John Sherlock, Oldtown, Bohermeen, Navan

*2156 John & Majella Carolan, Woodview Cottage, Flemingstown, Balrath,

*2157/2158 Edward & Aileen Maguire, Gainstown, Navan

*2158 Gerard & Margaret Ormond, Gainstown

*2159 Fiona & Patrick Reilly, Gainstown

2165 Patrick Darcy, Boyerstown, Navan

2173 Reps of Rose Wall --- James & Teresa Wall, 16 Woodbine Lawn, Inniscarra View.

2180 Reps of Patrick Brady, c/o Brian Hughes, 26 Magdalene Street, Drogheda

*2183/2185 James & Thomas Dowdall, Knockumber, Navan

2200 Margaret & John Donaghy, Ardbraccan, Navan

*2203 John Markey, Ardbraccan

*2211 David McCarthy & Yolanda Potter, 21 Blackcastle Estate, Navan

*2211 Patrick Marron, 24 Moatville, Navan

2215 Michael Peter Fitzsimons, Ardbraccan, Navan

2219 Peter & Carol Callaghan, Orgenstown,

2220 John & Margaret Donaghy, Ardbraccan,

2221 Tara Mines Ltd. Knockcumber, Navan

2223 Vivienne Kennedy, Neilstown Lodge, Neilstown, Navan

*2226 John Carolan, Mullaghboy, Navan

*2326 Agnes Graham, Williamstown

*2327 Noel & Mairead McCormack , Site No. 3, Williamstown

Brian Smyth, Coolfore Road, Ardbraccan

Patricia Gibney, 5 Woodlands, Navan ( About Plot 2387)

NAVAN TO KELLS TO NORTH OF KELLS

*3006 Patrick Rispin., Grange, Bohermeen

*3007 Andrew Rispin, Grange, Bohermeen

*3012 John McLoughlin, Phoenixtown, Ardbraccan

3016 Thomas Tallon, Martry, Kells

3017 Patrick Martin Boggins, Nugentstown, Kells

*3019 Fintan & Hilda Hogan, Ballybeg, Kells

*3024 Patrick & Mary McRedmond, 98 Johnstown Avenue, Dun Laoghaire

3026 Andrew, James, Lawrence & Terence Brooks Febog, Kells

and Kathleen Connell, Ballybeg, Kells

947

*3037 / 3109 Brendan Heerey, Kilmainham., Kells

3039 Winifred Madden, Kilmainham, Kells

3040 / 3122 Tom Hickey, Kilmainham, Kells

3041 Eugene J. Reilly Kilberry House, Kilberry, Navan

3046 Bridget Tansey, Carkfree, Ballinameen, Boyle, Co. Roscommon

3065 George Armstrong & W. & G. Armstrong (Kells) Ltd., Market Street, Kells

*3066 Trevor Fitzherbert, Swynnerton, Blackcastle, Navan

3072 George Armstrong, Newrath, Kells

3075 Thomas Gavigan, Farrell Street, Kells

3075 Thomas & Veronica Flanagan, Oldcastle Road, Kells (as occupier)

3082 Damien & Mary Mulvany, Cavan Road, Kells

3094 Norman Ormiston, Blackwater House, Kells

3095 Phillip Dunne, Cakestown Glebe, Kells

3103 Thomas Garvey, Rockfield Road, Kells

--------------

4003 Edward & Bridget Whelan, Calliaghstown, Kells

4016 Patrick Carry, 154 Woodsland, Navan

4018 James McDonald, Drumbaragh, Kells

4019 4025 Michael & Elizabeth Farrelly, Castlekeeran, Kells

*4026 Laurence Farnan, Pottlebane, Carnaross

4027 John Farrelly, Newrath Big, Lloyd, Kells

4031 John O'Connor, 3 Chesterfield Grove,

4035 Michael & Elizabeth Farrelly, Castlekeeran, Kells

*4036 Matthew Farrelly Woodpole, Carnaross & Christopher Farrelly, Woodpole

*4039 Matthew Muldoon, Ballylist, Carnaross

*4073 Evelyn Reyburn, Cordoogan, Monasterboice, Co. Louth

----------------------------

Note -- * Indicates that the owner was represented by M/s Gaynor Corr, Agricultural

Consultants and details of their objections are included in the composite listing of the

typical objections, which mainly related to " Accommodation Works and Related Issues",

given at pages 39/40 in Section 13 of this Report.

Since almost all of the objectors to the Motorway Order listed above also objected to the

effects of the Road Development, I propose to deal with their objections in my comments

on the Road Development issues. The Council had prepared responses to each of the

original objections received by An Bord and these are referred to at Sections 49, 85, 101

& 120 of this Report. Copies of the Council's responses were handed in to the Hearing at

Days 10, 13, 16, 18 & 28 as listed in Appendix 4 of this Report.

Having regard to the evidence given by the Council's witnesses, the submissions made at

the Hearing by the landowners or by their representatives and to the responses made by

the Council, I am satisfied that adequate evidence was presented to justify all of the

acquisitions proposed by the Council in the First Schedule of the Motorway Order. I am

satisfied that adequate access is being provided to lands where the direct access is being

prohibited in the Fourth Schedule of the Order and to the lands being severed by the

scheme roads, insofar as it is reasonable to do so. I am also satisfied that in the cases of

948

severed land where it would have been unreasonable or unsafe to provide access, the

Council's proposals to acquire such severed parcels of land as part of the Road

Development are justified.

As set out in the Second Schedule to the Motorway Order, 16 Wayleaves are to be

acquired and evidence on these was given by Mr. Evans when giving evidence, see

Section 102.1. No objections were raised at the Hearing to the acquisition of these

wayleaves. In the Third Schedule of the Order are listed the 88 Public Rights of Way in

Part 1 that are proposed to be extinguished and the 22 Private rights of Way in Part 2 that

are also proposed to be extinguished. Objections were made to two of the Public Rights

of Way, one being about no's 4 & 5 on the R125 by residents in the Leshamstown Lane

area and the other being by M/s Steen O'Reilly Solicitors on behalf of Ronald Sherlock,

t/a Sherlock Furniture Balreask Old, Navan about no. 50 at Swan Lane, Navan. The basis

for the objection to the R125 extinguishment has been detailed earlier in this section of

the Report and I outlined why I considered the objection should not be upheld.

Agreement was reached between the Council and M/s Sherlock Furniture on an

alternative access during the Hearing and their objection to the extinguishment of those

rights of way was withdrawn, see document submitted by Mr. Frank Burke, Consulting

Engineer on Day 22 as listed in Appendix 4 of this Report and also Sections 87 & 117.

No objections were raised in respect of any other of the Public Rights of Way, or about

any of the Private Rights of Way at the Hearing. Finally the Seventh Schedule of the

Order sets out details of the Three Planning Permissions proposed to be suspended and

the Seven Planning Permissions proposed to be modified. During the Hearing reference

was made to Planning Ref. 98/1340 by Mr. Swan, the owner of Plot 1063 and in their

objection to An Bord M/s Armstrongs, the owners of Plots 3065 & 3072, refer to

Planning Ref. 98/1362. Both of these Planning Permissions are listed in part 2,

Permissions being suspended.

I am satisfied that, in respect of the Public and Private Rights of Way that it is proposed

to extinguish, the Council are proposing adequate alternative access arrangements in the

Road Development Proposal to be put in place for the users, including those for the part

of the R125 proposed to be extinguished. I am also satisfied that the acquisition of the

Wayleaves and the revocation and suspension of the specified Planning Permissions are

necessary for the purposes of construction of the Motorway scheme.

Proposed Road Development :

As listed in Section 6 of this Report, submissions in respect of the Road Development

were received from the following, those who made submissions or who cross-examined

or questioned Council witnesses at the Hearing being highlighted :-

Duchas, 7 Ely Place, Dublin 2.-- Architectural, Archaeological & Nature Conservation.

An Taisce, Tailors Hall, Back Lane, Dublin 8.

The Arts Council, 70 Merrion Square, Dublin 2.

Bat Conservation Group, Cavan/Meath Branch, 32 The Old Mill, Rathoath.

949

Meath Roads Action Group, c/o Eamon Halligan, Raynestown, Dunshaughlin

Meath Archaeological & Historical Society -- Oliver Ward, Spiddal, Nobber

Irish Georgian Society, 74 Merrion Square, Dublin 2

Dunboyne Historical Society -- Linda Clare, Coolcommon, Batterstown, Dunboyne.

CLONEE TO DUNSHAUGHLIN

Liam Scott, Piercetown House, Piercetown, Dunboyne

Newtown Bridge Residents Association, c/o Lorrha Lodge, Summerhill Road

Dunboyne -- Deirdre Deasy & Owen McBreen

Garnett Hall Residents Association, c/o 5 Garnett Hall, Dunboyne --

Catherine Connolly & Dawn Tolan

David Deasy, Lorrha Lodge, Dunboyne

Owen & Mairin McBreen, Summerhill Road, Dunboyne

Mary Keane, Leshamstown, Drumree

Brendan & Dolores Murphy, Leshamstown ( Representing Residents )

Andy Morgan, Leshamstown Lane

Barbara Finlay, Leshamstown Manor. Jack Irwin, Roestown.

Frank Fitzmaurice, Leshamstown

Raynestown Residents Association, Raynestown, Dunshaughlin

DUNSHAUGHLIN TO NAVAN

Patricia & James Conroy, Collierstown, Tara

Tom Foley & Karen Carty, Collierstown

Anastasia Crickley, 30A St. Kevins Road, Dublin 8

Seamus Farrelly, Hill of Skryne, Tara

Conor Newman, M.A., N.U.I., Galway

Dr. Brian Lacey, Discovery Program Ltd., 34 Fitzwilliam Place, Dublin 2.

John Delaney, Montbretia, Grange, Bective, Navan.

Shiela Bradley, Dowdstown, Garlow Cross, Navan

Kathleen & Patrick Farrelly, Dowdstown, Garlow Cross,

Pat Raleigh, Mission Education Department, St. Columbans, Dalgan Park.

Catherine Reilly, 48 Blackcastle, Navan

Margaret McGrath, Sion Cottage, Johnstown, Navan

Catherine Cleary, Sion House, Johnstown, Navan.

Pauline Connolly, c/o St. Michaels Secondary School, Loreto, Navan

Bellinter Residents Association, Bellinter

Thomas & Margaret Hamill, Bellinter, Navan

Helen Ryan, Ardsbeg, Bellinter

James McCaldrin, Oak Lodge, Bellinter

Anne Barber, Bellinter

Christopher & Claire Oakes, Bellinter

John & Patricia McCormick, San Antonio, Bellinter

Alan Park, Bellinter Cross

Brendan, Anne, Estelle & Lynette Magee, Bellinter

Raymond & Elizabeth Martin, Bellinter

Cannistown Residents Association, c/o Thelma Keating, Talara House, The Avenue,

Aidan & Thelma Keating, Talara House, The Avenue, Ardsallagh

950

John & Rose Smyth, Ardsallagh

NAVAN BYPASS

Cannistown Residents Association, c/o Thelma Keating, Talara House, The Avenue,

Ardsallagh

James McIntyre, Boyne Hill, Navan

M/s Steen O'Reilly & Co. Solicitors, Navan, on behalf of Ronald Sherlock,

t/a Sherlock Furniture, Balreask Old, Navan.

Ray Keegan, Grange, Bective, Navan

Moatville Residents Association by Ruth Cahill, Chairperson, c/o 10 Moatville

Patricia Gibney, 5 Woodlands, Navan ( For CPO - Plot 2387 )

Brian Smyth, Tankardstown, Navan

Richard Byrne, Ardbraccan

H.R. & R. M. Pagan, Islay, Ardbraccan, Boyerstown

Simon Hilliard, Ardbraccan, Boyerstown

Sean Finlay, The Glebe House, Ardbracca

NAVAN TO KELLS TO NORTH OF KELLS

Edwina Dunne, Coolfore Road, Ardbraccan

Therese Coffey, Coolfore Road, Ardbraccan

Claudine Coffey, Coolfore Road, Ardbraccan

Sandra Coffey, Coolfore Road, Ardbraccan

Hugh Coyle, Coolfore Road, Ardbraccan

Paula Coyle, Coolfore Road, Ardbraccan

Thomas Regan, Coolfore Road, Ardbraccan

Rebecca Rennicks, Coolfore Road, Ardbraccan

Ivan Rennicks, Coolfore Road, Ardbraccan

Brian Smyth, Coolfore Road, Ardbraccan

Fiona Feely, Coolfore Road, Ardbraccan.

Note --- all of the above are adjacent to end of Navan By-pass section.

W. G. Dallas, Martry, Kells

Phillip Dunne, Cakestown Glebe, Kells

Mrs. Winnie Madden, Plot 3039

Norman Ormiston, Blackwater House, Kells Plot 3094

George Armstrong and W. & G. Armstrong (Kells) Ltd. Plot 3065 & 3072

Edward & Bridget Whelan, Calliaghstown, Kells (Boolies Road) Plot 4003

Gerard Murphy, Cavan Road, Kells

The principal issues in the submissions made to the Road Development (EIS) are detailed

in Section 146 with a summary of individual submissions being given in Section 13. The

issues raised at the Hearing varied as between different sections of the proposed Road

Development which reflected some matters that were of more concern at a particular

locality with some, such as traffic noise, being raised in all sections.

In the Clonee to Dunshaughlin Section the issues raised generally related to :- Traffic

noise; Construction effects -- noise, dust, effects on services such as wells etc, access to

property, traffic movements; cul-de-sac issues, boundary treatments etc; Air quality;

951

Severance effects; Shared underpasses; Landscape & Visual impacts; Footpaths;

Flooding from Tolka; Cultural Heritage -- local folklore issues.

In the Dunshaughlin to Navan Section the issues generally related to :- Traffic Noise;

Construction effects as before; Archaeology; Impacts on Tara /Skreen ; Landscape &

Visual impacts; Impacts on Dalgan Park; Boyne crossing; Severance issues; Stud farm

issues: Flooding from Skane; Impacts on Habitats; Drainage issues; Impact on Railway

route; Air quality; Cultural Heritage -- Tara, Buildings; Alternative routes.

In the Navan By-pass, and for the Navan to Kells /to North of Kells Sections, the

issues generally related to :- Traffic Noise; Construction effects as before; Severance

effects & underpasses; Habitats; Impacts on Ardbraccan House; Drainage issues;

Footpaths and effects of temporary road closures; Cultural heritage; Landscape &

Visual; Alternative routes.

From an examination of the EIS, and from the evidence given at the Hearing, including

the cross-examination of witnesses, it is clear that the most significant impact of the

proposed Road Development on the Environment is on Human Beings from the impacts

of Traffic Noise, Material Assets, Visual and Construction Effects. There are also

impacts on the Natural Environment, particularly on the Cultural Heritage, with the

impacts on Air, Visual and Landscape and on the Aquatic environment also being of

some significance.

Traffic Noise issues :

Traffic noise was one of the issues that was raised in all sections and was one of the most

frequent issues raised in the submissions made to the Road Development with the criteria

of 68dB LA 10 18hour used by the Council to determine when mitigation measures

would be applied being strongly criticised. There was also criticism by members of the

Bellinter Residents Association and by Dalgan Park of the methodology used when noise

measurements were taken in Dalgan Park with the level of the wind speed at the time

being questioned. Mr. Summers, who gave evidence on noise aspects for the Council in

that section, was not present when the measurements were being taken and could only

rely on the notes made at the time by his staff and this was strongly criticised by Bellinter

Residents and Counsel for Dalgan Park. (see Sections 50.23, 55 & 108A ). I am,

however, satisfied from the subsequent review undertaken by Mr. Dilworth, the other

noise expert, and from the general consistency of background noise levels reported across

the overall scheme in the EIS that the noise levels predicted for the proposed Motorway

Scheme in the EIS can be relied on when assessing the impact.

From the details given in the EIS, Vols. 3 to 7, the current noise profile along the

proposed route varies from 64/74 dB LA10 18hour in the vicinity of the N3 to levels of

49/56 dB LA10 18hour in areas away from the N3 between Clonee and Navan, and

levels of 46 /58 dB LA10 18hour between Navan and Kells except in the vicinity of the

N51 where levels are 73/74 dB, but with specific locations being as low as 40 dB LA10

where these are at a distance away from road traffic. From Kells northwards noise levels

952

are in the range of 43/ 52 dB LA10, except where the route is close to the N52 and N3

where noise levels are 67/76 dB. With a criteria of 68dB LA10 as the level for mitigation,

absolute increases in noise of up to 20dB would still be possible in some areas, where the

background noise levels were relatively low but the more typical increase would be in the

range 13/18 dB since the more typical levels away from the N3, N51 & N52 are in the

range 50/55dB LA10 18hour.

There is at present no National criterion for Traffic Noise in Ireland and the levels used

for road schemes are the same as those applied in the UK. During the Hearing the

possible effects of the recent Directive 2002/49/EC relating to "the assessment and

management of environmental noise" was raised by both Mr. Scott of Piercetown,

Dunboyne and Mr. McIntyre of Cannistown Residents and Boyne Hill, Navan ( see

Sections 29.6, 89.2 & 89.3). Mr. Macken S.C. also referred to the decision by An Bord on

the Outer Ring Road scheme in South County Dublin when appearing for the Morrins,

Plots 149/160. As detailed in Section 108 the Council submitted a Revised criteria for

assessing the noise exposure of noise sensitive residential receptors and the proposed

criterion is set out hereunder, the full document being listed at Day 20 in Appendix 4 :-

"Proposed M3 Motorway Noise Criterion :-

(1) The noise level shall be predicted at the ground floor façade of noise sensitive

residential properties that may be impacted upon by the scheme. Prediction

calculations shall be conducted for the Existing, Do Nothing and Do Something

scenarios. The accuracy of the prediction calculations shall be verified by comparison

of the modeled Existing noise levels with results obtained by measurement.

(2) The Target Noise Level is equal to a façade level of 68dB LA10 18hour (nominally

equivalent to a free field value of 63 LAeq 24hour) within 100 metres of a road where

the existing traffic flows are greater than or equal to 3000AADT, otherwise the

Target Noise Level is equal to a façade level of 65db LA10 18hour ( nominally

equivalent to a free field value of 60dB LAeq 24hour)

(3) Mitigation measures will be deemed necessary at existing noise sensitive residential

properties where all three of the following conditions are satisfied :-

(a) The Specific Noise Level associated with the new scheme is greater than or

equal to the Target Noise Level ( Note that the Specific Noise Level is defined

as being the noise level associated with the new scheme under consideration,

without taking into account any contributions from other roads or extraneous

sources)

(b) The combined predicted Do Something noise level from the new scheme

together with any other traffic in the vicinity is at least 1dB(A) more than the

predicted Do Nothing noise level for the same assessment year.

(c) The contribution to the increase in the combined predicted Do Something

noise level from the new scheme is at least 1dB(A).

953

(4) Where they are deemed necessary, mitigation measures will be implemented in order

to reduce the Specific Noise Level associated with the new scheme to a level below

the Target Noise Level. "

The Council stated that while the noise impact assessments for the M3 scheme had been

conducted in accordance with best practice in Ireland, with the publication of Directive

2002/49/EC on 29 June 2002 they considered it was appropriate to put forward a more

stringent noise criterion now and that this criterion was of a similar level to that applying

in Austria, France and Germany and more stringent than that in the UK, Portugal and

Greece.

From the cross-examination of Mr. Dilworth, one of the Council's noise experts, and of

Mr Searson who gave evidence on noise for Dalgan Park and other objectors, it is clear

that many of the examples of lower noise levels quoted by objectors as being applicable

in other Countries are either expressed in terms of LAeq or use other indices, with the

lowest European level being 55 LAeq and most European levels being around 60 LAeq.

These levels would be from 3 to 8 dB below the current Irish norm of 68 dB LA10 which

equates to 63 LAeq for a nominal free field scenario. M/s Dilworth and Searson agreed

that typical night time levels ( from around 2100 to 0070) would be up to 10dB below

daytime levels and that attenuation of up to 15dB could be obtained across a window left

ajar and that in-bedroom levels, even with a partially open window, would typically be

up to 25dB below daytime external façade levels, see Sections 47.1 & 108.2. With a

daytime façade arrival level of 60 dB LAeq free field or 65 dB LA10, as suggested for

flows of less than 3000 AADT, this could give in-bedroom night time levels of about 35

dB LAeq, which is within the range quoted by the WHO and in BS 8223/1999 that Mr.

Searson suggested should be the aim to be mitigated for in his evidence, see Section 67.1.

Similarly in-room daytime levels of about 45dB LAeq could be expected, again with a

window ajar, from a façade arrival level of 60 dB LAeq or 65dB LA10.

As proposed by the Council the target criterion of 65dB LA10 18hour would only apply

where traffic flows were less than 3000AADT, which would only be on the side roads

adjoining the motorway/dual carriageways. I do not consider this would be equitable

since it is the motorway that is the source of the impact and, in my opinion, the Revised

criterion of 65 dB LA10 façade level should be applied to all noise sensitive residential

receptors in the vicinity of the proposed M3 Motorway Scheme.

In my opinion the use of an arrival level of 65 dB LA10 18hour, equivalent to 60 dB

LAeq, rather than the level of 68dB LA10 18hour originally proposed would meet the

concerns of most of the objectors in respect of traffic noise impacts from the operation of

the proposed motorway in the context of the likely "in-room" levels that would result, as

distinct from the perceived noise effects that are being anticipated.

As set out in the procedures in the document " Control of Road Traffic Noise" (CRTN)

this façade measurement is taken at a distance of 1 metre from the most exposed part of

an external window. While there was discussion at the Hearing about other measurement

methodologies, in the absence of an Irish "standard " for assessing road traffic noise I

954

consider that the use of the CRTN methodology is still the most appropriate methology to

be used in the assessment of road traffic noise for the proposed motorway from Clonee to

North of Kells, subject to the revised criterion of 65 dB LA10 18hour being used to

determine when mitigation is required.

There are two areas along the proposed route where an external level of 60 dB LAeq

(65dB LA10 18hour) would still be significantly above the current ambient noise levels.

These would be at the Rathbeggan Lake area and at Ardbraccan House. The most

appropriate guidelines for these sort of external areas are in the recommendations for

gardens in the WHO 1995 Guidelines on Community Noise and in BS 8223/1999 for

gardens and balconies with a figure of 50 dB LAeq being suggested by the WHO and a

range of 50 to 55dB LAeq by BS 8223/1999. Having regard to the relative difference in

level and to the distance from the motorway I consider that it would be possible to

achieve an arrival level of 55 dB LA10 18hour or 50dB LAeq free field at the lakeside

edge nearest to the motorway at Rathbeggan Lakes. There are already some banks

proposed at Rathbeggan Lake to accommodate the access overbridge and these could be

extended to provide for the noise reduction required here.

Mr. Osbourne when being cross-examined on the effects of noise on horses stated that at

distances of over 300 metres noise had little effect and Mr. Dilworth, in response to my

question, refered to the reduction in noise as the distance from the source increased, see

Sections 54.5 and 108. 2 of this Report.

Having regard to the distance between the motorway and Ardbraccan House of some 450

metres at its closest point ( where the motorway is also in a cutting of about 1 metre), I

also consider that it would be possible to achieve a façade arrival level of 55 dB LA10

18hour at Ardbraccan House, but some mitigation measures would be necessary to

achieve this level. For the Ardbraccan House area, noise barriers could be placed along

the top of the embankment or, alternatively, a noise reducing material, such as porous

asphalt or a similar material, could be applied as the road surfacing used from the

Boyerstown / Bohermeen area northwards in combination with the appropriate location

of proprietory noise barriers to provide for the necessary additional noise reduction.

An arrival level of 55 dB LA10 18hour or 50 dB LAeq would allow for the noise

requirements as outlined by Mr. Searson as being necessary for the indoor musical events

to be continued, see Sections 108.5 & 113.2. Depending on traffic levels the outdoor

arrival levels of noise should frequently be below the target of 50 LAeq and at off-peak

flow times might well be in the low 40s, which would facillitate the holding of outdoor

musical events in the grounds of Ardbraccan House at certain times during the afternoon

and evening. Since those outdoor events would be weather dependant, and as this can be

very variable in normal Irish Summers, it would be unreasonable to require that

mitigation measures be provided which could be visually very obtrusive to provide for a

noise level that might be required for only occasional uses.

I consider that, on balance, mitigation to provide for the in-room arrival noise levels

agreed on by M/s Searson and Dilworth (circa 35 dB LAeq ie 50-15) as being reasonable

955

for indoor musical events would be a sufficiently low level to achieve, in the context of

the overall environmental impact at that location.

Submissions were made by The Arts Council and the Irish Georgian Society to An Bord

in respect of the impact of the motorway and its potential noise effects on the proposed

development of musical events at Ardbraccan House and asked that this be taken into

account when considering the proposed road development. An Taisce also referred to

Ardbraccan House in its submission. The suggested arrival level of 55dB LA10 18hour

would meet, to a reasonable extent, the basis of those submissions.

At my request the Council prepared noise contour maps for Dalgan Park to show the

noise levels within the Park area in the Do Nothing scenario, the noise levels there in

2024 for the Do Something scenario with mitigation by noise barriers and also a plan

showing the pathways and the present and proposed noise levels on these paths. These

maps were handed in on Day 28, as listed in Appendix 4 of this Report. As can be seen

from the map of the pathways the noise levels on all of the pathways to the east of the

Skane River will be the same, or less, in 2004 and 2024 with the M3 and mitigation noise

berms/ barriers in place for the 68dB LA10 18hour criterion as they would be in 2004

and 2024 if the M3 was not built. In general the levels shown on map SK 215, which are

in LA10 18hour terms, meet the WHO and BS 5228/1999 recommended levels for

gardens except for two locations -- one within 100 metres of the motorway near the

proposed Boyne Bridge at Bellinter and the other on the private footpath to the northeast

of the Main Building which is close to the existing N3.

Since the Revised criterion of 65 dB could reduce these noise levels from the proposed

M3 by a further 3 dB in the Gate Lodge area, by the application of the Revised criterion

to that house and to the nearby houses of Ms Bradley and the Farrellys on the

Dowdstown road, it is clear that the noise impacts on the Dalgan Park area from the

proposed motorway would not be significant and would be similar to the present noise

levels on the pathways there, except on the part of the path in the area to the west of the

River Skane that is close to the Boyne Crossing. In that location the level in 2024 would

be in the range 55/59 dB LAeq which in the overall context of the pathways would not be

significant. It should be noted that in the vicinity of the Gate Lodge off the Dowdstown

road, the predicted noise levels in 2004 with the M3, and with mitigation in place, would

be about 5dB below present levels and for 2024 it would be up to 7dB below the

expected level in the do Nothing scenario. This reduction comes from the Dowdstown

Road being moved by about 100 metres southwards away from the Gate Lodge and the

effects of the noise barriers on the motorway itself.

The need for a low noise level was also referred to in evidence given by Mr. Searson on

behalf of Ms Newman Maguire, Castlekeeran, Plot 4062, who has an artists studio at her

house. The predicted noise level in 2024 for this property is 62 dB LA10 18hour, see

Section 113.1, but this is a combination of noise from both the new N3 of 57dB, some

130 metres away and from the Kierans Well Road, to which her property fronts, giving

61dB. Both levels are well within the revised criterion and would provide for a daytime

956

in-room level in the range of 40/45 LAeq which is of the level regarded as "reasonable"

in BS 8223/1999 for living rooms.

A submission was made to the Hearing on behalf of the Lismullin Education

Foundation, see Section 83. Predicted noise levels for the two nearest receivers, nos. 35

& 37 in Table 4.8 are 68 & 66 dB LA10 18hour. The application of the Revised criterion

would reduce these levels to 65 dB LA10 and, as above, give in-room daytime levels of

about 45 dB LAeq which can be regarded as being in the "reasonable" category in terms

of BS 8223/1999 recommendations. The Lismulllin Center is 150 metres further from the

M3 than either of receiver 35 or 37 which would give a further reduction in noise levels

for that building and it should be noted that the route had been adjusted previously to

meet concerns expressed by the Centre, a point that was of concern to Ms Ryan (Plot

1083) from the perceived increased impact on properties to the east of the route. ( See

Section 1.2 in Vol.4A of the EIS and Section 50. 5 of this Report).

Evidence was given by Mr. Searson on noise levels at the properties of the Peters family,

Piercetown, Plot 294, and McCarthys, Blundellstown, Plot 1090, where he suggested

that the external arrival levels should be mitigated to 50 LAeq. Both of these properties

are adjacent to the existing N3 and presently experience noise levels in the range of 60 to

65 dB LAeq. Since the proposed target level would now be equivalent to 60 dB LAeq, I

consider this as a reasonable target arrival level for both properties as it is at the lower

end of the present noise levels at their respective properties, and no further mitigation

below the general target level is required in their cases.

The impact of noise on the operations of Tara Stud ( Plot 1064) through which the

motorway would run for about 3 kms. was raised in cross-examination and I asked the

Council to investigate the feasibility of providing a bund along the western edge of

theacquisition line to reduce the effects of traffic noise. The Council responded in a

document handed in on Day 28, as listed in Appendix 4, in which they confirmed that a 2

metre high bund could be provided in addition to the woodland screen proposed within

the proposed landtake. I consider this would be of benefit in mitigating the impact of the

motorway on the operations of the Stud and that this bunding should be provided as

proposed in the Council's submission.

As referred to in Section 108.2, noise levels on the Ardsallagh Road are predicted to be

at 69dB even with noise barriers in place on the motorway since the traffic using the

Ardsallagh Road itself will be the dominant noise. Having regard to the fact that the noise

level from the motorway would be a contributing factor the Council have undertaken to

provide a noise reducing surface for 400 metres of the proposed realignment of L-4009-8

north of the new staggered junction, and on the full 890 metres of the realigned L-4009-8

north of the River Boyne and over the connecting section of L4009-8 of about 1000

metres between both sections of new realigned roads, see document handed in on Day 28

as listed in Appendix 4 of this Report. This would reduce the noise effects from traffic

using the Ardsallagh Road itself adequately, with the noise bunds on the motorway

mitigating the noise effects form the motorway on the nearby houses.

957

Following my request that other adjoining side roads be assessed, the Council confirmed

that none of the other side roads would have predicted levels above the then criterion of

68dB and, from the document submitted on Day 28, it can be seen that the predicted

levels will be within the revised criterion of 65dB . In general terms, the application of

the revised criterion of 65 dB as the "cap" on road traffiic noise should limit the

maximum "overall" increase above the present ambient noise levels in the "quieter" areas

along the proposed route to an increase falling within the range of 10 to 13 decibels,

which is similar to the criteria on which An Bord's decision on the Outer Ring Road was

based.

A further assessment was carried out by the Council during the Hearing of noise levels at

Ms Martin's house on the Trevet Road arising from her questions and the details, as listed

in Appendix 4 at Day 28 were forwarded to her. The levels predicted are less than the

revised criterion of 65dB LA10.

I am satisfied that the application of the Revised Target criterion of 65 dB LA10

18hour at the nearest noise sensitive receiver to be used in determining when mitigation

measures are to be applied, in conjunction with the existing measures outlined in the EIS,

subject to the lower levels of 55 dB LA10 being applied at Rathbeggan Lake and at

Ardbraccan House, would result in the impact of Traffic Noise on the environment being

considered acceptable and not being of significance.

The application of this revised Target Noise criterion would require increased noise

barrier heights in some locations where noise barriers are already proposed to meet the

EIS criterion of 68dB, and the provision of new noise barriers in some other locations

where, in the EIS, no barriers were recommended. While this would increase the visual

impacts and in some cases this might be a significant increase in the scale of the visual

impact, the noise impact and the use of 68dB to determine the need for mitigation was the

single most common objection made both to An Bord before the Hearing and at the

Hearing itself. When asked if a change in the criterion would require additional noise

bariers, Mr. Dilworth said that any change in the criterion would have an effect on the

mitigation required, see Section 89.3 of this Report. I consider that, on balance, any

increase in visual impact that might follow from the aplication of the Revised Target

criterion would be outweighed by the reduction achieved in the noise impact and that

there would be a positive impact overall on the environment.

There are a number of proprietary noise barrier materials now available, and Mr. Searson

submitted photographs of some examples, which would be visually unobtrusive. In most

cases where noise barriers are proposed in the EIS, landscaping is also proposed and any

additional noise berms or bunds could be suitably landscaped or wall type noise barriers

could be screened by landscaping. I am satisfied that this issue was adequately addressed

at the Hearing and does not require a further assessment if the revised Target Noise

criterion was to be applied in determining the mitigation measures required on the M3

Scheme.

958

Construction Noise and Vibration issues :

The Construction effects include Construction Noise and arising from my comments on

the levels proposed in the EIS, see Section 108.2, the Council made an amendment to the

noise limits proposed in the EIS which, effectively, reduced by 5dB the levels shown in

the EIS, eg. Table 4.9 in Vol. 3A, for the periods Monday to Friday 0700 to 1900 and

Saturday 0800 to 1630, see document handed in on Day 25 as listed in Appendix 4 of this

Report. The maximum 1 hour level would now be 70 dB LAeq Monday to Friday and

65dB on Saturday with the peak being 80dB and 75dB respectively. Having regard to the

length of scheme, it is unlikely that construction noise at these levels will be generated

for extended periods in specific locations and on that basis I consider the Council's

amended proposals for Construction Noise limits are acceptable. However, I consider that

the site working hours should be limited so that no construction work takes place within

100 metres of any occcupied dwelling house before 0700 hours Monday to Saturday,

after 1900 hours Monday to Friday, after 1630 on Saturdays and not at any time on

Sundays or Public Holidays.

