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Shell’s Incredible Traffic Management Plan

Shell’s Incredible Peat Traffic Plan

SUBMISSION: Re: P03/3343

Minister’s ConsentThe first thing to note about the Transport Management Plan is that it was specifically required as one of the conditions of consent by the Minister of the Marine in his communication1 of 15th April, 2002. It is consequently extraordinary that it had to be requested as further information as recently as 17th Feb. 2004 by the Planning Authority. It should have been included in the EIS. The fact that it wasn’t adds to Shell’s credibility gap, which dates back to the arrogantly inadequate responses made to An Bord Pleanala’s request for further information, previously.

5.5 metre road width
However to deal with the present, what the Transport Management Plan envisages is so incredible that it defies ordinary commonsense and simple arithmetic in a most extraordinary way. For instance the revamped haul route will have an average width of 5.5 metres, and will include at least four ‘single-lane-only’ bottlenecks, yet we are asked to believe that up to 800, 2.5 metre-wide truck trips per day (averaging 80 per hour) can be expected to travel in opposite directions at up to 40 miles per hour on this 5.5m route while maintaining a very tight schedule on absolutely depends on free-flowing conditions for viability.

6' traffic clearance
Taken in more detail, it means that trucks will be passing one another at a rate of once every 90 seconds with a space of only 0.5m total clearance. This in turn allows only 0.16m (6') clearance at the road margins on either side and 0.16m (6') between the vehicles themselves. However, the full picture is even more implausible in that the margins are admittedly very prone to subsidence so that a 6' (0.16m) clearance cannot be considered safe even for ordinary rates of HGV traffic, say 10 per day. Eighty times that amount (i.e. 8,000%) places it beyond all belief.

Independent Expert Evaluation
Shell is effectively presenting ‘desk-studies’ as workable solutions when, in fact, they fail to stand up to even preliminary scrutiny. It is outrageous, consequently, that these proposals are not being subjected to independent expert evaluation such as the ERM Report, DNV Report, Posford Haskoning Report and Peer Review Group Report which were commissioned in respect of the previous application. Those reports provided a credible basis for identifying and addressing vital issues. The Planning Authority failed to commission such expert evaluation last time around and drew severe criticism as a result. Yet it is repeating this failure again despite several requests, oral and written, to do so.

Extreme Liberties
What seems likely in the event of this impractical scheme being approved is that once permission is achieved, extreme liberties will be taken with the conditions set. It will be forced through by hook-or-by-crook - like a battle field operation with little regard for consequences. Who can honestly envisage up to 800 trucks a day passing each other in opposite directions at up to 40 mph at 90 second intervals with no more than 6' clearance between the trucks themselves and between trucks and road margins? There will be extraordinary pressure on Shell E & P Ireland Ltd from Shell Ltd. to meet deadlines. E & P stands for Exploration and Development which represents the darker side of Shell, as the Ogoni people in Nigeria, and others world-wide have good reason to know. The international head office creates the pressure, local management must deliver – weather etc. is irrelevant.

Going further into the matter, consider what might happen in practice at each of the recognised bottlenecks and, especially, at the crossing of the main Belmullet to Ballina/Castlebar Road (R313) Consider the R313 where up to 80 trucks must cross every hour. This means a truck every 45 seconds. Unless they queue into groups of 5, or so, there is no way in which they can be accommodated. However such queuing is not possible as the various stages of unloading, wheel-washing recording etc. would be over-loaded by such crowding. Worse still, the crossings of the R313 are to be staggered so that the returning trucks cross in two stages, first into the west-bound lane and then, 1km on, they must cross the east-bound lane. This results in non-Shell traffic on the R313 being subjected to unmanageable levels of interruptions - one every 45 seconds and further complicated by involving two separate junctions 1km apart. As non-Shell traffic on that stretch runs at up to 2,000 per day (i.e. up to 200 per hour - 1 every 20 or so seconds) the schedule set by Shell of 400, 45-52 minute round trips cannot be remotely realistic.

This is still only the tip of the iceberg. Each of the acknowledged single-lane bottlenecks would add to the potential grid-lock, especially those where the bottleneck is compounded by an extended curve and consequent poor vision. Equally, the impact on queues at loading, weighing, recording, wheel-wash and unloading apron, as well as egress from deposition site back into the traffic-flow on the public roads, is literally inestimable. Yet the Response does little more than gloss over such real and potentially insurmountable obstacles.

