Below is a submission on behalf of the directors of Connolly's Red Mills for the proposed development by Carlow and Kilkenny County Council pursuant to the provisions of Section 38 of the Road Traffic Act, 1994 as amended by the Public Transport Regulation Act, 2009 (Section 46), to carry out works on the bridge in Goresbridge consisting of the following:

A new raised footpath of 1.800m width to allow for the safe movement of pedestrians in both directions;
New pedestrian railing, independent of the existing masonry parapet to protect the heritage of the bridge;
A new traffic light controlled shuttle system will be installed;
The carriageway width will be reduced to one lane of 3.250m;
A rubbing strip will be introduced on the downstream side of the bridge with a raised kerb to segregate the running surface;
Approaches to the bridge will be modified by narrowing the running lanes and calming the traffic, improving pedestrian access to the proposed footway by introducing pedestrian crossings and raised footways”.

Background

The “Proposal Summary to Accompany Public Consultation” document submitted amongst the consultation documents explains that, following a Stage 1 preliminary design exercise, Clandillon Civil Consulting (“CCC”) provided an Option Design Report in September 2023 which reviewed 3 options for pedestrian improvements at the bridge in Goresbridge;

• Option 1 – Shared Bridge with Raised Footpath

• Option 2 – Cantilever Footway

• Option 3 – Standalone Footbridge

Following an appraisal by the consultants, they proposed Option 1, with Options 2 and 3 being discounted, which it appears the Council has accepted.

The details of this Option Design Report and appraisal by the consultant do not form part of the current consultation documents, nor does the process followed for accepting Option 1 by the Council. Was this an Executive of Members decision?

The CCC report refers to ORS Consulting carrying out a detailed traffic assessment for Option 1. It is understood this was done in November 2023.

Following this it is understood works commenced on Option 1, in particular the installation of ducting for services and works in the latter end of 2023.

Local concerns were expressed to Kilkenny County Council over the works commencing and the inadequacy of the trials carried out by ORS Consulting, in particular the timing of trials relative to peak times when large agricultural machinery and other commercial users require access over the bridge. As a result works were stopped. Concerns were also expressed at the time about the commencement of works without community engagement.

The consultation process for Option 1 commenced on 26th January 2024.

Issues

Public Consultation

1. The CCC report refers to the Goresbridge Local Area Plan (2005) having had the stated objective “To examine and bring forward proposals for the improvement of pedestrian facilities on the bridge in conjunction with Carlow County Council.”

While this is correct, the LAP further states as follows: “The achievement of the objectives will be dependent on the availability of finance and the inclusion of the objectives in the work programmes of the County Council and the responsible agencies. The local community, through local associations such as Residents Associations and Tidy Towns, can play a huge role in contributing to the achievement of some of the objectives above. Kilkenny County Council’s policy will be to facilitate and aid local organisations in this capacity”.

The current public consultation does not reflect the commitment made to the community of Goresbridge through the LAP, as it focuses on a single option that was been selected without any public consultation or formal Council agreement following public consultation.

2. It considered the current public Consultation is misleading by implying submissions from the public can be made with respect to the technical aspects of the works, the operation of the scheme and alternatives. Under the provisions of Article 120(3) of the Planning and Development Regulations 2001 (as amended), submissions can only be considered concerning whether the development would be likely to have significant effects on the environment in the context of the Habitats Directive.

At the public information session facilitated by Kilkenny County Council on 15th February 2024, the limitation of the public’s influence on the outcome of the public consultation process being restricted to whether the project would be likely to have significant effects on the environment in the context of the Habitats Directive, was not made clear. The online submissions to the public consultation to date, confirm a lack of awareness of this limitation.

3. CCC report notes that the bridge in Goresbridge is a protected structure. However, rather than describing the bridge, the report describes the grain store close to the bridge which is currently operating as a café/restaurant, which was constructed some 100 years after the bridge.

Gore’s Bridge is described in the NIAH as follows: “Nine-arch bridge over river, built 1760. Part repointed rubble limestone walls centred on granite ashlar triangular cutwaters to piers to upriver (north) elevation having shallow pyramidal capping with cut-granite rounded coping to parapets. Series of nine round arches with granite ashlar voussoirs. Sited spanning River Barrow with grass banks to river”.

The appraisal of the bridge in the NIAH is given as follows: “A bridge erected by Samuel Biass and Thomas Dunn representing an important component of the mid eighteenth-century civil engineering heritage of County Kilkenny with the architectural value of the composition confirmed not only by the silver-grey granite dressings demonstrating good quality workmanship, but also by the elegant "sweep" of the arches making a pleasing visual statement at a crossing over the River Barrow: meanwhile, the bridge remains of additional interest for its connections with the Battle of Goresbridge (23rd June 1798) when a party of rebels 'commanded by General Roche, Edward Fitzgerald, and priest John Murphy…made their appearance opposite Gore's-bridge... The royal forces stationed there, consisted only of one troop of the 4th Dragoon Guards, and a company of the Wexford militia, who prepared to stop their progress; and for that purpose took possession of the bridge; but the army, on perceiving the rebels planting their cannon on the opposite side, and fording the river in considerable numbers, thought it more prudent to retreat. All the dragoons escaped; but twenty-four of the Wexford militia were taken prisoner; and eight of them being Protestants, were murdered on that and the following day' (Taylor 1829, 141-2)”.

