Critique of DfI responses to letters (updated 28-01-2025)

Based on a careful review of the TOF response letters (TOF-1389-2024 and TOF-1506-2024), several key statements were made without supporting evidence or detailed justification:

  1. Cost Estimation for Bridge Project
    “…such a project would require significant capital investment and there are very specific environmental constraints as Strangford Lough is designated as a Special Area of Conservation and an Area of Special Scientific Interest.”

While the environmental designations are factual, no evidence is provided about:

  • The actual estimated capital costs
  • The specific environmental constraints and their impact
  • Any detailed feasibility assessment
  1. Comparative Bridge Cost Example
    “For comparison the Narrow Water Bridge has a span of 195m and a tender price of €102m (£87m).”

While providing a specific example, this comparison:

  • Doesn’t account for different site conditions
  • Doesn’t provide evidence why this is an appropriate comparison
  • Doesn’t explain how this relates to potential Strangford crossing costs
  1. Claims About Economic Benefits
    “…it would be very difficult to demonstrate the value for money of this as a transportation proposal”

No evidence is provided regarding:

  • Any cost-benefit analysis
  • Economic impact assessments
  • Regional development benefits
  • Wider economic benefits
  1. Ferry Service Performance Statistics
    While specific statistics are provided for 2023-24 (e.g., “22,000 scheduled sailings”), no evidence is presented about:
  • Long-term performance trends
  • Comparative service reliability metrics
  • User satisfaction data
  • Economic impact of service disruptions
  1. Claims About Funding and Resources
    “Taking forward a feasibility study is not considered a good use of public funding particularly during a time when the Department is facing significant funding and resource challenges.”

No evidence is provided about:

  • Actual costs of feasibility studies
  • Department’s current resource allocation
  • Alternative funding options
  • Opportunity costs

This analysis is supported by new evidence from the Cost Drivers report (NIC-Costs-Report-Final-Oct-2024) which emphasizes the importance of early project assessment and clear strategic direction. The report notes that “Government has not been able to identify, with a single voice, what the most important infrastructure projects are to achieve its goals and then to ensure it is collectively working to deliver them on time and to budget.”

The DfI responses appear to exemplify what the NIC report describes as “a lack of clear strategic direction” and highlight systemic issues in infrastructure planning and assessment in Northern Ireland.


Fact check on Minister O’Dowd’s statements. Assessment of each key element of the Minister’s September 3rd, 2024 statement:

  1. “numerous requests for a permanent crossing”
    TRUE – Evidenced in “History of Roads Service” and “2013 Strategic Review Report”
  2. “would require very significant capital investment”
    PARTIALLY TRUE – But no consideration of:
  • Current £3.52m annual operating costs (DFI 2024-0366)
  • £2.09m annual subsidy
  • Future vessel replacement costs
  • Wider economic costs of current arrangement
  1. “sensitive environment…designated as Special Area of Conservation and Area of Special Scientific Interest”
    TRUE – Confirmed in environmental documentation
  2. “would improve journey times”
    UNDERSTATED – Documents show:
  • Current alternative route: 75km/1.5 hours
  • Direct crossing: 8 minutes
  • Critical for emergency services
  • Significant economic impact
  1. “insufficient economic benefits to justify such a major investment”
    FALSE based on evidence:
  • Current ferry costs £2.09m annual subsidy
  • Cleddau comparison shows potential 20x traffic increase
  • Census data shows 345,733 combined population base
  • Significant suppressed economic activity
  • Multiple departmental budgets affected
  1. “provides a reliable service”
    CONTRADICTED by DfI’s own data (2023/24):
  • 108 sailings cancelled due to fog
  • 32 cancelled due to staff unavailability
  • 550 cancelled due to industrial action
  • 158 cancelled due to mechanical/technical issues
  • Total 848 lost sailings
  1. “currently the most economical method”
    FALSE based on financial data:
  • £3.52m annual operating costs
  • Only 41% cost recovery
  • £14.84 cost per vehicle
  • £8.81 subsidy per vehicle
  • Operating at only 36.3% of theoretical capacity
  1. “complements the existing road network”
    MISLEADING given:
  • 75km detour required when service unavailable
  • Significant journey time impacts
  • Emergency service access issues
  • Economic connectivity constraints

The evidence suggests several key aspects of the Minister’s statement are either incorrect or fail to acknowledge significant contrary evidence contained within departmental documentation.