DCC Dublin City Development Plan 2022-2028

SUBMISSION TO

Pre-Draft Plan Public Consultation Strategic Issues Paper

22nd February 2021

On behalf of: Core Group Lower Kimmage Road Residents Association (LOKRA)

Contact Details: 200 Lower Kimmage Road D6W R298 e-mail: [email protected]

Table of Contents Introduction...... 3

Theme 1: Shaping the City ...... 4

Theme 2: Climate Action ...... 7

Theme 3: Quality Housing and Sustainable Neighbourhoods ...... 9

Theme 4: The City Economy ...... 14

Theme 5: The city, Urban Villages and Retail ...... 17

Theme 6: Sustainable Movement and Transport ...... 19

Theme 7: Green Infrastructure, Open Space, Recreation and Natural Heritage ...... 21

Theme 8: Built Heritage and Archaeology ...... 24

Theme 9: Culture ...... 26

Theme 10: Sustainable Environment Infrastructure and Flood Risk ...... 27

Key Asks: ...... 31

Introduction

LOKRA Core Group welcome the opportunity to contribute our thinking to the Development Plan 2022-2028 via this process. We trust that fair consideration will be given to our requests and proposals. Where possible, we have attempted to follow the question format suggested in the Strategic Issues Document. Due to the challenges of Covid-19 however, it has not been possible for us to engage fully with our community on these responses. This is therefore the considered response of the LOKRA Core Group, which will be expanded on following wider consultation with our neighbours, in follow-on consultation processes – Covid permitting.

LOKRA, the Lower Kimmage Residents Association represents residents of the Dublin 6W area currently zoned (Z1, Z2, Z3, Z9), within 4.6 kilometres at the centre of our road, to the GPO and just outside the canal cordon, in a neighbourhood that is described elsewhere by the NTA as sustainable, mixed residential, with specific areas of conservation and archaeological interest, and small areas of open space. Lower Kimmage Road is both a gateway and a path among others to the traditional city centre, and historically, along the route of the Poddle river, to the foothills of the Dublin mountains1. Lower Kimmage Road has two important ‘nodes’ where travellers make directional decisions- the Kimmage Crossroads (KCR) and Sundrive Cross. These nodes have perhaps unduly influenced perceptions of our road. Recent transport, planning proposals and local heritage and regeneration projects have brought about our formal assertion of our identity as a diverse and inclusive community, strongly engaged not just as a single historic village, but as two villages, at Sundrive and Harold’s Cross, and with care for our diverse population and distinct communities of interest which thrive along our road. Lower Kimmage Road is within short walking distance of five schools, a nursing Home, Our Lady’s Hospice, two sports grounds, three Community Centres, and two small and treasured public parks underlining the need for design thinking that is inclusively family oriented, age and child friendly.

1 Dictionary of National Biography, 1885-1900/O'Donnell, Hugh Roe - Wikisource, the free online library Theme 1: Shaping the City

What areas of the City should be identified for regeneration?

• We believe that some Urban Villages close to the city but just outside the canal cordon, are in need of regeneration, with the village area at Sundrive Cross on the Lower Kimmage Road (LKR), being a stark example of decades of underdevelopment, having been undermined by insensitive redevelopment and is in need of substantial regeneration to save a precious historic resource to the city as a whole. • We would like Dublin City Council (DCC) to review the development of Sundrive Cross as an Urban Village, there is currently no central hub in this important part of our neighbourhood and this is the optimum location for a village centre, with pedestrian, public transport and vehicular access, commercial, residential and amenity usages in the vicinity. It has been underdeveloped and requires regeneration with careful planning and stimulus from DCC, in consultation with the community, to develop the area for residents, visitors and local business and innovation leading industry. • The principal requirement for Lower Kimmage Road in the new Development Plan is for a protective planning framework for the entirety of the road; Lower Kimmage Road North is included in the promised but deferred Local Area Plan (LAP) for Harold’s Cross; it makes no sense to stop the development of this Plan at the boundary of Sundrive Cross and not extend thinking the length of the road. There is currently no protective plan at all for this neighbourhood which has negative implications in cohesive community development. We believe that the introduction of an LAP or other strategic planning framework instrument, eg. an enforceable Master Plan in the context of a Special Development and Regeneration Area (SDRA) that would outline a roadmap to regeneration for this area. • We have inputted significantly into the NTA plans for the BusConnects project and our community largely supports an improved public transport network and the promise of a quieter, cleaner, healthier and safer street. The development of a village hub at Sundrive Cross would further support this aspiration. and should be consistent with the development and investment in Harold’s Cross and other related nodes as each sustains and supports the other in an integrated neighbourhood. • Sensitive regeneration involves assessing built heritage for its value. Sundrive Cross reflects some rare examples of Art Deco architecture that LOKRA Core believe merit examination in the context of an ACA. Identifying the art deco terraces diagonally opposite and parallel developments of housing facing onto the Cross- roads reflect in many ways a rural heritage and history. Equally other parts of Lower Kimmage Road have complete terraces of art nouveau homes that merit appropriate protections.

What criteria should the Plan set out for assessing higher density proposals?

• We see the integration of sustainable neighbourhood development as critical to the success of the regeneration of our area. While we understand increased density is critical to achieving a modern vibrant city, we live in a historical area and the impact of increased development will need to be carefully planned in compliance with Urban Development and Building Height Guidelines. Development must be balanced with appropriate consideration to the surrounding area and neighbourhood, provision of services and additional green space. The plan should be accountable to how it serves integration and connectivity of Urban Villages • There are some vacant and infill sites within our neighbourhood and we feel that these should be utilised to increase density along with new developments, services and green spaces, which are appropriately scaled for the area. These sites could also help to provide for the anticipated 25% growth in demographic along the periphery of LKR in the next three to five years, but within our neighbourhood, further strengthening the essential consideration of overarching Master Plan and SDRA. The plan should only conceive of development where there is an agreed, neighbourhood led, sustainable and enforceable plan that respects heritage and provides for the sustainable prosperity of the people living in the neighbourhood. • While increased height is appropriate for the city centre a more considered approach will need to be taken in Urban Villages. The plan must be sensitive to existing vistas and architectural landscape, taking its call from e.g. protected structures in our case, Mount Argus Church. • Most critical, is that development is not solely residential but the plan must be accountable to equally provide the services and supports required to flourish in an Urban Village, healthcare, education, community centres, libraries, sports facilities, public spaces, childcare services, recreational facilities and playgrounds. We also see innovation and light manufacturing, retail and sustainable commercial uses as a critical element to ensure that, as a residential part of the city, we are thriving locally and contributing to the city economy and are a destination and a hub as we have historically been.

How can the Development Plan promote sustainable neighbourhood and communities? Is the 15 minute City an achievable goal?

