FINGAL COUNTY COUNCIL

MONDAY, 14th March 2016

ITEM NO.

DRAFT DONABATE LOCAL AREA PLAN

In accordance with Section 20 of the Planning & Development Act 2000 (as amended), the proposed Draft Donabate Local Area Plan was on public display from Tuesday 1st December, 2015 to Thursday 21st January, 2015, at Fingal County Council Offices, County Hall, Swords; Grove Road, Blanchardstown and Donabate Portrane Community Library, Donabate Portrane Community Leisure Centre, Portrane Road, Donabate. It was also available on the Council’s website at www.fingal.ie

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TABLE OF CONTENTS

1.0 INTRODUCTION

2.0 SUMMARY OF SUBMISSIONS AND RESPONSES

3.0 MOVEMENT & TRANSPORT 3.1 Access to Newbridge Demesne & Walkways / Cycleways 3.2 Broadmeadow Way and Fingal Coastal Way 3.3 Footpaths / Cycleways – Turvey Avenue and Hearse Road 3.4 Traffic & Pedestrian safety Road Widening Parking & Pedestrian Crossings Traffic Calming Access for Disability / Mobility / Visually Impaired 3.5 Public Transport Rail Bus 3.6 Metro North 3.7 Donabate Distributor Road Phasing, Alignment, Detail, 3.8 St Patrick’s Schools – Access, Parking, Safety

4.0 DEVELOPMENT WITHIN NEW LAP DEVELOPMENT AREAS 4.1 Density & No. of Units Proposed 4.2 Phasing 4.3 Mix of Units & Social and Affordable Housing 4.4 Permeability & Accessibility 4.5 Strategic Landscape Corridor at Corballis & Tree Planting 4.6 Visual Impact of Development on the Estuaries and Building Heights

5.0 DONABATE TOWN CENTRE 5.1 Enhancement and Consolidation of Donabate Town Centre

6.0 INFRASTRUCTURE ISSUES 6.1 Flooding 6.2 Foul Drainage and Water Supply

7.0 COMMUNITY INFRASTRUCTURE 7.1 School Provision and School Site Location 7.2 Community / Cultural / Exhibition and Performing Arts Centre 7.3 Community Facilities Childcare Church Sites Open Space Requirements Playgrounds / Skate Park Corballis Nature Park Other Community / Recreation Facilities 2

7.4 Ballymastone Education and Recreation Campus 7.5 Graveyard 7.6 Tourism Opportunities Newbridge House and Demesne Fingal Coastal Way Donabate-Portrane Heritage Trail 7.7 Employment Live-Work Units Fingal Local Economic and Community Plan (LECP) 2016-2021

8.0 ENVIRONMENT 8.1 Protection of Malahide and Rogerstown Estuaries Impact of Walking / Cycling Routes on the Estuaries Ecological Buffer Zone 8.2 Coastal Erosion 8.3 SEA / ER / NIR 8.4 Dublin Bay Biosphere Reserve 8.5 Other

9.0 SUSTAINABILITY Sustainability and the LAP

10.0 MISCELLANEOUS 10.1 St Ita’s Development 10.2 Culture & Heritage Irish Language Conservation St Catherine’s Castle, Bob’s Castle and Martello Tower at Donabate Beach Old Stone Buildings – Adjacent to Smyths Pub Old Milestone on the R126 Water Pump opposite the Graveyard Marine Slipway and Beach Shelter at Balcarrick 10.3 Public Consultation 10.4 LAP Boundary 10.5 Donabate Urban Framework Plan 10.6 Public Realm Strategy

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1.0 INTRODUCTION

This Chief Executive’s Report forms part of the statutory procedure for the making of a Local Area Plan as required by Section 20 of the Planning and Development Acts 2000- 2015. It consists of a summary of the issues raised and the report and recommendations of the Chief Executive on the submissions received on the Draft Donabate Local Area Plan.

Format of Chief Executive’s Report This Report contains the following:-

• A list of the persons or bodies that made submissions/observations • A summary of the issues raised by the submissions/observations. • The Chief Executive’s response to the issues raised. • The Chief Executive’s recommendations to the issues raised.

The issues arising are summarised under the following headings:

MOVEMENT AND TRANSPORT • Access to Newbridge Demesne - Pedestrian Access along Turvey Avenue to Newbridge Demesne & Village – re-open the ‘red door’ on Turvey Avenue, Earlier opening hours to access Demesne. Footpaths / Cyclepath required along Hearse Road • Traffic safety is a concern along Hearse Road and Turvey Ave. • Roads have not been improved since WWII. • Pedestrian safety at crossing of Main Street near Smyths Pub, with new link into Village. • Turvey Avenue upgrade should be completed prior to occupation of units. • What is the timeframe for upgrade of Hearse Road? • Need for additional bus stop along Hearse Road. Installation of bus shelters needed at designated strategic locations. • Walkways and Cycleways – need for a comprehensive network of routes linking housing areas to schools, town centre, train station, etc • Broadmeadow Way – when will it be complete? • Permeability between New and Existing Development Areas • Donabate Distributor Road Phasing, Alignment, Detail – rationale for the route chosen, impact of road on existing residents, Access from DDR to football club lands, clarification regarding single / dual aspect of DDR. Road should be complete before any large scale development is permitted. • Increased traffic from St Ita’s. Traffic and Parking Issues in town centre, rail station, etc. • Public Transport – no train every 20 minutes, need for improved train service • St Patrick’s Schools – Access, Parking, Safety, Drop off / Pick up zone needed, policing of the core school pick-up times, additional signage, widening of footpaths,. Upgrading of footpaths near school is required • Pedestrian / Cycle access to the schools from Carr’s Mill application (Ref: F14A/0033) should be completed before development takes place. • Local Authority to consult with transport providers (i.e. Irish Rail, Dublin Bus) to ensure that services can provide a sufficient transport service to accommodate current and future population. • Traffic speed limits of 30kph should be introduced in the Village and 30kph in new estates. • Extension of Metro North to Donabate and insert new objective to extend the Metro North to meet the existing Northern Line at Donabate. • Rail: Iarnrod Eireann welcomes and supports the stated measures in the plan to increase the density of development in close proximity to Donabate rail station and village. Submissions note Rail service is at capacity. • Re-open old road / ramp out of the northbound station car park up to Turvey Avenue for the use of pedestrians, wheelchair users and parents with buggies. Platform Shelters and covering of platforms at Donabate railway station is required. Improve access to train station from town

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centre. • Rahillion to Portrane walkway would cause great disturbance to residents and landowners. Alternative route should be investigated travelling north from the Windmill to the route of the old Beaverstown to Burrow Road over the canal, by the bridge nearest the sluice gate. • Road widening needed of the R126 approaching Donabate from Hillside Cottage to the railway bridge. No residential development should commence on lands west of the railway line until these road widening works have been completed. • LAP notes that there is Pay and Display parking on Main Street, but there is no parking on Main Street. • Dublin Airport Authority has no comment to make on the Draft LAP. • Timeframe for completion of Turvey Green Route under p.p. reference: F12A/0086. • NTA is satisfied that proposals set out are consistent with the principles set out in Chapter 7 of the Draft NTA Transport Strategy, and will form the basis for the sustainable development of Donabate from a transportation planning perspective.

DEVELOPMENT WITHIN THE LAP AREAS • Density – higher density should be promoted within walking distance (500m) of the Rail Station • Residential Density Guildelines should not be applied in this area given it is on the edge of the Dublin Metropolitan Area. • Need for reduced heights and lower density • Number of units – one submission refers to 5,500 units. • Densities proposed at Ballymastone are too high. • Phasing - How will the phasing be achieved? • Provide direct pedestrian / cycle links through development lands to schools, shops, services and Donabate Station. These links should be in place prior to the occupation of housing. • Direct linkages through the new development lands for walking and cycling should be prioritised at the Ballymastone Education Campus. • Pedestrian and cycle facilities should be developed in a sequential manner. • Objective to be added to LAP stating that pedestrian and cycling proposals will be phased to prioritise improvements within the village centre and to provide linkages between the centre / station and new / existing residential areas. • Mix of units, need for larger affordable houses, need for starter homes, family homes, Social Affordable Housing and rural housing. • High level of permeability required – pedestrian and cycle access to schools, train station, village, beaches, estuaries, open space, etc. • Social and Affordable Housing – maximum 15% of all units should be S&A housing units and they should be fully integrated within all new housing estates. • All S&A housing is being placed in one part of Donabate – this contravenes Part V of the Planning Act. • Removal of Strategic Landscape Corridor • Need for more units in Phase 1 behind Smyths Pub • Need to protect the stone buildings adjacent to Smyths Pub. • How will people cross road onto Main Street at Smyths Pub? Very busy junction. • Chapter 7 – alternatives – consider other potential alternatives? • Chapter 9 – clarify what ‘Alternative C’ refers to, under the Indicator column. • Department of the Environment, Community and Local Government considers that the Draft LAP provides a comprehensive framework for the proper planning and sustainable development of the area and gives spatial expression to the economic, social, cultural and environmental aims of Fingal County. • During construction of lands near The Links estate, construction traffic should use an access off New Road. The proposed new road between The Links estate and adjacent development in Ballymastone is not serving the best interests of the residents in The Links. • Donabate Construction Traffic Management Plan should include traffic signs to inform construction traffic of HGV restrictions,. Zebra crossings and yellow boxes should be implemented. • Restrict the number of units to 3,600. • High-rise development proposed 60m from the Estuary. High rise apartments in the Village are not sustainable. • Development so close to Estuaries is not appropriate. Rahillion development will be visible from the 5

Estuary. • Fingal should appoint Building Inspectors that inspect each stage of the construction life cycle. • Lap will provide for energy standards in buildings constructed, similar to those adopted in other LAPs around Fingal. • New residential developments should implement a tree planting programme and avoid the removal of existing trees.

DONABATE TOWN CENTRE • Traffic and Parking Issues • Mobility Access for those with Disability – use planters instead of seteel bollards, safe crossing points (not road markings as these can not be seen by the visually impaired), Poles should be on the inside of a wall, not on pavements, pavement crossings should align, • Streetscape, Tree Planting required • Lack of parking at graveyard • Develop multi-storey car park at train station • Urban tree planting scheme should be carried out at appropriate locations in the town centre and along Beaverstown Road. • Ensure enhancement of Donabate Town Centre and do not create competing centres in new LAP lands. • Consolidate development within Donabate Town Centre.

INFRASTRUCTURAL ISSUES • Flooding • Flooding at entrance to Newbridge Demesne, Portrane Road, Beaverstown Road, Kilcrea / Hearse Road and Corballis. • Welcome the exclusion of some zoned lands from residential development – shows a strong commitment to ensuring the appropriate use of lands relative to their flood risk vulnerability. • The provision of a sewage mains connection for current Corballis residents and current residents of Turvey Avenue (R132 end) should be promoted and supported as part of this LAP. • Need for a new pumping station at Donabate South. • Water Supply and proposed new water supply from River Shannon • Liaise with Irish Water at earliest opportunity to facilitate mains sewage infrastructure o the eastern side of the Peninsula to include the 3 no., local golf clubs, hotel and residential areas. • Improvements to Railway Station • Increased Rail Capacity • Connect the Rush agglomeration into the Portrane / Donabate / Lusk sewerage scheme • Chapter 3 – reference the EPA Drinking Water Report 2014 (EPA 2015) which provides the most recent published drinking water quality information. • Chapter 5 – section 5.7.5 – describe the condition of surface water drainage infrastructure in the Plan area in the context of flood risk implications • Irish Water welcomes the policies and objectives in relation to water services within the Draft LAP. • Provide infrastructure in tandem with development.

COMMUNITY INFRASTRUCTURE • Schools provision and Location of school sites • One of the school site locations should be west of the railway line. Location of school site in Corballis should be closer to the footbridge. • Dept of Education and Skills welcomes the inclusion of the proposed school sites to provide for the possible future educational needs arising from the proposed total umber of residential units envisaged for the LAP area. It is important that land is zoned for educational provision where provision of services and access will not hinder the development of the school within the required timeframe. Identify specific land use zoning ‘Educational’ and identify suitably located lands to meet the educational infrastructure needs. Implementation strategy and phasing of schools sites is important. Dept is open to the concept of multi-campus school arrangements, i.e. where two or three primary schools are located side by side or a primary and post primary school share the same site. Dept requests that site reservations are made, as close as possible to community facilities 6

such as sports facilities, libraries, etc, so that these resources can be shared between the school and the community, which is reflected in the LAP. • Remove post primary school from Ballymastone lands in order to fully develop a sports recreational campus. • The existing post primary school site has been removed in the Draft Development Plan. • Clarification of size of school required at Corballis. • Need for a primary health-care centre. • Need for a Community / Cultural / Exhibition and Performing Arts Centre – possible space for cultural centre beside Parish Hall. Designation of suitable land / site for ‘local cultural spaces, performance and entertainment spaces’. Site should be close to railway station and bus routes from Portrane and Swords. • Additional Community Centre required • Donabate Portrane Heritage Trail should be developed as part of the LAP. • Garda Station needed. One submission notes the setting aside ofa building in ballymastone for a Garda Station and seeks details of same. • Youth Facilities / Youth café • Playgrounds should be included in all new developments. • Increase the open space requirement from 10% to 15%. • Skate Park, Swimming Pool required • Facilities for the Elderly • Health Centre required • Better Access required for Sports Clubs at Ballymastone • Masterplan for Sports Campus – new pitches, clubhouses, parking, access • Graveyard expansion required and more facilities needed. Develop Masterplan as soon as possible. • Newbridge Demesne Opportunities – bike hire, café • Identify sites for Churches • Designate a site for a Business Park close to Village • Provide for essential community facilities in new LAP areas including Garda Station, Fire and Medical services, crèche and after-school facilities. • Facilitate further development of the all-weather pitch / multi-use facility at Ballisk Donabate, to ensure it meets the standards to accommodate international hockey games. • Provide for bike stations for a public bike scheme at key public transport points including Newbridge Demesne.