In relation to monitoring of Construction Noise, which was an issue raised during the

Hearing in cross-examination, the Council undertook to provide and maintain a number

of Noise Monitors in place as "Control Stations " in the context of the requirements of

BS 5228/ 1997 " Noise and Vibration Control on Construction and Open Sites" where

construction works that would generate significant noise levels are in operation. As set

out in the document submitted at Day 25, as listed in Appendix 4, a minimum of Four

Noise monitors and Two Vibration monitors should be adequate for normal operations

but the Council have also undertaken to provide more if required for specific periods.

Responsibility for selecting locations and ensuring correct operation would lie with the

Council's Site Representative, who would also be responsible for advising residents of the

results of such monitoring.

The effects of blasting when removing rock in excavation work was raised both by

property owners concerned about possible structural effects and by some of the Stud

Farms on account of the effects on thoroughbred horses. During the Hearing the Council

gave an undertaking that where blasting would be taking place in the vicinity of houses, a

pre-blasting structural survey of such houses would be undertaken which, generally,

satisfied the concerns that had been raised.

In the EIS it was stated that the magnitude of vibration effects from blasting would be

considered in terms of Peak Particle Velocities (PPVs). Evidence was given by Mr.

Searson that no limits were given in the EIS in relation to the accoustical parameters in

relation to the firng of explosives and he drew attention to limits set for such activities at

Tara Mines where a limit of 125 DB (L) was set during daytime for the peak air overpressure

for commercial blasting operations by the EPA, where the value of dB(L) was

known as Pmax. Mr. Searson said that where the bloodstock industry was involved a

stricter limit was necessary and in reply to my question he indicated a level of 20 dB(L)

lower, which actually equates to the night-time Pmax limit imposed on Tara Mines by the

EPA. In the circumstances of concerns expressed, I consider that a daytime limit for

959

Pmax ( peak air over-pressure) of 125 dB(L) be set for all blasting operations undertaken

on the M3 Scheme with a level of 105dB(L) being set for any blasting operations taking

place adjacent to paddocks or other areas normally used by bloodstock animals.

Construction Effects :

A substantial number of the submissions and objections referred to the effects of the road

construction on the services to properties including the effects on private wells, septic

tanks and other utilities, access to driveways and houses generally, surface flooding from

roadways onto property and boundary treatments. In general the Council responses to

these submisions were to the effect that some of these were issues which would be dealt

with, if the Order was approved, in subsequent negotiation about compensation terms and

that others would be dealt with by the contractor as part of the detailed design stage.

During the Hearing a number of objectors questioned the lack of certainty in some of way

the responses they had received had been worded and in cross-examination of the

Council witnesses a number of clarifications and undertakings were given by the Council

on these issues. The Council then confirmed that if the Order was approved the

negotiations on accommodation works would be undertaken by the Council and these

would then be included in the PPP contract for construction by the Contractor which

clarified concerns raised by some objectors at the Hearing about who would be

responsible for dealing with those works.

Two areas are identified in the EIS specifically where there was a potential for impact on

the groundwater where cuttings would be excavated, at the Dunsany road area shown in

Figure 8.1 in Vol. 3A and at the Bohermeen Road area referred to in Section 8.4.4 in

Volume 5A of the EIS. A submission was made to the Hearing by Mr. McKillen, (see

Section 48.2 ) on behalf of 10 residents in the Dunsany road area and a number of

objections to the Motorway Order and Submissions to the EIS were made from the

Dunsany/ Leshamstown areas. During the Hearing the Council gave an undertaking to

carry out pre-construction pump testing of wells in the Dunsany Road area to establish

their vulnerability and that deepening of the well or other appropriate remedial action

would be undertaken by the Council's contractor as appropriate. Details of this

undertaking, and copies of letters issued to the property owners in the locality, were

handed in on Day 21as listed in Appendix 4 of this report. The persons written to are :-

Arthur & Elodie McFaul, JP & Ann McKillen, John O'Connor, Tom & Mary Byrne, JP

Irwin, all of Roestown; Evan Newall, Peter Conlon, John Morgan, all of Readsland,;

Walter Smyth, Leo & Michelle Lawlor, John Nulty, Frank & Mary Fitzmaurice, all of

Leshamstown and PA & Carmel Carroll, Dunsany Road, Drumree. Almost all of these

are in the list of objectors to the Motorway Order or to the EIS given above.

In the case of the Bohermeen Road area, the EIS stated that further monitoring of existing

wells and pump testing would be undertaken to establish potential impacts and the

Council's general commitments on remedial works to wells would be applicable there.

Attrention was drawn to a potential for an impact on St Ultan'sWell, a local historical

well adjacent in the grounds of Ardbraccan House and located some 500 metres from the

960

Bohermeen Road motorway cutting but adjacent to the Randalstown fault zone. When

questioned Mr. Finlay suggested that a limited lining of the motorway cutting might be

required if the pump testing indicated a potential impact on St Ultan's well as being the

more appropriate mitigation, rather than the use of a grout curtain as indicated in the EIS,

see Section 136.2 of this Report. I consider the potential impact on wells in the

Bohermeen and Ardbraccan areas has been adequately dealt with in the EIS and by the

evidence given at the Hearing.

The Council confirmed that the Contractor would be responsible for ensuring that

services such as water supplies, septic tanks, sewer connections, utility connections and

access to properties would be maintained and that adequate notice and liaison about

construction work which might affect any of these services would be given. The Council

also confirmed that surface water drainage for road realignment associated with over/

underbridges or diversions associated with the motorway scheme would be designed and

constructed so as to ensure water did not enter onto driveways.

Arising from queries and submissions at the Hearing the Council undertook that any

sections of disused surfaced roadways ( cul-de-sacs) that became redundant as a result of

realignment for over/underbridges or other diversions would have the surface ripped up

and topsoil spread there to render them unusable.

The use of local roads by construction traffic, including their possible use for imported

fill and for disposal of unsuitable material was discused at the Hearing and the Council

confirmed the access to the site of the motorway and its associated link roads would be

confined to using only the following roads :- National Roads -- N3, N51 &N52; Regional

Roads -- R125 except for section between junctions with R154 & N3 ( ie via Drumree&

Dunsany), R154, R155, R156 & R157 ( except for sections through Dunboyne), R161,

R163 & R164 and Local Roads --- L - 1005 Collierstown road for 600 metres northeast

of Ross Cross, L - 2201 Dowdstown road for 1100 metres west of Garelow Cross and L-

8001- 10 Phoenixtown road from the N3. The Council also confirmed that the use of all

other local roads would be prohibited in the contract conditions which means that all

construction traffic approaching or leaving the site, from Clonee to North of Kells, would

be confined to using the National and Regional roads where these intersect the route of

the proposed M3 scheme and the sections of three specific Local Roads from their

junction with the N3 to where the M3 crosses that Local Road. Imported fill and

unsuitable material would also arrive at and leave from the site via these road as well.

The type of boundary treatment to replace existing roadside fences that would be

removed was referred to in many of the submissions and was also raised at the Hearing

on behalf of a number of property owners. While this is part of the acommodation works

negotiations between the Council and each landowner, it was clear from the crossexamination

of the Council's witnesses that the wording of the Council responses had

created some confusion about who would be responsonible for these negotiations in the

context of the Council's references to the PPP contractor and the detailed design stage.

The Council had confirmed that all negotiations about compensation/and accommodation

works would be conducted by or on behalf of the Council with each the landowner as in

961

the case of "normal" contracts (see above ), but at my request for a clarification on the

boundary treatment issue, the Council included a note on the issue of boundary

treatments, dated 15 November 2002, with the documents handed in on Day 28 as listed

in Appendix 4 of this Report. This set out that there were two types of "standard" fencing

which would be applicable across the scheme, a timber post and rail fence and a

blockwork or stonefaced blockwork wall and that landscaping or a hedge could be

planted with the timber rail fence. The Council confirmed that existing boundaries

including those at house frontages would be replaced by the same or by similar type of

boundary, the details to be negotiated by the Council on an individual basis.

Arising from the evidence given on behalf of the Peters family in Piercetown, Plot 294,

and their request for a wall to replace their frontage which would be removed as part of

the re-positioning of the realigned N3, see Sections 25.16 & 47.2, as their house would

be within 50 metres of the realigned N3 the Council were asked to submit details of the

locations of all houses within 50 metres of new roads in the proposed M3 scheme. From

the details submitted, as listed at Day 28 in Appendix 4 of this report, it appears that most

houses within 50 metres of new roads are on the realigned side roads or overbridge

realignments where they presently front onto existing roads, or were fronting onto the

existing N3, N51 or N52, where these would become part of the motorway scheme. Apart

from houses being acquired to be demolished as part of the proposed motorway, the only

house that would be within 50 metres of a completely new road would be in Plot 4022

west of Drumbaragh. Having regard to the Councils's undertaking to replace existing

frontage boundaries at houses by the same or a similar type of boundary, I consider that

this issue can be dealt with adequately within the context of the accommodation works

and compensation negotiations between the Council and individual preoperty owners..

I am satisfied that the Council provided adequately clarification to the issues raised

relating to the "Construction Effects" and that queries raised in objections and

submissions were adequately dealt with in the written responses given by the Council

and, where necessary, by the clarification given by the Council subsequently at the

Hearing.

Air Quality and Dust Issues :

While Air Quality was referred to in a number of submissions to the EIS, the evidence

given by the Council indicates that for worst case receptors the predicted pollutant

concentrations for NO2, PM10 and Benzene will remain below the present limits on

traffic related pollutants in existing and proposed National and EU Air Quality Standards

for both scenarios for both 2004 and 2024. While Mr. Healy in giving evidence on behalf

of Dalgan Park questioned the accuracy of some of the baseline monitored levels

recorded, he confirmed when cross-examined that his evidence was only based on what

he would have expected the levels to have been, and that he had not carried out any tests

himself. The Council witnesses on Air Quality confirmed they were satisfied with the

accuracy of their predictions and no contrary evidence was submitted to the Hearing. I

am satisfied that the levels recorded in the Councils baseline monitoring can be regarded

as being typical of what would be obtained in a short term monitoring exercise and in the

962

type of location such as were used in this case and am also satisfied that the predictions

made can be relied on.

However, in view of the concerns expressed by a number of objectors to the effects from

increased traffic levels and that fact that trends are best identified by a long term

monitoring of pollutants like PMs and NO2, I consider that as part of the M3 Motorweay

scheme the Council should be required to set up and maintain at least two continuous

monitoring stations to monitor levels of Nitrogen Oxide (NO2) and Particulates (PM10).

From comments made by both Dr. Porter and Mr. Healy, the most appropriate locations

for these stations would be at the major interchanges where traffic conditions would be

favourable to increased emission levels and I consider, having regard also to the areas

from where the submissions were made, that the Interchanges at Pace and Blundellstown

are the most suitable locations for such longterm monitors to be located.

Issues relating to the Control of Dust were included in the objections and raised in crossexamination

by several people at the Hearing and while there are dust control measures

outlined in the EIS and these were expanded on by the Council's witneses at the Hearing

particularly in relation to the imposition of a speed limit of 20 kms.per hour on vehicles

using unsurfaced site roads and other measures, generally as detailed in the EIS. In

response to queries about monitoring of dust emissions during construction work, the

Council undertook to install and maintain Dust Monitors consisting of "Bergerhoff Jars"

at a number of specific sites while construction work that could generate dust was in

progress. The locations of the 25 sites nominated where these Dust Monitors will be

placed by the Council along the length of the proposed road are given in the documents

the Council handed in on Day 28, as listed in Appendix 4 of this Report, are given

hereunder :-

Houses of Liam Scott, Piercetown; Teresa Peters, Piercetow; Kieran Lavelle, Piercetown:

Property of David Robinstown, Rathbeggan; Michael Lynn, Derockstown; Newalls,

Readsland House; Tom Byrne, Roestown,; Bernard Walsh, Newtown cottage, Dunboyne;

Properties adjoining Roestown crossing N3; Properties on Trevet Road; Sandra Ryans

Lismullin; properties adjoining Dowdstown Overbridge; Properties on Ardsallagh Road

north of Overbridge; Property north of mainline at Trim Road overbridge; Property

northeast of mainline at Robinstown Road overbridge; Property northeast of mainline at

Athboy Road realignment; Property east of mainline at Boyerstown Road; Halting site at

townparks; House east of Kilcarn Link at Ballybatter Road; House east of Kilcarn link at

Swan Lane; ON N3 north of Kells; Northeast of Twiun Roundabouts at Calliagfhstown;

Grangegoddan Glebe; West of Pheonoxtown Overbridge; East of Drumbaragh

Roundabout; East of Derver Roundabout.

I am satisfied on the basis of the undertaking given and the details submitted, which are

additional to the Dust minimisation measures outlined in the EIS, that the impact of Dust

on the environment from the proposed Road Development will be adequately controlled

and not of significance.

963

Material Assets & Severance issues :

The impacts on Material Assets are described in the EIS for agricultural assets, nonagricultural

assets and for natural resources and, in general terms, the impacts on

agricultural and non-agricultural assets are those from the acquisition of lands and houses

and these impacts can be mitigated by the accommodation works and compensation terms

that will be negotiated by the Council with the owners, if the proposed Motorway Order

is approved. A total of 224 agricultural propoerties will be affected by acquisition of land

for the Road Development.

A total of 13 houses are proposed to be acquired for demolition as part of the Road

Development, with 3 residential properties having all of the atttached lands acquired and

45 residential properties being affected by partial acquisitions and 28 commercial

properties would also be affected by partial acquisitions, all of which make up the Nonagricultural

Material Assets affected by the proposed Motorway.

Where severance of lands is caused by the route, access arrangements have been provided

and these are shown on drawings in the "B" Volumes of the EIS. The main source of

objections to the arrangements proposed was from the use of shared under/overpasses and

passageways with landowners seeking separate facilities where their lands were severed.

In cases where the area of land severed was of a relatively small area or where the cost of

providing an access passage was more than the value of the severed land, the Council

proposed to acquire those parcels for use in their landscaping proposals usually as

Specific Landscaping Measures (SLMs). I consider that in the locations where such

acquisitions are proposed, and as already stated, these acquisitions are justified as part of

the Road Development.

In the light of concerns expressed by landowners on the use of "shared facilities", the

Council commissioned a Report from Professor Kevin Dodd, Lecturer in the Veterinary

Faculty in UCD in the Large Animal Clinical Studies Department who specialises in the

epidemiology of infectious diseases. As detailed in his evidence at Section 27 in this

Report, Professor Dodd concluded that the use of shared facilities represented no extra

risks over the residual risks that were always present and that his understanding of current

Department of Agriculture, Food and Rural Development policy was that an shared

under/overpass did not represent an un-acceptable risk provided there was no mingling

of herds and that reasonable steps were taken to prevent the build-up of faecal matter. As

Professor Dodd described these steps by saying that a good neighbour policy of leaving

the underpass as one would expect to find it and the risk of disease transmission would be

kept to a minimum if that good neighbour policy would be followed. The Council

confirmed that where shared under/overpasses were being provided they would provide

reasonable holding facilities on the landowners land as part of the accommodation works

wherea shared under/overbridge was being provided. The Council also submitted details

of other road schemes constructed as at November 2002 on Day 28 of the Hearing, as

listed at Appendix 4 of this Report, and while the number in place is small they appear to

be operating satisfactorily.

964

Details of the locations and number of users for each shared under/overpass were also

submitted by the Council and the details are listed at Days 25 & 28 as listed in Appendix

4. These details show that dairy farmers are involved in only a few of the shared

facilities and as dairy farming could involve twice daily usage "return trips" during the

milking season, there could be some justification in the concerns expressed by dairy

farmers about the practicalities, as distinct from disease issues, of using the shared

under/overpasses particularly where large dairy herds are involved, since it is a common

farming practice to let the herds find their own way back to their field after being milked

when this does not involves crossing public roads.

Evidence was given on behalf of two dairy farmers who had concerns about the use of a

shared facility, Mr. & Mrs. Morrin, Johnstown house, Dunshaughlin, Plots 149/160, and

Mr. Kieran, Knockmark, Dunshaughlin, Plot 172, and written submissioins were made to

the Hearing by Mr. & Mrs. Duffy, Plot 162, Mr. & Mrs. Joyce, Plot 163 and by Mr.

Summerville, Plot 166, all of Rath Hill Dunshaughlin, all of whom sought a separate

facility. The only other shared facility which has a dairy farmer listed as a user is for an

underbridge under the Athboy Link road where M/s Dowdalls, Plot 2183, share with

Tara Mines land usage.

An overbridge with a 6 metre wide carriageway was proposed by the Council to service

the Morrins, Plots 149/160, who have a very large dairy operation and Mr. Delaney, Plot

159, who has a large sheep flock and also stocks beef cattle and this issue was discussed

in Section 44 of this Report when it was suggested that the overbridge be widened to

provide for two passageways across the bridge separated by a wall that, effectively,

would give each landowner their own crossing facility. The Council subsequently

reported that the additional cost for widening the overbridge to 10 metres, which would

give each landowner a nominal 5 metre passage divided by a wall, was € 225000 while

the 6 metres bridge as proposed was estimated to cost € 700000. Having regard to the

scale of the dairy operations on the Morrin farm and the impact of the motorway on the

operations of both landowners, I consider that a widening of the overbridge to 10 metres

overall width, which would give each landowner an effective passageway width of about

4.5 metres, would be the appropriate mitigation of the severance impact on both the land

holdings. Both land holdings were already being provided with separate access

passageways as far the shared overbridge and the Council also confirmed that widening

of the bridge could be carried out within the landtake in the Order.

In the case of Mr. Michael Kieran, Knockmark, plot 172, on whose behalf evidence was

also given, see Section 43 of this Report, he is the only dairy farmer of the five

landowners for whom this underpass is proposed. Mr. Kieran rents on a longterm basis

two of the adjoining lands, Plots 155 and 171 which means that there would only be three

users while that renting arangement continues. The Council proposed to provide a 6

metre wide by 4.5 metre high "box" underpass here located on Mr. Kieran's land as he

would be the most frequent user. From details supplied in respect of the Keogh

submission on the Navan By-pass Section, the cost of a 4.5 metre by 4.5 metre box

underpass at the Kilcarn Link, a dual carriageway is € 41000 for the unit plus installation

costs. Having regard to the fact of the R125 at Knockmark being a wide single

965

carriageway, which would require a lessor length than at the Kilcarn Link, the additional

cost of providing two 4.5 m by 4.5 m "box" underpasses in place of the 6.0m by 4.5m

proposed would be marginal, since the installation costs for two would not be much more

than that for the larger unit. I consider that the provision of Two underpass units at

Knockmark, which would provide one unit for Mr. Kieran as the sole dairy farmer and

most frquent user and the other as a shared unit between the less frequent users, would be

the more appropriate mitigation of the severance impact in this location.

Written submissions were made to the Hearing in respect of the shared underpass facility

proposed at Rath Hill, Dunshaughlin, see Section 48.3 of this report by the Duffys, Plot

162, Joyces, Plot 163 and Pat Summerville, Plot 166 each of whom sought a separate

underpass/ acess road on grounds of disease concerns. I am satisfied from the evidence

given by Professor Dodd that the risk of disease being spread by the use of shared fcilities

is no higher that that which presently exists in normal farming operations where good

husbandry practices are followed. However I accept that the requirements for stock

movements are more frequent for dairy farmers that in dry stock or tillage and can require

twice daily returns in the milking season. The underpass being proposed by the Council

at Rath Hill is also for a 6 metre by 4.5 metre high "box" and I consider that the provision

of Two 4.5metre by 4.5 metre underpass "box" units, located at the boundary of Plots 163

and 166 would provide a more appropriate mitigation of the severance impacts at this

location. Both Mr. Summerville, Plot 166 and the Joyces Plot 163 are dairy farmers and

each of these would then share a unit with their adjoining landowner ( Plot 166 with 167,

163 with 162) whose usage would normally be of a lessor frequency.

As stated above, from the details supplied to the Hearing, the only other daiy farmers

involved with a shared underpass are the Dowdalls of Knockumber, Plot 2183, who share

a 4.5 metre by 4.5 metre "box" with Tara Mines and who made a written submission to

the Hearing, see Section 100.2 of this Report. I consider that this proposal is adequate to

mitigate the severance impacts in that location since they share with only one nonfarming

user whose use would seem likely to be infrequent.

Mr. Keogh, the owner of Plot 2114 at Cannistown, who made a verbal submission to the

Hearing, see Section 100.1 of this Report, that the height of the underpass proposed at 4.5

metre was inadequate for a combine harvester where he gave a height of 4.88 metres as

applying. From the brochure he submitted, as listed at Day 22 in Appendix 4 of this

Report, there is no reference to machine height given but the machine appears to be of

integral construction. Having regard to the fact of a 5 metre by 5 metre "box" being

available for an additional cost of € 9000 for the unit only and as the additional

installation cost would be marginal, I consider that the size of underpass to be installed

should be increased to 5 metre by 5 metre as the more appropriate mitigation of

severance in this case. Three landowners would share this underpass and the increased

height would involve sinking the floor level a greater depth below ground level than was

proposed for the 4.5 metre high unit. While the floor level would be above the normal

water table, as is reported in the Council's response to Mr. Keogh's request in the

document submitted to the Hearing on Day 28 and listed at Appendix 4 of this Report,

966

the floor of underpass may be subject to flooding after heavy rain, but see my further

comments at page 971 of this Report.

Objections to the severance impact were made by the Ryans, Lismullin, Plot 1083, both

to An Bord and at the Hearing in Ms Ryan's cross-examination of Council witness. This

holding is being split by the motorway with a substantial part being separated from the

farmyard area and access is being provided by means of a service passage, shared with

another farmer, in Plot 1084 which links into the realigned overbridge at Lismullin on

Local road L - 6200-0, a cul-de-sac roadway. Arising from Ms Ryans concerns, see

Section 50.5, I requested the Council to examine the feasibilty of providing an underpass

to connect both parts of Plot 1083 directly and details of this were submitted by the

Council on Day 13, as listed at Appendix 4 of this Report. This indicated that it would be

feasible to provide a dedicated underpass but the mainline would have to be raised by

about 2 metres and this would require additional filling to the embankment and bunds in

this area. The cost was estimated at € 710000, half of which was accounted for by the

extra filling. There would be some saving on this cost by the reduction in length of

service road required on the far side of the motorway as this would not have to extend to

the Ryan holding. In my opinion the increased height of the embankment required to

provide this underpass would not have an increased visual impact on adjoining houses

since there are bunds already being provided for landscape and visual screening. I

consider that the decision on the provision of an underpass for Plot 1083, while noting it

is feasible to do this without increasing the visual impact of the motorway in the locality,

is a matter for consideration in the overall compensation and accommodation

negotiations between the Council and the landowner in this instance.

An objection was made by the Raynestown Residents Association in their submission to

An Bord to the provision of a service road to Plot 251off the Raynestown Road adjacent

to the motorway which they said was un-necessary since that landowner could gain

access elsewhere. Mr. O'Sullivan, Plot 221, Raynestown made a similar objection to Plot

221b.20 being acquired for access road no. 13. Ms Joyce handed in a map showing the

location of this acquisition arising from these objections and confirmed that the Council

had not been able to establish that the alternative access referred to by the Raynestown

Residents had any legal standing. This map is listed at Day 7 in Appendix 4 of this

Report. I am satisfied that the acquisition of plot 221b.202 to provide for Access road no.

13 to plot 251 is justified. It should be noted that Mr. John O'Sullivan withdrew his

objection to the acquisition of plot 221 on day 25.

Access to the Henshaw property, Plot 326, which is being provided with one dedicated

underpass as part of the Kennedy road underbridge in Dunboyne and a shared underpass

with Plot 326, was clarified for the Henshaws during Mr. O'Donnell's questioning of Ms

Joyce, see Section 46.

There was a reference to the provision of an overpass for the farm in Dalgan Park, Plot

1094 during Mr. O'Donnell's cross-examination of Mr. Farrelly, see Section 53.2, but Mr.

Farrelly said that an alternative access had been provided which included for an access

off the Dowdstown Road realignment and that an overpass was not required to mitigate

967

the impact on the farming operations in Dalgan Park. It would be possible to provide an

overpass to link the lands on either side of the motorway, without involving any other

landowner or creating an adverse visual impact, and this could be used instead of the

alternative suggested by the Council which does involve using, in part, existing public

roads. In my opinion this is an issue about which is the more appropriate access

arrangement that should be provided and this would best be determined as part of the

negotiations betweeen the Council and the landowner on the accommodation works and

compensation arrangements in this case.

Evidence was given on Behalf of Mr. & Mrs. Henry Newman, Plots 3047 & 3053 of

Gardenrath, Kells on the effects of severance on their farming operations. Having regard

to the submissions made, the evidence given and the Council's responses, I consider that

the mitigation measures propoosed by the Council are reasonable and that any further

mitigation would be by way of accommodation woorks and compensation.

Use of Natural Assets :

The proposed Road Development will require the use of some 718.449 hectares of land

of which some 654 hectares is used as agricultural land, 57.85 is part of public roadways

and the balance is in residential or commercial use. While the quantities of imported

filling required was given in Vol. 2 of the EIS as being likely to exceed 4.5 M cu. metres,

more accurate calculations were undertaken by the project team after the EIS was

published. From the details provided in evidence at the Hearing by the Council it now

appears that some 5.33 M cubic metres of imported filling would be required to make up

the shortfall between what can be excavated within the landtake and is suitable for use in

road construction and the total quantity required to construct the motorway scheme and

this will come from existing Natural Resources in the area surrounding the route and

probably mainly from within County Meath.

As previously described the Council were not able to identify from where this imported

fill would come, but they confirmed that any proposal by the contractor to use sites for

which there was not an existing planning permission would require that a planning

application(s) would have to be submitted for determination by the relevant Planning

Authority in acordance with normal planning procedure. I consider that having regard to

nature of the difficulties outlined by the Council, see Section 145 at Section 50 (3) (d),

and to the evidence given and cross-examination that subsequently followed at the

Hearing on this issue, the issue of the use of imported materials and of their possible

origin and impacts were adequately dealt with at the Hearing.

Socio-economic issues :

Concerns were expressed by and on behalf of the Columban Missionairies, Dalgan Park,

by the Bellinter Residents association and by other residents in at area adjoinng Dalgan

Park at the absence of references to the facilities available and to the activities engaged

in at Dalgan Park in the Socio-economic Section in Vol. 4A of the EIS. I previously

referred to the issues raised about this lack of reference by Mr. O'Donnell on behalf of

968

Dalgan Park in Section 147 of this Report, as well as in my comments in Section 145.

During the Hearing evidence was given by a number of witnesses on behalf of Dalgan

Park and in submissions given by individual residents in the Bellinter area as well as by

Bellinter Residents Association about the extent of the facilities and of the range of

activities, both public and private, in Dalgan Park and Dowdstown House and the

Council witnesses were cross-extensively on these issues. I am satisfied that in the

context of Section 51(7)(a)(iii) of the Roads Act 1993 as amended, adequate evidence on

the possible socio-economic impacts of the proposed M3 Road Development on Dalgan

Park was provided by the Council at the Hearing and that the likely significant effects of

the proposed development can be assessed.

As part of the Socio-economic assessment made in the EIS generally, a number of

footpaths are proposed at various locations which are detailed in the EIS and in direct

evidence given to the Hearing by the Council witnesses. In a number of the submissions

made to An Bord and at the Hearing there were requests for footpaths to be provided to

mitigate traffic effects and for road safety concerns and in my site inspection I had also

noted a number of locations where additional footpaths would assist in mitigating the

impacts referred to in the objections or submissions made to an Bord. Set out hereunder

are the details where I am satisfied the provision of Footpaths, additional to those set out

in the EIS, would mitigate adequately the impact of the proposed development :-

(1) Provide footpath from circa chn. 240 on Loughsallagh to Clonee tie-in and to circa

chn. 200 on Dunboyne road from Loughsallagh Roundabout to facilitate existing

houses fronting this section of roadway.

(2) Provide for footpath on both sides of Leshamstown Lane, with a cyclepath along one

side, from a point at least 200 metres to the south of Mr. Finlays house as shown on

Figure 8.1 in Vol. 3A of the EIS to its junction with the Dunsany Road.

(3) Provide for a footpath incorporating a cyclepath from the Leshamstown Lane

junction with the Dunsany Road along the south side of the Dunsany Road through to

the Roestown Roundabout and to extend for at least 200 metres on the Dunshaughlin

side of the Roestown Roundabout.

(4) Extend footpaths, with cyclepaths incorporated, from the Raynestown and

Derrockstown Road overbridge realignments, along one side of each road, to their

respective junctions with the existing N3.

(5) Provide for a footpath, with cycleway incorporated, along the Collierstown Road

from the Ross Cross junction with the N3 as far as the junction with the Trevet Road.

(6) Provide for footpath, with cyclepath incorporated, along eastern side of the full length

of the Woodpark Road to link in with the Pace footpath/cyclepath at the southern end

and to link in with the Blackbull Roundabout footpath/ cyclepath at the northern end.

Specific crossing points for pedestrians and cyclists are to be provided at all new

roundabouts being constructed as part of the proposed Road Development from Clonee to

North of Kells with suitable refuges being provided at the centre of the crossing point and

these to be located at a distance from the exit of the roundabout that provides adequate

visibility of traffic approaching and exiting the roundabout..

969

The temporary closure of the Ballybatter Road L-8010-0 ( known locally as

Botharalainn) while the Kilcarn Link road is being constructed will require traffic

diversions over a period of some 9 to 12 months and concern was expressed by the

Cannistown Residents Association about the effects of the diversions on local traffic

patterns. The Council submitted details of the Traffic Diversion routes that could be

signposted and these are listed at Day 23 in Appendix 4 of this Report. Pedestrian

facilities for school children who normally use the Ballybatter Road when going to

Cannistown National School could be provided while the Link Road bridge was being

constructed as shown on the Map submitted. Since the temporary closure of the

Ballybatter road will require compliance with the provisions of Section 75 of the Roads

Act 1993, which includes provision for input by the public, I consider this is an issue

which can adequately be dealt with by that procedure. The Council may need to consider

some traffic calming measures adjacent to Canniostown National school during the

period of the closure of the Ballybatter road as the diversions could increase traffic

movements in the vicinity of the school at times when children are entering the school.

Mr. Evan Newall, Readsland, in his submissions sought the provision of a footpath along

the new Link road from the Knocks Roundabout to the Roestown Roundabout to

facilitate pedestrian traffic that he considered would arise from future developments on

zoned land in the vicinity. There is space within the verge being provided as oart of the

new road for a footpath to be provided but I consider that it would be premature to

provide such a facility at present as part of theRoad Development and this can be dealt

with, in due course and as the future development takes place, within the provisions of

the Planning and Development Act 2000.

Landscape and Visual issues :

After the noise impacts and the construction effects on properties, the impact on the

Landscape and the Visual impacts were the next most common objections raised both

in submissions made prior to and at the Hearing. The proposed route passes through a

number of different areas of County Meath that are zoned as " Areas of Visual Quality "

(VQs) in the 2001 County Development Plan and, as previously described, the route is

shown on a map of the County that has the various VQs marked on it. As was referred to

by both Mr. Killeen and Mr. Burns when giving evidence, see Sections 21, 39, 62, 99 &

107, the route mainly passes through the VQ 11 area of Rural and Agricultural with some

sections of the VQ 3 --River Valleys and VQ 11-- Tara & Dunsany District being

traversed in the Dunshaughlin to Navan Section. Mr. Killeen was of the opinion that the

proposed route being set in low-lying areas when traversing the VQ's 3 and 11 was in the

optimum location and Mr. Burns said that the crossing of the Boyne in VQ 3 and at a

location of "High Natural Beauty" would have a minor impact in landscape terms due to

the strong planting on both sides of the valley at the crossing point and as the road would

not be widely visible beyond the bridge structure.

Mr. Burns said that where the proposed route crossed the VQ 11 Tara & Dunsany District

zone it was set low in the valley at the maximum distance from the Hills of Tara and

Skreen and would have no appreciable adverse impact from either viewpoint. He also

970

refered to the Blundellstown Interchange where additional landscaping was proposed as

specific mitigation to reduce the overall visual scale of the structure and its illumination.