While there is an urgent need for a LAP e.g. continuing the line of progress for Harolds Cross and the North part of the road, or enforceable planning framework such as a Master Plan or SDRA for Lower Kimmage Road and the wider neighbourhood, we believe the 15 minute city has a head start in our local network of urban villages. To facilitate a successful outcome, some basic principles should be considered: • A citizen led, inclusive approach to improvements to villages, residential areas (including placemaking and place branding) and a full range of strategies to drive progress. • Significant investment in and re-imagining of vacant spaces / buildings and Public Realm in local neighbourhoods which would support the ideal of an attractive place to live, work, play and learn, as envisaged in the 15 minute city concept. • Enhanced orbital public transport links for the local village network capitalising on micro-mobility and inclusive transformational innovations in transport thinking • Support for a sustainable local economy and social infrastructure as outlined under Theme 3. • The development of structures such as participatory community councils with proper research support that can give voice to all sectors of our community, including children, youth, families, older people, business and entrepreneurs - including social entrepreneurs, people with differing care needs and specific disabilities, people experiencing disadvantage in its multiple distributed expressions, and network structures to enhance and support communities of interest.

The 15 Minute city is feasible where micro mobility is built in and acknowledged (see Theme 6) and where healthy street indicators are taken seriously, in line with green thinking and just transitions.

Where increased density is proposed, how can we ensure that appropriate standards of urban design and architecture are promoted to ensure sustainable and liveable communities?

• There has been significant concern in relation to the virtually unfettered developer led planning that has resulted in decades in poorly conceived and inappropriate development in the city and its Urban Villages. • The move to a planning led development model is welcomed and urgent, as are the control of building heights guidelines aimed at protecting residential area integrity and taking Urban Realm, cultural context and significant landmarks and historic sites into account. • While acknowledging the need for rental property across the city, there appears to be an over-emphasis on this one form of accommodation in our area, with Harold’s Cross alone seeing significant increase in planning applications for rental only / Co living and Student type accommodation. These developments are aimed at large investment companies (Ref: the Strategic Housing Development Plan 2017), with no apparent auditing of the balance of local housing requirements and with little attention being paid to the incorporation and addition of associated services and publicly available open green / blue space. • LOKRA requests an audit of the balance of existing and planned housing provision for the area, to include: affordable homes – apartment / duplex / houses; Rental property – short term / long term / buy to let; Student accommodation – shared homes / short-term rental / co-living; Social housing – homes / apartments and homeless hubs • We suggest that there is inadequate focus on family housing provision and that the schools have the potential to support the development of Lower Kimmage Road, Sundrive and Harold’s Cross and surrounding residential areas as learning communities. We ask that particular attention be given to this in co-operation with the school’s communities. • All planning development tax should be distributed back into the neighbourhood from which development monies are collected. In this way, e.g. water supplies can be renewed, sustainability objectives can be serviced and community give-back guaranteed. Theme 2: Climate Action

How can the Dublin City Development Plan facilitate Dublin’s transition to a low carbon society?

• Engage communities in innovative ‘green’ thinking and invest in and promote environmental protection, green research and projects at local level. • Promote and support Lower Kimmage Road as a vital Green Lung, part of a chain of small but precious parks- Ravensdale Park, Mount Argus Park, Harold’s Cross Park providing essential linear green space following the path of the Poddle to the city. To support this into the future will require: o The prioritization of health and safety for everyone in the city and in local areas such as LKR that suffer on a daily basis with a growing, unsustainable and unacceptable volume of motor traffic. o Lower Kimmage Road Nitrogen Dioxide (NO2) levels currently are reported by the EPA at dangerous levels, directly impacting negatively on resident’s health and on the environment. Our air quality is poor. We need this to change. o A reduction in the volume of this traffic, and enforcement of a 30km speed limit together with a range of measures as listed in LOKRA’s recent submission to the NTA CBC 11 3rd Phase Public Consultation and in keeping with Irelands commitments in the Stockholm Declaration (Feb 2020). This would help achieve a safer, healthier, cleaner road on which our community can thrive, with proper planning and ease of access to services for our residents. • Expand and create green areas, with the planting of heritage trees, wild area etc. wherever possible • Increase the roll-out of electric car charging points • Increase the roll-out of quality and affordable Park and Ride facilities for both cars and bikes, scooters and innovative micro mobility transport solutions including mobility chairs for older residents in schemes similar to Go-Cars, to encourage a move to public transport use and more active commuting. • Start investing in future-proofed public transport options such as Metro Note also suggestions in the following questions and in Themes 7 and 10

What measures do you think Dublin City Council needs to introduce in order to improve and promote climate action awareness?

• Our research with our community indicates a high value on ‘green’ thinking, on the environment and on ecology. There is a de facto interest in the ‘green deal’ and ‘just transitions’ which should be accessible for all our community. This enthusiasm and interest needs to be harvested and supported. • Local neighbourhood supports and engagement with schools and community groups would be a start. • From the NTA ‘assets’ we know that here are environmental studies for the Lower Kimmage Road including parks on ecology, wildlife and environment - could these be published / readily accessible? These could then from the basis of a public information programme for the locality and for an education programme to be designed so that we can protect what needs to be protected with the support of DCC, Parks Department etc. • A city-wide educational campaign in relation to care on our residential roads, green spaces and neighbourhoods.

How can energy efficiency and effectiveness be improved within the period of the next City Development Plan?

• LOKRA requests an urgent audit of the carbon footprint of this area with recommendations of what options there might be to reduce our carbon footprint locally – eg. what kinds of investments and by whom might support a lower carbon footprint for this neighbourhood • The EU and DFHERIS progress will be investment-led in collaboration with the Universities - we have TU Dublin on our doorsteps and TCD, UCD and DCU almost equidistant – engage with and connect learning institutions with local enterprise / innovation projects • Critically evaluate all infrastructural investments, to ensure energy efficiency is integral to all planning applications and approvals • Support and invest in existing public buildings (community centres / sports halls / libraries etc) to re-engineer their facilities with a view to energy sustainability • Expand the current system for retro-fitting homes with further incentives and promotion to ensure speedy uptake. • Invest in the education of Irish graduates / apprentices to sustain this infrastructural change and maintenance over the coming years, specifically assuring a balance of labour distribution to neighbourhoods who give hugely to the city and Greater Dublin Region by becoming transport corridors - this should include broad pay -back as part of the development of sustainable and green innovations flagged in the programme for Government.

Theme 3: Quality Housing and Sustainable Neighbourhoods

Lower Kimmage Road is a community that reaches out to local neighbouring areas such as Harold’s Cross, Kenilworth, Mt. Argus, Priory, Larkfield, Sundrive, Clareville, Aideen, St. Martins, Corrib and Hazelbrook to name a few and aims to be serve cohesion across the neighbourhood. As such, we view ourselves as integrated rather than peripheral to our neighbours and we request equal consideration in terms of funding, neighbourhood development schemes etc. We interact with villages and community nodes that form a natural network across our area. This allows for a coherent, neighbourhood wide treatment in the development plan which would be necessary and optimal in terms of employment, housing integration and amenity development.

Do you think that the City’s neighbourhoods deliver a good quality of life and what would make your community a more ‘liveable’ place?

Lower Kimmage Road and its environs, as a city neighbourhood has been neglected and requires regeneration, the development of a sustainable economic and social infrastructure for the area needs to be carefully considered in the new Development Plan, as envisaged in the ideal of the 15 minute city. The key to any sustainable neighbourhood is a sustainable local economy

Sustainable Urban Village Economy:

There are strong concerns against a ‘K’ shaped recovery where the social divides are exacerbated, so access to opportunity is a key facilitator; one advantage that Ireland has – and our neighbourhood is important for this - is that over 50% of our national population has a third level qualification. this is something with which to build high skills ‘clean, green’ jobs with. However we also know that the ‘K’ is a reality for us and that we have many who are excluded, not necessarily only socioeconomically but in terms of being able to access skills, or articulate and join debates.

