6. Public Consultation
I am very unhappy, but not surprised, at the complete failure of this process (and other NTA processes) to have much, if any, regard to the principles of the Aarhus Convention of 25 June 1998 and in latter years to the Kazakhstan Advice setting out how the convention should be handled in the context of Covid 19. I have a doubt as to whether you have ever read the convention and if you are even aware of the Kazakhstan Advice.
It is to my mind beyond argument that this plan and various other spin offs envisaged by it, such as BusConnects corridors, have major environmental impact. Under Article 6 of the Convention, if a decision is to be made on such matters, there is a requirement to inform the public in "an adequate, timely and effective manner" on many aspects of the proposal. There are requirements for "reasonable time frames" and "effective public participation". The Kazakhstan advice of 1 July 2020 addresses circumstances where public meetings are impossible and suggests that additional efforts are needed to communicate with a particular focus on facilitating those who are not computer literate to engage.
I could write a book on all of this, with commentary on every sub-paragraph, but the following aspects are of particular concern.
a timescale from early November to 17 December (sneakily extended at a very late stage to 11 January) is inadequate. The Authority took from 22 January 2021 to November 2021 to move from preliminary consultation to a draft plan; they expect the public to respond in less than 2 months comprising within it Christmas and New Year
the Authority is spending millions of taxpayers money, but has spent nothing on targeted communication summarising its plans. It would have been very cheap to have a leaflet delivery company leaflet for example Terenure on specific local proposals, a point noted on several submissions. We wre not leafletted either on recent changes to the 15A route caused by the C corridor.
the Authority has a general tendency to run important consultation periods either finishing just before Christmas or straddling Christmas. This is particularly troubling in the last two years when Covid has been a huge concern at Christmas.
this site is quite user unfriendly, even to people with reasonable technology skills, a point noted on several submissions. It is quite tricky to navigate back as I am typing these comments to core documents.
core documents for complex proposals are not readily available in hard copy. You could easily have indicated in November to those really interested an address to which they could apply for hard copies of whatever documents they wanted and arranged delivery in a structured way.
there is no summary document highlighting key new features of the plans by area of the city
I am particularly perturbed by your failure to distribute any leaflet in areas which are clearly affected by specific proposals and you should clearly know that people may have views on them. This of course deprives you of the opportunity to set out your own reasons for the proposal and leaves the field open to others to spin on an issue, so it's not in the public interest. On the Dunsany/Navan rail issue, one submission clearly suggests that all other submissions are on a false premise. I dont know the rights and wrongs of this, but a local leaflet could have clarified and you would have been aware of this issue at least in November. Issues which clearly merited local leaflets include
the proposal to make Charlemont the south city hub, with three proposed Luas lines identified in your documents
some local specific proposals in Terenure
the route for the Lucan Luas, which has shifted from a branch ex Blackhorse to a full blown line
the M3/M4 connector road to relieve an M50 crisis on the bridge
fare structures beyond the fixed Dublin zone affecting places such as Laytown and Newbridge
It is evident that some of the above will be the main issues raised on consultation. I would expect that after Monday, some interim paper would issue setting out what you are doing about these issues. Further as your plan has at some point anyhow have to go before a Dáil Committee, it would be really useful for such a committee to have a session for one day on the items I listed above (not however the Terenure specifics) as they are all issues involving substantial public money.