ENVIRONMENT • Impact on Malahide and Rogerstown Estuaries • Coastal Erosion, particularly at The Burrow, Portrane • Impact of coastal erosion on Coastal Walk • Provide for coastal walkway connecting Portrane to Donabate and Rush via Rogerstown. • SEA / AA • Maintain trees and hedgerows • Energy, Climate Change, Green Roofs • Greenways and impact on Estuary • Provide appropriate environmental buffer zones in lands adjacent to the coast / estuaries to continue to provide suitable habitat for protected species and to also serve as an additional flood alleviation measure. • Reference the UNESCO designated biosphere reserve for Dublin Bay, which lies adjacent to the Plan area. • Definition of Green Infrastructure needs to be clarified. • The proposed greenway routes have the potential to significantly negatively impact on Rogerstown and Malahide Estuaries, particularly the indicative routes across both estuaries. Further discussion on these routes is required. • Include reference to bats in Section 8.3.8 of the LAP. • SEA, ER and NIR should include reference to the cumulative impact of legal hunting in Malahide Estuary by foreshore licence holders and the threats arising from illegal hunting in both Malahide and Rogerstown Estuaries. • Table 3.1 of the NIR should make it clear that the conservation objectives are defined by a list of attributes and targets and refer to Table 3.3. 7

• Table 3.3. of the NIR should include the attributes for the conservation objectives. • Wildlife Acts should be cited collectively as the Wildlife Acts of 1976 to 2012. • References to the National Parks and Wildlife Service should be amended to read National Parks and Wildlife Service of the Department of Arts, Heritage and the Gaeltacht. • Ecological Buffer Zone extends into the southern portion of the Corballis LAP lands. There should be no development permitted on these lands. • Trees should not be removed. Tree planting scheme should be promoted at appropriate locations in town centre and Beaverstown Road.

SUSTAINABILITY • Lack of sustainability with the plan • Rainwater butt collectors should be mandatory in all new developments. • New build should be eco housing and incorporate sustainable techniques • Sustainable design in new school buildings is important – must achieve A3 building energy rating. • LAP is unsustainable. • LAP will provide for energy standards in buildings constructed, similar to those adopted in other LAPs around Fingal. • SEA / AA / ER / NIR • Chapter 7 – alternatives – consider other potential alternatives? • Chapter 9 – clarify what ‘Alternative C’ refers to, under the Indicator column.

MISCELLANEAOUS • St Ita’s Development and Impact on Peninsula • Language Heritage – naming of mixed residential and mixed use schemes should reflect local history, folklore and / or place names in the Irish language. Promote use of Irish language on shopfronts, etc • Protect stone buildings beside Smyths Pub • Liaise with current owners of Turvey Golf Club in consultation with local community to develop tourism / recreation use. • Lack of public participation and lack of meaningful consultation with the community. FCC did not carry out proper public consultation. Holding two mid-week evenings of public consultation was not sufficient. • Joined up thinking needed within Council Departments • LAP excludes Portrane and other areas outside of LAP boundaries • Chapter 4 – make reference to Fingal’s Local Community and Economic Plan • Future amendments to the Plan should be screened for likely significant effects in accordance with the criteria as set out in Schedule 2A of the SEA Regulations. • Exclusion of residential housing developments along the Portrane Road – these should be included as part of LAP and included in future housing totals. • Prohibit the opening up and use of existing cul-de-sacs for construction and motor vehicle through traffic • Expansion of Donabate graveyard should be included within LAP • Urban Framework Plan to be completed for Donabate within one year of adoption of LAP. Public realm strategy and traffic management strategy also required. • St Ita’s Historic Walled Garden – suggested community use and its restoration should be included within LAP. • Marine slipway for recreational use is required. • Restoration of red brick beach shelter, Balcarrick required. • Need to protect the stone buildings adjacent to Smyths Pub. • Protection of old Milestone on the R126 near Donabate Square should be included as part of this LAP. • Integration of new development with existing development is very important and should be emphasised in the overall strategy. • Over-emphasis in the Plan on Donabate, to the detriment of Portrane. • Implement public realm strategy for Donabate Beach and for Portrane Beach and Tower Bay. • Provide car parking at Donabate beachfront. • Protect and enhance the settings of St Catherine’s Castle and Bob’s Castle in Portrane. • Promote the restoration of the Martello Tower at Donabate Beach. 8

• Reinstate the water pump at the lands opposite the entrance to Donabate Grave Yard and provide a bench at this location. • Facilitate and enhance the visitor experience and amenities at Newbridge House and Demesne. • Local Authority to explore potential for co-ordinated tourism approach between Fingal and all current Golf Clubs on the peninsula. • Security concerns, controlling anti-social behaviour, community based CCTV could be investigated, Garda station needed

The preparation of this report forms part of the statutory procedure for the preparation of a Local Area Plan as set out in the Planning and Development Act 2000-2015. Under the Planning and Development Act 2000, the Chief Executive, as part of the LAP process, is required to prepare a “Chief Executive’s Report” on the submissions and observations received, to respond to the issues raised and to make recommendations on the policies to be included in the LAP.

Minor typographical or graphical errors or discrepancies will be amended in the final Local Area Plan and have not been included in this report. Similarly, where draft plans or policy documents referenced in the document have been up-dated or approved since the preparation of the Draft Plan, these will be amended accordingly in the final document.

An Environmental Report resulting from a Strategic Environmental Assessment (SEA) and a Natura Impact Report resulting from an Appropriate Assessment (AA) accompany the Draft Local Area Plan. The CE’s Report on submissions received includes a summary and consideration of all submissions on these documents and the process of SEA / AA.

In addition, any amendments proposed arising from the CE’s Recommendations have been screened and assessed for the purposes of SEA and AA.

2.0 SUMMARY OF SUBMISSIONS AND RESPONSES A total of 65 no. submissions were received during the public display of the Draft Donabate Local Area Plan. All submissions have been given careful and serious consideration.

The following is a list of persons / organisations who made submissions or observations on the Draft Donabate Local Area Plan.

List of Submissions Received for Donabate Local Area Plan Submission Organisation 01 Aidan Mc Goey 02 Transport Infrastructure Ireland (TII) 03 Breda Dockrell (via Councillor Paul Mulville by email) 04 Environmental Protection Agency 05 Department of Arts, Heritage and the Gaeltacht 06 Dianne Sims 07 Irish Rail 08 Valerie Henderson 09 Philippa Coady 9

Submission Organisation 10 Department of the Environment, Community and Local Government 11 Councillor Paul Mulville 12 Jenny and Shay Foley 13 Jim O’Donoghue 14 Breda Dockrell 15 Sandra Campbell 16 National Transport Authority 17 David Fletcher 18 Jeanette Baird 19 Councillor Adrian Henchy 20 Councillor Roderic O’Gorman 21 Irish Water 22 Donabate Portrane Community Council 23 Dublin Airport Authority 24 Alan Hand 25 Eilish Mc Dermott 26 Ann Hogan 27 Department of Education and Skills 28 Charlie Weston 29 Conroy Crowe Kelly (on behalf of McGarrell Reilly & Rossmere) 30 Downey Planning (on behalf of St Ita’s& St Pats Clubs) 31 Scoil Phadraic Caillini Board of Management 32 Brendan Delaney 33 Robbie Sinnott 34 Anthony Manning 35 Ann Spencer 36 David Reid 37 Martin Harte 38 Corina Johnston 39 Cathal Fitzgerald 40 Fergal Donovan 41 Paula O’Reilly 42 Wayne Hand 43 Markus Kohler 44 Marina Reilly 45 Joan Fogarty 46 Anthony Zaidan 47 Orla Kelly 48 Vikki Doyle 49 Sharon Burke 50 Dermot Barry 51 Ian Chambers 52 Sinead Kealy 53 Michelle Taafe 54 Andrew Lunt 10

Submission Organisation 55 Antoinette Fitzgerald 56 Nuala Hegarty 57 Gniewomir Tadeusz Okuniewicz 58 Gerry Farrell 59 Maeve Minshull 60 Suzanne Browne 61 Liz Corcoran (St Patrick’s BNS Parents Council) 62 Loirin O’Leary (St Patrick’s BNS Board of Mgt) 63 Brian Horan 64 Brian McCormack 65 Ken Jinks

The key issues arising in the submissions received have been summarised and categorised into the various headings below. The Chief Executive’s response is noted and recommendations made, if appropriate.

3.0 MOVEMENT & TRANSPORT The NTA is satisfied that proposals set out are consistent with the principles set out in Chapter 7 of the Draft NTA Transport Strategy, and will form the basis for the sustainable development of Donabate from a transportation planning perspective. Dublin Airport Authority have no comment to make on the Draft LAP.

3.1 Access to Newbridge Demesne & Walkways / Cycleways Access to Newbridge Demesne was noted in a large number of the submissions received. The need for a new access point from Turvey Avenue was highlighted, together with improved and safe access for those with mobility issues. The steep gradient of the roads and footpaths to access the park was highlighted as a difficulty for those with mobility needs. Safe pedestrian access from Turvey Avenue and from Donabate Village to access Newbridge Demesne needs to be prioritised. A number of submissions requested the re-opening of the ‘red door’ on Turvey Avenue, which provides direct access to the Demesne and requested earlier opening times for gates to the Demesne.

The timeframe for completion of walkways and cycleways was noted, together with the need for a comprehensive network of routes linking new and existing housing areas to schools, town centre, train station and Ballymastone Education and Recreation Campus, etc, with these links in place prior to the occupation of housing.

One submission requested the insertion of a new objective in the LAP stating that pedestrian and cycling proposals will be phased to prioritise improvements within the village centre and to provide linkages between the centre / station and new / existing residential areas

Another submission queried the completion date for the Turvey Green Route under planning permission reference: F12A/0086.

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Response A key feature of the development strategy of this LAP is the delivery of inter-connecting pedestrian and cycle routes to optimize access to and use of green infrastructure. These routes are detailed in Section 4 of the LAP and they provide for a network of approximately 30km of looped cycleways and pedestrian linkages throughout the Peninsula Lands, which will link the LAP lands to the Village Centre, the Rail Station, existing residential areas and schools, Newbridge Demesne, Turvey Nature Reserve, St Ita’s and the beaches at Donabate and Portrane. These routes are an integral component in the overall movement network, providing a sustainable way of travelling around Donabate and importantly integrating the LAP lands with the established village. Three key priority green routes / loops have been identified in this LAP:

• Turvey / Newbridge Loop • Rahillion / St Ita’s Loop • Fingal Coastal Way (Malahide and Rogerstown Estuary)

It is an objective of the Local Area Plan to improve access to Newbridge Demesne and to implement the Turvey / Newbridge Loop – a pedestrian and cycle route which links Turvey Nature Reserve to Newbridge Demesne, the Broadmeadow Way and Donabate Village via the new and existing developments areas at Turvey and Corballis. Objective 3.6 of the LAP states:

‘Objective 3.6 Ensure the construction of the following cycleway/footpath improvements in tandem with development: • Link path/route from Newbridge Demesne to Donabate Village via the Corballis LAP lands; • Link path/route from Rahillion LAP Lands south to St Patrick’s Boys and Girls National Schools; and • Provide a pedestrian/cycle link from Newbridge Demesne to lands at Turvey.‘ (own emphasis)

The access to Newbridge Demesne via Newbridge Square is relatively steep at present. However, it is considered that the footpath improvements proposed along Turvey Avenue and the improved access arrangements to the Demesne from the Beverton / Beresford estate (i.e. opening the red door access point to the Demesne) will provide greater flexibility and ease of access. The completion of the linear open space at Turvey (which is an important section of the Turvey / Newbridge Looped Walkway) and the upgrading of pedestrian facilities on Turvey Avenue (to include pedestrian / cycle crossing facilities from Turvey LAP lands at Berseford / Beverton Estate to Newbridge Demesne) are key infrastructural elements required as part of Phase 1 development on these lands, and their completion is expected in the short to medium term.

A designated green route area has been reserved along the western boundary of the Turvey LAP lands (as permitted under Reg Ref: F12A/0086). Construction of this section of the route is underway, in tandem with the development of the Beresford housing

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scheme. Any outstanding sections of this route will be required to be completed prior to any further housing development in Phase 1 of the LAP lands at Turvey.

The opening hours of Newbridge Demesne is not within the remit of the Local Area Plan process.

The Council is fully committed to the planning, development and implementation of the strategic green routes (Turvey Loop, Rahillion Loop and Fingal Coastal Way) throughout the Peninsula. The delivery of these routes is dependent on a multi-agency approach between landowners, environmental bodies and funding agencies with Fingal as the lead agency. The Council is currently progressing with the planning of various sections of these routes. Funding will be primarily from the Council with additional funding sought from various funding bodies. The early transfer of open space lands within the plan area will facilitate the planning and implementation of these routes and they will form part of the public open space network within the plan area and will be taken in charge and maintained by the Council.

Table 9.1 (and Figure 9.1) incorporates these routes into the overall phased development of the LAP lands.

Recommendation No change.

3.2 Broadmeadow Way and Fingal Coastal Way A number of submissions refer to the Broadmeadow Way and the creation of a link to Donabate Village from this route. The timeframe for completion of Broadmeadow Way was raised. The tourism potential of the route is also noted.