• We need community-based education and information programmes so that we can all engage with the ideas and concepts behind the green economy, and prepare ourselves to work in these new and evolving local opportunities in local enterprise / development / innovation hubs • We do not want to be a neighbourhood of high-rise apartment blocks and to be feeders to a city centre ailing retail trade. We have a New York style potential industrial heritage that could be capitalised on, but also a highly educated and lively thinking community. This community could devise the next 'big thing' and create real wealth locally. Our ambition is to provide the environment for the next ecology centre / science hub / digital creative space – and be the neighbourhood you choose to live in. • It is vital that we don't lose our neighbourhood as a site for generating and creating employment, a place where people walk to and travel into work, and can find work in, creating and adding value. The EU has a budget of €750 million invested in technology-led, clean industries, and in strengthening the Green Deal. The estimate in development for the next priority list is for 37% green industrial development, 27% digitisation projects. LOKRA recommends that these types of funding streams be used to help support the set-up of innovation hubs in urban village settings, such as at Sundrive Cross, looking North, South, East and West embracing all neighbourhoods, and with the Harold’s Cross village.

LOKRA requests for the neighbourhoods of Lower Kimmage road / Sundrive Cross / Harold’s Cross, an audit of the area’s assets in the region of the triangle from Harold’s Cross bridge to Terenure and KCR, Ravensdale, Greenmount and Sundrive Cross, to include:

• Space usage audit of: current retail, industry, manufacturing and services • Industry, manufacturing and services current provision - scale of operation, engagement with and use of technology / robotics / AI / Training / access, delivery • Green agenda: biodiversity, ecological impacts, contribution to the circular economy • Home businesses and home working - how many businesses are operating from homes / from premises / what premises? How many people have / intend to change their daily working pattern and commute? Following this baseline data, we would like to see the following for our area: • A Community Enterprise Hub to support manufacturing and innovation, entrepreneurship and employment. We need to move beyond retail and hospitality to ensure the future sustainability of urban villages. • There are existing local enterprise areas such as Ravensdale and Greenmount which could become revitalised hubs for local industry - innovation hubs - creativity hubs - development hubs. • We need alignment with innovation hubs in Universities and with City of Dublin ETB and Skillnet Ireland to understand what the specific skills and research are to help transition these businesses to fast-track to the new tech-led future that is green. • This can be done in tandem with sensitive and appropriate residential development and green spaces. • A digital hub is also essential to facilitate local enterprise, remote working and youth and elder digital training and education. • A creative connection hub - bringing community strengths together - arts, science, learning, technology with education and community base. • Regeneration of shop fronts and Community Centre facilities In essence, we need green regeneration and wealth generation based locally on knowledge innovation and creativity

Sustainable Social Infrastructure: As the Development Plan document indicates: 30% of RSES principles relate to Healthy Placemaking including Sustainability, Urban regeneration, Creativity and Healthy communities. These principals must be central to any Urban Village development. There are many initiatives that could be put in place to improve social infrastructure and quality of life in this area, for example:

• A state of the art Medical Centre with full geriatric, paediatric, counselling, physio, dental, diagnostic educational and other support services adequately resourced to meet home based community need. • A Local Cultural Centre – the local network of south central villages is well served with libraries to the east, but needs a cultural hub to support the development of an arts culture in this area and to advance local projects, training and exhibitions for all ages and groups. • A theatre, cinema, entertainment space for the entire area that can be repurposed for multiple use is perfect for Sundrive Cross as it looks N,S,E,W. • While Whelan Park on Lower Kimmage Road is used extensively for football training and games, there is a lack of an indoor sports / fitness / youth facility to encourage, support and educate on healthy lifestyle choices and community engagement. Rosary Hall provides some possibility in this regard but requires significant investment. The loss through the Mill Development on Lower Kimmage Road to the area of a wheelchair friendly youth and sports hall remains an aching gap for which no trade back has been given, and from which DCC profited substantially. • Significantly upgraded Urban Realm to include appropriate dwell spaces, green areas and community information facilities – this could be considered In the context of the Bus Connects public realm proposals, which should dove-tail with a larger vision for the area supported by the DCC Development Plan

How can we plan for different sectors of society including an ageing population, people with disabilities, children and young people and ethnic minorities?

• As a primarily residential area with a varying age demographic there are elements of infrastructure which are missing in this area. While the area is well served with schools there are few recreational or sporting facilities for families. • For the older residents accessibility is an issue and consideration should be made as to how older people and those with disabilities can be better accommodated within city neighbourhoods. The improvement of pedestrian and cycling facilities would be beneficial to all residents. The Age Friendly Village initiative in Harold’s Cross is vital to the thriving of our neighbourhood and needs to extend South to join with Terenure initiatives along the KCR and exploiting the vital resource of the Mount Argus Community Centre at 174 Lower Kimmage Road. • Social inclusion is critical to a cohesive community and while Lower Kimmage Road has existing social and homeless housing hubs, the community has not been involved in the development or siting of the hubs and integration into the community is minimal. The development of community consultation groups would be welcomed. Equally the distribution of essential hubs needs to be balanced and to prioritise integration into the fabric of surrounding neighbouring areas.

What impact has Covid-19 had on your neighbourhood and community and how could we adapt to deal with its impact?

The impact of Covid-19 has already brought us closer to the vision of the 15-minute city and heightened the realisation of the value of Urban Village life and the critical importance of strong, sustainable and vibrant local communities

As Malcolm Smith, an urban design fellow with Arup, stated in a recent New York Times article stated: “It has shone a light on the importance of developing cities in smaller modules, with essential services concentrated around community hubs,” he wrote. “In the 19th century, the response to cholera in London brought big infrastructure, the sewer network. I hope Covid-19 will lead to lots of smaller scale but widespread interventions.”

It also created a new urgency and momentum for change and vision that must be built on and encouraged. A prerequisite for successful change must be local, fully inclusive engagement.

• COVID has highlighted the paucity of green space and trees along the Lower Kimmage Road. The HX Grow community initiated and led project and Bus Connects provides some threads of hope for further greening, but this is essential and a priority for health and wellbeing. • COVID has illustrated the challenges of the digital divide for our community very sharply as notwithstanding the provision of 6 key consultations by varying state agencies that will each impact our residents, we have not been in a position to engage with residents as we normally would or as we all wish. Many homes do not have devices and lack the skills to engage on-line. Lower Kimmage Road and Harold’s Cross has no community education outreach service that could provide supported tuition in critical skills like these informally. This is an essential development. • The importance of the Age friendly Village concept to the development of social networks is a vital learning opportunity for all. The closure of churches and Community Centres has meant that informal networks cannot be co-ordinated and some people who are more isolated are more subject to isolation than ordinarily. Social infrastructure is disabled including by our lack of meeting points and service provisions. • Our parks could host yoga, movement and relaxation in socially distanced ways that are inclusive for the diversity of our populations, including for younger parents at home. This opportunity has not been seized. • We would also acknowledge the core work undertaken by some DCC teams around litter, graffiti etc., including over COVID across the breadth of our district. • The provision of a Community Support office at local level with a paid research and development officer would enable greater sustainable, co-ordinated and systematic resolution of issues. A continued issue is making visible the networks, activities and groups that exist and how people can access and support or participate in these. CDCC cold use live stream signage with video display to promote consultations, meeting schedules, eco-feeds from parks etc in neighbourhood parks so that people had more opportunity to engage.