Mr. Burns considered that the proposed M3 would not visually impinge on the sensitive

landscape setting surrounding the National Monument at the Hill of Tara and pointed to

the M3 being generally more distant from Tara than the existing N3. The issue of the

impact on the landscape surrounding Tara, and Dalgan Park, was discussed at length at

the Hearing and the photomontages prepared by the Council to indicate the visual impact

of the M3 were also debated, see Section 62. Both Council witnesses were strongly

pressed on this issue, and while Mr. Killeen acknowledged that the impact of the route

when traversing the VQ 9 area would be severe in the short term during the construction

and early operation phases, he considered that the mitigation measures proposed would

ensure the effective integration of the M3 route into the local landscape. Mr Burns

considered that the selected route was well sited in a difficult landscape and that while

accepting that a short section did impact on the setting of Tara, he maintained that short

section did not bestow a severe rating on the selected route. Mr. Burns said his

classification of the impact from the Hill of Tara as being of minor significance came

from the view from the Hill being very expansive with a view over a very wide area of

the surrounding landscape available and the road and interchange being sited low in

valley areas which were well screened locally and from the Hill of Tara. It should be

noted that while there was strong criticism of these opinions, no rebutting evidence on

landscape or visual impacts was given at the Hearing.

The proposed route crosses part of an area included in a Tree Preservation Order in the

2001 County Development Plan at Dowdstown to the south and east of Bellinter Bridge,

also shown on the Landscape zoning map, and the reasons why this could not be avoided

were adequately dealt with at the Hearing with details of mitigation planting being

included in the tree planting proposals. A number of Listed Views as designated in the

County Development Plan, VP 1 for Tara, VP 27 for Skreen, VP 28(c) for Ardsallagh,

Bellinter and Dowdstown and VP 32 Blackwater Valley are within the route corridor and

there was evidence given that these would not be significantly impacted. Lighting at the

Interchanges, Roundabouts and the two toll Plazas was also raised as a concern by a

number of objectors and I am satisfied from the evidence was given at the Hearing that

with the use of fully cut-off lanterns, the fact of no High Mast lighting being used and

with the landscaping and screening measures proposed, the lighting impact will not be

significant.

While extensive landscaping measures are proposed in the EIS to mitigate the impacts

from the motorway, 10 properties would continue to experience severe negative impacts

into the longer term, even after the planting has developed, with major negative impacts

being experienced by a further 38 properties. These account for 10% of the total number

of properties of 486 that were assessed in the EIS. During the Hearing I had asked the

Council to consider the possibility of some landscape planting being done in the early

stages of the construction program, particularly in the vicinity of locations where severe

or major negative longer term impacts had been identified. The Council submitted

proposals for this "Advanced Planting" which are listed at Days 24 and 28 in Appendix

4 of this Report, which generally outline the locations where parts of the Specific

971

Landscaping Measures (SLMs) could be planted at the initial stage of the construction

contract with the balance being infilled at a later stage.

Arising from issues raised during cross-examination and from the submissions made

prior to the Hearing the Council were also asked to re-examine the design of certain

sections of the longitudinal profile to see if some further reduction in the vertical

alignment could be obtained, subject to surface water drainage constraints, which would

reduvce the visual impact for properties in the immediate vicinity, see Section 115 of this

Report.

The Council subsequently submitted proposals, as listed at Day 28 in Appendix 4 which

indicated that some modification in the vertical profile would be possible at each of the

locations requested and those details are as follows :-

1. At Trevet Road (Branstown/ Commons) area --- Revisions from chn 24100 to 25600

( generally through Tara Stud lands) which give reductions of from about 1 metre to

3.5 metres in embankment height as shown on Drawings 4B/ 3.3 Rev. A and 4B /3.4

Rev.A

2. Through Dalgan Park --- Revisions from chn 32600 to 33450 ( Dowdstown Bridge to

southern approach to Boyne Bridge ), giving up to 1.2 metes of a reduction in the

level of the "false cutting" at chn 33000 as shown on Drawing 4B/ 3.8 Rev. A, chn

33000 being about midway in the row of houses at Bellinter.

3. At Coolfore Road (Ardbraccan ) area --- Revisions from chn 61200 to 62400 ( in the

vicinity of theToll Plaza and the Grange Overbridge) giving reductions of up to 2.5

metres, as shown on Drawing CSK - 2236 Rev.1. Due to drainage outfall and culvert

constraints no further reduction in the vertical profile from Durhamstown towards the

White Quarry/Toll Plaza was possible.

4. Kilcarn Link Road --- This arose in the cross-examination of Ms Joyce by Mr.

McIntyre, see Section 86.4 and the possibility of redesigning the vertical alignment of

the link road was examined by the Council who submitted their findings on Day 28 as

listed in Appendix 4 of this Report. This showed that it was feasible to redesign the

Link Road to provide for an alignment that has a constant fall from the interchange

towards the Swan Lane footbridge which would provide for a single outfall for road

drainage to the Boyne at Kilcarn Bridge, a reduction in the road level behind Mr.

McIntyre's house from being on 3 metres of fill to being in 2.5 metres of cut and

would require the re-positioning of the underpass being provided for Plots 1133, 2112

& 2114 previously referred to in my comments on shared underpasses. However the

cost of the Revised design as Option B is some € 400000 more that the cost of Option

A as provided for in the EIS, due mainly to increased excavation and filling costs and

to the extra retaining wall costs associated with the Ballybatter road Overbridge area

to remain within the landtake in the Motorway Order. While the Council considered

that their original design, Option A as in the EIS, was still the preferred option, I

consider that there are certain benefits from the Revised Design which could justify

the additional cost involved. The use of a single drainage outfall to the Boyne would

remove the need to outfall to a tributary stream at chn. 850 in Option A which was the

subject of some concerns raised by Cannistown Residents Association, see Section

972

95.2 and 94.2; the revised location for the proposed Shared Underpass more readily

facilitates Plots 1133 & 2112 ( Paul & Francis Foley) and requires a shorter length of

access road to service the Keoghs, Plot 2114 and should also overcome the possible

flooding of the floor where a 5 metre high underpass was provided ( see reference on

page 965) and the visual and noise impacts at Mr. McIntyre's house would be

reduced. On balance I consider that the overall environmental mitigations that would

result from the use of the Revised vertical alignment, as shown on Drawings OH

5053 003/004/007 Rev. DO1, would justify the additional costs of its construction.

Submissions were made prior to and at the Hearing by the owners of Plot 331 adjacent to

the proposed Newtown Bridge Roundabout in Dunboyne about the visual impact of that

Roundabout, as well as other issues relating to it which were dealt with in the comments

on the Motorway Order. Having regard to the evidence given and cross-examination of

Council witnesses about this matter, I consider that the visual impact on Plot 331 could

be mitigated by the construction of a stone faced wall of not less than 2 metres in height

along the road side boundary of this property. Submissions were made at the Hearing by

both Meegan families, Plots 4019 & 4063, regarding the visual and noise impact of the

proposed N3 and the Roundabout at Drumbaragh and I am satisfied from the responses

given by the Council that the landscaping proposals outlined in the EIS will provide

adequate mitigation for those properties, and that the revised noise criterion outlined

previously will also adequately meet the concerns raised.

During cross-examination of Mr. Guthrie by Mr. Carty, Cannistown, the removal of some

trees to facilitate the construction of the Ardsallagh Overbridge was raised, see Section

50. 18 and the Council were asked to re-examine their proposal to see if a re-positiuoning

of the Overbridge would reduce the impact on the tree numbers. The Council handed in a

report on this on Day 28, as listed in Appendix 4 of this Report, which found that while

technically feasible to relocate the bridge, the number of trees "saved" was minimal and

some areas of redundant road, which it was intended to plant, would not then be available

for such planting. I consider that the Overbridge should be constructed as proposcd in the

EIS as no net benefit for the environment would result from its re-positioning.

Evidence was given on behalf of Ms Newman Maguire Plot 4063, Castlekeeran about the

visual and noise effects of the proposed new N3 and the effect this would have on her

Artists studio located at her house on the Kieran's Well road, see Sections 102.3, 112 &

113 of this Report. The new N3 is on an embankment as it passes by Ms Newman

Maguire's property some 120 metres to the south and while there is no landscape

screening proposed in that location, the Council agreed that a "reduced" version of a SLM

could be provided on the embankment on either side of the Kierans Road Underbridge

from approx. chn 85000 to chn 85600. As referred to in my comments about noise

impacts previously, the noise contribution from the N3 is predicted to be 57 dB LA10 but

the actual arrival level of 62 dB is a consequence of the Kierans Well road fronting her

property so further mitigation is not possible. However I consider that the parapet on the

mainline N3 where it crosses over the Kierans Well road underbridge should consist of a

solid wall in this case, rather than the standard railing type parapet, which would act as a

973

hard landscape screen to maintain the screning effect at the bridge crossing in this

location.

The visual impacts from the proposed motorway on Ardbraccan House were the subject

of a considerable part of the cross-examination by Mr. Casey of Mr. Burns, the Council's

landscaping witness, and of Ms Joyce and Mr. Evans, the Project Engineers, see Sections

127, 128, 132 & 134 of this Report, with three main issues being identified. These were

(1) the visual impact of traffic on the motorway between the Bohermeen Road and the

Durhamstown Road areas where the motorway is partially in a cutting of up to 4 metres

deep, at grade for a short section at chn. 49040 to chn. 49140, in cutting again of up to 3.2

metres and then on an embankment from 49430 northwards; (2) light spillage from traffic

coming eastwards (towards Ardbraccan House) across the Durhamstown Overbridge and

(3) light spillage from southbound traffic on the motorway from the vicinity of the White

Quarry area, as well as some concerns of light from the Grange Toll Plaza being visible

from the upper floors of Ardbraccan House.

The gradients used in the vertical alignment from the Boyerstown Road area towards the

White Quarry area are generally 0.5%, which is about the limit to ensure ponding of

surface water does not occur, and the road levels are dictated by stream crossings in the

vicinity of chn 48100 and chn 49950. I am satisfied the cuttings to the west of

Ardbraccan House are as deep as can practically be obtained on that route and that it

would not be possible to excavate to the depths suggested by Ms Maher in her evidence

due to the constraints of those stream crossings.

During his cross-examination Mr. Burns confirmed that the existing hedgerow ( which

included an old stone wall) from about chn 48700 to 49200 would be maintained and

strengthened by additional planting as part of SLM 28 shown in the EIS in figure 5.1.6 in

Vol.5A and he maintained this would provide an adequate screen of traffic on the

motorway from the Ardbraccan House viewpoint. He said that the SLM would continue

from Chn 49200, where the existing hedgerow ended, northwards through the

Durhanstown Overbridge area where it would be on the embankment. The effectiveness

of this landscape screening was strongly questioned and Mr. Burns showed photographs

of planting along a number of road embankments of what he said would be the effect at

Ardbraccan when established and referred to the screen planting extending over a 10 to

15 metre width. The availability of this width for planting was questioned by Mr. Casey

who suggested that the overall landtake width would not permit such a planting width and

who also showed photographs/photomontages of a view of the road from Ardbraccan as

it would be when in place The retention of the old stone walling, which has stone gate

piers and is said to be part of the demesne walls, was also an issue since it is within the

landtake in the Motorway Order. During the Hearing the Council confirmed that this

stone wall between chn 48700 and about chn. 49100/49200, where it ends, would be

retained "as is" within the planted area.

At its closest point, which is about chn 49230, the motorway take line is some 456 metres

from the south-eastern corner of Ardbraccan House so that any view of passing traffic is

upwards of half a kilometre away and through planted landscaping of varying widths,

974

through the existing trees and hedges along intervening field boundaries ( including the

hedgerow and old stone wall from chn 48700 to 49200 refered to above) and through

trees and shrubbery in Ardbraccan's grounds. Ardbraccan House itself is oriented along

an axis that is to the east of a south-east/north-west line ( at about 60 degrees east of

south ) so that the garden elevation, which is the opposite of the elevation shown in

Photograph no. 1 in Appendix G of Mr. O'Sullivan's report in Vol. 5C of the EIS, faces

towards the Durhamstown Overbridge area and not towards the proposed motorway at its

closest point. From an examination of the map in the Book of Additional Drawings

submitted by the Council on Day 20, and from the large scale Aerial Photo-drawings, it

appears that only an obligue view of the motorway from Ardbraccan House itself could

be seen from about chn. 49000 northwards and that it would be only as it emerges from

the cutting at about chn. 49400 that a more direct view could be seen. At that point the

motorway is more than 500 metres from Ardbraccan House.

Since this area is at the interface between the Navan By-pass and Navan to Kells sections

with the landscaping proposals set out in Vols. 5 & 6, of the EIS, I requested that the

Council prepare a composite drawing to show the landscaping proposals from the Grange

Toll Plaza area south to the Boyerstown Road area during the Arbraccan module, and this

was handed in on Day 28, as listed at Appendix 4 as Drawing OH 5044 003 Rev.D01.

This Drawing clearly shows that a continous landscaping "band" would run on both sides

of the proposed motorway from the Toll Plaza to the Boyerstown road area, with a dense

woodland mix being planted in the Durhamstown Overbridge area. This composite

Drawing also shows the orientation of the proposed roads, both the Motorway and the

realigned Durhamstown Road, relative to the elevation of Ardbraccan House facing

towards the pleasure grounds, which is the elevation shown in Mr. Searson's photograph

No. 3 handed in with his Brief of Evidence on Day 22. In my opinion the view of traffic

on these roads from Ardbraccan House, when the landscaping shown has become

established, would not be very noticeable in view of the distance and relative orientation

involved, even during the winter months and when at the design flows in 2024, and

while there might be some impact, it is unlikely that there would be a significant visual

impact on Ardbraccan House.

During his closing submission Mr. Casey suggested that the width available for planting

at the top of the embankment bewtwen chn. 48700 and 49200 be checked, as he

considered there was insufficient width in the landtake to provide for the motorway and

the planting widths given by Mr. Burns. From scaling the relevant drawings I am satisfied

that there are planting widths of 10 to 13 metres available at the top of the embankment

generally between chn 48700 and 48950 and widths of 8 to 10 metres from chn. 48950 to

49200, and that there is adequate width available within the Motorway Order landtake to

accommodate the road as designed and the landscaping proposed and shown on Drawing

OH 5044 003.

Due to the relative orientation of the Durhamstown Road and Ardbraccan House it is

doubtful that there would be a light spillage impact on Ardbraccan House from east

bound traffic crossing the Durhamstown Overbridge --- as the composite drawing

indicates that headlight beams would tend to impact to the north of the House --- until the

975

screen planting matured there could be a justification for some timber screening to be

installed within the planted area to act as a screen for any light spillage that might be of

concern. This would also provide screening against possible views of traffic while the

planting was maturing. Screening of 1.8 metres in height from about chn. 300 to about

700 on the Durhamstown Road and from about chn. 49400 to the south face of the

Durhasmstown Overbridge on the motorway should be adequate for that purpose.

Arising from the concerns expressed about light spillage from the south bound

cariageway of the motorway impacting on the northwest facing elevation of Ardbraccan

House as light beams from vehicles traversed the curve between the White Quarry area

and the Durhamstown Road crossing, Mr. Evans prepared a drawing and vertical

alignment profile of this section of the motorway which he handed in to the Hearing on

Day 27, as listed in Appendix 4 of this Report. This drawing shows that it would only be

while southbound vehicles were traversing the motorway between chns. 60400 to 61000

that their light beams could impact across the NW facing elevation. It should be noted

that at this location the motorway is about 1km. from Ardbraccan House. During the

Hearing a number of photographs showing a light shining through the trees at night were

submitted by Mr. Casey, see Section 134 of this report and documents listed at Day 27.

These purported to show the impact of traffic headlights on Ardbraccan House at night

and were taken in the vicinity, and to the south, of the White Quarry. The photographer

indicated that he was trying to replicate light impacts from the Toll Plaza area rather than

from the motorway near the White Quarry area.

During his closing submission Mr. Casey questioned the efficacy of screen planting and

timber screening against tangential light spillage from traffic on the motorway and

suggested that 8 to 10 metre high trees would be needed to divert the flash of headlights

from Ardbraccan House, see page 887of this Report. Unless they are very much out of

focus, headlight beams from modern vehicles are directed towards the road surface and,

as can be seen on the Newbridge By-pass ( also referred to by Mr. Casey ), the central

median anti-dazzle planting of about 1.2 to 1.5 metres in height there at present provides

a reasonable screening effect for the headlight beams of vehicles travelling in opposing

carriageways. While the motorway vertical alignment rises as it approaches the

Durhamstown Road and Ardbraccan area from chn. 60850 near the the White Quarry

area, it does not follow as Mr. Casey implied, that the light beams would require screens

of 8 to 10 metres to protect the façade of Ardbraccan House from being impacted.

The installation of 1.8 metre high timber screens along and within the planted area to the

east of the south-bound carriageway from about chn. 60250 to 61250 should, in my

opinion, prevent the possibility of most vehicle light beams, except the high mounted

lights on some HGVs, from impacting on the northwest facing elevation of Ardbraccan

House, particularly at the distance involved between the critical area and the House.

There had been some concerns expressed in submissions from Ardbraccan about light

spillages from the Toll Plaza at Grange but the screening proposed and the use of fully

cut-off lanterns there should minimise the risk of spillage to the immediate vicinity of the

Plaza. Mr. Casey had drawn attention to the level of the Toll Plaza being about the same

976

as that of the upper floors of Ardbraccan House and suggested the lighting would be

visible from the windows on the upper floors. However the distance between Ardbraccan

House and the Toll Plaza of 2.149 kms makes this rather remote and the most that would

be likely to be seen is a distant light not unlike that typically seen in the rural countryside

of an outside light of 150/200 watts. A comparison can be drawn between the likely

impact at Ardbraccan House from the Toll Plaza lighting and impact that can be seen of

the Public Lighting at the northern end of Urlingford on the N8 when standing at the

southern end of the Public Lighting in Johnstown, the next lighted area norrth of

Urlingford. The distance between both sets of lights is 2 kms and there is a clear line of

sight southwards from Johnstown. On a November night at about 9.30pm the Urlingford

lighting, which is not fully cut-off, is relatively insignificant and unlikely to be very

noticeable through branches of trees. In my opinion the lighting impact from the Toll

Plaza on Ardbraccan House would not be a significant impact.

Having taken into account the various submissions made to An Bord relating to

landscape and visual aspects of the Road Development, the details in the EIS, the

evidence given by the Council at the Hearing and the issues raised in their crossexamination,

I consider that with the addition of the "Advance Planting" proposals and

the Revised Vertical alignments outlined above the impacts of the proposed Road

Development on the Landscape and Visual aspects of the environment could be mitigated

to leave no significant adverse impact when the landscaping has become established.

In the vicinity of Ardbraccan House some timber screening not less than 1.8 metres in

height should be installed in a number of specific locations to assist in providing

mitigation until the screen planting has become fully established. This may need to be

maintained in position along the off-side of the south-bound carriageway, after the

planting has matured, to provide a visual screen against light spillage towards Ardbraccan

House from vehicles on the south bound carriageway at night.

Both the River Boyne Bridge and the Ardsallagh Road Bridge are more than 100

metres in length and the environmental effects were specifically considered as required

by the Roads Act 1993, as amended. Details of this consideration are given at pages 7 &

8 in Vol. 4A of the EIS for the Ardsallagh Overbridge and at pages 9 to 11 for the Boyne

River Bridge. Both Mr Guthrie in Section 50.1 and Mr. Sheehy in Section 52.1 of this

Report expanded on the design considerations followed, which were influenced by

headroom requirements and visual impacts in the case of the Ardsallagh Overbridge.

In the case of the River Boyne crossing, the design considerations followed were

influenced by the need for compatibility with the nearby Bellinter Bridge, a stone arched

bridge which is in an area described as a listed view VP 28c in the Development Plan; the

need to minimise interference with river flow fishing and amenity activities on the river

banks; have adequate capacity for river flood flows and allow for possible future

navigation. The Design Option identified in the EIS for both bridges is that of a Multi-

Span Girder Bridge and a specimen design concept or profile for both Bridges is given in

Vol. 4B of the EIS at Drawings 4B/ 9.1 and 4B / 9.2 for the Boyne Bridge and 4B/ 9.3 for

the Ardsallagh Overbridge. A Photomontage of the elevation of the Boyne Bridge is

977

given at Drawing 4B/9.4 in Vol.4B of the EIS which shows the main central span

supported on piers that are constructed outside of the river channel.

The visual appearance of the Boyne Bridge was the subject of much of Mr. Sheehy's

cross-examination, see Section 52 of this Report, and concerns were expressed that the

PPP Contractor might alter the design shown in the EIS. The Council confirmed that,

while the Contractor would be responsible for completing the detailed design and could

offer an alternative concept, if that alternative design did not meet the Council's

requirements it would not be accepted. Arising from some of the queries on this bridge

and from other concerns, the Council were asked to submit the design tolerances within

which a contractor would have to remain by reference to indicative levels shown on the

EIS Drawings, see page 384 in Section 52.6. The Council submitted their proposals for

this request on Day 28 as listed in Appendix 4 of this Report which indicated that no

change in levels that would have a material adverse impact would be permitted.

In his direct evidence in Section 62.1 of this Report, Mr. Burns said that the proposed

motorway route crossed the "River Valleys" zone, VQ 3, where the Boyne was also an

area of "High Natural Beauty " both of these being so listed in the Development Plan. he

considered that the impact at the crossing would be minor in landscape planning terms

since the route passed through strong planting on both sides of the valley and would not

be widely visible beyond the bridge structure. The proposed Boyne Bridge would be

located some 130 metres downstream of the existing Bellinter Bridge and would be seen

mainly from that bridge. The design structure selected of concrete deck slab on steel boxbeams

gives a slim appearance to the construction depth and the flat arch shape should

not be visually obtrusive and would merge with the surrounding landscape. While it

would be of a concrete appearance the flat arch shape would be sympathetic to the

existing Bellinter Bridge and should not detract from that bridge.

The Ardsallagh Overbridge would carry the Ardsallagh road across the motorway, which

would be in a cutting at that point and the Multi-Span Box Girder Bridge proposed for

that crossing would have a similar apearance to that of the proposed Boyne Bridge. I

consider that there would be no appreciable adverse visual impact from either of the

bridges proposed for the Boyne crossing or the Ardsallagh overbridges on the basis of the

details provided in the EIS at Vols. 4A and 4B.

The proposed Kilcarn Link Road would jopin the existing N3 at a new roundabout

located some 120 metres north of where the R161 joins the N3.This is about 100 metres

away from the "Old" Kilcarn Bridge which is still in place and the proposed new

roundabout junction will have no effect on the "Old" Kilcarn Bridge.

Drainage and Flooding issues :

The design of the road drainage system and the capacity of culverts and attenuation ponds

to deal with storm run-off and the potential for pollution of watercourses were raised in a

number of submissions and these issues were generally clarified in the Council's evidence

to the Hearing on Drainage and in the cross-examination of Council witnesses, see

978

Sections 35, 59,& 95 in this Report. Evidence was given that the design criteria for

culverts and bridges had been discussed and agreed with the Eastern Regional Fisheries

Board (ERFB), with a letter from them being handed in to the Hearing on Day 10, as

listed in Appendix 4 of this Report, which indicated that the ERFB had no basic objection

to the proposed road drainage details. I consider that the design criteria used for storm

run-off calculations of a return period of 1 in 10 years, with 1 in 100 years being used

where houses were adjacent or where there weree historical flooding situations and the

use of minimum pipe sizes of 900 mm acceptable and adequate for mitigation purposes.

The possibility of flooding at the Newtown Bridge area of Dunboyne was raised by the

Newtown Bridge Residents Association and by local residents in their submission to An

Bord and in further submissions to the Hearing. Concerns about flooding from the effects

of the motorway crossing of the River Skane at Dowdstown were also raised by Ms.

Bradley and the Farrellys in their submissions to An Bord and in further submissions to

the Hearing. During the Hearing the Council met with the Newtown Bridge Residents

and agreed to increase the size of the culvert crossing under the R 156 at Newtown

Bridge to 9.9 sq. metres, which is almost a 100% increase on their initial proposal. This

should be adequate to prevent a worsening of the flooding that has occurred in recent

years at the Newtown Bridge locality and the Residents Association were satisfied with

the Council's response. Further severe flooding occurred in the locality in November

2002 which should provide useful data for the final design of the culvert at Newtown

Bridge. In the case of the River Skane at Dowdstown, the Council carried out a further

study of the river catchment upstream of the proposed crossing and submitted their

findings to the Hearing on Day 28, as listed in Appendix 4 of this Report. While this

Study concluded that the proposed crossing would not worsen the existing flood flows,

the Council undertook to provide a number of "overflow" pipes through the overbridge

and motorway embankments which would prevent a build-up of water in a river flood

situation near the houses of Ms Bradley and the Farrellys. Concerns about flooding of

their lands from attenuation poinds being constructed adjacent to their retained lands

were expressed by M/s McDonnell and Roche, Plots 352, 353 & 470, see section 47.2

and 48.3. Having regard to the evidence on Drainage and responses given by the Council

I am satisfied that adequate precautions are proposed in the EIS to prevent this from

occuring.

Flora and Fauna :

The impacts of the construction of culverts and bridges on the Habitats of the protected

species listed at Annex 11 of the Habitats Directive ( Lamprey, White Clawed Crayfish

& Fresh Water Pearl Mussel ) and on spawning grounds was raised by M/s O'Donnell

and Sweetman in respect of crossings of the River Skane near Dowdstown, the Boyne

crossing at Ardsallagh and on crossings of the River Kells Blackwater and its tributaries

in the Navan to Kells to North of Kells sections. The Council gave evidence that

"bottomless" culverts would be used when crossing small rivers and streams such as the

Skane, as they had agreed with the ERFB, which would mean that construction work

would not be impacting on the stream or river bed which avoided the risk of damage to

the habitat. In the case of the larger crossings, such as the River Boyne crossing at

979

Ardsallagh and the River Kells Blackwater crossings, no piers wopuld be constructed in

the river channels which, again, would avoid impacting on the habitats.

In their letter to An Bord of 22 April 2002 Duchas drew attention to the Rivers Boyne

and Blackwater now being proposed candidate Special Areas of Conservation

(pSAC). Duchas also stated that both rivers were already designated as Salmonid rivers

and listed in Annex 11 of the Habitats Directive with any construction work on them to

be carried out in consultation with the ERFB. The EIS had referred to the salmonid status

and, as required, the ERFB had been consulted about the construction work requirements

in that regard and the proposed design of bridges and culverts had been prepared to meet

the requirements of the ERFB, with bottomless culverts being used on tributaries and the

piers for bridge crossings of both Boyne and Blackwater rivers being kept clear of trhe

river channels. Duchas also set out some mitigation measures that are additional to those

specified in the EIS relating to tree felling, hedgerow cutting, bat protection and mammal

passes. These mitigation measures are similar to measures also proposed by the Council

in evidence given to the Hearing, see Sections 34.2, 57 & 110.

As can be seen from the cross-examination of Mr. Nairn in Sections 57.7 & 57.8 this

letter from Duchas did not come to the Council's notice until the later part of August and

was not addressed specifically in the evidence given for the Council in the Dunshaughlin

to Navan Section. In evidence subsequently on the Navan to Kells to North of Kells

Sections, the Council referred to the letter from Duchas and stated that as the river

crossings did not have any piers within the river channel, there would not be any dircet

impact on the area for which the proposed candidate SAC was being considered. In

subsequent cross-examination of Mr. Nairn, Mr. Sweetman maintained that these pSACs

were Natura 2000 sites and that the requirements of Article 6 of the Habitats Directive for

Natura 2000 sites required that the mitigation measures be fully given in the EIS and that

in the absence of this they could not be assessed and also that the consent of the

Commission was required before approval could be given as the proposal affected a

Natura 2000 site

On Day 28 the Council handed in two documents that referred to these issues, both being

listed at Appendix 4 of this Report. In one the Council set out mitigation proposals for

treating and controlling discharges during the construction of the M3 Boyne Bridge

across the River Boyne at Ardsallagh which arose principally from queries raised in

cross-examination in Sections 50 and 52. The second document followed from Mr.

Sweetman's cross-examination of Mr. Nairn in Section 110.2 and was a note from Mr.

Nairn on the status of the pSACs and followed from his further contacts with Duchas.

I have read the detailed methodology outlined in Annex 111 of the Booklet on Managing

Natura 2000 Sites and the provisions of Article 6 of Directive 92/43/EC, the Habitats

Directive ( handed in by Mr. Sweetman to the Hearing on Day 24 as listed in Appendix 4

of this report), from which it is clear that where the proposal is not likely to have

significant effects on the Natura 2000 site, then authorisation can be granted by the

competent authority without further reference to the Commission. Having regard to the

evidence given by the Council to the fact of no piers being constructed within the

980

channels of either the Boyne or Blackwater Rivers and of the other precautions that

would be put in place while construction work was in progress on these bridge crossings,

I am satisfied that no direct impact or likely significant effect would occur to these

Natura 2000 sites and that approval could then be given to the proposed works by An

Bord as the relevant competent authority.

As an added precaution I would suggest that no construction compound for storing

machinery or fuel oils be located within 200 metres of either the main river or tributaties

of the River Boyne or Blackwater. I also consider that the Council should consult with

Duchas about the proposed Bridge crossings of the pSACs before any construction

contract is awarded and that any requirements of Duchas be incorporated into the

conditions of contract.

The Meath/Cavan Branch of the Bat Conservation Group made a submission to An Bord

that the Bat survey in the EIS was inadequate as it did not cover the entire length of the

road. No representative of this branch or group attended at the Hearing but it is clear from

the evidence given that Bat surveys were undertaken at various locations where there

were either suitable conditions or local evidence of Bats. I am satisfied that extent of the

surveys carried out along the route between Clonee and Derver were adequate to meet the

requirements of the Wildlife Act and Habitats Directive. Several of the Duchas

recommended mitigation measures apply to bats.

Archaeological Issues :

The impacts on Archaeology were raised mainly in the Dunshaughlin to Navan section

where the possible impact of the motorway on the archaeological landscape associated

with the Hills of Tara and Skreen were the subject of many of the submissions both to An

Bord and at the Hearing from objectors in that locality. There were some concerns

expressed about the effects of movement of routes for the Dunboyne By-pass R 157 (on

the Henshaw property, Plot 326) and for the R125 Link at Dunshaughlin ( on the Kieran

property, Plot 172) but these were clarified in cross-examination of the Council's

witnesses. Some queries about the Nugentstown site near Kells were raised at the Hearing

by Mr. Sweetman relating to the use of geophysical prospecting there and why no further

site investigations had, as yet, been carried out on that site which is adjacent to but clear

of the route. Ms Deery for the Council had replied that site investigations would be done

in advance of construction. While there had been some references to archaeological sites

in submissions made prior to the Hearing from the Ardbraccan area, these were not

subsequently pursued at the Hearing.

Ms Gowan, who was the Council's Archaeological Consultant for the Dunshaughlin to

Navan section in the EIS, gave evidence that the proposed route passed between the Hills

of Tara and of Skreen on the eastern side of the valley floor and sought to avoid the

important core zone around Tara with the route being some 1.5 kms. east of the limit of

the designated area and also east of the existing N3. She said that the route had succeeded

in avoiding all standing ( above ground) archaeological sites, it had sought to avoid all

981

known sites and sought to minimise the physical and visual impacts on the archaeological

landscapearound Tara. Ms Gowan referred to the geophysical survey that had been

carried out by the Council (detailed in Vol. 4C of the EIS) which provided them with a

good understanding of what might be located when excavation work commenced and

said that there were 5 areas identified by that survey which would be directly affected by

the road, one of which -- Area 19-- lies between Tara and Skreen, see Section 61 of this

Report.

Ms Gowan was subjected to strong cross-examination by Mr. O'Donnell and Mr.

Sweetman as well as cross-examination by the Bellinter Residents Association (BRA)

and the Meath Road Action Group (MRAG), much of which centered on the comments

she had made in the route selection process when a route to the east of Skreen was said to

be more suitable from an archaeological perspective. When Mr. O'Donnell suggested that

the proposed motorway route would have a profound effect on one of the most famous

archaeological complexes in the world, Ms Gowan disagreed and said the route would

not have a profound effect on the complex of the Hill of Tara since the chosen route

alignment was 1.5 kms from the outer edge of the designated zone of Tara as a complex

of monuments and not just one monument. In response to cross-examination by Mr. Park

of the BRA Ms Gowan pointed to the archaeological study having formed a strong input

to the engineering design of the route, a point which had been the cause of some concerns

expressed by other objectors who found the initial route had been moved closer to their

property as a consequence of the avoidance of sites of potential archaeological interest.

A detailed submission was made to the Hearing by Ms Clancy of the Meath

Archaelogical and Historical Society which had five parts to their section on cultural

heritage, se Section 81 of this Report. Their five concerns were:- the M3 traversing an

archaelogically sensitive landscape; the lack of a fullscale investigation of each

alternative route considered; that "cultural heritage" should extend to much more than

archaeologoy and buildings and include folklore, local history, old field names etc etc;

that the non-technical summary was very short with no details of what would be done if

more discoveries canme to light during construction and they questioned why a route

bewtween Tara and Skreen was being chosen. She also had some suggestions to make

about changes that should be made to the EIA procedure to give a greater role in this for

voluntary groups to participate.