A number of submissions noted the need for a coastal walkway connecting Portrane to Donabate and Rush via Rogerstown.

Submissions also noted that the routing of the Coastal Way at Rahillion requires re- assessment. An alternative route should be investigated travelling north from the Windmill to the route of the old Beaverstown to Burrow Road over the canal, by the bridge nearest the sluice gate.

Submissions seek clarity regarding the timeframe for completion of the walkways and ask if they will be finished before housing is built. The impacts of greenways on the Estuaries and Beaches needs to be considered.

Response As noted in response to 3. 1above, a key feature of the development strategy of this LAP is the delivery of inter-connecting pedestrian and cycle routes to optimise access to and use of green infrastructure. These routes are detailed in Section 4 of the LAP.

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Broadmeadow Way The Broadmeadow Way is a proposed pedestrian/cycle trail between Donabate and Malahide and it is a critical link in the Fingal Coastal Way route as it spans the Malahide Estuary, thereby linking the two peninsulas. The overall length of the trail is approximately 6km and it will benefit both commuters and recreational users. The Council is currently progressing this project through the required statutory planning and environmental approvals process.

Whilst the principal routing of the Broadmeadow Way links Malahide Demesne to Newbridge Demesne, an opportunity clearly exists to provide connections from this route to Donabate Village through the Corballis LAP lands. This opportunity was recognized as part of the preparation of the Draft Donabate LAP and a link from the Broadmeadow Way to Donabate Village has been included within the written statement (and accompanying maps) of the LAP. This will maximise the accessibility of Donabate, with a spur illustrated off the Broadmeadow Way to travel through the Corballis LAP lands northwards to the Village.

This is further supported within Objective 4.3 of the Draft LAP, which states:

Objective 4.3 Develop a suitable link from the proposed Broadmeadow Way through the LAP lands at Corballis and linking through to Donabate Village.

Fingal Coastal Way The Broadmeadow Way scheme will form part of and integrate with the Fingal Coastal Way, a strategic coastal walking and cycling route which is a long standing objective of the Fingal Development Plan. Objectives ED61 and NH61 of Fingal Draft Development Plan 2017-2023 state the following:

‘Objective ED61 Promote and facilitate opportunities to create an integrated pedestrian and cycle network linking key tourist destinations in the County, by advancing the proposed Fingal Coastal Way, through carrying out a route evaluation study within two years of the adoption of this Plan, ensuring a balance is achieved between nature conservation and public use and through identifying public rights of way in consultation with all relevant stakeholders, and by exploiting former rail networks for use as potential new tourist and recreational walking routes.’ Objective NH61 Objective NH61 Plan and develop the Fingal Coastal Way from north of Balbriggan to Howth taking full account of the need to protect the natural and cultural heritage of the coast and the need to avoid significant adverse impacts on European Sites, other protected areas and species protected by law.

The Draft Fingal Development Plan 2017-2023 also includes the following:

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Objective DONABATE 4: ‘Develop a continuous network of signed pathways and cycleways as appropriate, around Donabate Peninsula linking Portrane and Donabate to Malahide and Rush via the Rogerstown and Malahide Estuaries whilst ensuring the protection of designated sites, and avoiding any routing along the northern boundary of Malahide Inner Estuary by virtue of its ecological sensitivity.’

The coastal route at Rahillion incorporates a 2km stretch, running parallel to the Rogerstown Estuary travelling west from Portrane to the railway bridge over Rogerstown Estuary. This will complete The Coastal Way and the Rahillion Loop at this location. Construction of this section of the Rahillion Loop / Coastal Way will provide a dual function in completing a key component of the Fingal Coastal Way, but also in creating an accessible green looped walkway from Donabate to Portrane.

This route is illustrated as ‘indicative’ on Figure 4.4 (Rahillion Loop) and other walkway maps within the LAP. A Constraint Study for a walking and cycling route between Donabate and Portrane is currently being undertaken. Four route options have been considered and two of these are deemed feasible. These two route options are to be discussed with the landowners in more detail before a final preferred route will be identified.

The development of the Fingal Coastal Way is further supported in the objectives contained within the Fingal Tourism Strategy 2015-2018 (Section 6.3 of the Draft LAP). This Coastal Way is supported with the inclusion of the following objectives within the Draft LAP:

‘Objective 4.1 Support the completion of pedestrian / cycle routes (greenways) at Turvey / Newbridge Loop, Rahillion / St Ita’s Loop and the Fingal Coastal Way in tandem with the phased delivery of development of LAP lands.

Objective 4.5 Provide, as part of the Fingal Coastal Way, an agreed and appropriately designed combined pedestrian and cycle route, with linkages to the proposed GDA Cycle Network, minimizing access points and signage to avoid disturbance to ecologically sensitive locations and ensuring the integrity of the protected habitats and species within Rogerstown and Malahide Estuaries and the ecological buffer zones within the plan lands.’

The Fingal Coastal Way will provide a major recreational and leisure facility in its own right and has the potential to become a major day trip/tourist attraction within the Dublin region. The tourism potential of the Coastal Way is also recognized and it will provide a link with existing pedestrian/cycle routes (including the proposed Broadmeadow Way, the Malahide-Sutton cycleway, etc), Dart and suburban rail stations in the wider Fingal area as well as the Dublin City environs that borders Fingal, thereby

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opening up the coastal corridor not only to residents of Fingal but to residents of Dublin City.

In this regard, the intention to provide a coastal walkway along the Peninsula’s coastline and to create a link to Malahide (via the Broadmeadow Way) is considered to be adequately addressed in both the existing objectives within the Draft Fingal Development Plan 2017-2023, the Draft Donabate LAP and the Fingal Tourism Strategy 2015-2018.

All walkways on the peninsula are included within the Phasing table in Section 9 of the LAP. The completion of the Rahillion Looped Walkway with trail through St Ita’s to the Coast and completion of the northern section running parallel to the Rahillion LAP lands (along the southern boundary of Rogerstown Estuary) is required as part of Phase 1 development, with the routes to be completed in tandem with the development on the Ballymastone, Rahillion and St Ita’s lands. The completion of the linear open space at Turvey (which is an important section of the Turvey / Newbridge Looped Walkway) and the upgrading of pedestrian facilities on Turvey Avenue (to include pedestrian / cycle crossing facilities from Turvey LAP lands at Beresford / Beverton Estate to Newbridge Demesne) are key infrastructural elements required as part of Phase 1 development on these lands, and their completion is expected in the short term.

Recommendation No change.

3.3 Footpaths / Cycleways – Turvey Avenue and Hearse Road Footpath improvements are required on Hearse Road and on Turvey Avenue to provide continued access to the Village. At present, there is no continuous footpath from Waterlefe / Beverton to the Village. Footpath and cyclepaths required along Hearse Road to access the Village.

Response There are a number of specific objectives contained within the Draft LAP which support the provision of footpath improvements on Turvey Avenue, including the following:

Objective 3.6 ‘Ensure the construction of the following cycleway/footpath improvements in tandem with development:

• Link path/route from Newbridge Demesne to Donabate Village via the Corballis LAP lands; • Link path/route from Rahillion LAP Lands south to St Patrick’s Boys and Girls National Schools; and • Provide a pedestrian/cycle link from Newbridge Demesne to lands at Turvey.

Objective 8.15

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Provide for high quality footpaths along Turvey Avenue to connect development at Turvey continuously to Donabate Village.’

Section 9 of the Draft LAP outlines the phasing arrangements for development and infrastructure. The key site specific infrastructure requirements for Phase 1 include:

‘Provide footpath upgrade along Turvey Avenue to connect development from Turvey continuously to Donabate Village’,

and

‘Prior to any residential unit being sold and occupied in Phase 1 of the Corballis West development, a footpath to connect development within these lands continuously to Donabate Village along the Hearse Road shall be provided.‘

It is acknowledged that existing pedestrian infrastructure on Hearse Road is poor with very restricted potential for roadside footpaths. A new pedestrian / cycle bridge over the rail line is also proposed to connect new development in this Corballis West area to the Village and Train Station (Sections 3 and 9 of the Draft LAP contain more detail).

There is also a new objective for Donabate included within Chapter 4 of the Draft Fingal Development Plan 2017-2023, which states:

‘Objective DONABATE 16 Provide a pedestrian path and cycle lane as appropriate, on the Hearse Road to enable safe access to Donabate Village.’

Notwithstanding the inclusion of objectives within the Draft LAP, it is acknowledged that there are a number of constraints that currently prevent the immediate delivery of a continuous footpath along Turvey Avenue. The Council is actively working towards resolving these identified constraints and, to this end, it is also recommended that an action plan be prepared following the adoption of the LAP that will ensure that the necessary funding and resources are identified to deliver this critical piece of infrastructure. The action plan will include for a full traffic assessment to examine the delivery of a pedestrian crossing from Newbridge Demensne to Beresford Estate / Turvey Avenue. Similarly, an action plan will be prepared for the provision of a footpath along Hearse Road identifying potential constraints and identifying the funding and resources required to deliver a footpath at this location.

Recommendation Council to prepare an Action Plan following the adoption of the LAP, to address the pedestrian access to Newbridge Demesne from Turvey Avenue and to examine footpath provision along Turvey Avenue and Hearse Road.

3.4 Traffic & Pedestrian safety 17

A number of submissions note issues with traffic and pedestrian safety, particularly along Hearse Road and Turvey Avenue. Concern for pedestrian safety at the crossing of Main Street near Smyths Pub, as shown in the new link into Donabate Village from the Corballis LAP lands is noted. It is submitted that the Turvey Avenue upgrade should be completed prior to occupation of units and the timeframe for the upgrade of Hearse Road is queried. Traffic congestion and parking problems are noted, with one submission requesting the provision of a multi-storey car park at the train station and another submission noting the need for increased parking at the graveyard. Another observation highlighted that traffic speed limits of 30kph should be introduced in the Village and 30kph in all new estates.

It is submitted that road widening of the R126 approaching Donabate from Hillside Cottage to the railway bridge is needed and that no residential development should commence on lands west of the railway line until these road widening works have been completed.

Mobility Access for those with a disability (i.e. visual impairment) was raised in one submission received. It is recommended that planters be used instead of steel bollards and that safe crossing points are essential. Road markings are not useful as these cannot be seen by the visually impaired. Poles should be on the inside of a wall, not on pavements and pavement crossings should align.

Response Road Widening Having regard to the issue of road widening of the R126 on the approach to Donabate from Hillside Cottage, it is advised that negotiations are underway with a view to carrying out road improvement works at this location. The proposed distributor road will also allow traffic to effectively by-pass the existing railway bridge, which will alleviate traffic in this area.

This is supported in the Draft Fingal Development Plan 2017-2023 with the inclusion of the following objective:

‘Objective DONABATE 14 Prioritise the early widening of the narrow dangerous short section of the R126 approaching Donabate from Hillside Cottage to the railway bridge on urgent health and safety grounds.’

The Draft LAP also provides a phasing proposal that delivers new development and the associated key physical infrastructure.

The Council commissioned a site specific Saturn Traffic Model to be created for Donabate encompassing existing and proposed residential lands. This traffic modelling work was carried out by RPS Consultants and included extensive traffic surveys undertaken around the village in April 2014. This research was tasked with assessing the traffic implications of the phased delivery of new road infrastructure including the Donabate Distributor Road (DDR) to support the development of the zoned housing lands and fed into the ‘Donabate LAP Traffic Analysis Report’’ (2015). The traffic and 18 environmental assessments included the testing of several development scenarios for different geographical sectors of Donabate and sections of road infrastructure. These assessments evaluated the provisions of the permitted distributor road in the context of the overall LAP housing numbers, taking into account the phased release of housing lands and various phasing arrangements, to minimise traffic congestion and to ensure adequate infrastructural provision.

On the basis of this assessment in respect of road network improvements, the initial phases of housing in the LAP require the construction of particular elements of infrastructure. This road infrastructure will underpin the initial phases of development consistent with incremental housing growth outwards from the core of the existing Village. The Council can also utilise the provisions of Section 48 and 49 of the Planning and Development Act, 2000, to generate financial contributions towards the capital costs of providing local and strategic transport infrastructure, including the Donabate Distributor Road.

Parking & Pedestrian Crossings Issues relating to parking in the town centre, at the railway station, the graveyard and the provision of safe pedestrian crossings of Main Street to the railway station / village are noted. Whilst these areas are not included within the identified LAP zoned lands, the Donabate Urban Centre Strategy (June 2010) addresses a number of issues which are of importance to the town centre and wider Donabate area, including recommendations relating to traffic management and car parking in the area, pedestrian and cycling activities and movement, environmental improvements to the urban realm, etc. Furthermore, Donabate Urban Framework Plan, when complete, will provide further details in relation to traffic management, car parking, pedestrian safety, public realm, streetscape, etc. In the interim the Donabate Urban Centre Strategy (2010) shall provide guidance in relation to these matters.

Traffic Calming Objective 3.4 of the Draft Donabate LAP states the following:

‘Objective 3.4 Implement local and strategic traffic relief measures to improve traffic freeflow and safety – Donabate Village and on road networks serving schools through phased construction of a Distributor Road and a series of internal link roads through the LAP lands.’

All new residential developments are required to incorporate traffic calming measures to reduce vehicular speed within housing areas. The Draft Fingal Development Plan 2017- 2023 also notes the following in relation to Traffic Calming:

‘Traffic Calming New residential developments should be designed to create low-speed environments by the use of engineering design and urban design in accordance with DMURS. In existing residential developments, motorised traffic often travels at inappropriately high speeds, causing an increased risk of collisions and intimidating pedestrians and residents. 19

Objective MT24 ‘Implement traffic calming on particular roads and in appropriate areas of the County, especially residential areas, to reduce vehicle speeds in the interests of road safety and residential amenity.