What measures should be considered to encourage the use of vacant sites, upper floors of buildings and underutilised infill sites?

Lower Kimmage Road, Sundrive Cross and neighbouring areas, suffer from a number of vacant sites and units. These could be converted on a permanent basis, to house any of the suggested business / innovation or cultural / social functions outlined earlier in this Theme. They could also be utilised on a temporary basis, while awaiting development, by innovative local projects or start-ups to allow them to ‘feel the market’ and refine their offerings of just to support home working. These could include:

• Niche / specialised food and beverage outlets • Art and craft design, performance arts and retail • Textile / clothing design and retail • Temporary office space for local commuters

LOKRA would be very happy to engage in a learning process with government agencies to help develop and support such initiatives.

Theme 4: The City Economy

How should the Plan support economic growth and ensure that development is located in the right places and developed in tandem with the requisite physical and social infrastructure?

• We are living in a time and a world of dynamic change and portable work. Physical and social infrastructure needs to be designed as multi-functional to accommodate current requirements but also facilitate future change needs with minimally disruption. We can see the issues there are now with the requirement to ‘re- purpose’ buildings from office to residential for example. • It is critical to address unemployment blackspots with innovative thinking and shared goals if the city economy is to fulfil its promise of tackling social in-equality. • More focus needs to be put on developing functioning and sustainable community hubs that can support economic growth from the periphery as well as centrally. This would lead to a ‘lifting of all boats’, with security in a range of infrastructural and social locations as well as sustainability of both city and suburban communities. • Similarly transport infrastructure needs to be sustainable, dynamic and able to adapt to future needs. This will require a more ‘joined up’ approach to projects and the commencement of a proper metro network interconnected with other modes of public transport for the wider city. What key sectors in the City Economy should the Plan support and how can this Plan contribute towards the development of a strong resilient economy?

• Areas of economic activity such as the financial, digital and pharmaceutical sectors have seen significant investment and returns in recent years. It is time now however, to focus on stronger development of local talent and enterprise, which has shown itself to be both innovative and flexible during Covid times. We need to invest in and capitalise on this pool of local talent if we are not to lose it to other countries and economies, including through continued educational opportunities. • Ireland has a strong international reputation in culture and the arts – a sector that has been decimated during Covid. It is vital that these ‘soft’ areas of potential economic growth and return be strongly supported in the Development Plan or a vital and unique Irish resource with international appeal will be lost. . Lower Kimmage Road and Harold’s Cross enjoys a wealth of artists living and practicing in the area. The development of local platforms for performances is important in nurturing, connecting and sustaining talent.

How can the Plan address issues of economic deprivation in the City and spread the benefits of economic growth across all sectors of society?

• By working on regeneration of areas of deprivation and seriously investing in support services to enable education and employment in deprived communities for all generations. • Create facilitated support networks and hubs to encourage and build on local creativity, talent and innovation. • Provide ‘proud places’ for people to live, work, study and socialise in with the use of creative urban realm design and local culture. • Invest in creative education such as Street Art educational courses, as has been done in Malaga, to give creative young people an education in the arts and a pride in contributing to the beauty of city lanes and urban spaces. These areas become tourist trails in their own right with many stunning examples such as Buenos Aires and Malaga. How can the Plan promote orderly growth and the transformation of key regeneration areas as generators of economic activity? What polices or approaches are needed to achieve transformation of these regeneration areas?

• Engagement with key stakeholders within the areas is critical. As well as local schools and businesses, it is vital to include local residents associations, community centres and groups, disability organisations, elderly support organisations and community Gardai. • Consultation is not something that has been done well in this country and adherence to the Aarhus Convention needs to be wholesome and not just window dressing, if there is to be local ‘buy-in’ and support for projects. This will allow for a far greater chance of more rapid and orderly growth and a successful project that all can be proud of. How do we enhance existing Development Plan policies and objectives on tourism to deliver on its potential for the City and how should the Plan promote sustainable tourism development in the City?

• We should not assume that all tourists are only interested in Temple Bar and Guinness. There is an increasing young cohort of travellers interested in the green and lived experience of the society they are visiting. • Develop more experiential tourist options and trails • One suggestion that would also fit in with the goal of ‘spreading the benefits of economic activity’ could be to add a Southern Culture Trail section to that going east / west in the city centre, with appropriate (useable) pocket parks and dwell zones. (see Theme 8) • This could start at Dublin Castle / Christ Church and follow the historic and architectural development of Dublin’s earliest suburbs along the route of the Poddle River and could reflect the integrated pluralistic accepting communities that have lived along this famous medieval route, extending along the route of Art O Neill out into the Dublin Mountains. • An entire sports programme of a triathalon style could be developed for young people to discover districts and to use multiple modes of participation with a specific award for completion affiliated only to Dublin City. • Examine the Learning Cities model practiced in Cork and elsewhere under UNESCO. Nothing drives tourism and enquiry more than learning. Continue with the cultural talks provided by DCC experts.

Place making and high quality liveable cities are a key part of ensuring international competitiveness to encourage and attract Foreign Direct Investment, mobile highly skilled people and international tourists. How can Dublin maintain and enhance its attractiveness as a place to live work, visit and invest in?

• There has been an organic trend within the city for ‘zones’ to become associated with different cultures or activities. While Dublin is small by international standards, there is no reason why it can’t have areas of specialist interest – be it ethnic food, art, music etc. which are developed and promoted. • More could be done with these ‘themed zones’ in the city to make them more recognisable and accessible to tourists. • This should go hand in hand with strict planning guidelines on streetscape and activity to ensure an attractive and consistent offering. • There is also a richness of district neighbourhoods within walking distance of the city that could add to the visitors knowledge of the lived experience of the city. Many of these, such as Rathmines and Ranelagh are already well developed. Others such as the Art Deco influenced area at Sundrive Cross is crying out for re- generation, cohesive identity and placemaking. As stated in the recent webinar on this subject: “Quality is key in retaining our standing as an attractive city”. It is essential that this principal applies to all planning and development throughout the Dublin area. • These inner suburbs could offer a different but complementary experience to both investors and visitors and also help sustain local employment, viability and the concept of the 15 minute city. • In this context, shared transport options such as City Bikes / Scooters etc. should be extended in range to include the inner suburbs. How can the evening and night time economy be developed for the benefit of the City?

• If a night-time economy is to be attractive to all citizens and visitors, it is vital that an appropriate culture of safety and respect is built into policy and infrastructural planning • Ensure proper policing is available to re-assure patrons on health and safety grounds and minimise disruptive anti-social behaviour • Consider extended opening of cultural centres – even on a rotational basis to allow citizens who don’t have the opportunity to visit during the working day to engage with these as part of the ‘night out’ experience. • Provide safe, sustainable and convenient public transport with Park and Ride options eg. at the M50 rim to facilitate suburban commuters How can the Plan ensure that the role of the third level education sector is optimised in the City?

