Case studies of EIA in practice - Introduction to Environmental Impact Assessment - page 271

The CC tested the various route options against their ability to provide the best
solution “in terms of human safety, capacity and economic viability”. However, there
appears to have been no systematic attempt to test the alternatives against the need to
avoid the loss of priority habitat, even after the Council became aware of the importance
of Ballyseedy Wood. The conclusion of the independent study was that “[the] alternatives
were not examined to the same rigour or degree as the preferred route and appear to have
been rejected without clearly defined and quantified justification” (Weston & Smith
1999).
An issue that appears not to have been considered by the CC in its route selection is
the need to serve those areas where future development growth is planned. In this case
this was the northern edge of Tralee, which was the location of a new Regional Technical
College and of allocated industrial areas. This suggests that a more northerly route
alignment for the dual carriageway—which would have avoided the impacts on
Ballyseedy Wood—may have been better placed than the proposed scheme to
accommodate the growth in traffic generated by these planned developments. The
proposed scheme would involve traffic serving these planned growth areas passing
through the town centre of Tralee. This would add to existing traffic problems in the
town, and may have resulted in the time benefits derived from the improved N21 being
lost because of increased congestion in Tralee. The independent study comments:
It is surprising therefore that an alternative alignment for both the N22 and
N21, which links the infrastructure to the areas of Tralee where future
development is planned, has not been more fully investigated. A northern
route proposed by private individuals, which could be of dual carriageway
standard, was not adequately assessed in terms of the strategic objectives
of the Operational [Transport] Programme or in terms of its benefits such
as avoiding Ballyseedy Wood and maintaining the existing distinctive
quality of the area around the
Ballyseedy Monument. There are other possible alignments that appear
not to have been fully considered, such as routes south or north of the
railway line [which runs to the north of the existing N21]. Although the
Council's Design Report rejects such routes because of the problems of
crossing the railway line, farm severance and the impact on property,
there appear to have been insufftcient investigations and assessment on
which to base such an outright rejection of such options.
Overall, there is little to suggest that the Council's alternatives have
been tested to the same degree as the preferred option. The alternatives
considered were not subjected to detailed costings, surveys, time-saving
considerations, their ecological impacts or indeed their ability to meet the
strategic objectives of Structural Funding. In the absence of the rigorous
testing of all alternatives against clear objectively determined criteria it
cannot, in this case, be concluded that the objectives of the [OTP] cannot
be achieved with an alternative solution to that which would damage the
priority habitat. (Weston & Smith 1999)