A submission was made by Mr. Lumley for An Taisce, see Section 80 of this Report, in

which he referred to the aims of the Valletta Convention of 1992 as a means of protecting

the archaeological heritage and referred to what he saw a fundamental flaw in the way

archaeology was being dealt with on major projects in Ireland and not only on road

projects and pointed to the need for the broader archaeological landscape to be

considered and not just confined to the immediate vicinity of the proposed development

site. Mr. Lumley also referred to the Carrickmines issue as an example of what could

occur where inadequate proper on-site assessment procedures were not followed and he

criticised the absence of a representative of Duchas at the Hearing.

982

Mr. Conor Newman, the former Director of the Discovery Program who had made a

submission to An Bord also made a submission to the Hearing, see Section 82 of this

Report, in which he expressed his concerns about the impact of the motorway on the

archaeological and historical landscape of the Hill of Tara, and he criticised the absence

of the geophysical images from the EIS saying that the interpretative drawings without

the images compromised the archaeological analysis and assessment of the EIS. He

suggested that "resolving" archaeological sites that were found to be in the way of

"development" was a current expediency and said that the imperative began with

preservation and not just in excavating sites, and that in considering the archaeological

landscape of Tara the point of convergence between moral and cultural imperatives had

been reached that required Tara to be preserved.

In their submission to An Bord of 22 April 2002 Duchas said they agreed with the

recommendations for mitigating impacts on archaeology set out in Volumes 3 to 7, both

A & C, of the EIS and recommended that pre-construction archaeological investigations

where recommended in the EIS should be carried out as early as possible. They made a

number of recommendations from an underwater archaeological perspective almost al of

which were already included in the EIS or in the Council's Archaeology direct evidence.

These comments by Duchas support the comments made by the Councils archaeologists

that the route proposed had the support of Duchas and while documents submitted by the

BRA from the Ombudsmans Office ( see Day 17 at Appendix 4 of this Report and

Section 70) might suggest that Duchas saw the Pink route as the preferred route at one

time, the references to both A & C volumes of the EIS in the letter of 22/04/02 discounts,

in my opinion, that suggestion by the BRA.

In the evidence presented by the Council and in the submissions made by Ms Clancy and

Mr. Newman there are references to the rich archaeological landscape in Co. Meath and

to the numerous finds in recent major projects that involve excavation, the M1 and Gas

pipelie projects being recent examples. It is common case that any route for a major road

across Co. Meath will inevitably result in some previously unknown archaeological sites.

The Council contend that by their investigations and, particularly, by the use of

geopophysical prospecting surveying they have sufficiently identified the potential for

underground archaelogical remains to be able to avoid a substantial number in the route

alignment now proposed. They also contend that the information gained would, as Ms

Gowan said, mean a greatly reduced risk of unexpected negative impact on unknown

archaeological sites. Essentially the objectors case is that a different route to the east of

Skreen should have been selected for the Section between Dunshaughlin and Navan and

that would have "removed" the potential impact from the Hill of Tara archaeological

landscape. In this regard it has to be noted that no similar geophysical survey was carried

out on a potential route to the east of Skreen so that an exact comparison of "apples with

apples " can not be drawn.

The proposed route between Dunshaughlin and Navan would impact directly on five sites

of archaeological potential, all of which were identified by the geophysical survey, three

of these-- Areas 26, 28 & 29-- are at the Gerrardstown Stud/ Roestown area, one -- Area

19-- lies between Tara and Skreen near Baronstown and the other site -- Area 4-- is in

983

Dowdstown. The route lies to the east of the existing N3 and is some 1.5 kms from the

Hill of Tara Record of Monuments and Places (RMP) " core zone" as shown on the map

SK 500 handed in by Ms Gowan on Day 17 during her cross-examination by the BRA.

At the Blundelstown Interchange the route is some 1.1 kms from that core zone. While

the proposed route comes close to the site known as Rath Lugh which is close to its

eastern edge, Ms Gowan said that they had avoided impacting directly on that site by

careful selection of the route. Mr. Lumley referred to the potential impact on a site at

Lismullin, which appears to be the site for which an adjustment was made to the route, as

described in Section 1.2 of Vol. 4A of the EIS where some changes to the geometric

design as mitigation measures are listed.

Having regard to all of the evidence given at the Hearing and the cross-examination on

the archaeology impacts in the Tara / Skreen area presented at the Hearing and to the

details set out in the EIS, I am satisfied that the route as proposed would not have a

significant impact on the archaelogical landscape associated with the Hill of Tara, as

indicated by the area designated as the core zone on the RMP Map SK 500. I also

consider that the route proposed will not impact significantly on the archeaological

landscape associated with the Hill of Skreen.

In the submisssions by Ms Clancy of the Meath Archaeological & Historical Society, that

of the Dunboyne Historical Society and in one of Mr. Laurence Ward's submissions it

was suggested that there should be a record made of features of interset such as local

place names, old field and road names, trees and bushes that were part of local or

traditional customs and similar items of local folklore or local customs, all of which

formed part of the cultural heritage and which would be lost when the road excavation

commenced. Having regard to the extent of the proposed road development across almost

the entire length of County Meath, it seems reasonable that a "local cultural heritage

survey" would be undertaken as a part of the preparatory work for the motorway scheme.

It should be possible to complete such a survey in a 9 to 12 month period which could be

undertaken under the direction of the Project Archaelogist, in consultation with those

who made the suggestion.

A number of references were made to the Carrickmines archaeology issue which was ongoing

during the early part of the Hearing and the Council were asked for their

suggestions on how they would deal with an unexpected " Carrickmines" type of

discovery being made. Towards the end of the Hearing the Council handed in their

response, which is listed at Day 25 in Appendix 4 of this Report. In this the Council

pointed to the Code of Practice agreed between the NRA, on behalf of itself and Local

Authorities, and Duchas and to the appointment of a Project Archaeologist and to the

undertaking given during the Hearing in response to a query by Ms Clancy that sufficient

funds and time would be allocated for thorough archaeological investigatrion before any

construction work commenced. The Council indicated that contracts for test excavation

would shortly be awarded and that groundwork for the next stage of archaeological

investigation would commence before the end of 2002. The Council said that this early

investigation strategy, with further geophysical surveying and test excavation, would

984

allow for early mitigation of impacts on any existing archaeology in advance of

construction.

I am satisfied from the evidence presented at the Hearing that the archaelogical impacts

from the proposed Motorway Scheme have been adequately identified in the EIS and that

appropriate mitigation measures have also been identified which would minimise these

impacts.

Architectural Heritage issues :

The items of the Architectural Heritage as described in the EIS were queried by Duchas

in their submission to an Bord of 25 April 2002 when these were said to have been a far

too restrive interpretation of the term " architectural heritage". Duchas specifically

referred to the items put forward in Vols. 3A to 6A as being only concerned with

"country houses" and listed a number of items such as vernacular structures, industrial

heritage items, demesne grounds including walls & gates and structures from the latter

part of the 19th and all of the 20th century that they said should have been included.

Duchas indicated that the content of Vol. 7A met the wider range they sought and

suggested the architectural heritage section needed to be reviewed. When the Council's

evidence on architectural heritage was being given for the Clonee to Dunshaughlin

Section, see Section 37.3 of this report, I asked the Council to respond to the letter from

Duchas and their response is detailed in Sections 60.1& 60.2 of this Report which

followed from a review of the matters raised by Duchas. The Council's responses were

handed in on Day 11, as listed in Appendix 4 of this Report.

In their response the Council referred to the details given in Vol. 3C of 20th century

houses and farmhouses including a vernacular structure; in Vol. 4C of late 19th and 20th

century houses, cornmills as industrial heritage, farm structures and demesne grounds; in

Vol. 5C houses appearing to be of 19th century origin and bridges; in Vol. 6C demesnes

and a late 19th century house and in Vol. 7C 19th century structures, late 19th century

houses , a schoolhouse and a railway bridge. The Council suggested that the references to

the"A" volumes indicated Duchas might have based their comments on these which gave

a summarised version of the full report that was given in the "C" volumes and said that,

having reviewed the EIS, they were not aware of the proposed road impacting on any

other architectural heritage along the Route. Mr. O'Sullivan who made the reports on the

architectural heritage in Vols. 3 to 5 gave examples of what he had listed as items of

architectural heritage along and reasonably adjacent to the route and said he reported on

what he had found, but could not report on what was not there to be impacted upon. Mr.

O'Sullivan commented that as the Inventory of National Heritage for Co. Meath had not

yet been prepared by Duchas, to an extent people were "working in the dark" as to what

the intentions of Duchas were.

No representative from Duchas attended at the Hearing so there was no opportunity for

any direct clarification between the Council and Duchas on the issues raised in the letter

of 25 April. The introduction to Section 14 in the A Volume of the EIS on Buildings of

Architectural, Artistic, Cultural or Historic Interest clearly refers to original reports being

985

presented in the C Volume in each volume of the EIS, but the Duchas letter of 25 April

on this issue only refers to the A volumes, whereas for the Archaeology submission the

Duchas letter of 22 April refers to both A and C volumes. No evidence was offered at the

Hearing by any objector that a building or structure of Architectural, Artistic, Cultural or

Historic Interest would be impacted and had not been so mentioned in the EIS nor did I

note in my site inspection any vernacular structure that should have been referred to in

the EIS and which was not included.

In the light of the Council's response to the Duchas letter of 25 April and in the absence

of any follow up by Duchas on this issue at the Hearing, I consider that the impact of the

proposed road development on the architectural heritage, within the definition as set out

in the Act of 1999, was adequately described in the EIS.

Mr. Lumley of An Taisce referred to the terms of the Granada Convention of 1985 being

put in place in Ireland by the Planning and Development Act of 1999 and then subsumed

into the Planning and Development Act of 2000 and was critical of the function for

scheduling buildings and sites as protected structures being devolved to local authorities.

He criticised the lack of action by Meath County Council in what he said was their failure

to have an adequate list of protected structures in their functional area.

Since the proposed route does not impact directly on any building of architectural

heritage, except for the old schoolhouse at Woodpole Cross, almost all of the crossexamination,

conducted mainly by M/s O'Donnell, Casey and Sweetman, related to the

possible effects on the settings or attendant grounds of Demesne Houses or those of

similar standing. As was pointed out by Mr. O'Sullivan in his cross-examination, the

curtilage or the attendant grounds had not yet been determined by the Planning Authority

for the various buildings he surveyed and that he had taken the curtilage as being the land

within the ownership of the house. This interpretation was disputed by those crossexamining

Mr. O'Sullivan, who maintained that it was not for him to define the curtilage,

and that he had made reports on whatever he had considered would impact on the setting

of the structure.

The extent of the Demesne attached to Ardbraccan House was debated between M/s

Casey for the owners of Ardbraccan House and Mr O'Sullivan for the Council, see

Section 131 of this Report. As part of the documents handed in by the Council on Day

20, as listed in Appendix 4 of this Report, there is a map of the Ardbraccan House area in

the Book of Additional Drawings which was originally prepared for the Judicial Review

Application. This Map, 009-001-ORAL-ARD, shows (a) the boundary of the Mahers

property, (b) the boundary of the Demesne of Ardbraccan and (c) the boundary of

Ardbraccan Estate and while the Estate extends to the townland boundary on the western

side of the proposed Motorway, the demense boundary is shown remaining on the eastern

side of the Motorway and some 248 metres from the Motorway at its nearest point. It

should be noted that the land between the motorway and the demesne boundary (Plots

2209 & 2214) have been purchased by the Mahers since the publication of the Motorway

Order but that is not relevant to the issue of impact on the demesne.

986

In his report on Ardbraccan House in Vol. 5C of the EIS, Mr. O'Sullivan dealt

extensively with the history and evolution of Ardbraccan House in sections 5 & 6 in

Appendix I and concluded at 7.1 that the setting of Ardbraccan House is the area of the

demesne as defined in the 1836 OS Map. This would correspond with the boundary of the

demesne as shown on the Map referred to in the previous paragraph.

In a report submitted to the Hearing by Mr. Casey as a Brief of Evidence of Mr. Terence

Reeves Smyth, see Section 142.2 of this Report, Mr. Smyth, while agreeing that Mr.

O'Sullivan's report on Ardbraccan House was very good, suggested that non-inclusion of

the area to the west of the local road was a draftsmans error in the map of 1836.

Acccording to Mr. Smyth the fact of that area being shown as "stippled" in the 1836 "fair

plan" and that it was held "in fee" in the Griffith valuation supports his opinion. However

Mr. O'Sullivan in his report in Vol. 5C had referred to this 1836 "fair plan" as not being

the "officially published Ordnance Survey Map" and he had also investigated the Griffith

valuation list and came to his opinion after referring to both of the matters mentioned in

Mr. Smyth's Brief of Evidence.

As detailed in Section 137 of this Report, Mr. Smyth was one of several witnesses

advised to the Hearing by Mr. Casey as likely to be giving evidence on behalf of the

owners of Ardbraccan House and whose Briefs of Evidence were handed in on Day 26,

as listed in Appendix 4 of this Report. However Mr. Smyth did not appear at the Hearing

and, as in the case of the Duchas letter of 25 April on the items of architectural heritage,

the differences in opinions between that of Mr. O'Sullivan and Mr. Smyth on the issue of

the extent of the "stippling" on the 1836 OS Map could not then be directly clarified.

Having regard to the detailed researches undertaken by Mr.O'Sullivan as set out in Vol.

5C, that he was cross-examined on this by Mr. Casey and the fact of the 1836 "fair plan"

not being the official OS Map, I consider that Mr. O'Sullivans interpretation of the extent

of the historical demesne of Ardbraccan is more likely to be correct. When pressed by

Mr. Casey on the likely impact on the setting of Ardbracccan House, Mr. O'Sullivan said

that he would not go so far as to say there would be a major impact and that he

considered the impact on the setting could be ameliorated by landscaping measures.

Having regard to the evidence in the EIS and that given to the Hearing, the crossexamination

of the Council's witnesses and the various documents submitted by both the

Council and the objectors, and as the proposed road development is 248 metres distant

from the boundary of the demesne at its nearest point, I consider that, while there would

be some impact on the setting, the impact would not be a significant one and I am also

satisfied that the impact could be mitigated by the landscaping and noise mitigation

measures proposed and as referred to previously in my comments.

As referred to at the seventh paragraph above, the route as proposed impacted directly on

an old schoolhouse at Woodpole Cross, north of Kells. In the EIS this is described at page

170 & 173 and shown in Plate 14.3 in Vol.7A and while it is in poor condition, it forms

part of a group of old vernacular buildings with the other buildings not being impacted.

Following a query I made about the possibility of the schoolhouse being "preserved", see

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Section 106.3 of this Report, the Council confirmed that as the schoolhouse was in the

side of the road embankment it would be possible to retain it intact by constructing a

retaining wall around it, see Report handed in on Day 24 as listed in Appendix 4 of this

Report. Since this building is included in the Motorway Order I consider that the building

could be protected by the construction of a retaining wall as shown on the Drawing

submitted, and that provided it is in a structural condition that allows for its rehabilitation,

it could be preserved by the Council as an example of a vernacular building and possibly

used as a local museum or resource centre in conjunction with the local Community

Council as part of the community facilities, as a socio-economic mitigation mesasure.

There is provision in the 1991 Local Government Act for the provision of assistance by

Local Authorities to "approved bodies"

Mr. Lumley referred to Baronstown and Lismullin Houses in his submission and Mr.

O'Donnell also referred to Lismullin, to Ardsallagh and to Dowdstown Houses. I am

satisfied that the settings of these houses would not be significantly affected by the

proposed road development and that the mitigation measures proposed in the EIS, as they

affect these houses, are adequate to protect their amenities.

Rail Link to Navan :

The proposal to re-open the disused railway line from Clonsilla to Navan, as referred to

as an Public Transport objective in the 2001 County Development Plan and in the SPGs

was referred to in a number of submissions and objections and the point was made that

the development of a rail link between Navan and Dublin should be promoted instead of

the development of a motorway. This suggestion does not take account of the strategies

identified in the National Development Plan at 4.9, 4.10 and 4.12 and the fact of the N3

being a link to regions beyond Navan and outside of Co. Meath. There is also the issue of

a feasibilty study having been identified in the Development Plan as being a necessary

first step in the provision of this rail link and, as I understand the position, such a study

has not yet been completed.

The Council gave evidence that the route selected for the proposed road development

had, insofar as it was practical to do so, maintained a corridor along the disused rail line.

Arising from concerns expressed, mainly by the BRA and MRAG representatives, I

asked that a set of Maps be submitted which showed the interface between the proposed

M3 and the railway corridor and this Book of Maps was handed in on Day 25, as listed in

Appendix 4 of this Report. This shows the provisions that have been made for a future

railway alignment but it has been necessary in some sections to incorporate sections of

the disused rail line where it was necessary to adjust the proposed road alignment due to

environmental factors. Evidence was given that Iarnrod Eireann had accepted the need

for these " incursions" to be made and that an amended rail corridor would have to be

acquired in those areas, when the time comes.

The issue of the crossing of the motorway and Railway line at Cannistown was raised

by a number of residents in that locality. At present the proposal is for the future rail line

to be carried over the motorway, see documents of minutes of meetings with Iarnrod

988

Eireann handed in on Day 17, as listed in Appendix 4 of this Report. Arising from

concerns expressed about the impact on adjoining houses with the extent of embankments

required to carry the rail line over the motorway, I asked that the Council examine the

possibility of providing a "false bridge" in the road embankment which would allow a

future rail line to be taken under the motorway without a major disruption to road traffic.

The Council submitted a Report on this request on Day 28, as listed at Appendix 4 of this

Report, which indicates that it would be feasible to provide such a bridge structure as an

underbridge option for a future re-opened rail line. There are a number of drainage issues

involved with such an arrangement and these might require a permanent pumping

solution which Iarnrod Eireann might not be pleased to accept as a maintenance cost.

However, there could be environmental costs with a rail-line carried over the motorway

which could outweigh the pumping costs associated with an underbridge option.

Since this underbridge option could only be realistically considered if it was constructed

as part of the proposed road development, and is likely to cost up to € 1M to construct

based on costs of other underbridges given to the Hearing, the constraints imposed by

adjacent houses and the visual impacts created by an overbridge rail line at Cannisrtown

would, in my opinion, justify the construction of such an underbridge as part of the

proposed road development, having regard to the public transport objectives in the

County Development Plan. However it would not be necessary for all of the underbridge

to be completed as part of the Road Development. By the use of piles or similar

construction techniques only the part of the walls "above ground" and the deck slab

would need to be constructed, with the completion being left to a future date when a

decision on the rail link would be taken. This would allow for the underbridge to be

completed without much disruption to traffic using the motorway overhead and for

issues of drainage etc to be fully investigated. The provision of an "above ground shell"

would provide for the underbridge option to be realistically considered and the cost,

which should be less than the € 1M completion estimate quoted above, would be justified

by the potential environmental benefits which could result from such a provision.

As noted in my comments on the Motorway Order and Proposed Road Development at

the end of the Hearing there were some 195 objections that had not been withdrawn and

76 submissions had been made about the proposed M3 scheme, with many of these

coming from groups of people who had common concerns. The Council issued responses

to each objection and submission received by An Bord and I have commented on these

responses in Sections 49, 85, 101 & 120 of this Report. In my comments in this Section

of the Report on the Motorway Order and Proposed Road Development many of the

issues raised in the objections and submissions have been dealt with either in general

comments like that on the revised Noise criterion and general construction effects, or

specifically as in the case of the shared underpasses or flooding concerns at Dowdstown/

& Newtown Bridge. All of the 34 objectors listed at Group 1 had an opportunity to get

clarification at least to their concerns and the Council issued supplementary responses to

those 30 listed at Group 2 and 29 of those who made submissions to the EIS also had an

opportunity for clarification. I consider that having regard to the number of objections

and submissions not formally withdrawn and that many, if not most, of the issues raised

989

have been referred to in my comments in this Section of the Report, it is not necessary to

make a specific comment on each individual of the 270 objections and submissions listed.

I have considered all of the objections and submissions received by An Bord prior to the

Hearing, and the responses, including the supplementary responses, made to these by the

Council and where I considered it was required I have then made specific comments. I

have also taken all of those objections and submissions into account when making my

recommendations. Where a specific comment has not been made about any individual

objection or submission, it can be taken that either it has been covered by my general

comments as detailed hereinbefore, or I am in general agreement with the response made

by the Council to that objection or submission.

However there are a number of what could be called "group" submissions where I will

make some further comment and these are in the (1) Leshamstown Lane area; (2)

Raynestown Road area; (3) Bellinter/ Dowdstown and (4) Ardbraccan/ Boyerstown areas.

1. Leshamstown Lane. In general the objections here were about the effects of the

closure of the R125 and about the construction effects on the properties. While not

recommending that the R125 be kept open for the reasons outlined, the provision of a

footpath on both sides of the road would mitigate the effects of additional traffic. The

Councils responses have dealt with the construction effects and the revisions to the

noise criterion and dust and construction noise level controls are additional mitigation

measures.

2. Raynestown Road. In general these objections were to the route selected and to the

effects of the realignment on their properties and their concerns of the beech trees

being affected. The Council's responses clarified the construction effects, at least 65

out of the 87 the beech trees are being retained, there would be replacement planting

and the provision of footpath and cyclepath as a link to the N3 would mitigate traffic

effects on their road.

3. Bellinter/ Dowdstown. In general their objections are set out in the objections of the

Bellinter Residents Association and the Meath Road Action Group that the wrong

route was chosen and to the effects on Tara, Dalgan Park and the Dowdstown/

Bellinter/ Ardsallagh areas as a consequence of this being the wrong route, and that

the route should have gone to the east of Skreen or a combined N2/N3 should be

developed.

4. There is a linkage between these objections and those of the Ardbraccan/

Boyerstown area, since they also supported the MRAG proposal and also said the

wrong route had been selected and that it should have gone north of Navan.

In the Route Selection Report for the Dunshaughlin to Navan Section it is stated that

one, but not the only one, of the factors which influenced the selection of the

preferred route between Tara and Skreen was the decision for the Navan By-pass to

be to the south and west of Navan, since this meant that the eastern options had to be

990

discounted ( See page 144 of the September 2001 Report ) as there would be major

environmental difficulties in connecting a route that was to the east of Skreen with a

by-pass route to the south of Navan. The Navan By-pass Route Selection Report

outlined the reasons which resulted in a route to the south and west of Navan as being

the preferred route there which lead to the route for which the EIS was prepared and

for which Approval has been sought. It should also be noted that a bypass to the south

and west of Navan was shown in the 1994 County Development Plan, even if on a

somewhat different route.

I have already commented that I consider the location of the route between the Hill of

Tara and the Hill of Skreen would not have a significant impact on the archaeological

landscape associated with Tara or with Skreen.

Concerns were raised about the impact of the motorway on Dalgan Park and its

activities and facilities which also form the basis of much of the BRA objections.

Dalgan Park extends to over 500 acres and is in three discrete parts, one largely used

for agricultural activities to the west of the River Skane through which the proposed

motorway would run largely in a cutting; the central part which contains the

buildings, parklands and the greater part of the pathways and the other part, used

entirely for agricultural purposes lies to the east of the existing N3. The Main

buildings in Dalgan Park are some 800 metres from the motorway route with

Dowdstown House being 600 metres distant from it. At these distances there would

be a natural attenuation in noise from the motorway, see Section 108.2, as well as the

mitigating effects from the noise bunds being proposed, while the visual impacts

would be experienced at a distance varying from 600 to 800 metres from those

buildings with most of the paths being more than 200 to 300 metres from the

motorway, see Maps submitted by the Council on Day 28, as listed in Appendix 4 of

this Report.

Having regard to the noise predictions shown on the noise contour maps, the

landscaping proposed for the motorway route and the further depression of the route

in the cutting and the other mitigation measures proposed, I consider that the impact

on the activities and facilities presently being used in Dalgan Park would not be

significant.

As regards the Ardbraccan area, most of the objections were to the noise impacts

and to the effects of the construction on properties there. Having regard to the revised

noise criterion and to the Council's clarification on construction effects and the

general landscaping proposals and the other mitigation measures proposed, I consider

that the impact on the Ardbraccan area by the motorway route would not be

significant.

In the event of An Bord deciding to approve the proposed Road Develoment, and if the

proposed Tolling scheme is approved, during the construction phase the Council should

give consideration to the request made on behalf of Ms. Maher that the Public Right of

Way on Local Road L- 8008-13 be extinguished at its northern end to prevent it being

991

used as a short-cut by traffic which has no local neccesity to use that road. The

provisions of Section 73 of the Roads Act 1993 are available to the Council for that

purpose.

The Council should also consider become a "partner" with the owners of Ardbraccan

House and the Heritage Council in developing a scheme to assist in the replacement of

the specimen trees in the grounds of Ardbraccan House, about which evidence was given

to the Hearing that they are near the end of their life. Mr. O'Sullivan in his report referred

to a possible "Heritage Quality Control" approach advocated by the Heritage Council in a

submission to the National Development Plan 2000-2006. This might form the basis for

developing a tree plantation scheme that could assist in replacing the specimen trees in

the grounds of Ardbraccan House that were referred to at the Hearing and which form

part of its setting.

3. General Conclusions :

I have considered the details outlined in the several documents submitted by the Council

to An Bord, in support of their application for approval to the Motorway Order and

proposed Road Development for the proposed M3 Scheme, as to the likely effects of the

proposed development on the Environment. I have also considered the objections and

submissions made to An Bord in respect of the proposed development

Having regard to the details and conclusions in the EIS and to the submissions made on

the proposed Road Development (EIS) I consider that, on balance, there would not be an

adverse effect on the Environment from the proposed Road Development. Taking into

account the evidence given and the submissions made at the Hearing, I recommend that

the Road Development be modified by the inclusion of the following requirements and I

am satisfied that, with the inclusion of these modifications, the effects on the

Environment from the construction of the M3 Clonee to North of Kells Motorway

Scheme would then be acceptable.

1. Noise :

(a) Modify the Target Noise Level from its present façade level of 68 dB LA10

18hour to 65 dB LA10 18hour for use when predicting future noise levels at

ground floor or upper floor facades as appropriate of noise sensitive residential

properties and in determining the extent, if required, of mitigation measures at

that receptor. --- This will protect the residential amenities of people living

adjacent to the proposed motorway and associated roads.

(b) Amend the noise levels specified for construction noise in Tables 4.9, 4.6, 4.8,

4.12 & 4.11 in Section 4 in Volumes 3A to 7A respectively of the EIS to provide

for a reduction of 5dB LAeq in the limits given for the periods Monday to Friday

0700 to 1900 and for Saturday 0800 to 1630.

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(c) Modify the site Working Hours so that no construction work takes place within

100 metres of any occupied dwelling house before 0700 hours or after 1900 hours

Monday to Friday, before 0800 hours or after 1630 hours on Saturdays and not at

anytime on Sundays or Public Holidays

(d) Provide for inclusion in the Contract Documents of the requirements of both

standards and methodology of BS 5228/1997, Noise and Vibration Control on

construction Open Sites and provide for not less than Six Control Stations as

defined in BS 5228/1997, Four to be used for Noise monitoring and Two for

Vibration monitoring during construction works near sensitive receptors, the

locations and duration to be decided by the Council's nominated Site

Representative. --- These, (a), (b) & (c), will further protect the residential

amenities along the route during the construction period.

(e) Provide for a limit for the allowable Peak Air Over-pressure (Pmax) in all blasting

operations to be undertaken on the M3 scheme of 125dB(L) and 105 dB(L) when

blasting operations are proposed in the vicinity of locations where bloodstock

animals are in outside paddocks. -- This will protect the residential amenities and

animal health along the route during the construction period.

2. Air Quality :

(a) Continuous Monitoring Facilities to be established and maintained by the

Council at Pace and Blundellstown Interchanges to monitor levels of Nitrogen

Dioxide (NO2) and Particulates (PM10) with the results to be made available at

the Council Offices in Dunshaughlin and Navan at six monthly intervals. -- This

will monitor trends in the emissions of NO2 and PM10 in the vicinity of the

proposed motorway.

(b) That Dust Deposition Guages ( Bergerhoff beakers) be established and

maintained at the 25 locations nominated by the Council on the schedules

submitted to the Hearing to monitor dust deposition levels during construction

work, the maximum permissible levels to be specified in the contract documents

and advised to the house owners where the guages will be located. -- This will

further protect the residential amenities along the route during the construction

period.

3. Material Assets :

Modify the shared Underpass/ Overpass being provided at the following

locations :-

(a) At mainline chn 12130 in Johnstown for plots 159 & 160 by constructing

a 10 metre overall wide bridge with a central solid dividing wall.

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(b) At R125 Link chn 1150 in Knockmark for plots 152, 155, 159, 171 & 172 by

constructing Two 4.5 metre by 4.5 metre box units side by side.

(c) At mainline chn. 11050 in Rath Hill for plots 162, 163, 166 & 167 by

constructing Two 4.5 metre by 4.5 metre box units side by side.

(d) At Kilcarn Link in Kennastown for plots 1133, 2112 & 2114 by

enlarging box unit to 5 metres by 5 metres located at chn. 750 on Revised

design as shown on drawing OH 5053 004 Rev. D01 submitted at Hearing.

These will further mitigate the severance impacts on those agricultural holdings.

4. Socio-economic :

1. Provide for footpaths at the following locations :-

(a) From circa chn. 240 on Loughsallagh to Clonee tie-in to circa chn. 200 on

Dunboyne road to front of existing houses.

(b) From a point at least 200 metres south of Mr. Finlay's house as shown on

Figure 8.1 in Volume 3A along the western side of Leshamstown Lane as

far as its junction with the Dunsany Road.

2. Provide for combined footpath and cyclepath in the following locations :-

(c) From Leshamstown Lane junction with the Dunsany road along south side

of Dunsany Road through the Roestown roundabout to a point at least 200

metres on the Dunshaughlin side of that roundabout.

(d) Extend from the end of the footpath being provided on each of the

Raynestown and Derrockstown Overbridge realignments to the junctions

with the Existing N3.

(e) From the junction of the Trevet road with the Collierstown road via the

Collierstown Overbridge to the Ross Cross junction on the N3.

(f) From the end of the pathway being provided off the Pace Interchange at thc

southern end of the Woodpark road northwards along the eastern side of the

Woodpark road to join with the pathway being provided off the Blackbull

Roundabout, generally as shown on the Drawing OH CPO 5003 Rev.D01

submitted by the Council to the Hearing.

(h) From a point at least 200 metres south of Mr. Finlay's house as shown on

Figure 8.1 in Volume 3A along the eastern side of Leshamstown Lane as far

as its junction with the Dunsany Road.

These will mitigate the effects on increased traffic and facilitate the use of

cycleways.

3. Provide for a wall 2 metres in height, stone faced on the roadward side, along

the roadside boundary of Plot 331 in Dunboyne to protect the residential

amenities from traffic movements at the roundabout.

994

5. Landscape :

(a) Advance Planting of Landscape areas to be undertaken in accordance

with the Schedules of possible locations submitted by the Council at the

Hearing on Days 23 & 28 as listed in Appendix 4 of this Report.

(b) A modified Specific Landscape Measure to be planted between chn

85000 and chn 85600 at Castlekeeran with solid bridge parapet walls to be

provided at the N3 crossing over the Castlekeeran road underbridge.

(c) The planting proposals shown on drawing OH 5044 003 Rev.D01

submitted by the Council at the Hearing for landscape screen planting

between Grange Toll Plaza and the Boyerstown Road Overbridge to be

fully complied with.

This will assist in mitigating the impact in areas where the longterm impact

would remain as severe or major negative after construction of the motorway.

6. Visual :

1. Modify the vertical alignment in accordance with the revised designs

submitted by the Council at the Hearing at :-

(a) Mainline chns 24100 to 25600 ( through Tara Stud lands) as shown on

Drawing 4B/3.3 Rev. A and 4B/3.4 Rev.A.

(b) Mainline chns 32600 to 33450 ( through Dalgan Park) as shown on

Drawing 4B/ 3.8 Rev. A

(c) Mainline chns 61200 to 62400 ( near Grange Toll Plaza/ Grange

Overbridge area) as shown on drawing CSK-2236 Rev.1

2. Modify vertical alignment of Kilcarn Link Road to new alignment as

shown on drawings OH 5053 004 & 007 Rev. D01.

3. Provide timber screen of not less than 1.8 metres in height within

landscape screen planting area from mainline chn 49400 to southern face

of Durhamstown road Overbridge and from chn 300 to chn 700 on

Durhamstown Road Realignment.

4. Provide timber screen of not less than 1.8 metres in height within

landscape screen planting area on outer edge of southbound carriageway

from mainline chn 60250 to 61250.

This will assist in mitigating the visual impacts on residents in the vicinity of

the motorway or road in the respective localities.

995

7. Flora and Fauna :

(a) The precautions to be taken when constructing bridges crossing the

Boyne and Kells Blackwater rivers as detailed in the Council's

submission of 21 November 2002 -- " Mitigation Proposals for Treating

and Controlling Discharge during the Construction of the Boyne Bridge "

-- shall be strictly complied with.

(b) No compound for storing construction machinery or fuel oils shall be

located within 200 metres of either of these rivers or their tributaries.

(c) The Council shall consult with Duchas before the construction works are

commenced and shall comply with any additional requirements Duchas

may specify for construction work adjacent to both rivers.