• Develop and support social inclusion to facilitate equity of access and ensure follow-on support structures are in place.

Theme 5: The city, Urban Villages and Retail

How can the Plan support retailing in the City Centre and ensure that the City Centre remains the premier shopping destination in the Region and State for comparison goods shopping?

To fulfil the objectives of attracting investment to the city centre and to: ‘support Irish owned businesses and small and medium size enterprises’ and to make the city centre ‘an attractive alternative to the M50 centres’, it is essential to improve access to the retail core and maintaining its viability. LOKRA recommends:

• Creating a second ‘outer’ parking zone inside the M50 to further reduce car traffic and congestion in the city centre and optimise the use of scarce city centre parking at the inner periphery of the retail core (Ilac Centre and St. Stephen’s Green) • Supporting the continuation of MetroLink to provide an underground Metro South West as proposed by the Metro South West Group, to city centre

Both of these initiatives would support the catchment of 230,000 population between the Red and Green LUAS lines in this sector (Metro South West Group analysis) – with no public transport option other than bus or car and the only quadrant of the city without any form of rail service. This is almost 20% of the population of Dublin outside the city centre (canal) boundary. It will be vital to incentivise this cohort to consider the city centre over local retail and hospitality offerings. They will NOT be incentivised if their only options are congested car transport and inadequate bus services to serve this ever-growing population and it is essential to put real and sustainable, future proofed solutions in place which will fulfil the objective that ‘private vehicles will be discouraged’ in the city centre.

What is the appropriate balance and mix between retail and other City Centre uses such as leisure, food and retail services in the Category 1 and 2 retail streets of the City Centre?

LOKRA supports the vision of a culturally linked and balanced use of the above services for the city centre and the re-designation of street categories as appropriate to facilitate and encourage pedestrian access and safe and sustainable trade - following appropriate analysis and inclusive consultation.

• The key here is to define the critical mass of each service that provides the best balance for all stakeholders, including day-time city users, city dwellers, inner and outer suburban users, tourists, disadvantaged and mobility impaired users as well as An Garda Siochana. This can only be determined after independent analysis, consultation and engagement with all concerned. • The significant impact of and learnings from Covid-19 must be taken into consideration. As Léan Doody, who leads the integrated cities and planning network for Europe for Arup said in a recent New York Times article, “There is an opportunity” as the pandemic fades from view, to “introduce new behaviours,” and “Perhaps city authorities, transport authorities and employers could think about policies to make a vision of the future that actually works for everyone,”

How can the Plan support the development of markets, niche and specialist retailing, independent retailing in the City Centre and in the other urban centres and villages of the City?

LOKRA views this as a very exciting possibility that should be built on locally as well as centrally. The scope for niche and specialist retailing is significantly under-developed in our neighbourhood. (see Theme 3)

• There is significant scope in the area of Lower Kimmage Road, in the local parks – particularly at Harold’s Cross, Mt. Argus and Eamon Ceannt, for the development of regular markets – food / craft / mixed. • This process of providing niche and specialist retailing as well as restaurant and coffee-shop offerings, needs to be developed as a coherent plan together with existing local businesses, business / retail property owners and community groups with a view to optimising the use of existing ‘mixed use’ space for the benefit of the community as a whole and by extension local retailers / business providers and re- generation hubs. • While some more affluent local areas have a wealth of local expertise, what is lacking in many under-developed areas and those needing re-generation, is expertise and co-ordination to harness the wealth of enthusiasm and local talent which could help form and drive positive change in placemaking and place branding. • It would be useful if DCC created a Task Force of experts in facilitation, leadership and knowledge of how the arms of planning and government work, to work with local communities in creating and developing a sustainable vision for their area – something similar to what Enterprise Ireland does for the economic and industrial sector. • As was stated in the Webinar session on this topic, Soft Social Infrastructure must be citizen led and requires integrated agency delivery.

How can the Plan support the development of a 24 hour City with cross generational appeal without impacting on existing uses in the City and the promotion of residential development?

As noted in the introduction above, development of a vibrant and viable night-time economy must not just be confined to the city centre. Urban Villages need the same (though not necessarily 24hr!), if local communities are to thrive and survive. There are some excellent examples in villages such as Ranelagh, Terenure and Rathmines.

• Night-time offerings on Lower Kimmage Road are predominantly take-aways, with currently just one restaurant offering night time service. There are already under- utilised and vacant retail sites at Sundrive Cross that could be developed. However, it is our contention that the starting point is to support a placemaking and place branding initiative here that would make the area attractive to location focused retail, food and beverage investors. • LOKRA would like to see a range of quality offerings, as available in other local villages, located at the Sundrive Cross village area. Due to our convenient location, there is already a significant (mostly one-way) consumer traffic from our area to these other villages to avail of their night-time economy services. There is no reason therefore that the opposite should also be the case, with Sundrive Cross being seen as an attractive destination for the early night-time economy. • Local consultation has been challenging in the context of Covid-19 and is still to take place with the community of Lower Kimmage Road in relation to proposals on this topic. LOKRA would like to ensure however, that an initiative be included in the Development Plan to support the regeneration and re-vitalisation of our long- neglected neighbourhood.

How can the Plan support the commercial viability, social and physical environments of Key District Centres, District Centres and Urban Villages and what mix of uses would best underpin these centres?

(See Theme 3)

Theme 6: Sustainable Movement and Transport

How do we encourage more people to travel sustainably such as walk, cycle and use public transport?

• The first priority should be to reduce the amount of motor congestion on our roads. To do this, it is essential to provide viable alternatives and incentives such as extensive and affordable Park & Ride facilities at the M50 rim. This would encourage motorists to avail of public transport options – assuming an integrated, attractive, efficient and reliable public transport system. • Public transport needs and deployment should be based on independent data analysis and modelling, with reference to POWSCAR and CSO data. • While Bus Connects aims to enhance the current bus service for the city, it will be inadequate alone to future-proof the sustainable requirements of a growing population, particularly in the South West quadrant between the Red and Green Luas Lines. • As the MetroLink project has been approved and soon to be initiated, this should be built upon to provide a larger sustainable network for the city and its environs, which could complement and feed into efficient Bus, Luas and DART systems. The first step in this could be that proposed by the Metro South West Group. Ireland is an serious outlier in Europe in terms of this form of public transport for a capital city. • Capitalise on existing natural infrastructure to provide green / blue safe cycleways, particularly for children and leisure cyclists wherever possible. • Better orbital public transport to support interconnectivity between local urban villages

Is shared mobility the future for Dublin? Should we be making use of shared community cars and bicycles, rather than privately owning them?