Ensure that where appropriate, traffic calming is included as a pre- condition as part of the development of all new estates or extensions to existing estates.’

Traffic calming is a matter best dealt by an appropriate housing layout. The provision of traffic calming measures in new developments is conditioned where required, through the Development Management process.

Access for Disability / Mobility / Visually Impaired Section 8.3.3 of the Draft Donabate LAP (Access for Disability / Mobility / Visually- Impaired) notes that street design must be inclusive and provide for all regardless of age or ability. Mobility impaired or elderly people and shoppers with prams or pushchairs need level access to shops, parking provision and covered areas close to services and good transport routes. Increased accessibility demands the provision of seating and other facilities, good pavement design and surface materials, the provision of dropped kerbs and other pedestrian priority measures.

It is noted in the LAP that the use of contrasting materials and textures can play an important role in helping to inform pedestrians of changes to the function of space (i.e. to demarcate footpaths, cycle paths, verges, etc). This is also useful to guide the visually impaired. The layout and colour of tactile paving used to assist the visually impaired in navigating the pedestrian environment should ensure that consistent logic is applied. (DMURS, pg 81, March 2013).

This is also supported by the inclusion of the objectives below within the Draft LAP:

‘Objective 8.9 Ensure as far as feasible that all urban and rural areas are accessible to all, with provision of facilities for people with mobility impairment and/or disabilities based on the principles of Universal Design. Implement a street network with a high quality public realm and priority for the pedestrian/cyclist and the mobility impaired.

Objective 8.10 Facilitate the provision of pedestrian crossings at appropriate locations within the LAP area and introduce tactile paving, ramps and kerb dishing at appropriate locations including pedestrian crossings, bus stops and rail platforms.’

New residential development within Donabate will be required to comply with the above objectives. Ensuring that new development areas and street design are inclusive and 20

provide for all regardless of age or ability will be dealt with as part of the Development Management process.

Streetscape and urban design will be dealt with as part of the Donabate Urban Centre Strategy (2010) and Donabate Urban Framework Plan (when complete).

Recommendation No change.

3.5 Public Transport The need for an additional bus stop along Hearse Road and the installation of bus shelters at designated strategic locations was raised in one submission. It was noted that the Local Authority should consult with transport providers (i.e. Irish Rail, Dublin Bus) to ensure that services can provide a sufficient transport service to accommodate current and future population.

With regard to Rail provision, the submission from Iarnród Éireann welcomes and supports the stated measures in the plan to increase the density of development in close proximity to Donabate rail station and village. Iarnród Éireann also supports the provisions in the Draft LAP regarding future rail infrastructure. A number of submissions received note that the rail service is at capacity, the service is irregular and that there is a need for an improved train service. Submissions request the re-opening of the old road / ramp out of the northbound station car park up to Turvey Avenue for the use of pedestrians, wheelchair users and parents with buggies. Platform Shelters and covering of platforms at Donabate railway station is also raised with a number of observations requesting an alternative access from the train station to the town centre to be provided.

Response The rail line is an important element in the sustainable development of the LAP lands and will allow for trips to be made from Donabate Village. The planned growth of Donabate will facilitate improved bus and rail services which should encourage a greater use of rail as a means of travel, both for shorter and longer trips. The LAP includes specific objectives to provide for a reservation for rail widening and to liaise with Iarnród Éireann to promote greater frequency of enhanced services to and from Donabate. There are also objectives to ensure pedestrian and cycle connections to the railway station.

Figure 3.1 of the Draft LAP highlights that the LAP lands are all within walking distance of the railway station. This is supported by the inclusion of Objective 3.1 in the Draft Plan, which reads as:

‘Objective 3.1 Provide a network of pedestrian and cycle access routes to Donabate Train Station from the new development lands.’

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The frequency of bus and rail services and the location of bus stops / bus shelters / platform upgrades, is not within the control of the Council and is, therefore, not something that can be addressed within the LAP process. The Council is, however, in regular consultation with the relevant bodies (Iarnród Éireann, Dublin Bus, etc) and all LAP proposals have been circulated to the relevant statutory bodies for comment.

Rail The ongoing consultation between Iarnród Éireann and relevant landowners regarding future rail infrastructure within the plan lands is acknowledged and welcomed. As part of the development management process, all applications shall be considered in the context of Iarnród Éireann’s future rail proposals. Appropriate consultation with relevant statutory bodies shall take place and applicants shall have regard to same. This is supported with the inclusion of the following objectives within the Draft LAP:

‘Objective 3.2 Support the NTA’s proposed electrification of the Northern Line from Malahide to Balbriggan to allow an extension of DART services to Balbriggan.

Objective 3.3 Ensure that all future rail improvement proposals including associated works such as overhead wires, access roads, maintenance yards and car-parks are designed and developed having regard to the environmental and visual sensitivities of the area and subject to Appropriate Assessment as required.’

A number of submissions request the re-opening of the old road / ramp out of the northbound train station car park up to Turvey Avenue for the use of pedestrians, wheelchair users and parents with buggies. This matter is the subject of on-going correspondence with Iarnród Éireann. The Draft Fingal Development Plan 2017-2023 includes the following Objectives in Chapter 4 relating to Donabate Railway Station, which read as follows:

‘Objective DONABATE 12 ‘Promote an enhanced Donabate rail station and improved rail services.’

Objective DONABATE 19 Facilitate a separate vehicular/pedestrian access to Donabate Train Station from Donabate Town Centre.’

Having regard to the submissions seeking an additional access to the Train Station from the town centre, this matter has been considered from a road engineering and traffic management perspective. It is the view of the Council that the present configuration of vehicular access points to the train station car park and the car park of the town centre contributes to a more efficient dispersal of traffic within the village. It is not considered appropriate, therefore, to create an additional vehicular access point to the railway station from the town centre.

Bus 22

The planned growth of Donabate will facilitate improved bus services which should encourage a greater use of bus transport as a means of travel, both for shorter and longer trips. The LAP supports and facilitates liaison between the Council and Dublin Bus. Furthermore there is provision within the Draft Fingal Development Plan 2017-2023 to promote and facilitate the development of a shuttle bus service, with the inclusion of the following objective:

‘Objective DONABATE 6 Promote and facilitate the development of a shuttle bus service linking Donabate and Portrane to Donabate Rail Station to the commuter bus services in Swords and to the proposed new Metro North.’

It is considered that rail and bus infrastructure has been adequately considered in the preparation of this LAP and that there are sufficiently objectives and policies included within the Draft LAP and the Draft Fingal Development Plan 2017-2023.

Recommendation No change.

3.6 Metro North Submissions received refer to the extension of Metro North to Donabate and request the insertion of a new objective to extend the new Metro North to meet the existing Northern Line at Donabate.

Response A revised Metro North has been included in the Government’s capital programme. It will link Swords via the Airport, to Dublin City Centre with a journey time of approximately 25 minutes. The provision of the proposed new Metro North is critical to the continued, sustainable growth of the Swords and surrounding areas, and it is essential that the metro stops are easily accessible to trip-intensive developments.

The intention to make provision for a possible future extension of the proposed new Metro North from its current finishing point at Lissenhall to connect with Donabate is welcomed. It is considered that the specification of an exact location would be inappropriate at this time until sufficient analysis has been completed on the most efficient / optimum route to Donabate. Further feasibility studies and analysis is required to determine the optimum route and future extension of the proposed new Metro North line to Donabate.

The Draft Fingal Development Plan 2017-2023 contains a new objective in Chapter 7, which reads as follows:

‘Objective MT14 Support TII in a possible future extension of the proposed new Metro North finishing point to connect with the Northern Line in Donabate, with a view to securing permission from An Bord Pleanála.

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It is recommended that this objective is also included in the Draft LAP to further support the extension of Metro North to Donabate.

Recommendation Insert new Objective to Section 3 of the Draft LAP to read as follows:

Objective 3.11 Support TII in a possible future extension of the proposed new Metro North finishing point to connect with the Northern Line in Donabate, with a view to securing permission from An Bord Pleanála.

3.7 Donabate Distributor Road Phasing, Alignment, Detail, A number of submissions received relate to the proposed Distributor Road. More information is sought regarding the rationale for the route chosen, the impact of proposed road on existing residents, cost of providing the proposed road, access to the proposed road for football club lands and existing residential areas. Clarification is sought regarding the proposed single / dual aspect of construction of the road. A number of submissions also request that the Distributor Road should be complete before any large scale development is permitted.

Response The Fingal Development Plan 2011-17 provided for a new road which followed an alignment from Hearse Road eastwards across the railway line, to the south east of the existing village before continuing northwards to join to the Portrane Road west of St. Ita’s Demesne. The Council applied to An Bord Pleanala for the approval of a Distributor Road scheme along this alignment in accordance with the FDP 2011-17. This proposed road infrastructure forms an important alternative road crossing of the railway line and aims to serve the new LAP development lands to the south and east of the existing settlement (Corballis East and Ballymastone).

Planning permission was granted in July 2011 (Ref: PL06F.KA0018 and PL06F.HA0031) for this route and it is proposed that it would be constructed on a in tandem with and to support the future expansion of Donabate into the new residential lands. The alignment of the proposed distributor route has been permitted under the above permission. It is not therefore possible to alter the route at this stage.

As noted in response to Section 3.4 above, the Council commissioned a site specific Saturn Traffic Model to be created for Donabate encompassing existing and proposed residential lands. This research was tasked with assessing the traffic implications of the phased delivery of new road infrastructure including the Donabate Distributor Road (DDR) to support the development of the zoned housing lands and the information fed into the ‘Donabate LAP Traffic Analysis Report’’ (2015).

On the basis of this assessment in respect of road network improvements, the initial phases of housing in the LAP require the construction of particular elements of road infrastructure. This road infrastructure should underpin the initial phases of development consistent with incremental housing growth outwards from the core of the existing 24

Village. It will also provide an alternative route for existing traffic to avoid Donabate Main Street and the existing railway crossing.

Fingal’s Capital Programme for the period 2016-2018 provides for the construction of the distributor road. This will initially result in the provision of a single carriageway road between Hearse Road and the Portrane Road, with the provision of a second carriageway to coincide with the completion of the latter phases of proposed housing development. This arrangement is indicated on Figure 9.1 of the Draft LAP and more detail is provided in Section 9 – Phasing. This distributor road is also included within the NTA’s Draft Transport Strategy for the Greater Dublin Area (2016-2035).

Delivery of the Donabate distributor road and the internal road infrastructure will be by the Council and the developer as part of planning approval. Given the significant cost involved in the construction of this route, a financial contribution of €5,000 per housing unit will be required for development within the LAP lands, under a Section 49 Contribution Scheme.

This is supported by the inclusion of the objective below in the Draft LAP:

Objective 3.4 Implement local and strategic traffic relief measures to improve traffic freeflow and safety – Donabate Village and on road networks serving schools through phased construction of a Distributor Road and a series of internal link roads through the LAP lands.

The following objective is also included within the Draft Fingal Development Plan 2017- 2023:

Objective DONABATE 1 Prioritise the early construction of a Donabate distributor road, delivering a new railway crossing, providing alternative access to Donabate and Portrane.

Recommendation No change.

3.8 St Patrick’s Schools – Access, Parking, Safety A large number of submissions were received in relation to the access, parking and pedestrian safety issues relating to St Patrick’s National Schools on the Portrane Road. It is noted that a drop off / pick up zone is needed, more policing of the core school pick- up times, additional signage and widening and upgrading of footpaths is required.

It was also noted that the pedestrian / cycle access to the schools from the Carr’s Mill application (Ref: F14A/0033) should be completed before development takes place.

Response 25

It is acknowledged that the set down area adjacent to the two primary schools on the Portrane Road is limited. The issue of access and parking at St Patrick’s National Schools is included in Section 3.6.3 of the Draft Plan. Additional access points to St Patrick’s Boys and Girls Schools are proposed as part of the development of the LAP lands at Rahillion, as permitted under Reg Ref: F14A/0033 and F11A/0173 (ABP Ref: PL06F.240634). There are 2 no. new footway/cycleway links illustrated from the south- western boundary of the Rahillion LAP lands to link the proposed development into St Patrick’s Boys and Girls National Schools. This is further supported in Objective 3.6, which states:

‘Objective 3.6 Ensure the construction of the following cycleway/footpath improvements in tandem with development: • Link path/route from Newbridge Demesne to Donabate Village via the Corballis LAP lands; • Link path/route from Rahillion LAP Lands south to St Patrick’s Boys and Girls National Schools; and • Provide a pedestrian/cycle link from Newbridge Demesne to lands at Turvey.’ (own emphasis)

Table 9.1 (Phase 1) also notes that ‘Prior to any residential unit being sold and occupied in the Rahillion LAP lands, a pedestrian/cycle access shall be provided from the LAP lands southwards into St Patrick’s Boys and Girls Schools.’. No further development can take place on the Rahillion LAP lands until such time as the links to the schools are in place.

It is important to recognize that here are a number of physical constraints including the existing layout of the school and adjoining buildings that limit the extent of works that can be provided to fully address all the issues raised. The Council has carried out a significant number of improvements to the area around the school in recent years to address many of the traffic and safety concerns, including the provision of a school warden. Furthermore, it is considered that the construction of the proposed distributor road will alleviate much of the traffic congestion at peak periods. The Council will continue to work with all relevant bodies including the Schools to examine all options that are feasible in order to address outstanding traffic and pedestrian safety issues at this location.

Recommendation No change.