Credibility Gap
The credibility gap is unbridgeable. The attitude of Shell is clearly as arrogant as previously, being dismissive of the consequences for the public overall. This was evident at the re-convened Oral Hearing in that the constraints set by Shell in commissioning their plans invariably turned out to be the root cause of the fundamental defects, which only became apparent as the Hearing unfolded. ‘Time constraints’ and ‘cost constraints’ were the main culprits, as indeed they are in the current proposed Transport Management Plan. Setting a schedule for 400 round-trips per day, for example, is so tight and inflexible that it shows little comprehension of the consequences of the multiple clogging-points en route. In this regard, the target of 120 working days to transport the waste peat appears to have forced all other considerations out of the picture.

When the uncertainty of weather is added to the above picture, and it is recalled that work on Srahmore bog has always been seriously hindered by the unpredictability of the weather, all assurances re targets ring hollow. With milled peat Bord na Mona were working at all times with a comparatively dry material which was capable of being stockpiled for many months to enable targets to be met in the event of extended bad weather. In the current instance, Bord na Mona are faced with an essentially slurry-like2 material, as raw peat is up to 95% water content. Bord na Mona cannot guarantee secure and containable conditions for such slurry-like waste either at the terminal or at the deposition site during inevitable periods of extended rainfall. The implications of such an untried and untested undertaking for traffic management during the projected six months of peat transportation are potentially of chaotic proportions. Nothing in the Response addresses the inevitable log-jams and protracted delays inherent in such clearly intractable problems.

Time Constraints
The consequences of unrealistic time constraints imposed on transport schedules apply equally to the route preparation. It is acknowledged in the Response that the proposed haul route roads as they stand are entirely inadequate and that not only re-construction but widening is needed before transportation of peat could commence. However, time constraints prevent much of this work being carried out, particularly in regard to widening. When it is realised that only minimal widening was envisaged in the first instance, the real seriousness of the situation emerges. Anyone living in the Erris area who drives regularly on these ‘rural non-national roads’ knows how frequently truck drivers unfamiliar with peat-based roads lose control and topple over due to the margins giving way. Likewise, those who walk on such roads when heavy vehicles pass know how jelly-like the wobble under-foot feels. Short-cuts are being taken re route preparation and these immense consequences for all aspects of traffic management are not addressed by the Response.

Time constraints likewise preclude the type of work necessary to provide an adequate foundation for the margins of the proposed haul road. The report acknowledges that the type of reinforcing envisaged is so deficient that very substantial subsidence is expected and will be the focus of on-going repair work. At 5.5 metres, road width makes no allowance for safety, and with up to 800 trucks per day passing in opposite directions at 90 second intervals constant use of the margins will be the norm. In such circumstances, it is inevitable that dangerous conditions will frequently prevail and that accidents with potentially life-threatening consequences become not merely a possibility but a probability.

Cost Constraints
Time-constraints are only one of the fundamental, unrealistic impositions. Another which is clearly quite as fundamental and pervasive is cost-constraints. A 6.5 metre wide road, with no bottlenecks and a solid foundation, is the minimum requirement implied by the survey findings as presented in the current ‘Response’. A road laid on bog is, in effect, ‘floating’ on the underlying peat and can never be stable. This is documented in the Response which acknowledges that peat-based roads are subject to surface break-up and to frequent, significant and unpredictable subsidence as the level of groundwater fluctuates with changing weather conditions. Every regular road-user in the Erris area knows that an apparently good road can deteriorate into a ‘humps-and-hollows’ condition in dry weather. Ironically it is the ‘good’ weather which causes the most dramatic damage.

The relatively cheap, quick-fix solution proposed might be adequate for normal traffic as the quoted standard suggests, but this standard is based on traffic use of only 200-1,000 per day over a design-life of 20 years. Heavy Goods Vehicles are assumed to account for 10% of that traffic (i.e. 20-100 HGV’s per day). Up-grading this standard, as proposed, to the 1,000-2,000 vehicles per day level (i.e. 100-200HGV’s) does not come anywhere near meeting the requirements of the projected six-month long, intensive use by 800 HGV’s per day - and this is only Shell traffic. Nor does the use of a geosynthetics layer dispel legitimate fears as there is nothing ‘normal’ about 800 HGV’s per day on top of the 'approximately 2,000 vehicles per day (which) have been recorded on this section of road' (R313). From this we can infer that another 200 HGV’s must be accommodated bringing the total to 1,000 HGV trips per day on this section of the R313.

Posted Date: 
8 June 2005 - 10:47pm