• While private car ownership is unlikely to disappear, there is certainly a place for significantly increased access to shared mobility options • Other forms of shared mobility such as Micro-Mobility, should be included in any future consultation process. Micro mobility whole-of-neighbourhood consideration practically would mean e.g. o e-charging bicycle/scooter storage included in designs for public realm o e-mobility chairs at micro-mobility points across the neighbourhood for local mobility, allowing mobility impaired people to transport local journeys to amenities, services, retail, bottle banks etc. o small e-mobility carriers for small groups such as e.g. children for schools/clubs with equipment to and from designated pick up points o e-carrier mobility carts for distribution of goods for businesses from networks of distribution points, reflecting the shopping local/shopping from home trends o Shared city bikes / scooters etc. should be extended beyond the canal to the inner suburbs

Should the Dublin City Centre of the future be car free, with access only for public transport, accessible vehicles & service vehicles?

• While in principle this may be an attractive option, it would be something to be decided following further public consultation, with a comprehensive suite of plans, parking and public transport options available.

Should cycling be permitted through pedestrianised zones or areas where most people are on foot? If so, what measures could be put in place to make this happen for example use of signage, introducing of speed limits?

• While it is laudable to encourage cycling as a sustainable and healthy form of transport, it is not so for everyone. There are many instances of cyclists being responsible for injury (sometimes significant) to pedestrians. • While many cyclists are considerate and operate withing the law, cyclists are largely un-regulated in this country with little accountability for the lack of adherence to the road safety code. • In this context, it is vital that any plans for the provision of shared cycle / pedestrian zones, be accompanied not just by signage and speed limits, but serious enforcement. • Where possible plans should still include an option of physical segregation of cyclists and pedestrians. • All plans should be available for public consultation before initiation.

Should electric vehicle charging points be provided on public streets and in areas where residential permits and pay and display schemes are in operation?

• This is something that would need to be considered on a ‘whole of neighbourhood / city’ basis and with appropriate consultation

Theme 7: Green Infrastructure, Open Space, Recreation and Natural Heritage

How do we ensure that all our citizens get the best from our green and blue infrastructure whilst the Covid-19 pandemic continues to play a prominent part in our lives?

Green Infrastructure and Open Space:

If the current pandemic has taught us anything, it is the extraordinary value of local green and blue space. This is something that should be remembered long after Covid-19 has become part of our everyday lives and not just ‘whilst the pandemic continues’ as in the question above. • We must be acutely aware not to further erode what little of this infrastructure exists – at a local level, this can start by recognising Lower Kimmage Road as a vital part of the Green Lung in this quadrant of the city. • Recently we welcomed the addition of 50 young trees being planted in Eamonn Ceannt Park. However, in the past we have witnessed whole-sale destruction of mature trees and hedges in this same park - removed due to “anti-social behaviour”. Communities need assurances that this type of impulse clearing shouldn’t happen again and that the root causes of ‘anti-social behaviour’ will be tackled and supported by DCC at source. • These mature trees and shrubs contributed much more to the air quality in our area than new young trees and this also needs be noted in relation to the NTA citywide Bus Connects scheme, The Poddle Flood Relief scheme and other river relief schemes under consideration. • Some suggestions include, opening up the landscape e.g.: Rewild the surrounding areas and stop further culverting of the Poddle River. • We also need to critically evaluate the removal of trees based on health and safety grounds (such as the removal of a beautiful row of mature trees in The Mall, Waterford City in February 2019; a row of established trees on Water Street and a row of mature oak in The Scalp Co Wicklow.) Where trees are deemed appropriate for removal, care must be taken not to do so during the nesting season as has happened in Stepaside.

Recreation and Natural Heritage:

• Unfortunately the historic route of the Poddle river along Lower Kimmage Road and at the village areas of Sundrive Cross, Harold’s Cross and its environs has already been heavily impacted by negative changes since the last Development Plan 2016-2022, despite our requests (at that time) for general preservation and enhancement of the neighbourhood and recreational spaces. • The NTA’s plans for a Bus Corridor on Lower Kimmage Road, include some minimal Urban Realm enhancements and LOKRA would suggest that DCC uses this as an opportunity to expand and enhance Urban Realm in the various nodes throughout the neighbourhood. • If the current trend for unfettered and un-balanced building projects in the area continues, there is a serious risk that there will be fewer options to expand on what little green space already exists and that it will be insufficient to service an ever-increasing and diverse population.

How do we promote the health, environment and heritage benefits of green and blue infrastructure?

• Covid-19 has shown that people have been naturally drawn to any available outdoor space and activity at this time. This can only be beneficial for the health and wellbeing of the nation and is something that needs to be built on. • Many new / revived uses for public spaces are evolving at this time such as roller- blading. These trends should be considered and where appropriate facilitated with nature friendly adjustments to infrastructure. • If DCC is sincere about listening to the submissions from us, and in supporting citizen led change in their areas, there must be support from Planners / Engineers / Parks / Wildlife Departments for the inhabitants of this area. The aim of this would be to set out a programme of development and education that enables true community engagement. • Local communities like ours do not have the resources or expertise to constructively challenge the impact of large developments on our area. We need pro-active, expert support to help preserve what’s left of this historic area, and not leave the decisions to the large commercial investors alone. • Our lived experience of this so far has been one of bad faith on the delivery of approved planning decisions – making it an up-hill battle all the way and after the fact, where developers deviating from and altering agreed plans to the detriment of adequate recreational space for the community. • Addressing anti-social behaviour in local parks, public and open spaces is a pre- requisite in making public green and blue infrastructures safe and attractive to all who use them

How do we integrate green solutions within compact urban development?

• There are many imaginative ways to do this – such as find local undeveloped open spaces and create useable Pocket Parks and Dwell Zones

Other suggestions include: o Vertical green spaces o Green roofs on bus shelters o Supporting communities to ‘green’ local lanes o Support the development of community garden projects and grow projects such as the award winning Harold’s Cross Grow project. o Encourage / incentivise the wilding of at least a portion of large urban gardens

How do we manage our natural assets as the population of Dublin City continues to grow?

• The incorporation of more green space / infrastructure must be part of any growth planned for the city • For example, a suitable tree planting scheme along Lower Kimmage Road would receive LOKRA support as a proven deterrent for speed, mitigate air and noise pollution, add visual amenity, tie into the HX2025 vision for a greener neighbourhood and enhance Lower Kimmage Road’s green lung identity. • Local residents’ groups have been campaigning for the integration of the lands fronting onto Lower Kimmage Road, on the banks of the river Poddle, with the existing park, including proposals submitted to Dublin City Council as part of a wider aim of establishing a cycling and walking “greenway” or Poddle Path.

How should the City facilitate the growing needs for sporting and recreational uses?

• Critically evaluate the planning of brownfield sites to incorporate wherever possible, green social spaces for sporting and recreational activity • The latest NTA Bus Connects plan, is resulting in the creation of an extensive cycling network for the city, with greenways along the rivers, canals and sea. This envisages a number of main cycling routes into the city, and orbital routes connecting these. • LOKRA is broadly supportive of cycle paths which take cyclists off the busy roads to traffic-free green / blue routes Theme 8: Built Heritage and Archaeology

How can we balance the need for new development against the protection and enhancement of our built heritage? • Critically, in planning and zoning terms, Dublin City Council have specifically designated Lower Kimmage Road both Z2 and Z1 status, i.e. to protect and improve the amenities of residential conservation areas, and to protect, provide and improve residential amenities. • An area of archaeological interest is also zoned following the course of the Poddle along much of Lower Kimmage Road. • In addition, Z9 zoning is granted to the overarching district, to preserve, provide and improve recreational amenities and open space and green networks.