4.0 DEVELOPMENT WITHIN NEW LAP DEVELOPMENT AREAS The submissions received from the Department of the Environment, Community and Local Government considers that the Draft LAP provides a comprehensive framework for the proper planning and sustainable development of the area and gives spatial expression to the economic, social, cultural and environmental aims of Fingal County.

4.1 Density & No. of Units Proposed

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A number of submissions were received regarding the number of units proposed and the density of development. One submission noted that higher density development should be promoted within walking distance (500m) of the Rail Station. Another submission noted that the Residential Density Guildelines should not be applied in this area given it is on the edge of the Dublin Metropolitan Area and that the National Spatial Strategy is outdated.

A number of submissions requested a reduction in the unit heights and densities proposed.

It is also suggested in one submission that Fingal should appoint Building Inspectors to inspect each stage of the construction life cycle.

Response A number of the submissions received referred to an inaccurate number of units proposed (i.e. 5,500 units). The likely number of units and density of development is outlined below and is clarified in more detail in Section 8 of the Draft LAP.

Density An overall density of residential development of approximately 35 dwellings per hectare will be targeted in the LAP lands. Based on this density of development and taking into account the following: • the land take required for the construction of a Distributor Road; • the lands currently occupied by St Ita’s and St Pat’s football clubs; • the lands identified as being unsuitable for residential development (based on the findings of the AA, SEA and SFRA), the Donabate LAP lands have the capacity to provide approximately 3,935 units. (It should be noted that this figure also includes 2 small areas of zoned residential lands within Donabate, which are not included within the LAP boundaries but are located in close proximity to same.) This is detailed as follows:

LAP AREA AREA (HA) UNITS (Approximately)

TURVEY 16 460 RAHILLION 5.5 125 BALLYMASTONE 38.3* 1,200 CORBALLIS 54.7** 1,850 Total Potential Housing in 107 ha 3,635 LAP Lands RS Zoned lands outside of LAP Boundaries RS Zoned land north of 2.5 80 Community Centre 27

RS Zoned land south of 6.4 220 Ballymastone LAP lands, fronting Balcarrick Road TOTAL 3,935 *50.2ha less road take of 3.1ha and existing football clubs of St Pats and St Ita’s (8.8ha) **65.6ha less road take of 5.3ha and lands deemed unsuitable for resid devt south of proposed Distributor Rd (5.6ha deemed unsuitable for residential development - Flood Risk Assessment).

The density of development and number of units now proposed is significantly lower than the previous Donabate LAP 2006.

Donabate is currently designated as a ‘Moderate Sustainable Growth Town’ in the Regional Planning Guidelines for the Greater Dublin Area 2010- 22. The RPG’s emphasise the continuing commuter role of such towns and the coupling of new development with natural increase, economic expansion and public transport services. ‘Sustainable Residential Development in Urban Areas’ (2009) provides guidance to Planning Authorities in considering appropriate densities for new residential development. Donabate most appropriately comes under section 5.10(f) ‘Outer Suburban/’Greenfield’ Sites’ which relates to ‘open lands on the periphery of cities or larger towns whose development will require the provision of new infrastructure, roads, sewers and ancillary social and commercial facilities, schools, shops, employment and community facilities’.

In relation to recommended densities the guidance advises that ‘net residential densities in the general range of 35-50 dwellings per hectare and such densities (involving a variety of housing types where possible) should be encouraged generally.’

The National Spatial Strategy (NSS) is a 20 year planning framework designed to achieve a better balance of social, economic and physical development and population growth between the regions in Ireland. It emphasises the importance, particularly in urban areas, of combining the location of housing with good transport facilities and the need to ensure that housing requirements are matched by zoned and serviced land. In order to promote sustainable development, it is essential to consolidate the physical growth of Fingal. This can be achieved through facilitating development in close proximity to public transport routes, as is the case with the LAP lands in Donabate. The NSS is due to be reviewed, and the preparation of the drafting of a National Planning Framework is anticipated during 2016. Unfortunately, the timeframe for the completion of this document does not align with the preparation of this LAP, however, it is not envisaged that the two should be in conflict having regard to the nature and scale of development proposed.

As previously noted in response to Section 3.5 above, Donabate has a commuter rail service which is planned for upgrading to increase capacity and frequency. The new development areas are all within walking distance of the train station (this is illustrated on Figure 3.1 of the Draft LAP) and this public transport facility will support appropriate increased density proximate to the village and adjoining areas. This will need to be balanced against, inter alia, the location of Donabate at the edge of the Metropolitan

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Area, providing a sustainable housing size, mix & type and respecting the prevailing form of housing in the town of Donabate.

The detailed design of each LAP area in terms of layout and density will be dealt with as part of the development management process.

The appointment of Building Inspectors is not an issue for inclusion within the LAP process. Inspections and certification of building work is dealt with through compliance documentation submitted and agreed by the design team and the Building Control Section of the Council.

Recommendation No change.

4.2 Phasing A number of submissions received raised the issue of phasing and asked how will the phasing be achieved? One submission noted that there is a need for more units to be included within Phase 1 development (area behind Smyths Pub). It was also submitted that a Donabate Construction Traffic Management Plan should include traffic signs to inform construction traffic of HGV restrictions, and that Zebra crossings and yellow boxes should be implemented.

Response Section 19(2) of the Planning and Development Act 2000 provides for the phasing of development within an LAP. Section 9 of the LAP examines the sequential development and phasing programme linked with necessary investment in road infrastructure, open space, drainage, educational and recreational amenities and local service provision. It sets out a phasing mechanism and the infrastructural works that are required in each phase. It is critical that the LAP ensures that development within the plan lands progresses in an ordered way which avoids the creation of sites geographically isolated from the existing settlement and infrastructural provision.

New development in Donabate will progress through a series of three sequential geographical phases expanding from the existing urban centre and each phase will be underpinned by infrastructural provision. As part of the initial phase of development, the Turvey and Rahillion areas will continue to develop to the west and north of the Village respectively. Lands at Corballis and Ballymastone will be developed on a sequential basis with development generally expanding southwards from the village into Corballis and eastwards into Ballymastone as logical physical extensions to the existing built form of the village. Latter phases of development will comprise the easterly section of Corballis lands and the easterly section of Ballymastone.

Accordingly, the phasing of development will be linked with the overall strategy for the LAP whereby the existing settlement will expand geographically from the centre, through the development of physically adjoining lands in a coherent manner. New development will integrate with the established settlement of Donabate and will be supported by the required infrastructure provision. Planning applications for each phase 29 shall be in accordance with the phasing set out in this section. In total, the proposed phases of development on LAP lands have the potential to achieve up to 3,635 dwelling units subject to detailed design appraisal. There is potential to achieve a total of 3,935 dwelling units, when two small areas of zoned residential lands are included (which are outside of the LAP boundaries).

New development will be underpinned by the phased delivery of road infrastructure and the Council commissioned a site specific Saturn Traffic Model to be created for Donabate encompassing existing and proposed residential lands. This research was tasked with assessing the traffic implications of the phased delivery of new road infrastructure including the Donabate Distributor Road (DDR) to support the development of the zoned housing lands. The traffic and environmental assessments included the testing of several development scenarios for different geographical sectors of Donabate and sections of road infrastructure. These assessments evaluated the provisions of the permitted Distributor road in the context of the overall LAP housing numbers, taking into account the phased release of housing lands and various phasing arrangements, to avoid traffic congestion and to ensure adequate infrastructural provision.

On the basis of this assessment in respect of road network improvements, the initial phases of housing in the LAP require the construction of particular elements of road infrastructure. This road infrastructure will underpin the initial phases of development consistent with incremental housing growth outwards from the core of the existing Village.

Table 9.1. highlights the proposed site / specific infrastructure requirements to be provided in tandem with each phase of development.

The Phasing Table (9.1) also includes the required delivery of key recreation and infrastructure amenities during each phase of development, including the Education and Recreation Campus at Ballymastone, Corballis Nature Park and the provision of green routes / looped walkways on the Peninsula.

It is not considered necessary to increase the number of units close to Smyths Pub in Phase 1. This was examined as part of the initial assessment of development lands within the LAP, but based on the results of the traffic analysis, it was decided that the optimum development of phase 1 lands was to focus on the area west of the railway line at Corballis, until such time as the required road infrastructure was in place to facilitate further development at this location. The larger Phase 2 LAP area to the south of Smyths Pub (Corballis East LAP lands) should remain part of Phase 2 and should not be included as part of Phase 1 development. The detailed traffic analysis study carried out for this area further supports this phasing arrangement.

Construction Traffic Management Plans and Haul Routes will be dealt with as part of the Development Management Process. Section 7.6.2 of the Draft LAP notes that Developer(s) will be required to submit a construction programme setting out a planned programme for the management / recovery / disposal of construction / demolition waste material generated at the site during the excavation and construction phases of development, in accordance with the relevant national waste management legislation at 30

planning application stage. The Construction and Demolition Waste Management Plan, as a minimum, shall include provision for the management of all construction and demolition waste arising on site, and make provision for the re-use of said material and / or the recovery or disposal of this waste to approved facilities by authorised collectors. Where appropriate, excavated material from development sites shall be re-used for landscaping, land restoration or for preparation for development on the planning application site. Objective 7.33 of the Draft LAP also states:

‘Developers shall take adequate measures to minimise the impacts of traffic, noise and dust during construction phases. A methodology statement for such measures shall be submitted at planning application stage and developers shall employ best practice as applicable at the time of construction.’

Recommendation No change.

4.3 Mix of units & Social and Affordable Housing A number of submissions raised the need for a mix of units and the need for larger affordable houses, the need for starter homes, family homes, etc. Social and Affordable Housing was also highlighted, with one submission requesting that a maximum of 15% of all units should be S&A housing units and they should be fully integrated within all new housing estates. Another submission noted that all S&A housing is being placed in one part of Donabate and that this contravenes Part V of the Planning Act.

Housing in rural areas was also raised in one submission received.

Response Housing in areas outside of the LAP boundaries (i.e. lands that are not zoned Objective ‘RA’) will be subject to the development management process and any rural housing policy that may apply. Rural housing does not form part of the discussion for the Donabate Local Area Plan, which specifically relates to new residential development areas, zoned for this use.

Mix of Units Section 8 of the Draft LAP sets out the development framework for the LAP areas. The urban design framework will create a new urban environment that will enhance and reflect the character of the area, create a distinctive identity and a sense of place which integrates with the existing Village and provides a mix of dwelling types. The LAP seeks to promote the development of new housing which delivers integrated, balanced communities and provides a sustainable social mix. The new LAP areas will cater for all members of society and deliver a range of house types and sizes, which will provide more opportunities for people to stay and live locally at every stage of their lives. The delivery of life long family homes as part of a successful mix of residential typologies is important and homes should be flexible enough to meet the changing needs of residents. This will ensure that spaces and features in new homes can readily meet the needs of most people, including those with reduced mobility. Innovative designs that 31 help achieve family housing typologies are also a priority for this LAP and will be dealt with at the Urban Design Appraisal / planning application stage.

Whilst it is acknowledged that standard family house-types will comprise a strong element of the LAP lands, contemporary architectural designs will be encouraged, with visual references and unique identities developed for the different neighbourhood areas. Modern designs which reflect the evolution of Donabate and respect existing building forms and local architectural elements on the Peninsula will be encouraged including the interpretation of traditional shapes and sizes into a modern contemporary style that is sensitive to its surrounding landscape with a general layout of development that makes it easy for people to find their way around.

Objective 8.1 of the Draft LAP requires the submission of detailed design appraisals with each planning application for greater than 8 no. dwelling units within the plan area. The design appraisal is required, inter alia, to demonstrate how the proposed units (i.e. unit and/or mix) can adapt to changing household needs.

Social and Affordable Housing A number of the submissions queried the location and number of social and affordable units proposed in the new LAP development areas. Changes to the way in which social and affordable housing can be delivered have been included in the Urban Regeneration and Housing Act 2015, which commenced on 1 September of 2015 pursuant to SI 364/2015 (the 2015 Act). There are two main changes to Part V. The first is that the maximum percentage of land which a planning authority can require to be transferred to it by a developer has been reduced from 20% to 10%. The second is that the options available to a developer, as to how they comply with its social and affordable housing obligations have been revised and are outlined below.

Compliance with Part V There are now 3 options for compliance with Part V (apart from the default option of transferring undeveloped land) as follows:-

(i). A developer can build the percentage of social and affordable housing required and then transfer it to either the planning authority or its nominated authority. The number and specification of the houses must be agreed in advance with the planning authority; or

(ii). A developer can transfer houses on other land, as per a prior agreement, to the planning authority or its nominated authority; or

(iii). A developer can grant a Lease to the planning authority of an agreed number and specification of houses, either within the application site or elsewhere within the planning authority's functional area.

These 3 options are in addition to the default option, which is the transfer of undeveloped land within the application site. The 2015 Act prescribes that it is no longer possible to make a payment in lieu of the provision of Social and Affordable Housing; or 32

to transfer undeveloped land that is somewhere other than within the application site; or to provide serviced sites.

The Housing Strategy (in the current Fingal Development Plan 2011 and in Appendix 1 of the Draft Fingal Development Plan 2017-2023) addresses the Council’s obligations set out in the Act, in accordance with the amended Part V, whilst recognising and having regard to the rapidly changing and evolving housing landscape both nationally and locally. Given the scope and content of the Housing Strategy and the requirement of the Planning Authority to conform to these requirements of the Act, it is it is not considered necessary to amend the text within the Draft LAP or to insert new objectives.

Social and Affordable housing will be delivered in the LAP areas in accordance with the provisions of the Housing Strategy and will be provided by the Council, private developers and/or approved housing bodies across the LAP lands. In order to promote and facilitate social integration, social and affordable housing will be integrated appropriately into the overall development of the lands.

