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They questioned the rationale for removing the existing 9 m carriageway and footpaths on the EIS Ballyowen Road requiring the importing of 30000 m3 of materials for a nett gain of 2 bus lanes on a widened carriageway of 14.5 m and 2 no. They questioned if the 3 tonne limit and 30 mph speed restrictions, described as "proposed", were part of the scheme and also the basis for the pavement design of 300mm blacktop when a 3 tonne limit applied, suggesting that thickness could be excessive and asked if different thicknesses applied to the Adamstown/N4 link as compared to the Adamstown/Fonthill link.

He said the assessment was self contradictory in several respects and gave as examples Figures 3 & 4 of Appendix D for NO2 AALV as exceedances, whereas the EIS at Table 8.15 said the predicted results were below limit values, and that in Table 8.15 the worst modeled 2004 value was lower than the best 2003 measured value which he said indicated the model was not accurately predicting pollution concentrations. They questioned the reference in the EIS of "Ballyowen Road" to describe the road from Balgaddy to Ballydowd while accepting that was on the OS maps but said "Ballyowen Road" was signed locally for the road running east from the roundabout at Ballyowen Park/ Willsbrook Park towards St. They accepted IFLUT recommended creating a new longterm link from Adamstown SDZ and ultimately to the Celbridge road and Liffey crossing at Weston but said the EIS discounted this at para 3.4.6 as splitting Adamstown in two which they said was a groundless suggestion. They queried why no dedicated bus lanes were provided in ORR Phase 1 to Grange Castle and if the effect of the new Lidl store at Pennyhill was taken into account in the traffic predictions. Evidence of Derry O'Leary -- -- -- -- -- -- -- -- 107 20. LTQL questioned the assumptions in the Traffic Model, submitting that traffic predictions in the EIS were based on "best case" scenarios assuming LUAS, Metro and other bus infrastructure were put in place which they doubted; that as a multi-modal model was used the future car volumes would be higher than in the EIS and pointed to a reference in the EIS at Section 5.2 to a finite capacity in the local road network being a constraint on local development in the absence of public transport initiatives as reinforcing the LTQL view of what would happen.

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Cross-examined by Hugh O'Sullivan -- -- -- -- -- -- -- 108 20. They sought SMA used as the surfacing medium instead of HRA to reduce traffic noise; questioned the rationale for replacing existing pavement when there were no signs of deterioration and said that it would be more cost effective and in keeping with sustainability to widen the existing road and footpaths.

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