1. The department should make known fully the extent of these plans so that people in areas such as Cherryvalley, Kings Road, Kingsdale Park, Knock Road & the Sandown Roads know whether these are to be affected, impacted and to what extent they are stakeholders.

2. No time has been given for residents to obtain a copy of the report and review its impact, the following observations are therefore skewed by this fact.

3. The Comber Walkway is a nature and bike route which has had a positive impact on the local community and this community element will be lost should this plan proceed, this is unacceptable given the loss of green spaces and gardens, due to extensive development in the east of the city.

4. The bike route exists in the absence of such a route along the main road and provides a safer community alternative. Given the amount of money spent advertising walking and cycling by the health department and councils it would seem a nonsense to now waste the gains made.

5. Having spent a considerable amount of public funds to complete the walkway, then to redo it after extensive sewage work, serious questions would need to be asked and public officials held to account for such waste. The proposed policy has been on the cards for some time and as such if it was a serious proposal ministers had a duty not to waste huge amounts of public funds on it, until a decision had been made.

6. The route is now a nature walk and as such the nature encouraged to flourish there should be protected

7. The proposal for a rapid bus service along this old line is flawed. It would turn a nature route into a desolate area during the hours of darkness, potentially dangerous and a magnetic for anti-social behaviour. It would need monitored and safeguarded for people trespassing onto the sites. Issues over public right of way may need addressing. Children continuing to play on it as they do now would need addressing. The proposed new bus service apparently would divert from the Upper Newtownards Road at Dundonald along the link road to this old railway line in order to travel town bound. The assumption must be that this would be faster than traveling on the existing routes, i.e. in a straight line along the Upper Newtownards Road into the city centre using a bus lane, but there is no evidence presented to me to back this up. The assumption would have to take account the time involved in getting to this new line, the amount of stops on route (the fewer stops the fewer people benefited - the more stops the more ineffective and slower the service) the speed the new service could reasonable achieve given the dangers to local residents and children, the number of underpasses to be constructed, the number of level crossing or traffic junctions that would be needed and consideration would have to be lent to the fact that it is not a straight line into the city and therefore a longer route. Furthermore, the areas involved along this route have an adequate bus service, which to date no one appears to be questioning even at projected levels. Taking all this into account, the new proposed service could not reasonably exceed a speed of more than 30mph which taking into account the number of intersections it would have to pass would mean it would be slower than the existing transport system. Furthermore if the reports are correct and there would be buses every five minutes during peak times, it is therefore possible that with buses going in both directions, that a bus would pass an intersection every 2/3 minutes and depending on how they proceed will depend on the knock on effect to rush hour traffic. For example if there was a level crossing / cross roads on the Kings Road with these proposed buses bringing traffic to a standstill every 2/3 minutes, traffic which is already bumper to bumper in 2008 would bring the whole east side of the city to a standstill by the time this policy is implemented. The cost benefit ratio in my view is flawed for the traffic projections are not lessened by the plan, and where there is perceived benefit during the rush hour this is negated by the cost of a service which is not needed at other times as the existing service at projected levels remains adequate in addition this proposal also assumes economic growth and the location of inward investment both of which are unknowns. It is clear on the limited information available to me that this plan is flawed.

8. Any proposal involving a light railway alternative using the same route would affect many more stakeholders covering different areas, streets, houses and have a substantial impact on communities. It is my view that you would be under a legal obligation to consult properly on such a proposal should it become an option on the table. It is clear that as stations would likely be needed and other issues considered such as local parking impacted by commuters and park and ride schemes that the number of potential stakeholders could be in the thousands and that they have a legal right in my opinion to know that they have a say in such a proposal should it become an option.

It is clear that many more objections could be raised if the information pertinent to the report had been made available to me, but I would request that you ensure that all relevant stakeholders are informed of the actual proposals on the table, that they are informed of how such proposals would impact on them and given their right to reply, within a proper consultation period.

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