This is supported in the Draft LAP, with the inclusion of Objective 8.12 and Objective 8.13, which read as follows:

‘Objective 8.12 Ensure that the Councils Housing Strategy and any/all requirements under Part 5 provisions of the Planning and Development Act 2000 (as amended) are incorporated into all residential schemes. Social housing provided on site shall be well designed and integrated into the overall scheme for the area.

Objective 8.13 Social and Affordable housing will be delivered in accordance with the provisions of the Housing Strategy and will be provided jointly by the Council, private developers and Approved Housing Bodies across the LAP lands. In order to promote and facilitate social integration, social and affordable housing shall be integrated appropriately into the overall development of the lands so as to ensure there is no concentration of social housing in any one specific area or zone.’

Recommendation No change.

4.4 Permeability & Accessibility Permeability and accessibility is raised in a number of submissions received. There is a high level of permeability required – with submissions noting the need for pedestrian and cycle access to schools, train station, village, beaches, estuaries, open space, newbridge demesne, etc. One submission requested that Fingal prohibit the opening up and use of existing cul-de-sacs for construction and motor vehicle through-traffic. Concern was also expressed regarding access / permeability through existing developments. The integration of new development with existing development was 33 highlighted as being very important in submissions received and that this approach should be emphasised in the overall strategy.

Another submission noted that during construction of lands near The Links estate, construction traffic should use an access off New Road and that the proposed new road between The Links estate and adjacent development in Ballymastone is not serving the best interests of the residents in The Links.

A number of submissions noted security concerns and the need to controlling anti-social behaviour. It is noted that community based CCTV could be investigated. Concern was also expressed in submissions received in relation to the permeability between new and existing residential areas and the perceived rise in anti-social behaviour as a result of these links.

Response Permeability is a key urban design consideration which is promoted in a number of National Guidance documents. A permeable area which provides linkages within the urban environment for people to walk and cycle from their homes to shops, schools, local services, places of work and public transport stops and stations can contribute to a range of planning objectives. These include increasing opportunities for social interaction, reduced travel times, greater health benefits, and increased passive supervision and safety within an area. The specific details in relation to the integration of new development and existing development will be dealt with at planning application stage and / or through the Donabate Urban Design Framework Plan. Any future proposals to improve facilities for pedestrians and cyclists in the village will have regard to their impact on residential amenity.

The objectives contained within the LAP fully support the provision of a network of key cycle and pedestrian routes throughout the Peninsula, particularly Green Infrastructure Objectives 4.1 to 4.13.

Objective 4.4 seeks to

‘Promote and develop a combined greenway for walking and cycling along the Peninsula coastline and complete an inter-connected network of looped green paths (walking and cycling) through the LAP lands at Rahillion, Corballis and Turvey, as well as Donabate Village, existing and proposed residential areas, schools, Turvey Nature Reserve & Allotments, Newbridge Demesne, Estuaries and the beaches. The walkways shall be designed and sited to reflect and integrate with their setting subject to Appropriate Assessment and detailed design assessment.’

Figures 4.1 to 4.6 in Section 4 of the LAP illustrate the proposed network of pedestrian and cycle routes within the LAP lands and the wider Peninsula area. This is further supported in the Draft Fingal Development Plan 2017-2023, specifically Objective DONABATE 5, which reads as follows

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‘Provide for a comprehensive network of pedestrian and cycle ways linking residential areas to one another, to the town centre, schools, the recreational campus at Ballymastone and the railway station.’

Section 8 of the Draft LAP further supports the development of these strategic accessible green routes, with the inclusion of the following Objectives:

Objective 8.4 Integrate pedestrian and cycling routes within the LAP lands with walkways through St Ita’s Demesne to the coast.

Objective 8.9 Ensure as far as feasible that all urban and rural areas are accessible to all, with provision of facilities for people with mobility impairment and/or disabilities based on the principles of Universal Design. Implement a street network with a high quality public realm and priority for the pedestrian/cyclist and the mobility impaired.

The Council is fully committed to the planning, development and implementation of the strategic green routes (Turvey Loop, Rahillion Loop and Fingal Coastal Way) throughout the Peninsula. The delivery of these routes is dependent on a multi-agency approach between landowners, environmental bodies and funding agencies with Fingal as the lead agency. The Council is currently progressing with the planning of various sections of these routes. Funding will be sourced from various funding bodies and from development contribution schemes. The early transfer of open space lands within the plan area will facilitate the planning and implementation of these routes. These green routes will form part of the public open space network within the plan area and will be taken in charge and maintained by the Council.

Table 9.1 (and Figure 9.1) incorporates these green routes into the overall phased development of the LAP lands.

Permeability between new and existing areas and anti-social behaviour Security concerns and anti-social behaviour is noted in submissions received. Concern is also expressed regarding the permeability of new and existing residential developments and the risk of increased anti-social behaviour.

A reduction in crime and anti-social behaviour can be achieved through the careful consideration of the building layout and the environmental design of a development. Consideration of how a proposed scheme may work and the early identification of areas of potential concern will be undertaken at the outset to identify any potential problems. Objective UD 13 of Fingal Development Plan 2011-2017 states:

‘Objective UD 13 Ensure crime prevention measures are incorporated in new developments.’

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It is considered that a similar objective can be included within Section 8.0 of the Draft LAP.

Accessibility and permeability between new and existing areas is a key strategy within the Draft LAP. Permeability describes the extent to which an area permits the movement of people, usually by walking or cycling and it can enhance the attractiveness of a neighbourhood through the provision of additional useable open space; can increase social interactions by facilitating more activity in the public realm, and can maximise the potential for walking and cycling to a range of services.

Any proposals for development within the LAP lands will need to ensure that the new development is connected and integrated with existing established areas and the train station, schools and other community facilities and amenities. Such an approach helps to increase the social capital of a neighbourhood. This relates to the intangible benefits of day-to-day social interactions, shared norms and values such as cultural interests and community based activities, as well as residents acting collectively for a common purpose. At its most basic level, this can foster social cohesion and help to prevent the growth of crime, particularly those offences often associated with urban and suburban areas such as vandalism. By increasing the levels of permeability, the opportunities for social interaction increase, and with it, the social capital necessary for successful neighbourhoods is also increased.

Community-based CCTV is not an issue for consideration within the LAP process.

Recommendation Insert new Objective to Section 8.0 of the Draft LAP:

‘Objective 8.17 Ensure crime prevention measures are incorporated into new developments.’

4.5 Strategic Landscape Corridor at Corballis & Tree Planting A number of submissions request that new residential developments should implement a tree planting programme and avoid the removal of existing trees. It is noted that a tree planting scheme should be promoted at appropriate locations in the town centre and along Beaverstown Road.

One submission also requests the removal of the Strategic Landscape Corridor illustrated on the Corballis LAP lands.

Response The Draft Donabate LAP contains the following in relation to trees and hedgerow in Section 5:

‘5.1.4 Trees and Hedgerow The loss of trees and hedgerows should be minimised and where removed should be compensated and replaced on site. The retention of trees and hedgerows is critical in protecting the positive attributes of landscape 36

character and heritage features of the plan lands. FDP 2011-2017 Objectives OS31 and LC08 seek to, ‘ensure trees, hedgerows and other features which demarcate townland boundaries are preserved and incorporated into the design of developments’ and ‘prohibit proposals necessitating the removal of extensive amounts of trees, hedgerows and historic walls or other distinctive boundary treatments.’

Therefore, in compliance with the FDP 2011-2017 policies and objectives, it is an objective of this LAP to ensure existing trees and hedgerows are preserved and incorporated into the design of future development schemes. It is acknowledged that breaks in hedgerows will be required for pedestrian and vehicular access. Where pedestrian bridges/vehicular bridge(s) are required over an existing watercourse, they shall be aesthetically pleasing, safe and inviting, and be designed to a high architectural specification.’

The following objectives are also included within Section 5 of the Draft LAP:

Objective 5.4 Seek the protection and retention of trees, hedgerows and historic walls or other distinctive boundary treatments that contribute to the visual amenity and landscape character of the area.

Objective 5.5 Protect, preserve and ensure the effective management of trees and groups of trees.

Objective 5.6 Require the use of native planting where appropriate in new developments in consultation with the Council. Indigenous, non-invasive species should be considered to provide habitat for locally occurring fauna ensuring, at a minimum, there should be no net loss of the tree and hedgerow resource.

Therefore, in compliance with the Fingal Development Plan 2011-2017 policies and objectives and the policies contained within the Draft Fingal Development Plan 2017- 2023, it is an objective of this LAP to ensure existing trees and hedgerows are preserved and incorporated into the design of future development schemes. It is acknowledged that breaks in hedgerows will be required for pedestrian and vehicular access. In addition, the Draft Fingal Development Plan 2017-2023 includes a new objective in Chapter 4, which reads as follows:

‘Objective DONABATE 15 Promote an urban tree planting scheme at appropriate locations in Donabate town centre and along Beaverstown Road.’

It is not considered necessary to insert any further objectives to the LAP as this issue is adequately addressed in the Draft LAP and within the Draft Fingal Development Plan.

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Strategic Landscape Corridor within the Corballis LAP lands In the interests of protecting residential and visual amenities, the LAP notes that no buildings shall be built above the 20m contour line in the Corballis LAP area and the maximum ridge / roof heights at this location shall be limited to 26m OD which is below the ridge height of the existing houses at ‘The Strand’. A Strategic Landscape Corridor is proposed along the length of this ridge, which provides an opportunity to develop a linear park running in an east-west direction, whilst protecting views of the Corballis lands from the Malahide Estuary. Objective 8.8 of the Draft LAP states the following:

Objective 8.8 A strategic landscaping scheme shall be implemented on the lands at Corballis, in advance of any development within the area above the 20m OD line to mitigate / soften the visual impact of the existing houses at ‘The Strand’ and to provide a visual backdrop to proposed development within this area.

The intention of this landscape screen is to protect the contours of the land at this location and stepped roof / ridge heights should be provided in the housing area to the south. It is an objective of this LAP that a strategic landscaping scheme shall be implemented in advance of any development within the area above the 20m OD line. This will mitigate / soften the visual impact of the existing houses at ‘The Strand’ and will provide a visual backdrop to proposed development within this area.

Detailed Visual Impact Assessments and Landscape Character Analysis will also be required as part of any application for development on these lands.

The Planning Authority is not in favour of removing this Strategic Landscape Corridor and it is considered that the detail relating to exact layout, detailed design of units and the passive surveillance of this landscaped area can be dealt with as part of the development management process.

Recommendation No change.

4.6 Visual Impact of Development on the Estuaries and Building Heights A number of submissions express concern regarding the proposed design and layout of the proposed new development areas. It is submitted that high-rise development proposed 60m from the Estuary is not appropriate and that high rise apartments in the Village are not sustainable. It is also submitted that development so close to both Estuaries is not appropriate, with the development on the Rahillion lands being visible from the Estuary.

Response Building heights across the LAP lands will be predominantly two storeys with opportunities for increased heights at specific locations. Increased heights may be appropriate at locations where higher buildings would make a contribution to the 38 streetscape or would provide overlooking of open space/ recreation areas (i.e. areas closest to the Village and Railway Station). Single storey units will also be appropriate at certain locations, including the northern edge of the Rahillion LAP lands.

The heights will generally be low and could not be considered ‘high-rise’. The detailed design of each LAP area in terms of height, layout and density will be dealt with as part of the development management process.

The LAP lands at Corballis and Rahillion are highly visually sensitive, because of their relative elevation and proximity to Malahide and Rogerstown Estuaries. The aspect of any buildings from the shorelines of both Estuaries require particular attention and a Visual Impact Assessment is required to be submitted for any planning applications on these lands. To minimise visual impact, the height of buildings along the southern and eastern edges of the Corballis lands and along the northern edge of the Rahillion lands should be carefully considered. Views to and from the LAP lands will be considered in the assessment of any development of these areas.

Rahillion The LAP acknowledges that particular care will need to be taken in the built form and massing along the northern edge of this area, given the proximity to the Estuary and ecological buffer zone. Care also needs to be taken to preserve the views from higher ground. The design of development needs to reflect single storey housing along the northern edge to preserve views at this location, as per Local Objective 238 of the FDP 2011-17. Planning permission has recently been granted for approximately 100 homes on the LAP lands at Rahillion (Reg Ref: F14A/0033). The remaining area of 1.4ha only has the potential to provide a maximum of 25 no. additional units. It was a condition of the planning permission that the development of the lands along the northern edge of the Rahillion LAP lands shall be single storey and this objective is reinforced in the Donabate LAP through Objective 8.14.

Objective 8.14 Development along the northern edge of the Rahillion LAP lands (southern boundary of Rogerstown Estuary) shall be single storey with a ridge height no greater than 5.5 m. The remaining Rahillion lands shall be developed for a maximum of 2.5 storey units only.

Corballis Particular care will be required, in terms of heights, form, massing and detailing with the buildings proposed along the southern edge of the Corballis LAP lands, facing the Malahide Estuary. This area has high sensitivity because of its visibility from Malahide Village and the Estuary. As the lands slope upwards, any development proposed will be required to investigate the staggering of building heights to ensure that new development is integrated sensitively into the landscape.