(d) Hedgerow and Tree removal or felling shall not be carried out during bird

nesting season of March to August inclusive.

(e) All buildings to be demolished along the route shall be first surveyed for

bats and those found to contain bats shall be demolished following the

mitigation measures stated in the EIS.

(f) Tree which may be suitable roosting sites for bats shall be surveyed and

those found to contain bats shall be felled under the supervision of a

suitably qualified person.

(g) All bridge and culvert design shall allow for mammal passes.

These would minimise the environmental impacts from the road construction on

habitats and fauna.

8. Archaeology :

The Council shall undertake a survey and prepare a record of local

cultural and historical place names and items of folklore interest

along the route of the proposed road development, under the direction of

the Project Archaeologist and in consultation with the Meath

Archaeological & Historical Society and Dunboyne Historical Society

This would mitigate the effects of the motorway construction on matters of local

and historical interest.

9. Architectural Heritage:

The Council shall construct retaining walls as shown on Drawing CSK996

2216/2217/2218 submitted to the Hearing to protect the structure of old

Woodpole Schoolhouse within the footprint of the embankment at that

location. If a structural survey shows that the structure can be

rehabilitated,the Council shall arrange for this to be done

This would allow for the possible preservation and re-use of a structure of

local cultural and historical interest.

10. Possible re-opening of disused Railway line :

The Council shall incorporate into the construction of the motorway

embankment at Cannistown such part of the railway underbridge structure

as outlined on Drawings OH RAIL 005 & 006 Rev.D01 submitted at the

Hearing that would allow for it to be completed without disruption to

traffic using the motorway if, in the future, the disused Clonsilla to Navan

railway line were to be re-opened.

This would provide an alternative to a possible railway bridge crossing over

the motorway in a sensitive location, if the railway line were to be re-opened at

some future date after the motorway was opened to traffic.`

150. Recommendations on the Application for Confirmation of the Motorway

Order and Approval of the proposed Road Development :

Having regard to all of the evidence within the EIS and given to the Hearing regarding

the Motorway Order, and having considered all of the written objections made to An

Bord, I am satisfied that the Council presented sufficient evidence regarding both the

need and the predicted traffic volumes for the proposed motorway which would justify all

of the acquisitions that were included in that Order. I recommend that the Motorway

Order be confirmed, without any modifications to the areas of land to be acquired in the

various plots in the First Schedule parts 1 and 2 of the Motorway Order, but with the

modifications in ownership or in the address that are listed in Table 1 of this Report.

Evidence was given by the Council that these amendments arose from changes in

ownership since the Order was made in early 2002, from changes in licensee or

occupancy, from changes in boundary demarcation and from changes made within the

published Order boundaries that did not involve any additional landtake. The Council

handed in a Schedule and a Book of Drawings which showed the changes being made

and confirmed that all affected owners had been notified by registered post of the changes

being made and were aware of these changes. See also Section 117 of this Report.

I also recommend that approval be given to the acquisition of the Wayleaves set out in

the Second Schedule, to the extinguishing of the Public Rights of Way set out in part 1 of

the Third Schedule and to the extinguishing of the Private Rights of Way set out in part 2

997

of the Third Schedule, to the Prohibition of direct access to the lands set out in the Fourth

Schedule and to the Revocation of the Planning Permissions set out in the Seventh

Schedule and to the Suspension of the Planning Permissions set out in the Seventh

Schedule all being Schedules in the Motorway Order.

Having considered all of the evidence and conclusions as to the likely effects on the

environment set out within the EIS and all of the written submissions made to An Bord

in respect of the proposed Road Development and all of the evidence given to the

Hearing and the cross-examination of the various witnesses and to the responses made

by the Council to the objections submitted, I am satisfied that (1) the proposed Road

Development would be in accordance with the objectives of the Meath County

Development Plan, (2) it would be in accordance with the strategies outlined in the

National Development Plan 2000 to 2006, in the Strategic Planning Guidelines for the

Greater Dublin Area and in the Dublin Transportation Office Report " Platform for

Change", (3) the proposal would not result in significant adverse effects on the

environment and (4) the proposal would be in accordance with the proper planning and

sustainable development of the area. I recommend that An Bord Pleanala should approve

the proposed Road Development under Section 51 of the Roads Act, 1993, as amended,

subject to the 10 modifications listed in Table 2 attached to this Report.

A list of the Objectors to the Motorway Order is given in Appendix 1; a list of those who

made submissions to the proposed Road Development is given in Appendix 2; a list of

M/s Gaynor Corr's clients is given in Appendix 3; a list of the various documents that

were handed in to the Hearing is given in Appendix 4; a list of the Wayleaves to be

acquired is given in Appendix 5; a list of the Public Rights of Way to be Extinguished is

given in Appendix 6; a list of the Private Rights of Way to be Extinguished is given in

Appendix 7 and a list of the Planning Permissions to be Revoked or Suspended is given

in Appendix 8.

Signed -------------------------

Brendan Devlin

Dated -------------------------

998

Table 1. Modifications to be attached to any Approval of the Motorway Order

under Section 49 of the Roads Act, 1993, as amended.

---------------------------------------------

Proposed Amendments to First Schedule, part 1

Plot No. Reason for As appears in Amended to

Amendment Schedule

207 Occupier deceased Andrew Neary Ann Neary

252 No Lessee Vincent McAuley Owner/Occupier -- no lessee

259 Owners deceased Kieran Lavelle, Occupier Kieran Lavelle, Owner

468 Now sole owner Padraig Tierney, Owner/reputed owner P. Tierney -- Owner

1077) (Annie Murphy has Fintan & Deirdre Murphy, Occupier Owner

1079) (right on 1079, not 1077 Fintan Murphy, Occupier Owner, Annie Murphy

1081 Change of ownership Lismullin Education Foundation Lismullin Education

Foundation 44 Westland Row Dublin 2

1119 Owners deceased Frank Corcoran, Occupier Frank Corcoran, Owner

2151 Part of Plot sold to John Sherlock 0.823 Ha.

2151k Part of Plot purchased from P&M Sherlock J. Sherlock, Oldtown, Bohermeen

2156 Change of address Woodview Cottage Flemingstown, Balrath

2170 Change in Boundary 0.195 Ha.

2180 Change in Boundary 5.441 Ha.

2190 James Curry recently deceased Reps. James Curry

2193 Margaret Phillips is deceased C. Collins, Occupier C. Collins, Owner

2384 Change in Boundary 1.854 Ha.

3026 Kathleen Connell recently deceased Reps of Kathleen Connell

c/o Steen O'Reilly & Co.Solicitors

3032 Additional lessee Private ROW in favour of CIE

3033 Additional lessee Private ROW in favour of CIE

3035 Additional Next of kin And other yet to be determined next of kin of S. Smith

3038) Part of plot in dispute John Newman & CIE 0.226 Ha.

3038) Additional Reputed Owner John Newman & Coras Iompair Eireann

3038) Occupying land John Newman, Kilmainham, Kells

3038 Additional Reputed owner John Newman & David Reilly

3046 Additional Next of kin And other yet to be determined next of kin of S. Smith

3068 Change of lessee Thomas Carolan, Oakley Park, Kells

3069 Amended address Thomas Mulvany & Reps of Bridget Mulvany

c/o M.A. Regan McEntee & Partners, Solicitors

-----------------------------------------------

Note --- Full details are set out in the Book of Schedule Amendments

and Book of CPO Drawing Amendments submitted

by Meath County Council at the Hearing on 21 Nov. 2002

999

Table 1, continued. Proposed Amendments to First Schedule, part 2

Plot No. Reason for As appears in Amended to

Amendment Schedule

174 Change of address Kilcooley, Drumree Knockmark Drumree

200 Occupier of land Meath CC Kieran Lavelle, Piercetown

207 Michael Neary deceased Ann Neary

216 Change of address Daniel Reilly, 29 Blackcastle Estate, Navan

223 Mis-spelled name Cummins Crimmins

252 No lessee Lessee & occupier V. McAuley Occupier/Owner

259 P. & B. Lavelle deceased K.Lavelle, occupier Kieran Lavelle, Owner

283 Change of address M. Reilly, Connisbeth, Fairyhouse Road, Dunboyne

309 Reduction in area due to temporary plots 0.690 Ha.

309 Different use, plot from 309 0.027Ha. Aidan Tierney/Bryan Maher

0.008 Ha. Aidan Tierney/Bryan Maher

349 New representatives Drummonds Ltd. c/o Dermot Rowan, Paddingstown, Clonee

351 Change in boundary 0.610 Ha.

352 Change in boundary 1.257 Ha.

441 Change of address Doon, Derrockstown, Dunshaughlin

451 Addition to address Laragh Homes Ltd. Laragh Homes Ltd, Stirling House

468a Now sole owner Padraig Tierney, Paceland, Dunboyne

468 Now sole owner Padraig Tierney, Paceland, Dunboyne

1079 Annie Murphy has right to reside Annie Murphy, Owner

1081 Change of ownership Lismullin Education Foundation Lismullin Education

Foundation 44 Westland Row Dublin 2

1119 Owners deceased Frank Corcoran, Occupier Frank Corcoran, Owner

1137 Now sole owner Dolores Roche, Cannistown, Navan

1142 Reputed Owner located James Foley, Ardsallagh, Navan

1143 Reputed Owner located Margaret & Dolores Callan, Cannistown, Navan

2105 Change of Ownership 0.129 Ha. Meath CC

2151 Part of plot sold to John Sherlock 0.997 Ha.

2151 Part of plot sold to John Sherlock 0.0038 Ha.

2151 Part of plot owned by Meath CC 0.040 Ha.

2151k Part of Plot purchased from P&M Sherlock J. Sherlock, Oldtown, Bohermeen

2156 Change of address Woodview Cottage Flemingstown, Balrath

2170 Change in Boundary 0.034 Ha. & 0.026 Ha

2180 Change in Boundary 1.097 Ha.

2190 James Curry recently deceased Reps. James Curry

2193 Margaret Phillips is deceased C. Collins, Occupier C. Collins, Owner

2215 Part of Plot purchased from M. P. Fitzsimons Pierce Fitzsimons, Ardbraccan

2223 Plot not now being acquired No entry in schedule

3026 Kathleen Connell recently deceased Reps of Kathleen Connell

c/o Steen O'Reilly & Co.Solicitors

3027 Change in boundary & K.Connell decd. 0.013 Ha. Reps of Kathleen Connell

1000

3032 Additional lessee Private ROW in favour of CIE

3033 Additional lessee Private ROW in favour of CIE

3035 Additional Next of kin And other yet to be determined next of kin of S. Smith

3038) Part of plot in dispute John Newman & CIE 0.226 Ha.

3038) Additional Reputed Owner John Newman & Coras Iompair Eireann

3038) Occupying land John Newman, Kilmainham, Kells

3044 Change of contact address Carmel Clarke, Henry Flanagan, Patrick Duff

c/o Headfort Golf Club, Kells & The Secretary,

Headfort Golf Club, Kells

3068 Change of lessee Thomas Carolan, Oakley Park, Kells

3069 Amended address Thomas Mulvany & Reps of Bridget Mulvany

c/o M.A. Regan McEntee & Partners, Solicitors

3081 Corrected address Ambrose Gillick, Cloughergoole, Virginia

3085 Land divided due to occupier 0.963 Ha. & 0.755 Ha.

3085 New occupiers Peter Caffrey, Cavan Road, Kells, as owners

3098 New address Sunset Homes Ltd, c/o S.O'Reilly, 9 Sunset Hts. Kells

3122 Additional Reputed owner M. Farrelly, T. Hickey, T.Healy, Kilmainham

4015 Part of plot sold to K. Meegan 3.8906 Ha.

4015 Part of plot bought from J. Meegan Kieran Meegan, Dumbaragh

4027 Change of address c/o John Farrelly, Newrath Big, Lloyd, Kells

4028 Change of address John Farrelly, Newrath Big, Lloyd, Kells

4056 Change of address Thomas P. Donegan, Castlekeeran, Carnaross

-------------------------------------------------------------

Table 1, continued. Proposed Amendments to Fourth Schedule

Plot No. Reason for As appears in Amended to

Amendment Schedule

207 Occupier deceased Andrew Neary Ann Neary

252 No Lessee Vincent McAuley Owner/Occupier -- no lessee

259 Owners deceased Kieran Lavelle, Occupier Kieran Lavelle, Owner

468 Now sole owner Padraig Tierney, Owner/reputed owner P. Tierney -- Owner

1079 Annie Murphy has right to reside. F.Murphy, Occupier Owner, Annie Murphy

1081 Change of ownership Lismullin Education Foundation Lismullin Education

Foundation 44 Westland Row Dublin 2

1119 Owners deceased Frank Corcoran, Occupier Frank Corcoran, Owner

2151 Part of Plot sold to John Sherlock 0.997 Ha.

2151 Part of Plot sold to John Sherlock 0.0038 Ha.

2151 Change in description 0.349 Ha Agricultural Land

2151c Change in area 1.097 Ha.

2151k Part of Plot purchased from P&M Sherlock J. Sherlock, Oldtown, Bohermeen

2156 Change of address Woodview Cottage Flemingstown, Balrath

1001

2170 Change in Boundary 0.034 Ha.

2180 Change in Boundary 1.097 Ha.

2190 James Curry recently deceased Reps. James Curry

2193 Margaret Phillips is deceased C. Collins, Occupier C. Collins, Owner

2215 Part of Plot sold to Pierce Fitzsimons 1.675 Ha.

3026 Kathleen Connell recently deceased Reps of Kathleen Connell

c/o Steen O'Reilly & Co.Solicitors

3026 Change in boundary 25.593 Ha.

3032 Additional lessee Private ROW in favour of CIE

3033 Additional lessee Private ROW in favour of CIE

3035 Additional Next of kin And other yet to be determined next of kin of S. Smith

3038) Additional Reputed Owner John Newman & Coras Iompair Eireann

3038) Occupying land John Newman, Kilmainham, Kells

3038) Part of plot in dispute John Newman No entry, not now required

3038) Additional Reputed Owner 0.004 Ha. John Newman & David Reilly

3046 Additional Next of kin And other yet to be determined next of kin of S. Smith

3068 Change of lessee Thomas Carolan, Oakley Park, Kells

3069 Change of owner Thomas Mulvany & Reps of Bridget Mulvany

c/o M.A. Regan McEntee & Partners, Solicitors

-----------------------------------------------------------------------

1002

Table 2. Modifications to be attached to any Approval of the proposed

Road Development under Section 51 of the Roads Act, 1993,

as amended.

-----------------------

1(a). Noise mitigation measures shall be incorporated into the design and

construction of the proposed motorway scheme by the use of appropriate

noise barriers or low noise surfacing or in a combination of methods so that

the predicted noise levels associated with the proposed motorway scheme in

the design year, 2024, shall not exceed 65 dB LA10 18hour, when measured

at one metre from the façade of the most exposed window at ground floor

level of single storey or upper floor level of two storey houses of noise

sensitive receptors in accordance with the assessment procedures set out in

section 4.6 in Volume 6A of the Environmental Impact Statement. The

predicted noise levels in the design year, 2024, shall be further modified at

Ardbraccan House, where they shall not exceed 55 dB LA10 18hour when

measured at one metre from the most exposed window at upper floor level,

and at Rathbeggan Lake where they shall not exceed 55 dB LA10 18hour

when measured at the north-eastern edge of the Lake.

Reason --- To protect the residential amenities of people living

adjacent to the motorway scheme and the particular

amenities of Rathbeggan Lake.

1(b). The requirements of BS 5228/1997 "Noise and Vibration Control on

Construction and Open Sites" in respect of the standards and methodology

relating to construction noise shall be incorporated into all Contracts for

Works in connection with the construction of the proposed motorway scheme

and not less than Six Control Stations shall be established, (1) Four of these

to be used to monitor noise levels and (2) Two of these to be used to monitor

vibration levels while construction work is in progress near sensitive

receptors. The locations and duration of such monitoring shall be decided by

the person nominated as the Council's Site Representative from time to time .

Reason --- To protect residential amenities during the period while

construction work is being undertaken for the motorway

scheme.

1(c). The Site working hours shall be modified so that no construction work shall

take place within 100 metres of any occupied house (1) before the hour of

0700 Mondays to Fridays or 0800 on Saturdays, (2) after the hour of 1900

Mondays to Fridays or 1630 on Saturdays and (3) not at any time on

1003

Sundays or Public Holidays, and that a clause to this effect shall be included

in all Contracts for works in connection with the construction of the road.

Reason --- To protect residential amenities during the period while

construction work is being undertaken for the motorway

scheme.

1(d). The noise levels specified for construction noise as set out in Table 4.12 in

Volume 6A of the Environmental Impact Statement, and in the equivalent

Tables in the other Volumes, shall be modified to provide for a reduction of

5dB in the levels specified for the hours of 0700 to 1900 on Mondays to

Fridays and for the hours of 0800 to 1630 on Saturdays.

Reason --- To protect residential amenities during the period while

construction work is being undertaken for the motorway

scheme.

1(e). The contract documents shall provide for a daytime limit for Peak Air

Over-pressure, measured as Pmax, of 125 dB(L) when any construction

work involving Blasting is being undertaken adjacent to sensitive receptors.

Where such work is adjacent to the locations normally used by bloodstock

animals the limit shall be reduced to 105 dB (L).

Reason --- To protect residential amenities and animal health during

the period while construction work is being undertaken for

the motorway scheme..

2(a). Continuous monitoring facilities shall be established and maintained by the

Local Authority at suitable locations at (1) the Pace Interchange and (2) the

Blundellstown Interchange to monitor levels of Nitrogen Dioxide (NO2) and

Particulates, PM10, the results to be made available at the Offices of the

Local Authority in Dunshaughlin and Navan at six monthly intervals at a

minimum.

Reason --- To monitor trends in the emissions of nitrogen dioxide and

particulates in the area adjoining the motorway.

2(b). Dust Deposition Guages, either Bergerhoff Beakers or similar, shall be

located and monitored at the 25 locations specified in the Schedule submitted

by the Local Authority at the Hearing on Day 28 while construction work is

in progress in the vicinity of the specified sites and the maximum permissible

deposition rates at such sites shall be specified in the contract documents.

Reason --- To protect residential amenities during the period while

construction work is being undertaken for the motorway

scheme.

1004

3. The shared underpass or overpass facilities being provided at the following

locations shall be modified as detailed hereunder :-

(a) The overbridge at mainline chainage 12130 in Johnstown serving Plots

159 and 160 shall be widened to 10 metres overall width and constructed

with a central solid dividing wall.

(b) The underpass at the R125 Link chainage 1150 in Knockmark serving

plots 152, 155,159, 171 &172 shall be replaced by Two 4.5 metre by 4.5

metre box units placed side by side.

(c) The underpass at mainline chainage 11050 in Rath Hill serving Plots 162,

163, 166 & 167 shall be replaced by Two 4.5 metre by 4.5 metre box units

placed side by side.

(d) The underpass at the Kilcarn Link in Kennastown serving Plots 1133,

2112 & 2114 shall be relocated to chainage 750 on a revised alignment

and increased in size to a 5 metres by 5 metres box unit.

Reason --- To mitigate the severance effects on the particular Plots.

4. (1) Footpaths incorporating cycle-lanes shall be provided within the existing

verges along the following roads :-

(a) From the junction of the Trevet and Collierstown roads westwards along

the Collierstown road to its junction with the N3 at Ross Cross.

(b) From the end of the pathway being provided off the Pace Interchange at

the southern end of the Woodpark road northwards along its eastern

verge to join with the pathway being provided off the Blackbull

Roundabout, as generally shown on Drawing OH CPO 5003 Rev. D01

submitted by the Local Authority at the Hearing.

(c) From the end of the paths being provided as part of overbridge road

realignment on each of the Raynestown and Derrockstown roads as far as

their junctions with the N3.

(d) From the junction of the Dunsany road with the Leshamstown Lane

along the southern side of the Dunsany road, through the Roestown

Roundabout to a point not less than 200 metres on the Dunshauhghlin

side of that roundabout.

(e) From a point 200 metres south of the house shown as "Mr. Finlays" on

Figure 8.1 in Volume 3A of the EIS northwards along the eastern side of

Leshamstown Lane to its junction with the Dunsany Road.

(2) Footpaths shall be provided within the existing verges along the

following roads :-

(a) From a point 200 metres south of the house shown as "Mr. Finlays" on

Figure 8.1 in Volume 3A of the EIS northwards along the western side of

Leshamstown Lane to its junction with the Dunsany Road.

(b) From about chainage 240 on the Loughsallagh to Clonee tie-in to about

chainage 200 on the Dunboyne road to front the existing houses.

Reason --- In the interests of road safety and to facilitate the use of

1005

public transport and cycleways by residents on these roads.

(3) A wall two metres in height, stone faced on the roadside face, shall be

provided along the roadside boundary of Plot 331 in Dunboyne.

Reason --- To protect the residential amenities of that property.

5. (a) Advance Planting of Landscaped areas shall be undertaken by the Local

Authority in accordance with the schedules of possible locations submitted at

the Hearing by the Local Authority on Days 23 & 28, where the construction

work program for the motorway permits of such advance planting.

(b) A modified format of a Specific Landscape Measure (as detailed in the EIS)

shall be planted between mainline chainages 85000 and 85600 at

Castlekeeran and a solid parapet wall shall be provided on the mainline

crossing over the Castlekeeran underbridge at chainage 85540.

(c) The planting proposals shown on Drawing OH 5044 003 Rev. D01 submitted

by the Local Authority at the Hearing for landscape screen planting between

the Grange Toll Plaza and the Boyerstown road overbridge areas shall be

fully complied with.

Reason --- To mitigate the visual impacts in these locations.

6. (1) The vertical alignment shall be modified in accordance with the revised

design and drawings submitted by the Local Authority at the Hearing in the

following locations :-

(a) Between mainline chainages 24100 and 25600 through Tara Stud lands

as shown on Drawings 4B/3.3 Rev.A and 4B/3.4 Rev.A.

(b) Between mainline chainages 32600 and 33450 through Dalgan Park

lands as shown on Drawing 4B/3.8 Rev.A.

(c) Between mainline chainages 61200 and 62400 near Grange Toll Plaza

as shown on Drawing CSK - 2236 Rev.1.

(2) The vertical alignment of the Kilcarn Link road shall be modified to the

revised alignment as shown on Drawings OH 5053 004 & 007 Rev.D01

submitted by the Local Authority at the Hearing.

(3) A timber screen, not less than 1.8 metres in height above ground level, shall

be provided within the landscape screeen planted areas between :-

(a) mainline chainage 49400 to southern face of Durhamstown overbridge

along eastern side of south bound carriageway;

(b) chainages 300 and 700 on the Durhamstown road realignment along

southern side of realigned roads;

(c) mainline chainages 60250 and 61250 along eastern side of south bound

carriageway.

Reason --- To mitigate the visual impacts in these locations.

1006

7. (a) The precautions specified in the document " Mitigation Proposals for

Treating and Controlling Discharge During Construction of the M3 Boyne

Bridge" submitted by the Local Authority at the Hearing shall be strictly

complied with during the construction of bridges crossing the Boyne and

Kells Blackwater Rivers.

(b) No compound for storing construction machinery overnight or for storing

fuel oils shall be located within 200 metres of the Boyne or Kells Blackwater

Rivers or their tributaries.

(c) Before any construction work on the Boyne or Kells Blackwater River is

commenced, the Local Authority shall consult with Duchas and shall

comply with any additional requirements Duchas may specify for

construction work adjacent to both Rivers.

(d) Hedgerow and tree felling shall not be carried out during the bird nesting

season from 1 March to 31 August.

(e) All buildings to be demolished along the route shall be surveyed for bats

and those found to contain bats shall only be demolished following the

mitigation measures set out in the EIS.

(f) Trees that may be suitable as roosting sites for bats shall be surveyed and

those found to contain bats shall only be felled under the supervision of a

suitably qualified person.

(g) All bridge and culvert designs shall provide for mammal passes.

Reason --- To mitigate impacts on habitats and fauna.

8. The Local Authority shall undertake a survey and prepare a record of local

cultural and historical place names and items of folklore interest impacted by

the route of the proposed motorway scheme under the direction of the Project

Archaeologist and in consultation with the Meath Archaeological & Historical

Society and the Dunboyne Historical Society.

Reason --- To preserve records of matters of local cultural and

historical interest.

9. The Local Authority shall construct retaining walls as shown on Drawings

CSK - 2216, 2217 & 2218 submitted by the Local Authority at the Hearing

to protect the Old Woodpole Schoolhouse during the construction of the road.

A structural survey of the building shall be carried out and if this shows that

the building can be rehabilitated, the Local Authority shall then arrange for

such rehabilitation as will allow for the preservation and future re--use of that

building.

Reason --- To preserve a structure of local cultural and historical

interest.

1007

10. The Local Authority shall incorporate into the construction of the motorway

embankment at Cannistown such parts of an underbridge structure as is

outlined in the Drawings OH RAIL 005 & 006 Rev. D01 submitted by the

Local Authority at the Hearing that would allow for its possible completion

for use as a railway underbridge without disrupting traffic on the motorway

when in use if, at some future date, the disused Clonsilla to Navan railway line

were to be re-opened and when the motorway would be in operation.

Reason --- To facilitate an alternative option to that of a rail line

crossing over the motorway in this sensitive location.

-------------------------------------------------------------

1008

Appendix 1. List of Objectors to the Motorway Scheme Order whose submissions

were made to An Bord Pleanala within the prescribed period.

-------------------------------------------------------

The context of the Schedules referred to in this List is as follows:-

1st Schedule -- part 1-- Lands on which the motorway will be provided;

part 2 -- Lands not forming part of the motorway.

2nd Schedule -- Wayleaves being acquired.

3rd Schedule -- part 1 -- Public rights of way to be extinguished;

part 2 -- Private rights of way to be extinguished.

4th Schedule -- Lands to which direct access is to be prohibited

7th Schedule -- part 1 -- Planning permissions to be revoked;

part 2 -- Planning permissions to be modified.

---------------------------------------------------------

Plot No. Schedules Townland Objectors name(s) Address

118 1st pt 2 Roestown John & Kathleen O' Connor, Roestown, Drumree

119 1st pt 2 Roestown Joseph & Ann McKillen, Roestown, Drumree

120 1st pt 2 Roestown Arthur & Elodie McFaul, Roestown, Drumree

121 1st pt 1 & 2; 4th Roestown Tom & Mary Byrne, Ashling, Roestown,

Dunshaughlin

122 1st pt 1&2; 4th Roestown Michael Delaney, Gaulstown, Dunshaughlin

123 ) 1st pt 2 Roestown Martin & Monica Kelly, Roestown, Drumree

124 ) 1st pt 2 Roestown

137 1st pt 2 Leshamstown John & Mary Neary, Leshamstown, Drumree

139 1st pt 1&2; 4th Readsland & Knocks Evan Newall 62/63 Brighton Green,

Rathgar, Dublin 6 and

Peter Newell, Readsland, Drumree

Dunshaughlin

144 1st pt 1&2; 4th Readsland Hugh Newall, Readsland, Drumree

1009

147 1st pt 2 Readsland John Francis Morgan, Readsland, Dunshaughlin

148 1st pt 2 Readsland Peter Conlon, Readsland, Dunshaughlin

149 ) 1st pt 1; 4th Rath Hill Michael & Mary Morrin, Johnstown House

160 ) 1st pt 1&2; 4th Johnstown Dunshaughlin

150 1st pt 2 Readsland Derek Gray, Readsland, Dunshaughlin

155 1st pt 2 Drumree Valerie Sunner, Knockmark, Drumree

157 1st pt 2 Drumree Declan Walsh, Knockmark, Drumree

159 1st pt 1&2; 4th Johnstown Patrick Delaney, Johnstown, Dunshaughlin

162 1st pt 1&2; 4th Rath Hill Michael & Maureen Duffy, Rath Hill, Dunshaughlin

163 1st pt 1&2; 4th Rath Hill Sean & Bernadette Joyce, Rath Hill, Dunshaughlin

166 1st pt 1&2; 4th Rath Hill Pat Summerville, Rath Hill, Dunshaughlin

167 ) 1st pt 1&2; 4th Rath Hill Patrick Jennings, Macetown, Navan

2147 ) 1st pt 2 Macetown

171 1st pt 2 Knockmark Christopher Lynch, Knockmark, Drumree

c/o John Lynch, Augherskeagh, Drumree

172 1st pt 2 Knockmark Michael Kieran, Knockmark, Drumree

173 1st pt 2 Knockmark Drunree GAA Club, c/o Sean Walsh,

Augherskeagh, Drumree

174 ) 1st pt 2 Knockmark Eddie Bannon, Kilcoole, Drumree

182 ) 1st pt 2 Merrywell Eddie Bannon (as occupier)

182 1st pt 2 Merrywell Patrick J. Geraghty, Greenacres, Powderlough

Dunshaughlin

(EIS related ) Bridget Bowens, Roestown, Drumree

(EIS related) Carmel & Patrick Carroll, The Haven, Readsland,

Drumree

(EIS related) Mr. & Mrs. P. Caton, Meadowcroft,

Leshamstown Lane, Dunshaughlin

1010

(EIS related) William & Bridget Crowley, Leshamstown Lane

(EIS related) Shay Fitzpatrick, Breffni, Leshamstown Lane

(EIS related) James Finlay, Leshamstown Manor, Drumree

(EIS related) Ann & Anthony Devey, Almeida House,

Leshamstown, Drumree

(EIS related) Paula & Alex Doyle, Tara House, Roestown

Drumree

(EIS related) Colm & Mary Murphy, Leshamstown, Drumree

(EIS related) Leo Lawlor Watermeadows,

Leshamstown, Drumree

(EIS related) Paul Manck, Birchlawn, Drumree

(EIS related) Patricia Murnane, Leshamstown, Drumree

(EIS related) Annette & Enda McDonagh, Leshamstown Lane,

Drumree

(EIS related) Walter Smyth, Leshamstown, Drumree

183 1st pt 2 Bedfanstown Gerry & Catherine Carry, Crosskeys, Drumree

186 1st pt 2 Derrockstown Louis & Mary Murray Fortfield, Derrockstown

188 1st pt 2 Derrockstown Thomas McManus, Derrockstown, Dunshaughlin.

189 1st pt 1&2; 4th Derrockstown Shane Cassidy, 119, Navan Road, Dublin 9

195 1st pt 1&2; 4th Derrockstown Tom Feerick, Derrockstown, Dunshaughlin

197

197 1st pt 1&2; 3rd pt 2; 4th Derrockstown Patrick McHale, Derrockstown,

206 1st pt 1&2; 4th Derrockstown Patrick & Michael Corbett, Derrockstown,

207 1st pt 1&2; 4th Derrockstown Andrew & Mary Neary, Derrockstown

208 1st pt 1&2; 4th Derrockstown Noel & Josephine McTigue, Derrockstown

1011

213 1st pt 2 Raynestown Patrick & Mary Townsend, Raynestown,

Dunshaughlin

215 1st pt 2 Raynestown Thomas & Irene Reeves, Raynestown,

217 1st pt 2 Raynestown Raymond & Sheelagh Brennan,

Raynestown

218 1st pt 2 Raynestown Michael & Marion McCullagh, Raynestown

219 1st pt 2 Raynestown Paul & Pauline Rafter, Raynestown, Dunshaughlin

220 1st pt 2 Raynestown Jason & Karen Huggard, Raynestown, Dunshaughlin

221 1st pt1&2; 4th Raynestown John O'Sullivan, Raynestown, Dunshaughlin

222 1st pt 1&2; 4th Raynestown Michael Clayton, 28 Greentrees Road, Dublin 12

223 1st pt 2 Raynestown David & Patricia Crimmins, Raynestown

229 1st pt 2 Raynestown Dermot & Philomena McGreal, Raynestown

230 1st pt 2 Raynestown Peadar & Pauline Creagh, Raynestown

231 1st pt 2 Raynestown Frank Goodman, Raynestown

232 1st pt 2 Raynestown Joseph & Noreen Sheridan, Bush Lane,

Raynestown

233 ) 1st pt 1&2;4th Raynestown John & Derek Maher, The Bush, Dunshaughlin

251 )

234 1st pt 2 Raynestown Patrick Ennis & Joan Burke,

The Bungalow, Raynestown

235 1st pt 2 Raynestown John & Marie Drake, Raynestown

236 1st pt 2 Raynestown Declan & Ellen Collins, Raynestown

237 1st pt 2 Raynestown Desmond & Anne Bellew, Raynestown

238 1st pt 2 Raynestown Sean & Patricia Wynne, Raynestown

239 1st pt 2 Raynestown Eamonn & Mary Halligan, Raynestown

240 1st pt 2 Raynestown John & Joanne Duffy, Raynestown

1012

241) 1st pt 2 Raynestown Thomas & Pauline Everard, Raynestown

242) 1st pt 2

252 1st pt 1&2; 3rd pt 2; 4th Rathbeggan Vincent McAuley, Bechmount, Rathbeggan

255 1st pt 1&2; 3rd pt 2; 4th Rathbeggan David Robinson, Rathbeggan, Dunshaughlin

256 1st pt 1&2; 4th Rathbeggan Ronald Robinson, Rathbeggan, Dunshaughlin

257 1st pt 1&2; 4th Rathbeggan Sylvester McAuley, Roselawn,

258 1st pt 1&2; 4th Rathbeggan Basil Brindley, Rathbeggan House Stud.