Given the CCC report refers to the wrong protected structure, there has been no assessment of the impact of the proposals on the bridge in Goresbridge, which is afforded protection as a Recorded Protected Structure (ref: RPS 92) under the Development Plan.

As the proposed works are to be carried out to a protected structure which will materially affect its character, the Planning Authority is obliged under the provisions of Section 179 of the Planning and Development Act 2000 (as amended) to undergo public consultation on not only the potentially significant effects on the environment but also all aspects of the proposed development, including impacts on the protected structure, road safety, residential and commercial amenities, etc. This will require a separate consultation process before any option can be agreed upon and for works to recommence.

Options

Option 1 - The CCC report singled out the option of a shared bridge with a raised footpath as the preferred option.

There was no structural engineering report submitted to support this option to confirm whether or not the bridge possesses the structural integrity to withstand a doubling of the weight and volume of heavy vehicle traffic to one side, with no counterweight on the other. The single-file traffic arrangement to one side of the bridge could result in the structural deterioration of the historic bridge structure.

As noted in the Background section of this submission, ORS Consulting carried out a traffic assessment and trials for Option 1 in November 2023.

There are peak times when the bridge is in use by large agricultural and haulage vehicles, particularly during the grain season, July through to September, including modern tractors with various attachments (spreaders, ploughs, balers etc), combine and forage harvesters, 46-tonne grain lorries, etc. The reduced carriage width of 3.25m is insufficient for most of these vehicles. Even where the reduced carriageway can accommodate some larger vehicles, they still present an intimidating threat to pedestrians and cyclists on the bridge, as they do at present.

No independent Road Safety Audit was included with the consultation documents, which it is assumed would be an essential element of the process prior to any decision.

If Option 1 is to be considered further, a proper understanding of the worst-case scenarios must be established from on-site assessment at times when larger vehicles are using the bridge at peak times.

As per the commitment in the LAP, the local community, including the farming community and associated businesses are principal traffic users of the bridge and must be engaged in the assessment.

Also, as noted in the Public Consultation section above, the CCC report refers to the wrong protected structure and no assessment of the impact of the works on the heritage of the bridge was undertaken. The NIAH appraisal of the bridge structure refers to the good quality workmanship and the design making a pleasing visual statement at a crossing over the River Barrow. The incorporation of a raised footpath, rubble strip, and pedestrian handrail at the historic bridge wall will detract from the design and character of the bridge structure.

The need for a traffic light-controlled crossing system also raises issues of traffic congestion and tail-backs at either side of the bridge. On the Goresbridge side, the tailbacks will have implications for vehicles entering in and out of the Tirlán premises and numerous other local businesses, including the Allcare Pharmacy on Bridge Street which like other businesses and houses, are entirely dependent on on-street parking.

The contributors to this submission would not be in favour of Option 1 for these reasons,

Option 2 - The contributors to this submission would not be supportive of Option 2 involving a cantilevered footway strapped to the site of the bridge for aesthetic and heritage reasons.

Option 3 – This is the optimum Option for the contributors to this submission, subject to the most appropriate location of a stand-alone bridge, design and heritage considerations, including safeguarding against adverse impacts on the natural habitats of the River Barrow (SAC).

The segregation of pedestrians and cyclists from vehicular traffic on the bridge eliminates the traffic hazard conflicts.

At the meeting in Goresbridge on 15th February 2024, it is understood issues around the impact on the SAC, heritage, floodplains, and cost were given by the meeting facilitators for not progressing Option 3.

Similar stand-alone bridges have been constructed in Castlecomer, Kilkenny and Leighlinbridge over the years. All three are constructed over stretches of river with similar SAC protection and floodplain designations, with their designs incorporating mitigation measures to ensure no adverse impacts on their ecological protection status.

In terms of potential heritage concerns, with appropriate siting and design Option 3 is most likely to have lesser built and cultural heritage impacts than Options 1 and 2.

Finally, in the absence of details of the Option Design Report or details of the designer’s appraisal of each option, it is not possible to establish what weight was attached to the potential a stand-alone pedestrian and cyclist bridge would make to the Barrow Blueway Project, and what potential existed for financial assistance this program could give to the provision of a bridge. Currently, the Barrow Blueway Project is supporting the delivery of a pedestrian bridge over the River Barrow in Athy which is currently at tender stage.

Conclusion

In conclusion, the proposed development by Carlow and Kilkenny County Council for works on the bridge in Goresbridge has elicited significant concerns and considerations from various stakeholders, including Connolly’s Red Mills. Pedestrian safety is paramount and speed controls should be considered but the proposed option does not seem a valid solution.

Options presented in the consultation, particularly Option 1, have faced criticism for potential structural risks, traffic management challenges, and heritage implications. While Options 2 and 3 seem to have been discounted without community consultation. In consultation with our suppliers, our Customers who are users of heavy good vehicles, Option 3 has emerged as the preferred choice, contingent upon careful design considerations and mitigation measures to address ecological and heritage concerns.

Moving forward, it is imperative for Carlow and Kilkenny County Council to address the outstanding issues raised during the consultation process, including the need for transparent decision-making, thorough impact assessments, and meaningful community engagement. Only through a collaborative and well-informed approach can a consensus be reached that balances the objectives of pedestrian safety, heritage preservation, and environmental sustainability, ensuring the long-term benefit of all stakeholders involved in the development of the bridge Goresbridge.

Kind regards,

Connolly's Red Mills Directors

Gore’s Bridge Pedestrian Improvements Scheme 2023/2024 - Submissions

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