It is an objective of FDP 2011-2017 and the Draft FDP 2017-2023 to preserve views along the Corballis coast road, which runs from the railway line east along the coast towards The Island Golf Club. This road provides views over the Malahide Estuary. There is also a Development Plan objective to preserve views from the coast road in Malahide 39

looking north over the Estuary towards Donabate. In assessing views and prospects it is not proposed that this should give rise to the prohibition of development along these routes, but development, where permitted, should not hinder or obstruct these views and prospects and should be designed and located to minimise impact. This is supported in Objective 5.2 of the Draft LAP, which states:

‘Objective 5.2 Protect views and prospects that contribute to the character of the landscape, particularly those identified in the Development Plan, and where appropriate, incorporate principal views of the surrounding area, in particular, views over Malahide Estuary, into future development schemes. Protect areas of high landscape quality including Special Amenity Areas, High Amenity zoned lands, and Highly Sensitive Landscapes identified on the Development Plan Green Infrastructure Maps.’

The majority of units in the Corballis LAP lands will be two storeys in height. As noted earlier in this report, a Strategic Landscape Corridor is proposed along the length of the ridge of the Corballis lands, which provides an opportunity to develop a linear park running in an east-west direction, whilst protecting views of the Corballis lands from the Estuary. This landscape screen will protect the contours of the land at this location and shall provide for stepped roof / ridge heights in the housing area to the south.

A proposed Nature Park will also be located south of the LAP lands at Corballis, providing a buffer zone between the development on the LAP lands and Malahide Estuary.

Planning applications in sensitive visual locations shall be accompanied by a Visual Impact Assessment, including cross sections and photomontages to assist the Planning Authority in determining the full visual impact of proposed development on the plan lands and on the high amenity lands adjoining. This should form part of the overall urban design appraisal.

Recommendation No change.

5.0 DONABATE TOWN CENTRE

5.1 Enhancement and Consolidation of Donabate Town Centre A number of submissions requested the consolidation of Donabate town centre and expressed opposition to the creation of competing centres within the new LAP lands. Submissions referred to the need to enhance the existing streetscape and urban design of the town centre.

Response It is the strategy of the LAP to support the consolidation of the existing village in Donabate as the focus for retail, commercial and services development. This will be supported by the creation of strong road, cycle and pedestrian links to the Village and 40 planned geographical expansion of the new housing areas. The new development areas are all less than 1km from the village core and their population will be integrated into the established functioning of the village for shopping and services activity. The development of the LAP lands and the resultant increase in population will encourage and support the re-development of infill and vacant / undeveloped sites in the Village Centre and the LAP will encourage new retail and economic opportunities to locate in Donabate urban centre. No competing centres are proposed at Corballis or Ballymastone.

It is a strategic aim of the Draft LAP to ‘support Donabate Village as the primary location for commercial, retail, community and cultural development serving the Town and Peninsula generally’.

A new local neighbourhood centre is proposed in Corballis adjoining the primary school and it is intended to serve the local needs of the new housing population only. Retail floorspace at Corballis will be limited to neighbourhood centre level and as such, will not be anchored by a supermarket or large convenience store. The Draft Fingal Development Plan 2017-2023 also includes the following objective, which supports the consolidation of Donabate Village:

‘Objective DONABATE 2: Channel and concentrate the development of additional commercial, social, community and civic facilities within the town centre and promote high quality urban design in such development.’

Issues relating to streetscape, public realm and urban design and the need for a general improvement and enhancement of Donabate Town Centre are noted. The Donabate Urban Centre Strategy (June 2010) addresses a number of issues which are of importance to the town centre and wider Donabate area, including recommendations relating to traffic management and car parking in the area, pedestrian and cycling activities, environmental improvements to the urban realm, etc. Furthermore, Donabate Urban Framework Plan, when complete, will provide further details in relation to traffic management, car parking, pedestrian safety, public realm, streetscape, etc. In the interim the Donabate Urban Centre Strategy (2010) shall provide guidance in relation to these matters.

Recommendation To further strengthen and support this policy of consolidation of Donabate Village Centre, it is recommended that a new Objective be inserted at the end of Section 6 of the Draft LAP, to read as follows:

‘Objective 6.11 Support the consolidation of Donabate Village as the focus for retail, commercial and services development on the Peninsula.’

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6.0 INFRASTRUCTURE ISSUES The submission received from Irish Water welcomes the policies and objectives in relation to water services within the Draft LAP. A number of submissions note the need to provide infrastructure in tandem with development.

6.1 Flooding The issue of flooding was highlighted in a number of submissions received, including flooding at the entrance to Newbridge Demesne, and along the Portrane Road, Beaverstown Road, Kilcrea / Hearse Road and on lands at Corballis.

The submission from the EPA welcomes the exclusion of some zoned lands at Corballis from residential development and acknowledges that it shows a strong commitment from Fingal in ensuring the appropriate use of lands relative to their flood risk vulnerability.

Response The Council is responsible for the management of surface water at a local level and the Office of Public Works (OPW) has responsibility for flood risk management at a strategic level. Flood Risk Management is dealt with in Section 7.5.2 of the Draft LAP. In accordance with the ‘The Planning System and Flood Risk Management Guidelines’ (November 2009), a Strategic Flood Risk Assessment [SFRA] undertaken to assess flood risk within and adjoining the plan area as part of the LAP preparation process. (This is included as Appendix 4 of the LAP.)

The Flood Risk Assessment (FRA) for the LAP area determined that the two most significant sources of flooding within the LAP area are the Turvey River and the Beaverstown Stream. There are a number of other minor areas of pluvial flooding within the LAP boundary. The FRA shows the majority of the ‘RA’ residential zoned lands are located outside of any flood risk areas. Only a very limited area of the LAP lands (southern portion of Corballis West) is identified as being at risk of flooding and is therefore deemed inappropriate for residential development. This area has therefore been excluded from development in this LAP.

The hydrology and hydraulics of the previous flood events that have occurred within the LAP lands have been assessed to determine the cause of flooding and to develop mitigation measures. The most significant event occurred in October 2011 on Beaverstown Road and was caused by a number of issues, including blocked culverts and a power cut to the pumping station on the Beaverstown Stream. The construction of a new pumping station (which has already been granted planning permission) will contain a backup generator ensuring local power outages do not prevent the pumping station from operating. Culverts will be checked regularly by Operational staff to ensure there are no blockages.

Climate change, in combination with the ongoing urbanization of catchments, means that the flood risk to property is continually changing. In order to minimize the impact of an increased future flood risk, there are various steps the Council can take, including Sustainable Urban Drainage Systems (SuDs) and control of development in flood plains. Policies in the LAP requiring the preparation of Strategic Flood Risk Assessments and the 42

inclusion of SuDs in applications for development within the LAP lands are included (Appendix 4 and 5 refer). SuDs measures suitable to the scale and location of development are required for all new developments as appropriate. Integration of SUDS techniques within these new developments will be required to ensure that the capacity of the existing network is not exceeded and the quality of the surface water runoff is not negatively impacted by the development. SUDS techniques will have the impact of both reducing pluvial and fluvial flooding and also improving discharge water quality. The SUDS features are required to be constructed up front to facilitate development

A SUDS Strategy for the LAP lands was commissioned by the Council and a ‘Donabate LAP SUDS Strategy’ recommends various SUDS measures for utilisation within the LAP area. This is included as Appendix 5 of the Draft LAP.

There are a number of essential water and drainage objectives contained within Section 7 of the Draft LAP and it is considered that the issue of flooding has been adequately addressed in the LAP written statement, accompanying flood zone maps and in the associated Flood Risk Assessment and SUDS Strategy documents included within Appendix 4 and 5 respectively.

Recommendation No change.

6.2 Foul Drainage and Water Supply The provision of a sewerage mains connection for current Corballis residents and current residents of Turvey Avenue (R132 end) was raised in a number of submissions. The need for a new pumping station at Donabate South was also raised in submissions received.

The issue of water supply and proposed new water supply from the River Shannon was highlighted, as was the need for liaison with Irish Water at the earliest opportunity to facilitate mains sewerage infrastructure to the eastern side of the Peninsula to include the 3 no. local golf clubs, hotel and residential areas.

Another submission requested the connection of the Rush agglomeration into the Portrane / Donabate / Lusk sewerage scheme.

The submission from the EPA requested some minor amendments to the SEA Environmental Report (ER).

Response In general response to issues raised in relation to Water Supply, Irish Water is Ireland’s national water utility which is responsible for providing and developing water services throughout Ireland. Supply and demand for high quality drinking water is finely balanced across the region and this will remain the case in the short to medium term pending the delivery of a number of projects to increase production, storage and delivery capacity. The ‘Water Supply Project Eastern and Midlands Region’ is currently at 43 the project planning stage with Irish Water and there is a need for a new water supply to service projected demand in Irish Water’s Eastern and Midlands Region. The need for a water supply from a new source has therefore been established, with the aim to have a Phase 1 scheme in place by 2021 (Irish Water: A Working Paper on Options Appraisal).

In the submission received from Irish Water, it is noted that:

Irish Water will endeavour to secure the provision of the infrastructure necessary to support the evolving population change and economic activity over the Donabate LAP period, subject to the availability of the necessary capital investment and in compliance with environmental objectives and regulations. It is Irish Water’s objective to provide and operate water services in economically and efficiently and in a manner that protects and enhances the environment including supporting the achievement of water body objectives under the Water Framework Directive and supports Ireland’s National Climate Change Policy and associated plans and frameworks.

Irish Water has significant challenges in balancing our commitments and available funds to achieve these objectives. Irish Water invests in the development and expansion of the water and wastewater infrastructure in line with its investment programme and connection policies which are subject to the approval by the Commission for Energy Regulation (CER). All capital investment beyond the Capital Investment Plan 2014-2016 is subject to the agreement of CER.’

The provision of a sewerage mains connection for current Corballis residents and current residents of Turvey Avenue (R132 end) and the eastern side of the Peninsula to include local golf clubs, hotel and residential areas is not an issue for the LAP process. The Council’s Strategic Infrastructure Division notes that provision of a sewerage mains connection to these areas are not included in the Irish Water Capital Investment Plan and therefore, may not be progressed in the absence of substantial development in the area necessitating further investment in infrastructure. These schemes are unlikely to be advanced prior to the development of LAP lands and are considered to be adequately covered within the general Objective WT01 within the Draft Fingal Development Plan 2017-2023, which states:

‘Liaise with and work in conjunction with Irish Water during the lifetime of the plan for the provision, extension and upgrading of waste water collection and treatment systems in all towns and villages of the County to serve existing populations and facilitate sustainable development of the County, in accordance with the requirements of the Settlement Strategy and associated Core Strategy.’

Listing specific projects or schemes is considered undesirable and the lands referred to are outside of the boundary of the LAP. The Council will continue to pursue the provision of all projects and schemes necessary within the County. 44

Phase 1 of the overall ‘Portrane-Donabate Rush and Lusk (PRDL) Waste Water Treatment Scheme’ has been completed and as part of this scheme, a new Portrane Wastewater Treatment Plant (WWTP) has been constructed immediately south of St Ita’s Hospital. It has the provision to cater for 65,000 population equivalent (PE). At present the loading is approximately 35,000 PE. The Donabate LAP lands are included within the Portrane Wastewater Treatment Plant (WWTP) catchment. Wastewater generated from the development of the LAP lands will be directed into this new WWTP facility. The provision of a new expanded foul sewer network and associated new foul pumping stations will be required for the LAP lands. New Pump Stations (PS) have been constructed in Donabate (Donabate PS) and on the R126 between Donabate and Portrane (Portrane PS). These pump stations are fully automated and are linked by telemetry to the operators of the WWTP.

Phase II of the PDRL Waste Water Treatment Scheme includes a proposal for the Ballalease Pumping Station to be constructed on Balcarrick Road adjacent to the proposed Donabate Distributor Road crossing. The preliminary design also indicates that another pump station would be required south of the proposed Ballalease Pumping Station provisionally called the Donabate South Pumping Station, which will be required to deliver the effluent from the zoned lands at Corballis East and West to the Ballalease PS. The detailed design of new pumping stations and associated outfalls will be subject to planning approval, Appropriate Assessment and Foreshore Licence, where appropriate.

The suggested amendments to the SEA Environmental Report (ER) have been noted and will be incorporated in the Final Environmental Report.

It is considered that the issues raised in the submissions relating to foul drainage, flooding and water supply have been adequately assessed and addressed within the Draft Donabate LAP written statement and associated Appendices (including the SEA, SFRA and SUDS Strategy).

Recommendation No change.

7.0 COMMUNITY INFRASTRUCTURE 7.1 School Provision and School Site Location The submission received from the Department of Education and Skills welcomes the inclusion of the proposed school sites to provide for the possible future educational needs arising from the proposed residential units envisaged for the LAP area. The submission notes that it is important that land is zoned for educational provision and a specific land use zoning ‘Educational’ should be identified with suitably located lands zoned for this purpose to meet the educational infrastructure needs. An Implementation strategy and phasing of schools sites is also highlighted as important. The Department noted that they are open to the concept of multi-campus school arrangements, i.e. where two or three primary schools are located side by side or a primary and a post primary school share the same site. The Department also requests 45 that site reservations are made, as close as possible to community facilities such as sports facilities, libraries, etc, so that these resources can be shared between the school and the community, which is reflected in the LAP.

Other submissions received highlighted that one of the school site locations should be west of the railway line. Another submission suggested that the location of school site in Corballis should be closer to the footbridge.

It was noted in one observation that the post primary school site should be removed from the Ballymastone lands in order to fully develop a sports recreational campus at this location.

Another submission highlighted that the existing post primary school site has been removed in the Draft Development Plan from the lands at Balcarrick Road.

Clarification is also sought regarding the size of the school required at Corballis.

