17.2.6 Noise
‘The number of goods vehicles travelling in the GDA is expected to increase as a result of growth over the period of the strategy. While this may lead to some localised impacts in terms of increased noise, it is forecast – in line with policies and objectives related to the management of Heavy Goods Vehicles – that these adverse effects would arise primarily on the national and strategic road network, rather than on local roads and as such, would not lead to a significant increase in the population exposure to high noise levels’.
This is an extraordinary statement. Many people live by major roads, including people living within the canals. The communities in the Dublin 7 areas live by primary / national roads - Phibsborough road, Botanic, North Circular road, Cabra road, Manor st etc. People living along these main arteries (in their 10s of thousands) are impacted very adversely by heavy traffic already, and are exposed to noise levels 5 times the recommended WHO levels every day, 20 hours + a day. How many people is acceptable for the NTA to expose to even higher levels of noise? Has the NTA studied the effects of high levels of noise on people? The latest studies show a direct link between noise and hypertension, heart disease, dementia etc. There is no
number attached to how many people will be affected, just a generalisation. This is unacceptable, and metrics around noise need to be attached, and the goal to radically diminish those. If people live beside roads, it is the NTA’s responsibility to ensure noise + air pollution are dealt with by ensuring traffic levels go down - people’s health should not be treated as collateral damage.
17.2.7 Mode Share
We would humbly suggest that the mode share targets, which include a reduction of car use of 9.1% across the GDA region and 10.5% for Dublin Metro, are not compatible with national climate emissions targets. Achieving modal shift in the more peripheral regions of the GDA is a daunting challenge, so the targets for Dublin Metro need to be much greater to compensate.
Targeting an 18% reduction on 2016 levels in commuter vehicle kilometres also seems like an extremely unambitious target given the changes to remote-working that are already baked in since then.