May 11, 2023

Dublin Port 3FM Project

Ciarán Cuffe, MEP for Dublin
Green Party Comhaontas Glas
The Tara Building
11-15 Tara Street, Dublin 2

Mr. Jerry Grant, Chairperson, Dublin Port

By email

Dublin Port Company, Port Centre - Alexandra Road

Dublin 1 - Ireland D01 H4C6

Dear Mr. Grant,


I welcome this consultation.  My suggestions are as follows.

  • Dublin needs more housing that is affordable and located close to the city centre. Repurposing some of Dublin Port’s lands for housing and other mixed-use development would be a better use of much of the lands scheduled for Port use in this proposal.
  • Modal shift is needed from road to rail, and strongly promoted through European Union, National and Dublin City Council’s plans. It is regrettable that a shift of freight traffic from road to rail is not central to these plans.
  • Continued port growth threatens our climate goals. Growth in port traffic going forward seems inconsistent with the Government’s Climate Action Plan and policies and suggest that Dublin Port’s strategic approach merits reconsideration. This could favour the relocation of certain functions such as oil and container storage to a new location close to the rail network, the reinstatement of rail services to and from the port, and the optimisation of lands within the port by better managing the leasing of lands and other measures.
  • Is this the right use of valuable lands? Ports don’t employ many people directly on an area basis. I note that direct employment in the Part has decreased dramatically per unit tonne and it may no longer be appropriate to make use of the designated lands for port activities which generate low levels of direct employment.
  • Access to the Bay is crucial for visitors and residents alike, especially for those who walk, cycle or take the bus. It may be prudent to prioritise the amenity value and housing potential of these areas rather than prioritise future port development. 
  • Additional roads are not the answer to transport needs in a climate-constrained world. even if some quality active travel routes are provided alongside. It is unclear how the proposed walking and cycling routes will link into the existing and future active travel infrastructure, and how surveillance of these routes will be provided.
  • Walking and cycling should be prioritised along existing and future desire-lines.. The proposed transport infrastructure is heavily road-based and discourages active travel in an area that attracts considerable numbers of visitors who could avail of walking, cycling or public transport to access the beaches of the Poolbeg Peninsula and the Great South Wall that fall within the Dublin Bay Biosphere.
  • Consultation could be clearer. While the display of the consultation material in an online consultation room is innovative, it makes it difficult to access the material in one clear document and may be challenging for some stakeholders to access. I suggest that future consultation should include one clear document that might be available in common formats such as .rtf, .doc, or .pdf.

I wish you well in your work.



Ciarán Cuffe

Ciarán CUFFE, MEP for Dublin

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