It is vital in any new Development Plan that these protections be maintained and indeed strengthened to further reflect the rich historic and archaeological heritage of this area.

What policies and/or incentives do you think can ensure that Protected Structures are properly maintained and do not fall into disrepair or subject to substandard remedial works? • LOKRA requests consideration of an appropriately defined Archeological Conservation Area as part of a Master Plan for this neighbourhood. • Pro-active and continuing engagement with owners / trustees of protected structures, such that essential repairs are carried out (with grant / agreed supports if necessary) in a timely manner and agreed remedial works are subject to independent monitoring, assessment and approval.

Are there any individual buildings or groups of buildings, Industrial Heritage Sites and features that should be added or removed from the Record of Protected Structures or designated as Architectural Conservation Areas?

• The area on and surrounding Lower Kimmage Road has a rich heritage in terms of architectural, archaeological and industrial history. • LOKRA would like to request an audit of the area in conjunction with local community groups to define and establish appropriate protection status of local heritage sites, buildings and features.

Are there any special views, landscaping, gardens, streetscapes that make a significant contribution to the character of the City and its suburbs and urban villages?

• There are some wonderful views within the area, such as Mt Argus through the Mill, the Gates and Park; looking back at the redbrick terraces, and Ravensdale Park • Many of the streetscapes in urban villages such as Sundrive Cross and Harold’s Cross have suffered from years of neglect in terms of urban realm development and landscaping • There is no reason why these could not provide ‘special views’ and contribute to the ‘character of the city and its… Urban Villages’, but they need investment and policy standards to achieve this.

Do you think there should be any additional or specific policies in the new Development Plan to protect built heritage, to include un-protected buildings and sites, or is the balance right?

• Lower Kimmage Road has a rich built heritage which demonstrates a wide range of architectural home styles in a relatively short distance. This includes significant examples of turn of the century Edwardian homes and architectural styles covering a broad spectrum of 20th century built heritage. • These should be considered in any initiative to appropriately protect this heritage

How can we better interpret, animate and develop our archaeological assets to strengthen their contribution to the tourism economy, while protecting them for future generations?

LOKRA recommends extending the city centre culture trails, to include one going south from Dublin Castle / Christ Church via St. Patrick’s Cathedral. This opens both the archaeological and cultural assets along this route, which forms a ‘green lung’ into the city and has a richness of nature to be explored in the local parks along the route to the KCR.

The proposal could be facilitated with the expansion of the city bike / scooter schemes to the city’s inner suburbs.

• This route negotiates Georgian terraces, past the birth place of Leopold Bloom, immortalised in Ulysses, crossing the Grand Canal and Robert Emmet Bridge, through many historical landmarks, particularly at Harold’s Cross Park, Mt Jerome Cemetery and Mt. Argus Church on LKR North. • The route continues onwards through what was once Plunkett Land at the Larkfield Townland now Sundrive Cross, and onto the Kimmage Cross Roads (KCR), with a public house dating from 1860. • It follows the course of the Poddle River, and the DyfLinn, Dubh Linn or Dark Pool, which gave the city its name

From a social perspective, this route:

• has and continues to embrace a multitude of religious traditions, critical thinkers, famous artists and writers and historical political figures • reflects the social and industrial evolution and development of the city with townlands that supported industrial mills and tanneries as well as extensive quarrying that assisted in the restoration of Christ Church Cathedral

From an architectural perspective:

• It demonstrates a rich residential heritage including Edwardian homes with rich art nouveau style frontages, locally sourced brick, balconies and decorative doorways • While gardens are modest in scale, they give coherent identity to the road. • Between 1920 and the 1950s, several styles include classical art deco and arts crafts styles and some early publicly funded housing which also shows influences of both Gothic and arts-crafts styles. • In this way on a short stretch of road, the history of architectural development over a century can be quickly illustrated • At Sundrive Cross there is an impressive and rare example of an Art Deco style curved mixed use building

Local heritage trails should also be created across these inner suburban villages to encourage both local circulation and visitor / tourist interest in these very accessible areas just outside the city centre

Theme 9: Culture

What parts of the City do you think need further investment in arts and culture?

• Inner suburban Urban Villages, located often within walking distance of the city, such as Sundrive Cross, Harold’s Cross and associated neighbourhoods. Can our libraries play a greater role in providing community arts and cultural spaces and in giving children the opportunities locally to take part in culturally enriching experiences?

• Yes – libraries are the cultural heart of many communities and there is a responsibility to optimise their use in supporting this • Libraries could be actively engaged with other cultural centres within the city and facilitate remote access to these in whatever way possible How do we ensure equal access to all?

• One of the most significant things that could be implemented would be the introduction and support of cultural hubs within local neighbourhoods (See Theme 3) • Keep cultural facilities free wherever possible • Subsidise performing arts and support free open air and indoor events – theatre and concerts • Support touring theatre and music events • Build on the Covid-19 experience that provided free exhibitions / concerts etc. available to all who are digitally connected • Enhance training and appreciation for the arts and culture in schools from the earliest age possible

What can the Development Plan include that supports creative industry within the City?

• Build strong linkages between the arts and industry in locally situated creative hubs • Locate it slightly outside the canals to local neighbourhoods and the inner suburbs of Urban Villages, where it can have the space to interact on a multi-modal basis within creative hubs. Successful start-ups can then be scaled to take their place in a larger context.

Theme 10: Sustainable Environment Infrastructure and Flood Risk

What do you think is the most important infrastructure to support Dublin’s growth?

Natural Infrastructure: • A successful co-existence must be achieved between the built and the natural environment / infrastructure. We should work around the existing precious natural amenities available in our city and the greater Dublin area and preserve and enhance them rather than sacrifice them to ill-conceived and short term developer led planning. • We need to build things around and in tandem with nature (the natural infrastructure) not through it. The lack of animal crossing facilities (eg. tunnels) along the M50 (as provided on other similar European schemes), has had serious consequences for wildlife in the area. We have all witnessed the carnage of dead foxes, badgers, domestic animals and even the occasional deer the central meridian. Is there a retrofit solution to this?

Built Infrastructure: • While the building infrastructure (homes, workplaces, transport, services) are obviously critical to supporting growth, for this growth to be achieved in a coherent and sustainable way, infrastructure provision must be developed with a holistic approach that includes respect and consideration for the communities and citizens it is there to serve. • This can only be done with inclusive and genuine engagement and with fully considered planning led development – unlike the disastrous developer led planning that has resulted in the current ‘mish mash’ of urban development and lack of social facilities and integration. There should be an alignment of government policy and plans with the broader context required in any coherent development such as transport, services and social infrastructures.