259 1st pt 1&2; 4th Piercetown K. P. & A. Lavelle, Piercetown, Dunboyne

Dunboyne

264 1st pt 2 Quarryland Bucco Ltd., Suite 1, Westpoint Health & Fitness

Centre, Blanchardstown, Co. Dublin

265 1st pt 1&2; 4th Quarryland Brendan Murphy, Quarryland, Dunboyne

266 1st pt 1&2; 4th Quarryland Hilda Potterton, Quarrylands, Dunboyne

272 1st pt 1&2; 4th Piercetown Eugene & Carol Lavelle, Piercetown, Dunboyne

280 1st pt 2 Piercetown Brendan & Elizabeth Donnelly

Piercetown, Dunboyne

285 1st pt 2 Piercetown Phillip Connell, Piercetown, Dunboyne

292 1st pt 2 Piercetown Sean McGuirk , Piercetown, Dunboyne

293 1st pt 1&2; 4th Piercetown Patrick Yorell jnr, 2, Old Fair Green, Dunboyne

294 1st pt 1& 2; 3rd ; 4th Piercetown Reps Patrick Peters ---

Theresa & Colum Peters, Piercetown, Dunboyne

298 1st pt 2 Piercetown Nancy Gibney, Piercetown, Dunboyne

299 1st pt 2 Piercetown Mary Gabrielle Ryan, Piercetown, Dunboyne

300 1st pt 1&2; 4th Pace Padraig Tierney & Mary Agnes Jackman

Paceland, Dunboyne and Castletroy, Co. Limerick.

301 1st pt 2 Piercetown Dubai Bloodstock Ltd., Woodpark, Dunboyne

1013

307 1st pt 1&2; 4th Piercetown Kilsaran Concrete Ltd., Piercetown, Dunboyne

308 1st pt 1&2; 4th Piercetown SERLA Print Ltd, Serla House, Grennhills Road

Tallaght, Dublin 24

312 1st pt 1&2; 4th Woodpark Hugh Mullally , Woodpark, Dunboyne

320 1st pt 1&2; 4th Bracetown Laurence Ward, Norman's Grove, Clonee

321 ) 1st pt 1&2; 4th Pace Mary Agnes Jackman & Co. 39 Oaklands,

468 ) Pace Castletroy,Co. Limerick

325) 1st pt 1&2; 4th Pace Reps of Christopher Gregan,

337) 1st pt 2 Dunboyne c/o Gertrude Gregan, Bennetstown

Dunboyne

326 1st pt 2 Dunboyne Peter & Edward Henshaw, Benettstown, Dunboyne

329 1st pt 2 Dunboyne Tom & Loreto Doherty, Newtown,

Summerhill Road, Dunboyne

330 1st pt 2 Castlefarm Mary J. Barden, Summerhill Road, Dunboyne

331 1st pt 2 Dunboyne Emer Ni Mhaoldomhnaigh & Bernard Walsh

Summerhill Road, Dunboyne

332 1st pt 2 Castlefarm Richard, M.J., & Doris Bruton, Newtown

Dunboyne

339 1st pt 2 Dunboyne Pat Gregan, Bennetstown, Dunboyne

340 1st pt 2 Dunboyne Sean Boylan, The Bungalow, Dublin Road,

Dunboyne

342 1st pt 2 Dunboyne Sean Delaney, Bracetown, Clonee

346 1st pt 2 Dunboyne John Connaughton (Ltd.), Ballybane,

Killiney Avenue, Co. Dublin

350 1st pt 2 Bracetown Reps of Joseph Laurence Ward,

c/o Laurence Ward, Norman's Grove

351 1st pt 2 Bracetown Michael Brazil , 23 Moatlands, Ratoath

352 1st pt 1& 2; 3rd pt 2; Bracetown Vincent McDonnell, Knockmore,

Ballina, Co. Mayo.

1014

353 1st pt 1& 2; Bracetown Anthony J. McDonnell, Knockmore, Ballina

356 1st pt 2 Bracetown James & Frances Pheonix, Bracetown,

371 1st pt 2 Clonee Strandfair Holdings -- Finnian O' Cinneide

Loughsallagh, Clonee ( as occupier)

375 1st pt 2 Clonee Ciaran & Lisa Byrne, Loughsallagh, Clonee

429 1st pt 2 Augherskeagh Mary Redmond, Barnaderg, Drumree

450 1st pt 2 Dunboyne John & Pamela Conneely ,The Maples,

Dunboyne

464 1st pt 2 Roestown S.J.D. Developments Ltd. Tullameadow,

Drumree

c/o Sean Dunleavy, Dunshaughlin

467 1st pt 2 Clonee Thomas O'Sullivan, Loughsallagh, Clonee

468 1st pt 1&2; 4th Pace Patrick Tierney, Paceland, Dunboyne

469 1st pt 2 Bennetstown Patrick Tierney, Paceland, dunboyne

469 ) 1st pt 2 Bennetstown CIE Michael Carroll, Solicitor

1144 ) 1st pt 1&2; 4th Ardsallagh Solicitor's Office, Bridgewater House

3032 ) 1st pt 1&2; 4th Cookstown Great Islandbridge, Dublin 8

3033 )1st pt 1&2; 3rd pt 2; 4th Cookstown Great

3046 ) 1st pt 1&2; 3rd pt 2; 4th Kilmainham

470 1st pt 2 Glascarn Anthony J. McDonnell, Knockmore, Ballina

And P. J. Roche, Glascarn, Ratoath

475 1st pt 2 Dunboyne Eamonn Walsh, Court Hill, Dunboyne

1052 1st pt 1&2; 4th Roestown Margaret Quinn, Westleigh Farm,

Roestown, Dunshaughlin

1053) 1st pt 1&2; 4th Roestown Michael & Dymphna O'Brien Rockfield,

1060) 1st pt 1&2; 4th Roestown Portmanna, Co. Meath

(EIS related) Cooksland Geraldine Hennessey, Spearsview Cottage

Cooksland, Dunshaughlin

1056 1st pt 1&2; 3rd; 4th Garretstown Gerrardstown Stud, Gerrardstown,

Dunshaughlin

1015

1057 1st pt1&2; 3rd pt 2; 4th Garretstown Liam O'Kane, Drumaweir, Greencastle,

Co. Donegal

1059 1st pt 1&2; 4th Berrillstown Dermot, Bridget & David Carty

Berrillstown, Tara

1061 1st pt 1& 2; 4th Berrillstown C.A.S Ltd., c/o Jones Engineering Ltd.,

Waterways House, Grand Canal Quay, Dublin 2

1062 1st pt 1& 2; 4th Skryne James Swan, Skryne, Tara

(1074 & 1075) Skryne James Swan ( as occupier)

1063 1st pt 1&2; 4th ; 7th pt 2 Skryne James J. Swan junior, Skryne, Tara

1064 1st pt 1&2; 4th Clowanstown The Limestone Land Co. Ltd.

c/o Tara Stud, Clowanstown, Tara

1067 1st pt 2 Collierstown Captain Anthony & Catherine Canavan,

Collierstown, Tara

1071 1st pt 2 Collierstown John & Patricia Scanlon, Collierstown, Tara

(EIS related) Collierstown George & Mary Begley, Collierstown, Tara

(EIS related) Collierstown Liam Doyle & Grace Martin, Branstown, Tara

1074 ) 1st pt 1&2; 4th Baronstown John Wilkinson, Barronstown, Tara

1075 ) 1st pt1&2; 4th Skryne

1076 1st pt 1&2; 4th Skryne Vincent & Ann Murphy, Skryne, Tara

1077 ) 1st pt 1&2; 4th Skryne Fintan & Deirdre Murphy, Skryne, Tara

1079 )

1080 1st pt 1&2; 4th Skryne Colin & Jessica Magnier, Skryne, Tara

1083 1st pt 1&2; 3rd pt 2; 4th Lismullin Phillip & Margaret Ryan, Lismullin, Navan

1087 1st pt1& 2; 4th Lismullin Patrick & Susan Meehan, Lismullen,

Garlow Cross, Navan

1088 1st pt 2 Lismullin John & Maureen Meehan, Lismullen, Navan

1089 1st pt 1&2; 4th Blundelstown Noel McGuinness

Blundellstown House, Garlow Cross

1016

1090 1st pt 1&2; 4th Philpotstown Reps Mary E. McCarthy,

c/o Cathal McCarthy, Philpottstown,

Garlow Cross

1091 1st pt 1&2; 4th Berrillstown Gerard Stafford, Berrillstown, Tara

and David Carty, Berrillstown

1092 1st pt 1&2; 4th Castletown Tara Liam Donohue, Darraugh, Garadice PO,

Ballyconnell. Co. Cavan

1093 1st pt 2 Ballinter Stephen & Margaret Neylon, Links View,

Bellinter, Navan

1094 1st pt 1&2; 4th Dowdstown Rev. Peter O'Neill,

Missionary Society of St. Columbans

St. Columbans (Dalgan Park) Navan

1096 1st pt 1&2; 4th Castletown Tara Pat Fallon Newgrange Business Park

Donore Road, Drogheda.

(EIS related) Bellinter Residents Association per Alan Park

Bellinter Cross, Navan

(EIS related ) James McCaldrin, Oak Lodge, Bellinter, Navan

(EIS related) Joseph Heery, Ardsallagh, Navan

1106 1st pt 2 Ballinter Brian Kelly, Bellinter, Navan

1109 1st pt 1&2; 3rd; 4th Ardsallagh Cormac Murray, Wood Lodge, Ardsallagh

1109 1st pt 1&2; 3rd; 4th Ardsallagh Thomas Wimesy, Gate Lodge,

Ardsallagh (as occupier)

1111 1st pt 2 Ardsallagh Brian & Jean Malone, Ardsallagh, Navan

1113 1st pt 2 Ardsallagh Peter & Mary Crisham, Ardsallagh

1115 ) 1st pt 2 Ardsallagh James Foley (Junior), Ardsallagh, Navan

1117 ) 1st pt 2 Ardsallagh

1116 ) 1st pt 2 Ardsallagh James Foley (Senior), Ardsallagh, Navan

1118 ) 1st pt 1&2; 4th Ardsallagh

1119 1st pt 1& 2; 4th Ardsallagh Frank Corcoran, Cannistown, Navan

1017

1120 1st pt 1&2; 4th Ardsallagh Peter & Rosemary McAree, Arovilla, Ardsallagh

1121 1st pt 1&2; 4th ; 7th pt 2 Ardsallagh Reps of Robert Slattery,

c/o Joan Slattery, Mullinam, Mulhuddart

Co. Dublin

1122 1st pt 2 Ardsallagh Emmet Clarke, Ardsallagh

---- Ardsallagh Frank & Marie Clarke, Ardsallagh

t/a Ardsallagh Furniture Reproduction Ltd.

(shared entrance with Plot 1122)

1123 1st pt 2 Ardsallagh Peter & Rosanna Burke, Ardsallagh, Navan

1124 1st pt 2 Ardsallagh Tony & Alison King, Tall Trees, Ardsallagh

1125 1st pt 2 Ardsallagh Joseph & Patricia Fitzsimons, Ardsallagh

1126 1st pt 2 Ardsallagh Robert Fitzsimons, Ardsallagh

1127 1st pt 2 Ardsallagh Thomas & Anna Farrelly, Ardsallagh

1128 1st pt 2 Ardsallagh John T. & Breda Connolly, Ardsallagh

1130 ) 1st pt 1&2; 4th Ardsallagh John Columba McEvoy, 34 Market Square,

1144 ) 1st pt 1&2; 4th Ardsallagh Navan

(CIE claim ownership of 1144)

1133 1st pt 1&2; 4th Kennastown Reps of Frank Foley, Cannistown, Navan

1135 1st pt 2 Kennastown Leslie & Mary Curtis, Cannistown

1136 1st pt 2 Kennastown Sean Carty, Cannistown

1138 1st pt 2 Ardsallagh John Moran, Secretary, Bective G. F. C.

Cannistown, Navan

2102 1st pt 2 Williamstown or Bawn John Fahy, The Bawn, Williamstown,

Navan

2103 1st pt 1&2; 4th Williamstown or Bawn Mark Corley, Grange, Bective, Navan

2107 1st pt 2 Balreask Old Reps of Christopher Dowdall, Balreask Old, Navan

1018

Thomas Dowdall, Trim road, Navan and

John Dowdall, Balreask Old, Navan

2110 1st pt 2 Balreask Old Noel & Sandra Farrell, Balreask Old, Navan

2111 1st pt 2 Philpotstown James & Kevin Brady, c/o Brian Hughes

26 Magdalene Street,Drogheda

2112 1st pt 1&2; 4th Kennastown Paul & Kathleen Foley, Cannistown, Navan

2113 1st pt 2 Kennanstown Vincent Keating, Ardsallagh, Navan

2114 1st pt 2 Kennastown Nicholas & Kathleen Keogh,

Rackenstown House, Dunshaughlin

2116 1st pt 2 Ballybatter or Balreask New Shiela O'Keefe St. Anne's, Balreask,

Navan

2117 1st pt 2; 3rd pt 2 Balreask Old Vitgeson Ltd., Moatlands, Navan

2117 1st pt 2 Balreask Old Maurice & Joan Whelan, Balreask Old,

Dublin Road, Navan

2117 1st pt 2; 3rd pt 2 Danny & Eilish Bermingham, Balreask Old

2118 1st pt 2 Balreask Old Daniel McCormack, Balreask House, Navan

2131 1st pt 2 Balreask Old Michael & Teresa Crowley, Balreask Old,

Dublin Road, Navan

2132 1st pt 2 Balreask Old Noel & Josephine Hogan, Balreask Old,

Dublin Road, Navan

2137 1st pt 2 Balreask Old Mary & Patrick Cleary, Naomh Mhuire,

Dublin Road, Navan

2140 1st pt 2 Macetown Maureen Foley, Macetown, Navan

2142 1st pt 2 Macetown Stan & Bernadette Kennelly, Knockanure House,

Macetown, Navan

2146 1st pt 2 Macetown Padraic & Denise Kilcoyne, Macetown,

2150 1st pt 1&2; 4th Macetown Owen & Mary McElroy, 44 Dunville Avenue

Rathmines, Dublin 6

1019

2151 1st pt 1&2; 4th Gainstown Patrick & Monica Sherlock, Gainstown,

Navan

2151 1st pt 1&2; 4th Gainstown John Sherlock, Oldtown, Bohermeen, Navan

( Not included in CPO but landowner has now acquired

land to south of his yard affected by CPO -- See amendment list)

2155 1st pt 2 Gainstown Donagh & Sheila Russell, Gainstown, Navan

2156 1st pt 1&2; 4th Gainstown John & Majella Carolan, Woodview Cottage,

Flemingstown, Balrath, Navan

2157 ) 1st pt 2 Gainstown Edward & Aileen Maguire, Gainstown, Navan

2158 ) 1st pt 2; 3rd pt 2 Gainstown

2158 1st pt 2; 3rd pt 2 Gainstown Gerard & Margaret Ormond, Gainstown

2159 1st pt 1&2; 4th Gainstown Fiona & Patrick Reilly, Gainstown

2162 1st pt 1&2; 4th Hanlonstown William & Margaret Smith, Curraghtown, Navan

2164 ) 1st pt 1&2; 4th Hanlonstown Jane Lightholder, Hanlonstown, Navan

2180 ) 1st pt 1&2; 4th Boyerstown

2165 1st pt 1&2; 4th Hanlonstown Patrick Darcy, Boyerstown, Navan

2166 ) 1st pt 1&2; 4th Boyerstown John & Marcella Devine, Boyerstown,

2384 ) 1st pt 1&2; 4th Boyerstown

2167 1st pt 1&2; 3rd ; 4th Boyerstown Joseph & Mary Casserly, Boyerstown,

2170 1st pt 1&2; 4th Boyerstown John McGlew, Boyerstown

2173 1st pt 2 Boyerstown Reps of Rose Wall --- James & Teresa Wall

16 Woodbine Lawn, Inniscarra View.

Ballincollig. Co. Cork

2180 1st pt 1&2; 4th Boyerstown Reps of Patrick Brady, c/o Brian Hughes

26 Magdalene Street, Drogheda

2181 1st pt 2 Knockumber Sean Murtagh, Boyerstown, Navan

2183 ) 1st pt 2 Knockumber James & Thomas Dowdall, Knockumber,

2185 ) 1st pt 2 Robinrath Navan

1020

2193 1st pt 1&2; 4th Ardbraccan Christopher Collins, Ardbraccan, Navan

2200 1st pt 1&2; 4th Ardbraccan Margaret & John Donaghy, Ardbraccan, Navan

2201 ) 1st pt 2 Ardbraccan Ann & Mathew Coffey, Possecks Town, Enfield

2224 ) 1st pt 2 Betaghstown

2202 1st pt 2 Ardbraccan Joseph Bartley, Ardbraccan

2203 1st pt 2 Ardbraccan John Markey, Ardbraccan

2208 ) 1st pt 1&2; 4th Ardbraccan Liam & Bernadette Harte, Ardbraccan

2217 ) 1st pt 2 Ardbraccan

2210 1st pt 2 Ardbraccan Sean & P.J. Galligan, Ardbraccan

2211 1st pt 2 Townparks David McCarthy & Yolanda Potter

21 Blackcastle Estate, Navan

2211 1st pt 2 Townparks Patrick Marron, 24 Moatville, Navan

2211 1st pt 2 Townparks Patrick O'Brien, 23 Moatville, Navan

2215 1st pt 1&2; 4th Ardbraccan Michael Peter Fitzsimons, Ardbraccan, Navan

2216 1st pt 2 Ardbraccan Joseph & Elizabeth Harte, Boyerstown,

2217 1st pt 2 Ardbraccan Liam & Bernadette Harte, Ardbraccan

2219 1st pt 2; 3rd pt 2 Neilstown Peter & Carol Callaghan, Orgenstown,

Bohermeen, Navan

2220 1st pt 2; 3rd pt 2 Neilstown John & Margaret Donaghy, Ardbraccan,

2221 1st pt 2 Townparks Tara Mines Ltd. Knockcumber, Navan

(EIS Related) S.J. Maher, Ardbraccan House, Navan

2222 1st pt 2; 3rd pt 2 Neilstown Frank Reilly, Bohermeen, Navan

2223 1st pt 2 Neilstown Vivienne Kennedy, Neilstown Lodge, Neilstown,

Navan

2226 1st pt 2 Townparks John Carolan, Mullaghboy, Navan

1021

2322 1st pt 2 Boyerstown Reps of Anne Brady, c/o Brian Hughes

26 Magdalene Street, Drogheda

2324 1st pt 2 Williamstown or Bawn Eamonn Corley, Grange, Bective, Navan

2325 1st pt 2 Williamstown or Bawn Thomas & Maureen Hare,

Williamstown, Navan

2326 1st pt 2 Williamstown or Bawn Agnes Graham, Williamstown

2327 1st pt 2 Williamstown or Bawn Noel & Mairead McCormack

Site No. 3, Williamstown

2331 1st pt 2 Ardbraccan Darren Ward & Trecy McLoughlin

Copperbeech Cottage, Durhamstown, Ardbraccan

( EIS related ) Brian Smyth, Coolfore Road, Ardbraccan

3000 1st pt 1 &2; 4th Ardbraccan Conaty's Farms Ltd. c/o Kevin Conaty

Boyerstown, Navan

3002 1st pt 1&2; 4th Ardbraccan Tommy Nally, Churchtown, Navan

3003 1st pt 1& 2; 4th Grange Sean Bennett, Ardbraccan

3004 1st pt 1& 2; 4th Grange Rose & Andrew Rispin, Grange, Bohermeen

Navan

3006 1st pt 1& 2; 4th Grange Patrick Rispin., Grange, Bohermeen

3007 1st pt 1& 2; 4th Grange Andrew Rispin, Grange, Bohermeen

3012 1st pt 1& 2; 4th Pheonixtown John McLoughlin, Phoenixtown,

Ardbraccan

3013 1st pt 2 Phoenixtown Dermot English, Phoenixtown, Bohermeen, Navan

3014 1st pt 2 Phoenixtown Vincent & Pauline Rennick, Cedar Lodge,

Phoenixtown

3016 1st pt 1&2; 4th Pheonixtown Thomas Tallon, Martry, Kells

3017 1st pt 1&2; 4th Martry Patrick Martin Boggins, Nugentstown, Kells

3018 1st pt 1&2; 4th ; 7th pt 1 Ballybeg Andrew Brooks, Febog, Kells

1022

3019 1st pt 2 Ballybeg Fintan & Hilda Hogan, Ballybeg, Kells

3020 1st pt 2 Ballybeg Stephanie Waters, Ballybeg, Kells

3022 1st pt 1& 2; 4th Phoenixtown Michael & Betty Fox , Phoenixtown,

3024 1st pt 2 Ballybeg Patrick & Mary McRedmond,

98 Johnstown Avenue, Dun Laoghaire

3026 1st pt 1&2; 4th Ballybeg Andrew, James, Lawrence & Terence Brooks

Febog, Kells And

Kathleen Connell, Ballybeg, Kells

3030 1st pt 1& 2; 4th Nugentstown Gerard & Declan Mullen, Kilmainham, Kells

3031 1st pt 1& 2; 4th Nugentstown Gerard Mullen , Kilmainham, Kells

3032 1st pt 2; 3rd pt 2 Cookstown Great Michael & Mary Christine Foley,

Cookstown Great, Kells

3033 1st pt1& 2; 3rd ;4th Cookstown Great Cathal & Vivienne Usher, Cookstown,

Kells

3037 ) 1st pt 2 Kilmainham Brendan Heerey, Kilmainham., Kells

3109 ) 1st pt 2 Kilmainham

3038 1st pt 1& 2; 3rd pt 2; 4th Kilmainham John Newman, Curragh, Kilmainham

3039 1st pt 2 Kilmainham Winifred Madden, Kilmainham, Kells

3040 ) 1st pt 2 Kilmainham Tom Hickey, Kilmainham, Kells

3122 )

3041 1stpt 2 Kilmainham Eugene J. Reilly Kilberry House, Kilberry,

(Headfort) Navan.

3046 1st pt 1&2; 3rd pt 2; 4th Kilmainham Bridget Tansey, Carkfree, Ballinameen,

Boyle, Co. Roscommon.

3047 1st pt 1&2; 3rd pt 2; 4th Gardenrath Henry Newman, Gardenrath Road, Kells

3053 1st pt 1&2; 4th Townparks Henry & Una Newman, Gardenrath

Road

3052 1st pt1& 2; 3rd ; 4th Gardenrath Charles Reilly, Brentwood, Bective St. Kells

1023

3064 1st pt 1&2; 4th Rockfield Seamus & Irene Yore, East Lodge,

Rockfield Road, Kells

3065 1st pt 2; 7th pt 2 Rockfield George Armstrong and

W. & G. Armstrong (Kells) Ltd., Market Street, Kells

3066 1st pt 1& 2; 4th Townparks (Kells) Trevor Fitzherbert, Swynnerton,

Blackcastle, Navan

3070 1st pt 1& 2; 4th Townparks (Kells) Edmund & Peter Kelly, Balrath Road, Kells

3071 ) 1st pt 2 Calliaghstown Thomas Duffy , Boolies, Balrath, Kells

4009 ) 1st pt 2 Chapelbride

3072 1st pt 2 Newrath Little George Armstrong, Newrath, Kells

3075 1st pt 2 Townparks Thomas Gavigan, Farrell Street, Kells

3075 1st pt 2 Townparks Thomas & Veronica Flanagan, Oldcastle Road

Kells (as occupier)

3082 ) 1st pt 2 Townparks Damien & Mary Mulvany, Cavan Road, Kells

4009 ) 1st pt 2 Chapelbride

3078 ) 1st pt 2 Townparks Thomas Clinton, Carlanstown, Kells

3085 )

3087 )

3090 1st pt 2 Archdeaconry Glebe Monica Flanagan,

Archdeaconry Glebe, Kells and

Collette Flanagan-Lynch, Moynalty Road, Kells

3093 1st pt 2 Whitecommons Noel & Nuala Gilsenan, Whitecommons, Kells

3094 1st pt 2 Cakestown Glebe Norman Ormiston, Blackwater House, Kells

3095 1st pt 2 Cakestown Glebe Phillip Dunne, Cakestown Glebe, Kells

3097 1st pt 2 Kilmainham Laurence & Pauline Stafford Kilmainham, Kells

3101 ) 1st pt 2 Townparks Thomas & Veronica Flanagan, Oldcastle Road

3111 ) 1st pt 2 Townparks Thomas & Veronica Flanagan, Oldcastle Road

3103 1st pt 2 Cakestown Glebe Thomas Garvey, Rockfield Road, Kells

3104 1st pt 2 Cakestown Glebe Sean Flood, Cakestown Glebe, Kells

1024

3105 1st pt 2 Tankardstown Gabriel Coffey, Coolfore Road, Ardbraccan

and Joe Coffey, Tankardstown, Navan

3108 1st pt 2 Kilmainham Thomas & Vivienne Jennings, Allendale

Kilmainham, Kells

3123 1st pt 2 Grange Seamus Bennett, Ardbraccan, Navan

4000 ) 1st pt 2 Calliaghstown Eamonn Duffy , Boolies, Balrath, Kells

4002 ) 1st pt 2 Calliaghstown

4003 1st pt 2; 7th pt 1 Calliaghstown Edward & Bridget Whelan,

Calliaghstown, Kells

4007 1st pt 2 Boolies Thomas McGuinness, Boolies, Balrath

4008 1st pt 2 Boolies John Grimes, Boolies, Balrath

4011 1st pt 2 Chapelbride Mathew Tevlin, Boltown, Kilskeer

4015 1st pt 2 Drumbaragh James Meegan, Drumbaragh, Kells

4016 1st pt 2; 7th pt 2 Drumbaragh Patrick Carry, 154 Woodsland, Navan

4018 1st pt 2 Drumbaragh James McDonald, Drumbaragh, Kells

4019 1st pt 2 Drumbaragh Michael & Bernadette Meegan,

Drumbarragh, Kells

4025 1st pt 2 Castlekeeran Michael & Elizabeth Farrelly, Castlekeeran, Kells

4026 1st pt 2 Castlekeeran Laurence Farnan, Pottlebane, Carnaross

4027 ) 1st pt 2 Castlekeeran John Farrelly, Newrath Big, Lloyd, Kells

4028 ) 1st pt 2 Castlekeeran

4031 1st pt 2 Woodpole John O'Connor, 3 Chesterfield Grove,

Castleknock, Dublin 15

4035 1st pt 2 Woodpole Michael & Elizabeth Farrelly, Castlekeeran, Kells

4036 1st pt 2 Woodpole Matthew Farrelly Woodpole, Carnaross and

Christopher Farrelly, Woodpole

4037 1st pt 2 Woodpole Bernard Reilly , Cornasaus, Carnaross

1025

4039 1st pt 2 Pottlebane Matthew Muldoon, Ballylist, Carnaross

4045 1st pt 2 Derver Margaret Gingles, Derver, Carnaross

4051 1st pt 2 Derver Michael Lynch, Derver, Carnaross

4054 1st pt 2 Castlekeeran John Kearney, Meenlagh, Carnaross

4062 1st pt 2 Castlekeeran Ms. Betty Newman Maguire

Castlekeeran, Carnaross

4063 1st pt 2; 7th pt 2 Drumbaragh Kieran & Martina Meegan, Drumbarragh,

4067 1st pt 2 Boolies David Kellett, Invyaaroge, Baillieboro

Co. Cavan

4069 1st pt 2 Boolies Michael Farrelly, Boolies, Balrath

4073 1st pt 2 Derver Evelyn Reyburn, Cordoogan,

Monasterboice, Co. Louth

------------------------------------------------------------

1026

Appendix 2. List of People or Organisations that made Submissions in respect of

the Road Development to an Bord Pleanala within the prescribed

period :-

1. Duchas, 7 Ely Place, Dublin 2.

(a) Archaeological --- Land & Underwater

(b) Architectural.

2. An Taisce, Tailors Hall, Back Lane, Dublin 8. ( by Ian Lumley)

3. The Arts Council, 70 Merrion Square, Dublin 2.

4. Bat Conservation Group, Cavan/Meath Branch, 32 The Old Mill, Rathoath.

5. Meath Roads Action Group, c/o Eamon Halligan, Raynestown, Dunshaughlin

6. Meath Archaeological & Historical Society -- Oliver Ward, Spiddal, Nobber

7. Irish Georgian Society, 74 Merrion Square, Dublin 2.

8. Dunboyne Historical Society -- Linda Clare, Coolcommon, Batterstown, Dunboyne.

9. Liam Scott, Piercetown House, Piercetown, Dunboyne

10. Newtown Bridge Residents Association, c/o Lorrha Lodge, Summerhill Road

Dunboyne -- Deirdre Deasy & Owen McBreen

11. Garnett Hall Residents Association, c/o 5 Garnett Hall, Dunboyne --

Catherine Connolly & Dawn Tolan

12. David Deasy, Lorrha Lodge, Dunboyne

13. Owen & Mairin McBreen, Summerhill Road, Dunboyne

14. Mary Keane, Leshamstown, Drumree

15. Brendan & Dolores Murphy, Leshamstown

16. Jack Irwin, Roestown.

17. Frank Fitzmaurice, Leshamstown

1027

18. Andy Morgan, Leshamstown Lane

19. Barbara Finlay, Leshamstown Manor.

20. Raynestown Residents Association, Raynestown, Dunshaughlin

21. Patricia & James Conroy, Collierstown, Tara

22. Tom Foley & Karen Carty, Collierstown

23. Anastasia Crickley, 30A St. Kevins Road, Dublin 8

24. Seamus Farrelly, Hill of Skryne, Tara

25. Conor Newman, M.A., N.U.I., Galway

26. Dr. Brian Lacey, Discovery Program Ltd., 34 Fitzwilliam Place, Dublin 2.

27. John Delaney, Montbretia, Grange, Bective, Navan.

28. Shiela Bradley, Dowdstown, Garlow Cross, Navan

29. Kathleen & Patrick Farrelly, Dowdstown, Garlow Cross,

30. Pat Raleigh, Mission Education Department, St. Columbans, Dalgan Park.

31. Catherine Reilly, 48 Blackcastle, Navan

32. Margaret McGrath, Sion Cottage, Johnstown, Navan

33. Catherine Cleary, Sion House, Johnstown, Navan.

34. Pauline Connolly, c/o St. Michaels Secondary School, Loreto, Navan

35. Bellinter Residents Association, Bellinter

36. Thomas & Margaret Hamill, Bellinter, Navan

37. Helen Ryan, Ardsbeg, Bellinter

38. James McCaldrin, Oak Lodge, Bellinter

39. Anne Barber, Bellinter

40. Christopher & Claire Oakes, Bellinter

1028

41. John & Patricia McCormick, San Antonio, Bellinter

42. Alan Park, Bellinter Cross

43. Brendan, Anne, Estelle & Lynette Magee, Bellinter

44. Raymond & Elizabeth Martin, Bellinter

45. Cannistown Residents Association,

c/o Thelma Keating, Talara House, The Avenue, Ardsallagh

46. Aidan & Thelma Keating, Talara House, The Avenue, Ardsallagh

47. John & Rose Smyth, Ardsallagh

48. James McIntyre, Boyne Hill, Navan

49. M/s Steen O'Reilly & Co. Solicitors, Navan,

on behalf of Ronald Sherlock,

t/a Sherlock Furniture, Balreask Old, Navan.

50. Ray Keegan, Grange, Bective, Navan

51. Moatville Residents Association

by Ruth Cahill, Chairperson, c/o 10 Moatville

52. Patricia Gibney, 5 Woodlands, Navan ( For CPO - Plot 2387 )

53. Brian Smyth, Tankardstown, Navan

54. Richard Byrne, Ardbraccan

55. Edwina Dunne, Coolfore Road, Ardbraccan

56. Therese Coffey, Coolfore Road, Ardbraccan

57. Claudine Coffey, Coolfore Road

58. Sandra Coffey, Coolfore Road

59. Hugh Coyle, Coolfore Road

60. Paula Coyle, Coolfore Road

61. Thomas Regan, Coolfore Road

1029

62. Rebecca Rennicks, Coolfore Road

63. Ivan Rennicks, Coolfore Road

64. Brian Smyth, Coolfore Road

65. Fiona Feely, Coolfore Road, Ardbraccan

66. H.R. & R. M. Pagan, Islay, Ardbraccan, Boyerstown

67. Simon Hilliard, Ardbraccan, Boyerstown

68. Sean Finlay, The Glebe House, Ardbraccan

69. W. G. Dallas, Martry, Kells

70. Phillip Dunne, Cakestown Glebe, Kells (CPO related )

71. Mrs. Winnie Madden, Plot 3039 (CPO related)

72. Norman Ormiston, Blackwater House, Kells Plot 3094 (CPO related)

73. George Armstrong and W. & G. Armstrong (Kells) Ltd. Plot 3065 & 3072

(CPO related)

74. Edward & Bridget Whelan, Calliaghstown, Kells (Boolies Road) Plot 4003

(CPO related)

75. John Kearney, Meenlagh, Carnaross Plot 4075 (CPO related)

76. Gerard Murphy, Cavan Road, Kells

-------------------------------------

1030

Appendix 3 Objectors represented by M/s Gaynor Corr & Associates,

Agronomists and Property Consultants, Portlaois.