Social Infrastructure: • The concept of the 15 minute city supported with local enterprise, communication, training, social and artistic hubs could spread benefits of our developing city in a more equitable and socially coherent way. • While appropriately designed ‘hard’ infrastructural projects (buildings, transport, digital etc.) all have a place in supporting Dublin’s growth, the development of a strong urban realm and social infrastructure (long neglected) can play an enormous role in developing the ‘human capital’ that is the cornerstone of any thriving economy. • At local level, we support appropriate services, sensitive and respectful to the proper spatial, green, modern development of our city and neighbourhood that respects and treasures the best of our past and delivers win-wins for all communities. The 'green lung' identity of LKR must be maintained and enhanced. • The absence of a Local Area Plan for this neighbourhood has led to stagnation and inertia in capitalising on the natural, historical and business potential of Lower Kimmage Road and the villages at Sundrive Cross and Harold’s Cross as well as related nodes. • LKR North is designated Z2, i.e. ‘to protect and or improve the amenities of residential conservation areas’ (some parts, along with LKR South, are Z1, ‘to protect, provide and improve residential amenities’) in the Dublin City Development Plan

Do you have any suggestions for how we could better manage the City’s water resources? • The first step in managing the city’s water resources – as with any resource management – is not to waste it. This has to start with a significantly enhanced drive to locate and address water leakages in the urban supply network. • By working with nature, it would be possible to use for example the Miyawaki Forest approach in certain locations. This new system of planting mixed native trees very closely together, which enables them to mature very quickly via a strong underground network of roots & fungi and above ground they compete for light so grow taller quicker. Only 1 year after planting Ireland’s first 15 acre forest in Co. Wicklow, many of the native trees are growing more than twice as fast as expected. These could be placed all along river banks without the need for concrete constructions.

Do sustainable urban drainage (SuDS) policies in the Plan need to be further developed and enhanced?

• Absolutely - This seems the best way forward for us and future generations but it needs interest and support across the board, from government to local level. • Education campaigns could support this. • Recognising the importance of flood pathways along highways and other routes, and the storage of water in low spots, is the first step to better urban flood management, another important step is to direct flood flows along routes where the risk of property flooding and the risk to health and safety is minimal and can be managed. • In Holland recently they have decided to plant native flowers and plants on all the bus stop shelters, creating mini habitats for insect and bird life at regular intervals around the cities. Collectively it also has an impact on flood prevention. Not only do we need nature spots but we need the interconnectivity for it to flourish, then we’ll be able to flourish also. We would recommend the NTA / TII consider adopting this idea while they are rolling out the Bus Network re-design process.

How can the Development Plan best support new energy generation technologies in order to provide more secure and low carbon forms of energy?

• As a residents’ association, we are not in a position to comment on the merits or demerits of energy generation technologies, except to state the obvious that investment should follow locally sustainable initiatives rather than depending on imported energy. • Ireland should aim to be a nett exporter of energy rather than the other way around. • It is vital to learn from best international practice in this regard • Listen to, evaluate and support new ideas from students and colleges and give financial support to expediting promising initiatives - Provide funding in the right areas. • Support passive house schemes and energy conservation initiatives at the level of individual homes and businesses

How could the Development Plan support more innovative forms of waste treatment, reduction and energy reuse?

• Investigate international best practice models for re-cycling and excess energy harnessing. • Support large and small scale projects (businesses / homes) that could contribute excess energy to the local or national grid. • The new large computer storage facilities produce enormous amounts of heat, which could be used to heat local homes / businesses. As of Sep 13, 2019 there are 53 operational data centres in Ireland, which have capacity of 622MW. (Our nearest is on The Long Mile Road). • Major companies need to be dissuaded from producing polluting packaging in the first place to support good consumer behaviours. A system of penalties for poor compliance or reward for the provision of sustainable, biodegradable alternatives could be considered. This could seriously reduce the amount of packaging going to landfill. • Review possible alternative uses for spent energy sources such as cooking oil - A village in England uses old grease from take-aways to fuel a tuk-tuk for tourists to bring them to a site of interest up a steep hill. There are lots of take-aways on Lower Kimmage Road and throughout the city. Perhaps a historical tour of local areas in a tuk-tuk or similar, could be enterprises to consider. • Local rubbish bins could have mixed bins, 1 paper, 1 plastic/cans & 1 waste (as seen in Scotland or at Dublin airport). These have the dual purpose of waste segregation and education and allow people become more aware of recycling on a day to day basis. • Invest in and support the circular economy. This has proven benefits internationally, not just in waste reduction and management but also in developing and consolidating essential social and community support networks

How can the Development Plan encourage the provision of high-quality, equally accessible and affordable digital connectivity?

The Digital Divide: • Digital connectivity must always be aligned from a social perspective with local need and future proofed sustainability. • The starting point should be an audit of the degree and impact of the digital divide, with recommendations for action - this has to be carried out by community education practitioners within the ETB / Aontas. • Skills bases have to be built at local level. So we need an audit of facilities and opportunities for accessible community education groups for digitally marginalised groups of all ages across the neighbourhood • This divide was so starkly demonstrated during the Covid-19 pandemic. Two key issues stand out: o The unequal distribution of digital technology for students, based on social and cultural disadvantage o The digital isolation of the older community, many of whom neither have access to or education in basic digital forms of communication. This has led to the problem of lockdowns being more profound than would be necessary, were there a support and informal educational system in place.

General Digital Services: • Some parks and public areas provide free wifi which is a welcome and growing trend. However, this should only be progressed when the impact on the habitat and ecology of the park life has been fully taken into consideration and where necessary mitigated for. Large servers used to power these digital schemes create noise and energy pollution and often these remote data centres can pollute elsewhere. It is necessary to take a full ‘360’ view of benefit vs risk when initiating these projects and to take impacts on the environment and animal / wildlife into consideration

Key Asks: While there are a number of suggestions and requests throughout this document, as a key starting point for the sustainable development of our neighbourhoods, LOKRA requests consideration of the following:

1) A protective planning framework for the entirety of the road; Lower Kimmage Road North included in the promised but deferred Local Area Plan (LAP) for Harold’s Cross; it makes no sense to stop the development of this Plan at the boundary of Sundrive Cross and not extend thinking the length of the road. 2) An enforceable Master Plan in the context of a Special Development and Regeneration Area (SDRA) 3) Consideration of an ACA as appropriate for sections of LKR

The provision of a Community Support office / Task Force of experts in facilitation, leadership and knowledge at local level, with a paid research and development officer to enable greater sustainable, co-ordinated and systematic development of ideas and resolution of issues

Audits to be carried out as follows:

1) An audit of the balance of existing and planned housing provision for the area, to include: affordable homes – apartment / duplex / houses; Rental property – short term / long term / buy to let; Student accommodation – shared homes / short-term rental / co-living; Social housing – homes / apartments and homeless hubs 2) An urgent audit of the carbon footprint of this area with recommendations of what options there might be to reduce our carbon footprint locally 3) For the neighbourhoods of Lower Kimmage road / Sundrive Cross / Harold’s Cross, an audit of the area’s assets in the region of the triangle from Harold’s Cross bridge to Terenure and KCR, Ravensdale, Greenmount and Sundrive Cross, to include: o Space usage audit of: current retail, industry, manufacturing and services o Industry, manufacturing and services current provision - scale of operation, engagement with and use of technology / robotics / AI / Training / access, delivery o Green agenda: biodiversity, ecological impacts, contribution to the circular economy o Home businesses and home working - how many businesses are operating from homes / from premises / what premises? How many people have / intend to change their daily working pattern and commute? 4) An audit of the area in conjunction with local community groups to define and establish appropriate protection status of local heritage sites, buildings and features.