---------------------------------------------------------

Plot No. Townland Objectors name(s) Address

118 Roestown John & Kathleen O' Connor, Roestown, Drumree

119 Roestown Joseph & Ann McKillen, Roestown, Drumree

120 Roestown Arthur & Elodie McFaul, Roestown, Drumree

121 Roestown Tom & Mary Byrne, Ashling, Roestown, Dunshaughlin

122 Roestown Michael Delaney, Gaulstown, Dunshaughlin

123&124 Roestown Martin & Monica Kelly, Roestown, Drumree

137 Leshamstown John & Mary Neary, Leshamstown, Drumree

147 Readsland John Francis Morgan, Readsland, Dunshaughlin

148 Readsland Peter Conlon, Readsland, Dunshaughlin

150 Readsland Derek Gray, Readsland, Dunshaughlin

155 Drumree Valerie Sunner, Knockmark, Drumree

157 Drumree Declan Walsh, Knockmark, Drumree

162 Rath Hill Michael & Maureen Duffy, Rath Hill, Dunshaughlin

163 Rath Hill Sean & Bernadette Joyce, Rath Hill, Dunshaughlin

166 Rath Hill Pat Summerville, Rath Hill, Dunshaughlin

167 ) Rath Hill Patrick Jennings, Macetown, Navan

2147 ) Macetown

171 Knockmark Christopher Lynch, Knockmark, Drumree

c/o John Lynch, Augherskeagh, Drumree

173 Knockmark Drunree GAA Club, c/o Sean Walsh,

Augherskeagh, Drumree

174 Knockmark Eddie Bannon, Kilcoole, Drumree

182 Merrywell Eddie Bannon (as occupier)

182 Merrywell Patrick J. Geraghty, Greenacres, Powderlough

Dunshaughlin

186 Derrockstown Louis & Mary Murray ? Fortfield, Derrockstown

(Murphy given)

188 Derrockstown Thomas McManus, Derrockstown, Dunshaughlin.

195 Derrockstown Tom Feerick, Derrockstown, Dunshaughlin

197 RoW to Feerick

197 Derrockstown Patrick McHale, Derrockstown,

206 Derrockstown Patrick & Michael Corbett, Derrockstown

207 Derrockstown Andrew & Mary Neary, Derrockstown

208 Derrockstown Noel & Josephine McTigue, Derrockstown

213 Raynestown Patrick & Mary Townsend, Raynestown, Dunshaughlin

215 Raynestown Thomas & Irene Reeves, Raynestown,

217 Raynestown Raymond & Sheelagh Brennan, Raynestown

218 Raynestown Michael & Marion McCullagh, Raynestow

1031

221 Raynestown John O'Sullivan, Raynestown, Dunshaughlin

222 Raynestown Michael Clayton, 28 Greentrees Road, Dublin

223 Raynestown David & Patricia Crimmins, Raynestown

229 Raynestown Dermot & Philomena McGreal, Raynestown

230 Raynestown Peadar & Pauline Creagh, Raynestown

231 Raynestown Frank Goodman, Raynestown

232 Raynestown Joseph & Noreen Sheridan, Bush Lane, Raynestown

234 Raynestown Patrick Ennis & Joan Burke, The Bungalow, Raynestown

235 Raynestown John & Marie Drake, Raynestown

236 Raynestown Declan & Ellen Collins, Raynestown

237 Raynestown Desmond & Anne Bellew, Raynestown

238 Raynestown Sean & Patricia Wynne, Raynestown

239 Raynestown Eamonn & Mary Halligan, Raynestown

240 Raynestown John & Joanne Duffy, Raynestown

241) Raynestown Thomas & Pauline Everard, Raynestown

242)

257 Rathbeggan Sylvester McAuley, Roselawn,

280 Piercetown Brendan & Elizabeth Donnelly, Piercetown, Dunboyne

285 Piercetown Phillip Connell, Piercetown, Dunboyne

292 Piercetown Sean McGuirk , Piercetown, Dunboyne

307 Piercetown Kilsaran Concrete Ltd., Piercetown, Dunboyne

308 Piercetown SERLA Print Ltd, Serla House, Grennhills Road

Tallaght, Dublin 24

312 Woodpark Hugh Mullally , Woodpark, Dunboyne

320 Bracetown Laurence Ward, Norman's Grove, Clonee

325) Pace Reps of Christopher Gregan,

337) Dunboyne c/o Gertrude Gregan, Bennetstown, Dunboyne

329 Dunboyne Tom & Loreto Doherty, Newtown,

Summerhill Road, Dunboyne

339 Dunboyne Pat Gregan, Bennetstown, Dunboyne

342 Dunboyne Sean Delaney, Bracetown, Clonee

350 Bracetown Reps of Joseph Laurence Ward,

c/o Laurence Ward, Norman's Grove

351 Bracetown Michael Brazil , 23 Moatlands, Ratoath

356 Bracetown James & Frances Pheonix, Bracetown,

371 Clonee Strandfair Holdings -- Finnian O' Cinneide

Loughsallagh, Clonee ( as occupier)

375 Clonee Ciaran & Lisa Byrne, Loughsallagh, Clonee

450 Dunboyne John & Pamela Conneely, The Maples, Dunboyne

464 Roestown S.J.D. Developments Ltd. Tullameadow, Drumree

c/o Sean Dunleavy, Dunshaughlin

1053) Roestown Michael & Dymphna O'Brien Rockfield,

1060) Roestown Portmanna, Co. Meath

1059 Berrillstown Dermot, Bridget & David Carty, Berrillstown, Tara

1067 Collierstown Capt. Anthony & Catherine Canavan, Collierstown

1071 Collierstown John & Patricia Scanlon, Collierstown, Tara

1032

1087 Lismullin Patrick & Susan Meehan, Lismullen,

Garlow Cross, Navan

1088 Lismullin John & Maureen Meehan, Lismullen, Navan

1091 Berrillstown Gerard Stafford, Berrillstown, Tara

and David Carty, Berrillstown

1093 Ballinter Stephen & Margaret Neylon, Links View,

Bellinter, Navan

1106 Ballinter Brian Kelly, Bellinter, Navan

1109 Ardsallagh Cormac Murray, Wood Lodge, Ardsallagh

1109 Ardsallagh Thomas Wimesy, Gate Lodge, Ardsallagh

(as occupier)

1115 ) Ardsallagh James Foley (Junior), Ardsallagh, Navan

1117 ) Ardsallagh

1116 ) Ardsallagh James Foley (Senior), Ardsallagh, Navan

1118 ) Ardsallagh

1119 Ardsallagh Frank Corcoran, Cannistown, Navan

1121 Ardsallagh Reps of Robert Slattery,

c/o Joan Slattery, Mullinam, Mulhuddart

Co.Dublin

1123 Ardsallagh Peter & Rosanna Burke, Ardsallagh, Navan

1124 Ardsallagh Tony & Alison King, Tall Trees, Ardsallagh

1130 ) Ardsallagh John Columba McEvoy, 34 Market Square, Navan

1144 ) Ardsallagh (CIE claim ownership of 1144)

1133 Kennastown Reps of Frank Foley, Cannistown, Navan

1135 Kennastown Leslie & Mary Curtis, Cannistown

1136 Kennastown Sean Carty, Cannistown

2102 Williamstown or Bawn John Fahy, The Bawn, Williamstown, Navan

2103 Williamstown or Bawn Mark Corley, Grange, Bective, Navan

2107 Balreask Old Reps of Christopher Dowdall, Balreask Old, Navan

Thomas Dowdall, Trim road, Navan and

John Dowdall, Balreask Old, Navan

2110 Balreask Old Noel & Sandra Farrell, Balreask Old, Navan

2112 Kennastown Paul & Kathleen Foley, Cannistown

2113 Kennanstown Vincent Keating, Ardsallagh, Navan

2114 Kennastown Nicholas & Kathleen Keogh,

Rackenstown House, Dunshaughlin

2116 Ballybatter or Balreask New Shiela O'Keefe St. Anne's, Balreask, Navan

2117 Balreask Old Maurice & Joan Whelan, Balreask Old,

Dublin Road, Navan

2117 Balreask Old Danny & Eilish Bermingham, Balreask Old

2118 Balreask Old Daniel McCormack, Balreask House, Navan

2131 Balreask Old Michael & Teresa Crowley, Balreask Old,

Dublin Road, Navan

2132 Balreask Old Noel & Josephine Hogan, Balreask Old,

Dublin Road, Navan

1033

2137 Balreask Old Mary & Patrick Cleary, Naomh Mhuire,

Dublin Road, Navan

2140 Macetown Maureen Foley, Macetown, Navan

2142 Macetown Stan & Bernadette Kennelly, Knockanure House,

Macetown, Navan

2146 Macetown Padraic & Denise Kilcoyne, Macetown,

2150 Macetown Owen & Mary McElroy, 44 Dunville Avenue

Rathmines, Dublin6

2151 Gainstown Patrick & Monica Sherlock, Gainstown, Navan

2151 Gainstown John Sherlock, Oldtown, Bohermeen, Navan

( Not included in CPO but landowner has now acquired

land to south of his yard affected by CPO - - amend CPO)

2155 Gainstown Donagh & Sheila Russell, Gainstown, Navan

2156 Gainstown John & Majella Carolan, Woodview Cottage,

Flemingstown, Balrath, Navan

2157 ) Gainstown Edward & Aileen Maguire, Gainstown, Navan

2158 ) Gainstown

2158 Gainstown Gerard & Margaret Ormond, Gainstown

2159 Gainstown Fiona & Patrick Reilly, Gainstown

2164 ) Hanlonstown Jane Lightholder, Hanlonstown, Navan

2180 ) Boyerstown

2166 ) Boyerstown John & Marcella Devine, Boyerstown,

2384 ) Boyerstown

2167 Boyerstown Joseph & Mary Casserly, Boyerstown,

2170 Boyerstown John McGlew, Boyerstown

2183 ) Knockumber James & Thomas Dowdall, Knockumber,

2185 ) Robinrath Navan

2193 Ardbraccan Christopher Collins, Ardbraccan, Navan

2201 ) Ardbraccan Ann & Mathew Coffey, Posseckstown, Enfield

2224 )

2202 Ardbraccan Joseph Bartley, Ardbraccan

2203 Ardbraccan John Markey, Ardbraccan

2208 ) Ardbraccan Liam & Bernadette Harte, Ardbraccan

2217 ) Ardbraccan

2210 Ardbraccan Sean & P.J. Galligan, Ardbraccan

2211 Townparks David McCarthy & Yolanda Potter

21 Blackcastle Estate, Navan

2211 Townparks Patrick Marron, 24 Moatville, Navan

2211 Townparks Patrick O'Brien, 23 Moatville, Navan

2216 Ardbraccan Joseph & Elizabeth Harte, Boyerstown,

2219 Neilstown Peter & Carol Callaghan, Orgenstown,

Bohermeen, Navan

2220 Neilstown John & Margaret Donaghy, Ardbraccan,

2222 Neilstown Frank Reilly, Bohermeen, Navan

1034

2226 Townparks John Carolan, Mullaghboy, Navan

2324 Williamstown or Bawn Eamonn Corley, Grange, Bective, Navan

2325 Williamstown or Bawn Thomas & Maureen Hare,

Williamstown, Navan

2326 Williamstown or Bawn Agnes Graham, Williamstown

2327 Williamstown or Bawn Noel & Mairead McCormack

Site No. 3, Williamstown

2331 Ardbraccan Darren Ward & Trecy McLoughlin

Copperbeech Cottage, Durhamstown, Ardbraccan

3001 Ardbraccan Conaty's Farms Ltd. c/o Kevin Conaty

Boyerstown, Navan

3002 Ardbraccan Tommy Nally, Churchtown, Navan

3003 Grange Sean Bennett, Ardbraccan

3004 Grange Rose & Andrew Rispin, Grange, Bohermeen

Navan

3006 Grange Patrick Rispin., Grange, Bohermeen

3007 Grange Andrew Rispin, Grange, Bohermeen

3012 Pheonixtown John McLoughlin, Phoenixtown, Ardbraccan

3014 Phoenixtown Vincent & Pauline Rennick, Cedar Lodge,

Phoenixtown

3019 Ballybeg Fintan & Hilda Hogan, Ballybeg, Kells

3020 Ballybeg Stephanie Waters, Ballybeg, Kells

3022 Phoenixtown Michael & Betty Fox , Phoenixtown,

3024 Ballybeg Patrick & Mary McRedmond,

98 Johnstown Avenue, Dun Laoghaire

3030 Nugentstown Gerard & Declan Mullen, Kilmainham, Kells

3031 Nugentstown Gerard Mullen, Kilmainham, Kells

3033 Cookstown Great Cathal & Vivienne Usher, Cookstown, Kells

3037 ) Kilmainham Brendan Heerey, Kilmainham., Kells

3109 ) Kilmainham

3039 Kilmainham Winifred Madden, Kilmainham, Kells

3052 Gardenrath Charles Reilly, Brentwood, Bective St. Kells

3064 Rockfield Seamus & Irene Yore, East Lodge,

Rockfield Road, Kells

3066 Townparks (Kells) Trevor Fitzherbert, Swynnerton,

Blackcastle, Navan

3070 Townparks (Kells) Edmund & Peter Kelly, Balrath Road, Kells

3071 ) Calliaghstown Thomas Duffy, Boolies, Balrath, Kells

4009 ) Chapelbride

3082 ) Townparks Damien & Mary Mulvany, Cavan Road, Kells

4009 ) Chapelbride

3087 Townparks Thomas Clinton, Carlanstown, Kells

3090 Archdeaconry Glebe Monica Flanagan, Archdeaconry Glebe, Kells and

Collette Flanagan-Lynch, Moynalty Road, Kells

3095 Cakestown Glebe Philip Dunne, Cakestown Glebe, Kells

3097 Kilmainham Laurence & Pauline Stafford Kilmainham, Kells

1035

3103 Cakestown Glebe Thomas Garvey, Rockfield Road, Kells

3104 Cakestown Glebe Sean Flood, Cakestown Glebe, Kells

3105 Tankardstown Gabriel Coffey, Coolfore Road, Ardbraccan

and Joe Coffey, Tankardstown, Navan

3108 Kilmainham Thomas & Vivienne Jennings, Allendale

Kilmainham, Kells

3123 Grange Seamus Bennett, Ardbraccan, Navan

4000 ) Calliaghstown Eamonn Duffy , Boolies, Balrath, Kells

4002 ) Calliaghstown

4007 Boolies Thomas McGuinness, Boolies, Balrath

4008 Boolies John Grimes, Boolies, Balrath

4011 Chapelbride Mathew Tevlin, Boltown, Kilskeer

4019 Drumbaragh Michael & Bernadette Meegan,

Drumbarragh, Kells

4026 Castlekeeran Laurence Farnan, Pottlebane, Carnaross

4027 ) Castlekeeran John Farrelly, Newrath Big, Lloyd, Kells

4028 ) Castlekeeran

4031 Woodpole John O'Connor, 3 Chesterfield Grove,

Castleknock, Dublin 15

4036 Woodpole Matthew Farrelly Woodpole, Carnaross and

Christopher Farrelly, Woodpole

4037 Woodpole Bernard Reilly , Cornasaus, Carnaross

4039 Pottlebane Matthew Muldoon, Ballylist, Carnaross

4051 Derver Michael Lynch, Derver, Carnaross

4054 Castlekeeran John Kearney, Meenlagh, Carnaross

4063 Drumbaragh Kieran & Martina Meegan, Drumbarragh,

4067 Boolies David Kellett, Invyaaroge, Baillieboro, Co. Cavan

4069 Boolies Michael Farrelly, Boolies, Balrath

4073 Derver Evelyn Reyburn, Cordoogan,

Monasterboice,Co. Louth

------------------------------------------------------------

1036

Appendix 4. List of Documents handed in to Hearing

from 21 August to 21 November

Day 1 -- 21 August

Letter from Dillon Eustace, Solicitors, dated 30/04/02 on behalf of their clients, Mr.&

Mrs. Morrin -- copy of their original submission to An Bord Pleanala.

Copy of Agreement between Meath County Council and Mr. Basil Brindley, Rathbeggan

House Stud and Withdrawal of his Objections to Plot 258.

Written Submission from Moatville Residents Association handed in to Hearing.

Copy of letter of 20 August from CIE withdrawing their objections with regard to plots

469, 1144, 3032, 3046 & 3115.

Brief of Evidence by Alan Guthrie, Project Technical Co-ordinator ( 2 copies)

Brief of Evidence by Charles Richardson, Traffic Engineer.

Day 2 -- 22 August

Brief of Evidence of Michael Killeen, Senior Executive Engineer, Planning Department,

Meath County Council

Report by Dr. D. O'Cinneide, Traffic Research Unit, U.C.C. on Prediction of Traffic

Volumes on N2/N3, handed in by Pat Butler SC for Meath County Council during

Charles Richardson's Evidence.

Submission by Father Sean McDonagh SSC, Dalgan Park -- "Motorway Madness."

Meath County Development Plan 1994, referred to in Mr. P. Butler's opening statement

and requested by Inspector.

List of Clients of Sudway & Co. who are making no further submissions to Hearing.

Written Submissions from Vitgeson Ltd. -- Plot 2117, Thomas McManus -- Plot 188 &

Andrew Brooks - Plot 3018, handed in by Sudway & Co.

Briefs of Evidence for Clonee to Dunshaughlin Section for Council from:-

Susan Joyce -- Engineering; Philip Farrelly -- Agricultural Properties

Prof. Kevin Dodd -- Agriculture; Ray Hanley -- Non-agricultural Properties

Edward Porter -- Air Quality; Bill Quirke -- Aquatic Environment

David Wilson -- Drainage; Thomas Burns -- Landscape & Visual effects

Chris Dilworth -- Noise & Vibration; Alan O'Connell -- Lighting

Bill O'Kelly-Lynch -- Socio Economic; Roger Goodwillie -- Terrestrial Env.

Harold O'Sullivan -- Architecture Heritage; Thaddeus Breen -- Archaeology

Brief of Evidence of Suzanne Dempsey of MC O'S -- Overview of EIS ( all sections)

Day 3 -- 23 August

FAX copy of letter sent by An Bord Pleanala to Waterford Corporation on 11 March

2002 regarding "Additional Information" -- referred to by Mr. Peter Sweetman in crossexamination

and request for an adjournment on 22 August. This "letter" sought from An

Bord by Inspector on 23 August. Photocopy of Fax also attached.

1037

Day 4 -- 27 August

Written Submission from Derek Gray, Readsland, Drumree. -- Plot 150

Copy of advertisement dated 19 December 2001 of proposed Variation to 2001 County

Development Plan, handed in by Mr. Galligan S. C. during cross-examination of Mr.

Killeen

Copy of NRA "National Roads Project Management Guidelines" handed in by Mr. T.

Flynn BL for Ardbraccan House as requested by Inspector from Mr. Galligan, SC, during

his cross-examination of Alan Guthrie.

Map showing Locations of possible Material Sources for M3 scheme handed in by Meath

County Council to Hearing

Copy of Newspaper Notice of Meath County Development Plan 2001 Variation No.2,

handed in during Mr. Galligan's cross-examination of Michael Killeen.

Briefs of Evidence for Dunshaughlin to Navan Section for Council handed in from :-

Alan Guthrie -- Engineering; Ernie Crawford -- Air Quality

Margaret Gowan -- Archaeology; Harold O'Sullivan -- Built Heritage

Eamon Daly -- Drainage; Richard Nairn -- Ecology

Thomas Burns -- Landscape & Visual Aspects; Philip Farrelly -- Agriculture

Stephen Summers -- Noise & Vibration; Liam Prendiville -- Socio Economics

Peter Sheehy -- Structures

Day 5 -- 28 August

Tables showing Traffic Volumes on the individual sections of M3/N3/N52 compared to

Capacity in Needs Study and Cross-sections proposed compared to those in Needs Study

-- handed in by Meath County Council as requested by Inspector during Alan Guthries

Cross-examination.

Copy of letter from NRA to Meath County Engineer dated 28 February 2001, handed in

by Michael Killeen, SEE Planning during re-examination by Pat. Butler SC for Meath

County Council.

Extracts from National Roads Needs Study & National Development Plan handed in by

Pat Butler SC as requested by Inspector

Verbal submissions made by :-

(1) Tom Doherty, Newtown, Summerhill Road, Dunboyne -- Plot 329

(2) Ciaron & Lisa Byrne, Loughsallagh, Clonee -- Plot 375

(3) Finnian O' Cinneide, Loughsallagh Cross, Clonee -- Plot 371

(4) Raynestown Residents Association

Written submissions from :-

(1) Sean & Bernadette Joyce, Rath Hill, Dunshaughlin -- Plot 163

(2) Pat Summerville, Rath Hill, Dunshaughlin -- Plot 166

(3) Michael & Maureen Duffy, Rath Hill, Dunshaughlin -- Plot 162

(4) Sean Delaney, Bracetown, Clonee -- Plot 342

(5) Maureen Foley, Macetown, Navan -- Plot 2140

(6) Thomas & Maureen Hare, Grangecon, Trim Road, Navan --Plot 2325

1038

(7) Peadar & Pauline Creagh, Raynestown, Dunshaughlin -- Plot 230

Briefs of Evidence for Navan Bypass Section for Council from :-

Susan Joyce -- Engineering; Philip Farrelly --Agricultural Properties

Jean Clarke -- Non-agricultural Properties

Edward Porter -- Air Quality; Bill Quirke -- Aquatic Environment

David Wilson -- Drainage; Thomas Burns -- Landscape & Visual effects

Chris Dilworth -- Noise & Vibration; Alan O'Connell -- Lighting

Bill O'Kelly-Lynch -- Socio Economic; Richard Nairn -- Terrestrial Env.

Harold O'Sullivan -- Architecture Heritage; Thaddeus Breen -- Archaeology

Day 6 -- 29 August

Verbal Submissions made by :-

(1) Geraldine Hennessey, Spearsview Cottage, Cooksland, per Kevin Walsh

(2) Laurence Ward, Normans Grove, Clonee -- Plot 320

(3) Joe McKillen on behalf of 10 Dunsany Road Residents

(4) Deirdre Deasy & Owen McBreen for Newtown Bridge Residents Association

(5) Owen & Mairin Mc Breen, Newtown, Summerhill Road, Dunboyne

(6) Sheila Bradley, Dowdstown, Garlow Cross, Navan

(7) Patrick & Kathleen Farrelly, Dowdstown, Garlow Cross. Navan

Written Submission from Gerry & Catherine Corry, Crosskeys, Drumree per Druker

Fanning & Partners -- Plot 183

N3 Clonee to Dunshaughlin Tolka River Impact Study, Vol. 2, River Catchment Study,

handed in by Pat Butler SC for the Council arising from submissions by Owen McBreen

Day 7 -- 30 August

List of Additional Withdrawals of Objections handed in to Hearing by Tom Corr of

Gaynor Corr

Verbal Submission from James Finlay & Brendan Murphy for Leshanstown Lane

Residents

2 Maps of Raynestown Road O/B Realignment handed in by Susan Joyce of MC O'S

arising from cross-examination on the need for Access Road no. 13 to Plot 251 by

Raynestown Residents

Day 8 -- 3 September

Map & Photographs handed in by Evan Newall -- Plots 139 & 144-- during his crossexamination

of Susan Joyce, Project Engineer

Matrix of Route Options for R125 requested by Michael Kieran - Plot 172 -- on Day 7

during his cross-examination of Susan Joyce

Map of his site handed in by Tom Byrne -- Plot 121 -- during his cross-examination of

Susan Joyce

1039

Extract from Roads Act 1993 for Section 69 thereof, handed in by Esmond Keane BL for

the Council arising from Laurence Wards Submission.

Day 9 -- 4 September

Brief of Evidence by Michael Osborne, Equine Expert Witness for the Council.

Day 10 -- 5 September

FAX received at Hotel on 4 Sept. -- Treated as additional (written) submission from Liam

Scott of Piercetown House.

FAX of report from Bill O'Kelly-Lynch to Suzanne Dempsey of MC O'Sullivans

(MCO'S) with details of Pedestrian count taken at N3/R157 Fairyhouse junction as

requested by Inspector following issues raised by Liam Scott at Hearing on Day 9.

Documents handed in by Meath County Council as requested by Inspector :-

1. Extracts from 1994 & 2001 Meath County Development Plans (CDP) :-

Section 3.5.10 - Trees and Woodlands from 1994 CDP

Section 3.6.5 (1) - Tree Preservation from 2001 CDP

Section 2.7 & 2.7.1 - Strategic Infrastructure Needs and Transportation

from 2001 CDP -- Public Transport

2. Section 13 of Planning & Development Act 2000

3. Planning Permissions granted ( with planning Ref. No.) for Borrow Pits for

M1 Motorway Project

4. Strategic Planning Guidelines (SPGs) for the Greater Dublin Area and

Executive Summary of same.

5. Review and Updates of SPGs of April 2000, April 2001 & April 2002

6. " Composite" Map requested by Inspector arising from Michael Killeen's

evidence showing Areas of Visual Quality; Views and Prospects & Tree

Preservation Orders in the 2001 CDP with route of M3 superimposed.

7. Two Maps showing N3/M3 Route Reservations on the 1994 and 2001 CDPs,

requested by Inspector arising from Michael Killeen's evidence.

Copy of Agreement reached between Dubai Bloodstock Ltd and Meath County Council

for Withdrawal of their objections for Plot 301

Errata Addendum to Vol. 3A of EIS , Chapters 4 & 17, handed in by Suzanne Dempsey

of MC O'S for the Council

Documents handed in by Susan Joyce, Project Engineer, arising from her crossexamination

:-

Costings/ Feasibility for pedestrian overbridge at PACE Interchange arising from

Liam Scotts cross-examination.

Costings / Feasibility for replacing Road Bridge on R125 arising from

Leshamstown Lane issues.

Response to query about "Uneven Drying of ground" by Tom Byrne -- Plot 121

Copies of correspondence with Eastern Regional Fisheries Board arising from

queries regarding effects on Rivers Tolka & Skane.

Calculations of Truck Movements expected in Construction Excavation/Filling

1040

Movements

Costings for Lighting along Leshamstown Lane

NRA guidelines for Road Design, cross sections etc

NRA letter of approval of 23/06/00 to PPP program with list of projects and covering

letter of 28/08/02 handed in by Council -- as requested by Inspector.

Eastern Fishery Board letter of confirmation of agreement on river/stream crossings dated

25/02/02 for Clonee to Dunshaughlin and Navan Bypass sections -- as requested by

Inspector

Dept. of Transport (UK) - A road safety Good Practice Guide - handed in to Hearing by

Bernard Walsh, Summerhill Road, Dunboyne in support of his request that the

Roundabout be reduced in size, and with supporting Documents on Roundabout Design

from European Countries and the "Galway Cycling Campaign" publication on

Roundabouts.

Copies of "Newtown Bridge" ( Dunboyne) discussions with Bernard Walsh -- Plot 331 --

handed in by Susan Joyce of MC O'S for the Council

Two Files of Responses to Specific Objections -- Vol. 1 & Vol. 2 -- for Clonee to

Dunshaughlin Section and Additional File of Non-specific Responses for Clonee to

Dunshaughlin and Navan Bypass Sections handed in by Susan Joyce, Project Engineer

List of Additional Withdrawals of Objections handed in to Hearing by Tom Corr of

Gaynor Corr.

Day 11 -- 10 September

Copy of Agreement reached between Eamon Walsh, Courthill, Dunboyne and Meath

County Council for Withdrawal of his Objections to Plot 475

Brief of Evidence given by Micheael Kieran, Knockmark, Drumree in support of his

Objection to Plot 172

Map of R125Link Road with Plots adjoining Micheal Kieran marked handed in by susan

Joyce followinhg Mr. Kieran's evidence

Brief of Evidence with Photographs and maps given by Tom Byrne, Roestown,

Dunshaughlin in support of his Objections to Plot 121

Maps showing locations of Noise Barriers and Footpaths handed in by Susan Joyce of

MCO'S arising from her cross-examination by Liam Scott, Piercetown House

Written Submission to Hearing from David & Olive Carty, Berrillstown, Tara -- Plot

1059

Written submission to Hearing from Terry Foley & Karen Carty, Collierstown, Tara

Written submission to Hearing from Anthony J. McDonnell of his objections to Plots 352

& 353 handed in by Sudway & Co on his behalf.

Photographs referred to by Evan Newall during his cross-examination of Harold O'

Sullivan on Architectural Heritage issues -- Plots 139 & 144

Council's Response to issues raised by Duchas in their Submission to An Bord Pleanala

on the Architectural Heritage sections in the EIS Vols. 3A to 6A, handed in by Meath

County Council as part of Harold O' Sullivan's evidence for Dunshaughlin to Navan

Section.

Harold O' Sullivan's Response to Submission by Duchas to An Bord Pleanala on Vols 3,

4 & 5

1041

Margaret Gowan's Response to Submission by Duchas to An Bord Pleanala on

Archaeology and architectural Heritage sections of EIS

Day 12 -- 11 September

Copy of note from Roads Design Office, Navan, to Liam Scott on the cost estimate for a

Pedestrian Overbridge arising from his cross-examination of Susan Joyce on 10 Sept.

Briefs of Evidence (2) of Michael Osborne on Equine matters for the Council for the

Clonee to Dunshaughlin and the Dunshaughlin to Navan & Navan By-pass sections

Copy of Advert used for "1st Public Consultation" exhibitions on 15 December 1999 as

requested by Inspector arising from cross-examination of Alan Guthrie, Project Engineer

by Brendan Magee of MRAG

Copy of "Letter of Approval" from NRA to M3 Scheme requested by Inspector arising

from Alan Guthries cross-examination by Brendan Magee

Day 13 -- 12 September

Verbal submission to Hearing by Julitta Clancy for Meath Archaeological and Historical

Society

Verbal Submission to Hearing by Seamus Farrelly, Hill of Skryne

"Archaeological Assessment, Preliminary Corridor" -- Report of June 1999 by Valerie J.

Keeley Ltd marked "Navan 1A 1999" handed in by Meath County Council during

Brendan Magees (MRAG) cross-examination of Thaddeus Breen, Archaeologist for the

Council, on this 1999 Report

Details of Costing for Underpass for Ryans, Lismullin -- Plot 1083, handed in by Alan

Guthrie as requested by Inspector

Five Files of Responses by Halcrow Barry Consultants for Meath County Council -- 2

copies of Vol. 1 of 1 for "General Objections", Vol. 1 of 2 & Vol. 2 of 2 for "Specific

Objections" and combined Vol.1 & 2 of "Specific Objections"

Day 14 -- 8 October

Written Submission from Patrick & Susan Meehan, Lismullen, Garlow Cross, Navan, -

Plot 1087 -- handed in on their behalf by Tom Corr of Gaynor Corr

Written Submission by Billie & Valerie Sunner, Knockmark, Drumree -- Plot 155 --

handed in on their behalf by Tom Corr

List of Additional Withdrawals of Objections handed in to Hearing by Tom Corr

Day 15 -- 9 October

Details of well water depths in Seamus Farrellys well handed in by Alan Guthrie arising

from Seamus Farrellys original submission.

Details of Accident Data on N3 handed in by Alan Guthrie, as requested by Inspector

1042

Day 16 -- 10 October

Photographs / Photomontages of View A and View B handed in by Thomas Burns,

Landscape Consultant for Council during his cross-examination by Ml. O' Donnell BL

and Peter Sweetman

Side-road Details for Dunshaughlin/Navan requested by Inspector during Alan Guthrie's

cross-examination on Farm Machinery difficulties for Dalgan Park using Dowdstown

Overbridge.

Brief of Evidence of Jack O'Sullivan, Environmental Consultant on behalf of the

Missionary Society of St Columban, Dalgan Park

Submission to Hearing by Fr. Pat Raleigh with Objections on behalf of Dalgan Park and

Dowdstown House.

Petitions objecting to building of Motorway through Dalgan Park submitted to Hearing

by Fr. Pat Raleigh, with covering letter and bundle of petitions

Submission to Hearing on Dalgan, its History, Archaeology and Natural Resources by

Ger Clarke, Development Officer, Mission Awareness Centre.

Route Selection Report for Dunshaughlin to Navan,Vols. 1 & 2 of Sept. 2001, handed in

by Alan Guthrie as requested by Inspector arising from cross-examination issues.

Two Files of Responses to Supplementary Objections for (1)Clonee to Dunshaughlin

Section and (2) Navan By-pass Section handed in by Susan Joyce, Project Engineer.

Day 17 -- 15 October

Copy of A4 page showing "Core area" of Tara as in Conor Newmans study of 1999,

handed in by Margaret Gowan, Archaeologist for the Council during her crossexamination

by Brendan Magee of MRAG

Two "Maps" of Tara area displayed by Margaret Gowan during her cross-examination

Copies of letter of 5 Sept. 2001 from Ombudsman to Bellinter Residents Association

handed in by Alan Park arising from his cross-examination of Margaret Gowan

Submission to Hearing with their Objections by Bellinter Residents Association (BRA)

Minutes of Meetings between Iarnrod Eireann and County Council/ Consultants on Rail

line issues, handed in to Hearing by Susan Joyce during BRA cross-examination.

Submission to Hearing with their Objections by Meath Roads Action Group (MRAG)

Supporting Documents handed in by MRAG -- (1) Agenda & Minutes of N3 Coordination

Meeting in St. Martins House (NRA HQ) on 5 April 2000; (2) No Dual

Carriageway through Tara & Dalgan areas compileid by BRA; (3) Alternative to N2 &

N3 Dual carriageways by MRAG & Constraints Study for Dunshaughlin to Navan, Final

issue of Jan. 2000

Assessment Matrix - Scheme Ranking handed in by Brendan Magee during his crossexamination

of Alan Guthrie

Verbal Submissions to Hearing from :-

Christopher & Claire Oakes, Belinter

Aidan Barber, Bellinter

Brendan Magee, Bellinter

1043

Written Submissions to Hearing from :-

Alan Park, Bellinter Cross -- Plot 1101

John & Patricia McCormack, Bellinter

Raymond & Elizabeth Martin, Bellinter

Day 18 -- 16 October

Verbal submission with File of supporting Documentation and Maps by Thomas &

Margaret Hamill, Bellinter

Brochure of "N3 Dunshaughlin to Kells Emerging Prefered Route" handed in by Susan

Joyce, Project Engineer

Three Files of Responses to Objections/Submissions for Navan to Kells and Kells to

North of Kells Sections handed to Inspector by Mike Evans Project Engineer of Arups

Briefs of Evidence for (1) Navan to Kells section and (2) Kells to North of Kells section

for Council from :- ( Separate Brief for each section from each Consultant )

Mike Evans of Arup -- Engineering; Thomas Burns -- Landscape & Visual

Philip Farrelly -- Agricultural; Air Quality -- Edward Porter

Siobhan Deery -- Archaeology; Chris Dilworth -- Noise & Vibration

Bill O'Kelly-Lynch -- Socio economic: Kevin Cleary -- Lighting

Richard Nairn -- Terrestrial Environment.

Jackie Jordan -- Architecture & Cultural Heritage

Day 19 -- 17 October

A3 copies of Margaret Gowans Graphics displayed by her during cross-exanination by

BRA/MRAG on 15 Oct. handed in to Inspector by Alan Guthrie

Brief of Evidence given by Paul Morrin on behalf of the Morrin Family-- Plots 149 &160

Brief of Evidence given by Robert Byrne, Agricultural Consultant for the Morrin Family

Submission to the Hearing by the Cannistown Residents Association

Submission to the Hearing by Evan Newall outlining basis for Agreement reached with

Meath County Council on the Newall objections to Plots 139 & 144

Day 20 -- 18 October

Documents handed in to Hearing by Susan Joyce, Project Engineer :-

Drawings showing areas where "redundant" road surfaces would be ripped up

arising from cross-examination issues, for Clonee to Dunshaughlin and

Navan Bypass sections

Drawings showing Cross-sections for houses at Overbridge realignments as

requested by Inspector, for Clonee to Dunshaughlin and Navan Bypass sections

Clonee to Dunshaughlin Route Selection Report, August 2000;

Navan Bypass Route Selection Report, 2001 and Navan Bypass Interface Route

Options Report -- arising from cross-examination issues.

Book of Additional Drawings showing (1) Locations of Footpaths proposed at

Roundabouts on Navan Bypass (2) Locations of Noise Barriers on Navan Bypass

(3) Details of Alternative Routes suggested from Public Consultations.

1044

Proposed Noise Criterion (Amended from that in EIS) for M3 scheme handed in to

Hearing by Council

Additional Information on Noise Impacts at Ardsallagh Road arising from BRA crossexamination

, handed in to Hearing by Council

Day 21 -- 22 October

Briefs of Evidence by Joe Higgins; Michael Kauntze; Robert Bryan; DBFL Consulting

Engineers; CRDS Ltd. and supporting documentation on behalf of Gerrardstown House

Stud -- Plot 1056

Extract from GSB Prospection Maps showing Geophysical results of Area 26 handed in

by Meath County Council during Lisa Courtney's cross-examination by Declan McGrath

BL for Gerrardstown.

Third Schedule to Housing Act 1966 handed in by Mr. Declan McGrath BL during his

Closing Submission on behalf of Gerrardstown Stud.

Copies of Undertakings given by Meath County Council to residents of the Dunsany

Road to undertake surveys and, if required from road construction impacts, rectification

works on individual wells and including Zone of Influence Map. Handed in to Hearing

by Meath County Council -- See Verbal Submission made by Joe McKillen on Day 6

N3 Navan to Dunshauughlin Road Improvement -- Summary of Environmental Impacts -

Extract from Route Selection Report of July 2001. Handed in by Alan Guthrie as a copy

of document referred to by MRAG during their submission to Hearing on Day 17.

Day 22 -- 23 October

Details of Wind Speed as recorded at Dublin Airport and Clones Met. Stations for 8

November 2000. Handed in by Alan Guthrie for the Council arising from the Inspector's

query following BRA cross-examination of Mr. Summers about noise measurements in

Dalgan Park.

Beaufort Scale of Wind Speeds, handed in by Meath County Council and refers to BRA

cross-examination of Mr. Summers, Noise Consultant for the Council

Report on Effects of Transposition of Data in Assessment Matrix at Table 4.2 in EIS

Vol.2, handed in by Alan Guthrie following request by Inspector and arising from crossexamination

of Thomas Burns, Landscape Consultant for the Council by BRA

Copy of Letter from European Commission, DG Environment to Ian Lumley, An Taisce

dated 10/10/2002 regarding An Taisce complaint to the EC ref. P2002/4957 about the

Carrickmines Castle issue, handed in by Ian Lumley, Heritage Officer of An Taisce

during his Verbal Submission to the Hearing

Verbal Submission by the Nicholas Keoghs, Senior and Junior, Dunshaughlin regarding

their land at Cannistown -- Plot 2114 -- to the Hearing, with Supporting Documents they

handed in of (1) Department of Agriculture, Food and Rural Development Advice for

Herd Owners on Keeping Herds Free from TB; (2) Photo Map showing M3 crossing

their lands at Cannistown & (3) Catalogue for John Deere 9000 WTS Combines.

Brochure of Thatched Cottage for Sale at Castlekeeran, Carnaross, handed in by Betty

Newman-Maguire during her Evidence to Hearing -- Plot 4062 refers.

1045

Copy of letter from Casey & Co. Solicitors, Bandon advising that they now represent

Sarah Maher/Lawson, Ardbraccan House in place of Arthur P. McClean & Co.

Briefs of Evidence ( 7 no. in all ) and Photographs handed in by Karl Searson, Consulting

Engineer on Noise impacts for Objectors

Points of agreement reached between Meath County Council and Sherlock Furniture,

Swan Lane, Navan regarding alternative access and withdrawal of objection, handed in

by Frank Burke on his behalf.

List of Additional Withdrawals of Objections handed in to Hearing by Tom Corr of

Gaynor Corr

Day 23 -- 24 October

Closing Submission made to Hearing by Leshamstown Lane group

Verbal Submission made to Hearing by Conor Newman, NUI Galway re Archeaeology

of Tara and M3

Details handed in by Susan Joyce of :-

(1) Ballybatter Road Traffic Diversion Management Proposals -- arising from

Cannistown Residents Association Submission on Day 20

(2) "Advanced Planting" Proposals as requested by Inspector for

Clonee/Dunshaughlin & Navan By-pass Sections

(3) Costings of "Separation" for Shared Overbridge for Morrins & Delaney

arising from Evidence given on Day 19 and the Inspector's suggestion

(4) Woodpark Road to Piercetown Footpath proposals arising from L.Scotts

cross-examination.

Day 24 -- 30 October

Box with Set of Documents from Arups handed in by Mike Evans, Project Engineer for

Navan to Kells to North of Kells Sections :-

(1) Constraints Report and Route Selection Reports of 1999, 2000 & 2001 for

Navan/Kells and Kells/North of Kells Corridors

(2) Cross Sections showing Houses in relation to Overbridge realignments

(3) Woodpole O/B showing possibilities of retaining "Old School Building"

(4) Traffic figures for M50 Toll plaza and M3 Toll Plaza projections

Written submission from Kieran & Martina Meegan, Drumbarragh -- Plot 4063

Letter of Agreement with Meath County Council from Keaveny Walsh & Co. Solicitors

on behalf of Thomas & Veronica Flanagan and Withdrawal of Objections to Plots 3101

& 3111

Written and Verbal Submission from R. Pagan on behalf of Boyerstown/Ardbraccan N3

Navan By-pass Group to Hearing

Documents used by Peter Sweetman during his cross-examination of Richard Nairn,

Ecological Consultant for the Council :-

(1) Council Directive 92/43/EEC, ( Habitats directive) downloaded from EU

Website

(2) Assessment of Plans and Projects Significantly Affecting NATURA 2000

sites -- Env. DG -- November 2001

1046

(3) Managing NATURA 2000 Sites -- The Provisions of Article 6 of the

"Habitats" Directive 92/43/EEC

Briefs of Evidence given to Hearing by Ronald J. Bergin, Consulting Engineer for several

Objectors -- Mr. & Mrs. Henry Newman, Plot 3047; Reps of Patrick Peters, Plot 294;

Limestone Land Co. Ltd. ( Tara Stud), Plot 1064; Reps of P.J. Roche, Plot 470;

Mr. Anthony J. McDonnell, Plots 352 & 353 and Columban Fathers, Dalgan Park.

Brief of Evidence given to Hearing by David Healy, Environmental Consultant, on behalf

of Dalgan Park and other Objectors

Analysis of Responses to Questionaires issued at Public Consultation on Dunshaughlin to

Navan Section, handed in by Thomas Hamill, Bellinter when querying Alan Guthrie.

Comments by Thomas Hamill on Wind Speed data from Met. Office as given to Hearing

on Day 21

Day 25 -- 31 October

Written Submissions handed in to Hearing by Tom Corr of Gaynor Corr on behalf of :-

Billie & Valerie Sunner, Knockmark, Drumree -- Plot 155 (See also sub. Day 14)

Sylvester Mcauley, Rathbeggan, Dunshaughlin -- Plot 257

Laurence Ward, Normans Grove, Clonee -- Plot 320 ( withdrawing objection

but making "observation")

James & Thomas Dowdall, Knockumber, Navan --Plots 2183 & 2185

Mark Corley, Grange, Bective, Navan --Plot 2103

Eamon Corley, Grange, Bective, Navn -- Plot 2324

John Newman, Curragh Farm, Kells -- Plot 3038

Thomas & Eamon Duffy, Boolies, Balrath, Kells -- Plots 3071 & 4009 and 4000

& 4002 respectively.

Copies of Letters from Roads Design Office, Navan to Frank Burke & Associates

detailing points agreed as the basis for a Withdrawal of Objections by Charles Reilly,

Bective St. Kells for Plot 3052 and by Cathal & Vivienne Usher, Cookstown for Plot

3033, both handed in to Hearing by Frank Burke.

Copy of Directive 97/62 EC -- Amending 92/43/EC -- Handed in by Peter Sweetman in

Evidence referring to issues he raised when cross-examining Richard Nairn on Day 24.

Submission to Hearing by Paddy Dowling of Killiney Design Associates on behalf of

Peter & Edward Henshaw -- Plot 326 at Bennetstown, Dunboyne with his supporting

Maps and the Council's Drawings of Underpasses

Book of Photographs handed in by Michael O'Donnell BL during his submission on

behalf of the Lismullin Educational Foundation Ltd. -- Plot 1081

Closing Submission by Bellinter Residents Association

Closing Submission by Meath Roads Action Group

Copy of Power Point presentation and CD of MRAG's previous submission on Day 17

File of Responses to Requests by Inspector handed in by Esmond Keane BL for Meath

County Council :-

(1) Details of Meetings with Council Members regarding M3 Scheme and

Minutes of approvals to proposal

(2) Details of Shared Farm Over/Underpasses currently in operation with report

on conditions experienced in use

1047

(3) Details of Users of Shared under/overpasses on Clonee/Dunshaughlin &

Navan Bypass Sections

(4) Copy of NRA Report, RS 46, on High Accident Locations 1996 to 2000

(5) Review of Noise Data in Vol 7A for R14;

(6) Proposals for Long Term Noise Monitors during Construction;

(7) Amended Limits for Construction Noise

(8) House Profiles at O/B crossings for Dunshaughlin to Navan Section

(9) Response by Margaret Gowan to Conor Newman's Submission on

Archaeology impacts of M3 on Tara /Skryne area.

(10) Proposed Measures to deal with the " Carrickmines " factor for

pre- construction archaeological investigation

(11) Fingal Co. Co. response to possible study of additional Interchange on

M50 between N2 & N3 junctions.

(12) Predicted traffic flow data at M3 Toll Plaza and existing traffic between

M50 Toll Plaza and M50/N3 Interchange

(13) Details of interface between M3 and Disused Railway line with provisions

being made for Future Railway alignment and Set of Maps showing same

Separate Roll of Maps showing these interfaces also handed in.

Day 26 -- 19 November

Page from Bruel & Kjaer Booklet on Road Traffic Noise levels from Mr. Searson

Letter from Tom Corr of Gaynor Corr with further withdrawals of objections.

Copy of NRA letter of 28/02/01 to O. Perkins re PPP & Toll scheme for N3 handed in by

Mr. Casey, Solicitor for Ms Maher during his submission to Hearing. Note -- Copy of

this letter previously handed in by Council on Day 5.

Two "sample" letters from Meath C.C. re Variations to CDP 2001 and Navan Envs. Dev.

Plan 1997 as sent to prescribed bodies under Section13 (8) of the P&D Act 2000 handed

in by Mr. P. Sweetman during his cross-examination by Mr. Keane about Mr.

Sweetman's visit to Council offices on 18/11/02.

Letter from Meath Co. Dev. Board dated 22/05/02 referring to the above sample letter

handed in by Mr. Casey solicitor following Mr. keane's cross-examination of Mr

Sweetman.

Two documents handed in by Mr. Keane during his cross-examinationof Mr. Sweetman

(1) copy of address labels of letters sent to prescribed & other bodies and (2) list of

bodies letters were sent to with acceptance references.

Briefs of Evidence of witnesses for Ms Maher handed in by Mr. Casey Solicitor from :-

Terence Reeves Smyth; Fiona Rooney; Shaffrey Associates; Sean Finlay and

Dr. Tina Aughney.

Day 27 -- 20 November

Thomas Hamill's further and additional submission on Route Selection Report Vol. 1

handed in by Mr. Hamill.

Location of Proposed Ventshafts for Tara Mines handed in by Mr. PM Pagan.

1048

Brief of Evidence and 8 photograph/photomontages of Gaffney & Cullivan handed in by

Mr, Casey, Solicitor

Brief of Evidence given for Ms Maher by Mr. Frank Burke.

Copy of Standard & Poor's Credit "Analysis of traffic Risk in Start up Toll Facilities"

handed in by Mr. F. Burke.

SiAS Presentation to Meath C.C. on 22/10/02 about Navan Integrated Strategy handed in

by Mr. Casey Solicitor.

Letter from Duchas to Ms Maher re their consideration of a recommendation on potential

Architectural Conservation areas handed in by Mr. Casey Solicotor.

Copy of planning refusal for a single house in the context of Ardbraccan "Setting"

handed in by Mr. Casey, Solicitor. Ref 98/1609.

Copy of Tara Mines "Confidential" preliminary review of Proposed Navan By-pass

routes and copy of Tara Mines "internal report" handed in by Council following direction

by Inspector.

Minutes of meetings between MC O'Sullivan and Tara Mines handed in by Ms Joyce

Minutes of meetings with Ardbraccan and MC O'Sullivan handed in by Ms Joyce.

Copy of note of Ms Maher's visit to Road Design Office on 12/10/00 handed in by Ms

Joyce.

Mr. Cullivan's "Addendum" to his Brief of Evidence giving details of the location of the

Jeep as the light source in Photo 8.

Ardbraccan M3 Motorway Video shown by Ms Maher to Hearing on Day 27

Two maps and long sections showing "traffic light spillage/impacts from M3"

southwards towards Ardbraccan House requested by Inspector and handed in by Mr.

Evans of Arup.

Day 28 -- 21 November

Bellinter Residents Association further submission on their "disputed values" in Table

4.2 arising in their cross-examination of Alan Guthrie, handed in by Alan Park

Bore hole details at Ardbraccan/Durhamstown area handed in by Mr P.Sweetman as

being "Relevant" to submissions on day 27

Map of Durhamstown Bridge "alternatives" handed in by Ms Maher during her evidence

on possible future interchange location there

Copy of Arts Council letter of 03/05/02 to an Bord re M3 handed in by Mr. Casey for Ms

Maher.

Letter of 03/11/00 from Michael Osbourne to Ms Maher with Equine Health issues and

road schemes data handed in by Mr. Casey, Solicitor

File of references used by Mr. Casey in his Closing Submission

FAX of further submission to Hearing by Conor Newman in response to Margaret

Gowan's response to his submission made on Day 23.

Composite Map of Landscaping proposals from Boyerstown O/B to Northern Toll Plaza.

Council's responses to Inspector's requests :-

From Road Design Office :-

Details of Landtakes

1049

Side road construction tolerances

From Halcrow Barry :-

Typical bridge construction periods

List of wells in Skryne area

Noise Study at Grace Martin's house

Baronstown Road Realignment

Map and calculcations for Skane catchment

Map of Dalgan Park with details of Footpaths and Farm roads

Project Team's analysis of Consultation questionaire returns

Report on flooding on River Skane

Noise Contour Maps for Dalgan Park area

Cross-section of Dowdstown Road

Location of Water Treatment Plant at Dalgan Park

Location of Dunshaughlin Sewage Treartment Works

Alternative alignment for Ardsallagh Overbridge

Locations for Dust Control Stations --Berjhofer jars

Noise levels and distances Dalgan Park

New Noise level criteria applied to noise sensitive areas

Plans showing redundant areas to be removed

Advance Planting Schedule for landscaping

Mitigation proposals for discharge during construction of bridge crossing River

Boyne

Review of vertical alignment in vicinity of Trevet road

Feasibility of providing noise bund for Tara Stud

Route alternative and structural impact on the Boyne crossing

Review of mainline vertical alignment through Dalgan Park

Provision of Temporary Link at Roestown to existing N3.

Noise reducing surfacing in Ardsallagh

Houses within 50 metres of new and existing roads.

Reworked Table 4.8 from Volume 4A on noise data

From MC O'Sullivans :-

Review of landtake requirements for Johnstown overbridge

Recalibration of Noise model at location No. 5 Vol. 3C (L. Scott query)

Review of design for Kilcarn Link road

Dust monitoring locations for Clonee / Dunshaughlin and Navan By-pass

Boundary treatment details

Review of Keogh's underpass proposals

Review of Cannistown Railway options

Clarification of underpass proposals for Henshaws

Navan By-pass noise eratta sheet

Houses within 50 metres on Clonee / Dunshaughlin and Navan By-pass

Navan Area Infrastructural Map from the CDP as referred to by Mr. Casey

Status of the proposed candidate SAC in the Rivers Boyne and Blackwater

Folder of Additional Supplementary Responses -- plot 294 & EIS 5045

From Arup :-

Shared access details on Navan to Kells to North of Kells

1050

Constraints and vertical alignment passing Coolfore Road with revised alignment

lowering the mainline at that location

Houses within 50 metres on Navan to Kells to North of Kells

Drawing showing existing pavement to be removed on Navan to Kells to North of Kells

Possible areas of advanced planting at house with severe visual impact on Navan to

Kells to North of Kells

Response to additional submission by John Newman, plot 3038

Additional Noise information from Navan to Kells to North of Kells

Dust Monitoring Locations from Navan to Kells to North of Kells

Documents received by Inspector from Council after Hearing had concluded,

See reference at page 771 in Section 116 of this Report :-

Official Version of the Habitats Directive 97/62/EC

Noise Directive 2002/49/EC with Annex 2

Control of Road Traffic Noise (CRTN) issued by theWelsh Office

Documents received through An Bord Pleanala after Hearing had concluded :-

From Greg Casey, Solicitor for Ms Maher, Ardbraccan House on 16 January 2003

--- E-mail explaining delay in forwarding hard copy of Power Point presentation

and other documents. ( No copy of Power Point or other documents subsequently

received from Mr. Casey, see page 818 of this Report)

From Simon Hilliard, Ardbraccan, Boyerstown, Navan on 24 February 2003 :-

Further submission dated 8 February 2003 outlining his concerns, with letter from

An Bord Pleanala of 20 February with details of attempts to contact him during

Hearing.

From Coras Iompair Eireann dated 28 February 2003enclosing a copy of their

Letter of 20 August 2002 to the Council ( already handed in on Day 1 as above)

with letter of 12 March 2003 from An Bord Pleanala to CIE attached.

----------------------------------------------

1051

Appendix 5. List of Wayleaves to be Acquired in Second Schedule

------------------------------

Wayleave Wayleave Wayleave Drawing Number

Number Width Location

1. 15 to 30 metres Nugentstown WA1 to WA2 on Map M3-035

2. 20metres Nugentstown and WB1 to WB2 on Map M3-035

Cookstown Great

3. 15 metres Kilmainham WC1 to WC2 on Map M3-037

4. 10 metres Rockfield WD1 to WD2 on Map M3-039

5. 15 metres Townparks & WE1 to WE2 on Map M3- 041

Commons of Lloyd

6. 15 metres Townparks & WF1 to WF2 on Map M3- 041

Commons of Lloyd

7. 15 metres Commons of Lloyd WG1 to WG2 on Map M3-041

8. 15 metres Commons of Lloyd WH1 to WH2 on Map M3-041

9. 15 metres Townparks WI1 to WI2 on Map M3-041

10. 15 metres Townparks WJ1 to WJ2 on Map M3-041

11. 15 metres Townparks WK1 to WK2 on Map M3-041

12. 15 metres Townparks WL1 to WL2 on Map M3-041

13. 15 metres Castlekeeran WM1 to WM2 on Map M3-045

14. 20 metres Castlekeeran WN1 to WN2 on Map M3-045

15. 20 metres Woodpole WO1 to WO2 on Map M3-045

16. 15 metres Derver WP1 to WP 2 on Map M3-047

--------------------------------

1052

Appendix 6. List of Public Rights of Way to be Extinguished in Third Schedule,

Part 1

------------------------------

R. o W. Road Location Drawing Number

Number Number

1. N3 Bracetown AA1 to AA2 on Maps M3-001/002

2. N3 Piercetown, Pace, AA3 to AA4 on Maps M3-004/005

Woodpark & Dunboyne

3. N3 Cookstown AA5 to AA6 on Map M3- 013

4. R125 Readsland AB1 to AB2 on Map M3-013

5. R125 Leshamstown & AB3 to AB4 on Map M3-012

Readsland

6. R125 Merrywell & AB5 to AB6 on Map M3-010

Bedfantstown

7. R154 Piercetown AC1 to AC2 on Map M3-005

8. R154 Merrywell AC3 to AC4 on Map M3-010

9. R154 Merrywell AC5 to AC6 on Map M3-010

10. R155 Piercetown AD1 to AD2 on Map M3-005

11. R155 Piercetown AD3 to Ad4 on map M3-005

12. R156 Clonee & AE1 to AE2 on Map M3-001

Loughsallagh

13. R156 Loughsallagh AE3 to AE4 on Map M3-001

14. R156 Dunboyne AE5 to AE6 on Map M3-003

15. R157 Bennettstown, AF1 to AF2 on Map M3-004

Dunboyne &Pace

16. R157 Dunboyne & Pace AF3 to AF4 on Map M3-004

17. R157 Castlefarm AF5 to AF6 on Map M3-002

R. o W. Road Location Drawing Number

1053

Number Number

18. L-2208 Readsland & AH1 to AH2 on Map M3-013

Roestown

19. L-2208 Roestown & AH3 to AH4 on Map M3-012

Readsland

20. L-2209 Derrockstown AI1 to AI2 on Map M3-008

21. L-2209 Derrockstown AI3 to AI4 on Map M3-008

22. L-22091 Raynestown AJ1to AJ2 on Map M3-007

23. L-22091 Raynestown AJ3 to AJ4 on Map M3-007

24. L-22091 Raynestown AJ5 to AJ6 on Map M3-007

25. L-22092 Rathbeggan AK1 to AK2 on Map M3-007

26. L-22161 Piercetown AM1 to AM2 on Map M3-005

27. L-5026 Piercetown AN1 to AN2 on map M3-005

28. L-2225 Pace AP1 to AP2 on map M3-004

29. L-2225 Piercetown AP3 to AP4 on Map M3-005

30. un-numbered Piercetown AQ1 to AQ2 on Map M3-005

31. un-numbered Bennetstown AS1 to AS2 on Map M3-004

32. un-numbered Johnstown AT1 to AT2 on Map M3-009

33. L-5012 Trevet, DA1 to DA2 on Map M3-015

Berrillstown & Clowanstown

34. L-1005 Collierstown DB1 to DB2 on Map M3-016

35. L-1005 Ross DC1 to DC2 on Map M3-016

36. L-5000 Skreen & DD1 To DD2 on Map M3-016

Baronstown

37. L-50021 Lismullin DE1 to DE2 on map M3-018

R. o W. Road Location Drawing Number

1054

Number Number

38. N3 Blundelstown, DF1 to DF2 on Map M3-019

Castletown Tara & Philpotstown

39. L-2201 Dowdstown DG1 to DG2 on Map M3-019/020

40. L-2200 Ballinter & DH1 to DH2 on Map M3-020

Ballinter & Dowdstown

41. L-2201 Ballinter DJ1 to DJ2 on Map M3-020

42. L-2201 Dowdstown DK1 to DK2 on MapM3-019

43. L-4009 Ardsallagh DL1 to DL2 on Map M3-021

44. L-8034 Ardsallagh & DM1 to DM2 on Map M3-021

Kennastown

45. L-8034 Ardsallagh & DN1 to DN2 on Map M3-021

Kennastown

46. R161 Williamstown or Bawn GA1 to GA2 on Map M3-022

47. R161 Williamstown or Bawn GB1 to GB2 on Map M3-022

48. R161 Philpotstown GC1 to GC2 on Map M3-023

49. N3 Balreask Old GD1 to GD2 on Map M3-024

50. L-34141 Balreask Old GE1 to GE2 on Map M3-024

51. N3 Balreask Old GF1 to GF2 on Map M3-024

52. L-4007 Macetown GG1 to GG2 on Map M3-025

53. L-4007 Macetown GH1 to GH2 on Map M3-025

54. L-4007 Gainstown GI 1 to GI2 on Map M3-025

55. L-8010 Gainstown GJ1 to GJ2 on Map M3-025

56. N51 Mullaghmore or GK1 to GK2 on Map M3-026

Allerstown

R. o W. Road Location Drawing Number

1055

Number Number

57. N51 Boyerstown GL1 to GL2 on Map M3-027

58. N51 Boyerstown GM1 to GM2 on Map M3-027

59. N51 Boyerstown GN1 to GN2 on Map M3-027

60. "Brady road" Boyerstown GO1 to GO2 on Map M3-027

61 "Brady road" Boyerstown GP1 to GP2 on Map M3-027

62. N51 Townpark GR1 to GR2 on Map M3-029

63. L-7418 Townpark & GQ1 to GQ2 on Map M3-029

Moathill

64. "Clogherboy Estate Townpark GS1 to Gs2 on Map M3-029

Road"

65. "Moatville Estate Townpark GT1 to GT2 on Map M3-029

Road"

66. L-8008 Ardbraccan GU1 to GU2 on Map M3-030

67. L-8008 Ardbraccan GV1 to GV2 on Map M3-030

68. L-8008 Ardbraccan GW1 to GW2 on Map M3-030

69. L-80091 Ardbraccan GX1 to GX2 on Map M3-030

70. L-8009 Ardbraccan GY1 to GY2 on Map M3-030

71. L-4005 Durhamstown, GZ1 to GZ2 on Map M3-032

Grange & Ardbraccan

72. L-4005 Ardbraccan HA1 to HA2 on Map M3-032

73. L-4005 Ardbraccan HB1 to HB2 on Map M3-032

74. L-8001 Pheonixtown KA1 to KA2 on Map M3-033

75. L-6833 Ballybeg KB1 to KB2 on Map M3-034

R. o W. Road Location Drawing Number

1056

Number Number

76. N3 Kilmainham & KC1 to KC2 on Map M3-037

Kilmainham (Headfort)

77. L-2813 Gardenrath & KD1 to KD2 on Map M3-036

Townparks

78. R164 Rockfield & KE1 to KE2 on Map M3-039

Townparks

79. N52 Newrath Little KF1 to KF2 on Map M3-039

& Townparks

80. N3 Commons of Lloyd KG1 to KG2 on Map M3-041

& Townparks

81. N52 Cakestown Glebe KH1 to KH2 on Map M3-042

82. N52 Cakestown Glebe KI 1 to KI 2 on Map M3-042

83. L-68353 Calliaghstown KJ1 to KJ2 on Map M3-039

84. L-68292 Castlekeeran KK1 to KK2 on Map M3-045

85. L-68294 Woodpole KL1 to KL2 on Map M3-046

86. N3 Derver KM1 to KM2 on Map M3-047

87. N3 Derver KN1 to KN2 on Map M3-047

88. N3 Derver KO1 to KO2 on Map M3-047

----------------------------------

1057

Appendix 7. List of Private Rights of Way to be Extinguished in Third Schedule,

Part 2

-----------------------------

R. o W. Plot (s) Location Drawing Number

Number Number

1. 361a.202 Loughsallagh NA1 to NA2 on Map M3-001

2. 357b.201 Loughsallagh NB1 to NB2 on Map M3-001

3. 500h.201 Loughsallagh NC1 to NC2 on Map M3-001

4. 352a.201 Bracetown NE1 to NE2 on Map M3-004

5. 200p.201 Piercetown NK1 to NK2 on Map M3-005

6. 200i.101, 200i.202 Piercetown NL1 to NL2 on Map M3-005

& 294a.201

7. 255c.201 & 252d.202 Rathbeggan NS1 to Ns2 on Map M3-007

8. 197a.101 Derrockstown NT1 to NT2 on Map M3-008

9. 152k.201 Knockmark NW1 to NW2 on Map M3-011

10. 197a.202 Derrockstown NY1 to NY2 on Map M3-008

11. 1057d.101, 1056d.101 Garretstown QA1 to QA2 on Map M3-014

& 1056d.202

12. 1083a.101 Lismullin QB1 to QB2 on Map M3-017

13. 1109d.202, 1109d.101 Ardsallagh QC1 to QC2 on Map M3-021

& 1109d.203

14. 2117b.203 Balreask Old TA1 to TA2 on Map M3-024

15. 2158a.201 Gainstown TB1 to TB2 on Map M3-025

16. 2167a.203 Boyerstown TD1 to TD2 on Map M3-027

17. 2222c.201, 2219c.201 Neillstown TE1 to TE2 on Map M3-030

& 2220c.201

1058

R. o W. Plot (s) Location Drawing Number

Number Number

18. 3032a.102, 3033a.101 Cookstown Great XB1 to XB2 on Map M3-035

3032a.209 & 303a.204

19. 3046a.101, 3038e.101 Kilmainham & XC1 to XC2 on Map M3-036

& 3047f.101 Gardenrath

20. 3038a.202 Kilmainham (Headfort) XD1 to XD2 on Map M3-037

21. 4001a.201 Calliaghstown XE1 to XE2 on Map M3-039

22. 4014.201& 4012a.201 Chapelbride XF1 to XF2 on Map M3-044

-----------------------------------

1059

Appendix 8. List of Planning Permissions modified in Seventh Schedule

-----------------------

Part 1 -- Permissions to be suspended

-----------------------

Planning Date Plot Details

Reference Granted Number

98/1404 11/11/1998 3018 Renovate Residence & provide septic tank.

98/1932 07/12/1998 3025 Extension &alterations to existing house,

provide septic tank and erect shed.

97/1337 14/11/1997 4003 New bungalow, septic tank & entrance.

------------------------------

Part 2 -- Permissions to be modified

------------------

98/1340 20/10/1999 1063 Erect fenceline as shown on M3-015

00/5120 31/01/2002 1121 Erect fenceline as shown on M3-021

00/1816 07/12/2000 3038 Erect fenceline as shown on M3-036

98/1362 25/09/1998 3065 Erect fenceline as shown on M3-039

01/33 07/03/2001 3076 Erect fenceline as shown on M3-040

97/768 30/04/1998 4016 Erect fenceline as shown on M3-044

00/2077 15/01/2001 4063 Erect fenceline as shown on M3-044

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