Response There are 3 existing primary schools in Donabate at present – St Patrick’s Boys School and St Patrick’s Girls School located on the Portrane Road and the Donabate-Portrane Educate Together Primary School on the Beaverstown Road. Donabate Community College (Colaiste Pobail Domhnach Beathach) is the only post-primary school in Donabate, and this is located adjacent to the Educate Together primary school and the Donabate-Portrane Community Centre & Library. The provision of new schools is primarily the responsibility of the Department of Education and Skills. In this regard the Department is guided by the Code of Practice on the Provision of Schools and the Planning System (2008). The Code of Practice sets out co-ordinated actions to be taken by Planning Authorities and the Department in planning for the provision of school sites within the planning system.

Based on the potential housing units proposed on the Donabate LAP lands, the Department of Education and Skills has a requirement for 48 no. primary classrooms (3 x 16 classroom schools) and one post primary school (catering for 1,000 pupils). To provide educational infrastructure there are 3 no. primary school sites designated in the LAP at the following locations:

1. Corballis - east of the railway line. 2. Ballymastone – southern section. 3. Ballymastone – northeastern section (as part of Education/Recreation Campus).

These locations were chosen to ensure that the new school sites will be located within the new residential communities and will also serve the existing residential community in Donabate, the majority of which is located east of the railway line. Furthermore, the school symbols are indicative only and do not preclude schools from being developed at other locations. It is considered that the residential lands to the west of the railway line (i.e. Turvey & Beverton estates) can access the existing schools on the Beaverstown Road on foot via the pedestrian link from Beverton estate via Hands Lane. The proposed 46 new primary school at Corballis can be accessed from the residential lands to the west via two new pedestrian footbridges proposed over the railway line within the Corballis lands. The exact location of the proposed school at Corballis will be determined at planning application stage. However, it will be located adjacent to the proposed local centre and will be easily accessible to those living in the immediate area.

The post primary school designation, which was previously located on lands zoned for open space fronting New Road, Balcarrick has been removed and new school site designations have instead been included within the Ballymastone Education and Recreation Campus lands. This corresponds with the Department’s request that site reservations are made, as close as possible to community facilities such as sports facilities, libraries, etc, so that these resources can be shared between the school and the community. This is also supported in the Draft Fingal Development Plan 2017-2023 policy Objective PM61, which promotes the clustering of community, recreational and open space facilities, being located in local centres or combined with school facilities as appropriate. It would therefore be inappropriate to remove the school site designations from the lands at Ballymastone LAP.

It is also considered that the lands remaining to the west of the railway line are not sufficient in size to provide the clustering of community, recreational and open space facilities, as promoted by the Department of Education and Skills. Furthermore, the lands to the east of the railway line, particularly at Ballymastone, provide an optimal location for the co-location of education, sporting, community and recreational facilities. The proposed local centre at Corballis was also chosen as a suitable site for a proposed school, given the possibility of shared facilities and the co-location of community infrastructure at this local centre designation.

It should be noted that if alternative sites are considered more suitable, become available or are required in the future, the Council will work with the Department of Education and Skills and other bodies to ensure the development of schools at the optimum locations.

Each school site shall have a general reservation of 5 acres in accordance with Department requirements. The exact size, detailed design, height and layout will be agreed with the Department at the time of construction, based on the latest statistical data.

Objective DONABATE 3 and Objectives PM70 and PM71 of the Draft Fingal Development Plan 2017-2023 commits the Council to reserve sites to facilitate the development of additional schools at both primary and secondary level in a timely manner in partnership with the Department of Education and Skills and/or other bodies. The Minister for Education and Skills is a statutory consultee for the purposes of the Fingal Development Plan and the Donabate Local Area Plan and has an active role in this regard. The Council continues to work pro-actively with the Department to ensure the issue of schools provision is properly addressed both through planning policy, to ensure that new schools are delivered in a timely and cost-effective manner in line with the proper planning and sustainable development of the areas in which they are needed.

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The Draft Fingal Development Plan 2017-2023 contains the following Objectives:

Objective DONABATE 3 Provide for the further development of recreational, community and educational (primary and second level) facilities.

Objective PM70 Reserve individual sites for primary and secondary schools in consultation with the Department of Education and Skills as and when they are required, using the most up to date statistical data, and in line with access to public transport.’

Strategic Policy 19, in Chapter 1 of the Draft Fingal Development Plan 2017-2023 also seeks to:

‘Ensure the timely provision of community infrastructure including schools, recreational, sport facilities and emergency services, commensurate with the number of housing units proposed for construction on lands zoned for residential development.’

It is not considered appropriate to create an additional zoning category specifically for ‘Education’ as requested by the Department of Education and Skills. Indicative school site icons are identified at strategic locations within the new development areas, with the exact location, layout and detail to be finalised at planning application stage. Education use is permitted in principle within the residential land use zoning categories with the LAP lands.

Recommendation No change.

7.2 Community / Cultural / Exhibition and Performing Arts Centre The need for a Community / Cultural / Exhibition and Performing Arts Centre was highlighted in a number of submissions, with a possible space for such a centre identified beside the Parish Hall in Donabate. Submissions received request that suitable land / sites are designated for ‘local cultural spaces, performance and entertainment spaces’. It is noted that a suitable site would be close to railway station and bus routes from Portrane and Swords. Other submissions stated that an additional Community Centre is required.

Response The positive intention of the submissions is acknowledged and the Council is supportive of additional community facilities and associated infrastructure. Fingal County Council will continue to support existing community facilities in the area (including the Donabate-Portrane Library, Newbridge Demesne, the Community Centre and all-weather pitch) and will support the provision of additional community facilities, where required.

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The need for local cultural, performance and entertainment spaces is recognised in the Draft LAP, with the inclusion of Objective 6.7, which reads as:

Objective 6.7 Facilitate the provision of local cultural spaces, performance and entertainment spaces, while protecting the existing amenities of the area.

A civic / public space is also proposed at the small local centre at Corballis and it is anticipated that this area will incorporate flexible space for local events and small markets.

A wide range of different community facilities, civic facilities and social services exist within the Donabate-Portrane area, ranging from education and health facilities, to those of local and neighbourhood importance such as places of worship, community centres and childcare facilities. The Council will continue to facilitate and support the development and expansion of such services in order to deliver a quality environment whilst improving the quality of life for all.

In recent years a number of state of the art community centres, such as those at Applewood and Holywell in Swords and Ongar and Tyrellstown in Dublin 15, have been provided as part of the Fingal Schools Model. Here schools and community centres were planned and provided as adaptable hubs, offering a range of activities throughout the day and evening time. Such a model provides an excellent opportunity for such a facility to be developed at Ballymastone and it is the intention of the Council to develop additional community, recreation, education and sporting facilities within this campus.

The Council supports the provision of community facilities including a Community / Cultural / Exhibition and Performing Arts Centre. The Council through its Arts Office seeks to promote the cultural life of the County and increase accessibility to arts and culture facilities for all members of the community. This aim will be achieved through both the retention of existing facilities and the introduction of new facilities. The location of such facilities in towns, districts and other areas with higher levels of public transport accessibility, together with a diverse range of complementary uses, can make a significant contribution to the vitality and viability of urban areas and the aims of sustainable development. The following objectives are included within the Draft Fingal Development Plan 2017-2023:

‘Objective PM84 Encourage the provision of new or improved arts and cultural facilities in Fingal, particularly in parts of the County where there is a deficiency in such provision.

Objective PM85 Actively foster and promote the arts in order to preserve and develop the unique history and heritage of the County.

Objective PM86

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Ensure that facilities where possible are accessible by public as well as private transport.’

The Draft Fingal Development Plan 2017-2023 contains objectives to ensure the provision of arts and cultural facilities across the county. However, it is considered that an Objective could be added to Section 6 of the Draft Donabate LAP to support the provision of a Community / Cultural / Exhibition and Performing Arts Centre to serve the Donabate-Portrane area.

Recommendation Insert new Objective 6.12 to read as:

Objective 6.12 Support the provision of a Community / Cultural / Exhibition and Performing Arts Centre for Donabate-Portrane and encourage the development of multi- functional community buildings which are not used exclusively by any one group.

7.3 Community Facilities A large number of submissions highlighted the need for a range of community facilities including a primary health-care centre, Garda Station, Fire and Medical services, crèche and after-school facilities, youth facilities, playgrounds, skate park, swimming pool, tennis courts, facilities for the elderly, additional sporting facilties and MUGA pitches, international hockey pitch, identify church sites, etc.

One submission also recommended that the open space requirements be increased from 10% to 15%.

Response The Council welcomes and supports the provision of a variety of community recreation, leisure and sporting infrastructure for new and existing residents. There is a need for facilities which cater for all elements of society, children, young people, the disabled and the elderly. All new development should be community focused and development should be on the basis of building communities. The Council acknowledges that social infrastructure needs to be provided for both the new and existing communities of Donabate. New facilities should be provided in tandem with residential development and community centres should be provided at the same time as housing and these facilities should be operated by the Council in conjunction with the communities.

It should be noted that the provision of certain community facilities is not within the control of the Council (i.e. Garda, Fire Stations, Medical Centres, etc) and is a function of higher level Government Departments. For example, a number of public, voluntary and private agencies are responsible for the provision of healthcare facilities within the County, with the Health Services Executive (HSE) being the primary agency responsible for delivering health and personal social services.

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One submission referred to the designation of lands at Ballymastone for a Garda Station. This would appear to be an error as no site has been identified within the LAP for a Garda Station. The location of Garda Stations is dealt with by the Department of Justice and Law Reform. However, Fingal would support the provision of such a facility within the Donabate-Portrane area.

Childcare It is an objective of the LAP to encourage the provision of full-day care / crèche facilities as part of any new residential development. One dedicated crèche facility will be required for every 75 no. units subject to existing supply provision. Crèche sizes and locations will be determined at planning application stage. The LAP envisages Corballis Local Centre and Ballymastone Educational and Recreational Campus as appropriate locations for such childcare provisions. The Council shall provide for dedicated full-day care crèche facilities and future childcare needs within the LAP lands. This is supported in Objective 6.1 of the Draft LAP, which states:

‘Objective 6.1 Implement Childcare Guidelines, as appropriate and support the provision of childcare and education facilities at appropriate locations and as required.’

Church Sites The location of future Church sites will be dealt with as part of the Development Management process and it is considered inappropriate to identify the specific locations of sites until such time as applications are lodged to the Planning Authority for assessment. The Council supports the provision of such facilities, and this is highlighted in Objective 6.3 within the Draft LAP, which reads as:

‘Objective 6.3 To support the provision of a new Church and Community Facility on lands at Ballymastone.’

Open Space Requirements The provision and management of open space on the LAP lands will be guided by the Council’s Open Space Strategy (November 2015). The Strategy outlined in the Draft LAP provides for a hierarchy of open spaces in line with Development Plan requirements, which will serve the plan area and provide links to the wider network of green spaces and coastal recreational areas. It should also be noted that in certain circumstances, where more intensive recreational uses are deemed desirable, the Council may consider arrangements whereby appropriate intensive facilities (i.e. skate park, MUGA pitch etc) may be provided in lieu of open space. Intensive recreational / amenity facilities should be in the form of buildings or enclosures which may include indoor or all-weather recreational facilities.

Playgrounds / Skate Park 51

The Draft Donabate LAP notes the following in relation to playgrounds and skate parks in Section 4:

‘4.2.4 Playgrounds There is an excellent playground located in the grounds of Newbridge House, which is a valuable resource for the young families in the area. However, there is a need for additional smaller play facilities in other parts of Donabate, particularly close to the town centre. The LAP should seek to provide suitable play facilities as part of all new residential development and to provide a range of play equipment to cater for a variety of age groups. Youth activity spaces such as skate parks, etc, should also be incorporated into larger developments.’

This is further supported by the inclusion of Objective 4.6 within the Draft LAP:

‘Objective 4.6 Provide appropriately scaled children’s playground facilities and youth activity spaces within residential development, having regard to relevant Fingal County Development Plan policy, Department of Environment guidance and best practice.’

It should also be noted that the Draft Development Plan 2017-2023 includes a new objective for Donabate to read as follows:

‘Objective DONABATE 13 Promote and facilitate the provision of a skate park in the Donabate / Portrane area.’

A youth activity space is included as part of the Ballymastone Education and Recreation Campus and will be incorporated into the Masterplan to be prepared to guide the development of this area.

Corballis Nature Park A Nature Park is also proposed at Corballis as part of this Draft LAP. This area will be managed as a natural landscape to ensure that the lands continue to play host to a variety of bird / wildlife.

Other Community / Recreation Facilities It is acknowledged that there are a wide range of community facilities required within the Donabate-Portrane area including facilities specifically for teenagers (youth cafes), the elderly, sporting facilities such as a swimming pool, athletics track, tennis club, international hockey pitch, etc.

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Whilst the Council may not be in a position financially to provide such services directly, it will support and encourage the provision of uses which provide a gain to the local community. The Draft LAP contains the following objective:

Objective 6.9 Facilitate the development of appropriate new recreation, leisure, tourism and service facilities and ensure access for all groups of the community.

The Draft Fingal Development Plan 2017-2023 also contains sufficient objectives to ensure the provision of community facilities across the county.

Objective PM65 Ensure proposals for large scale residential developments include a community facility, unless it can be established that the needs of the new residents can be adequately served within existing or committed community facilities in the area.

Objective PM66 Support the provision of new community centres and facilitate the refurbishment and extension of facilities where there is a need for such works. Such facilities shall be accessible by a range of travel modes with an emphasis put on walking, cycling and public transport use, while providing limited car parking facilities to meet anticipated demand of non-local visitors to the centre.

Objective PM67 Resist the loss of existing social and community facilities such as community centres and youth clubs or any sports facilities including playing fields, unless satisfactory alternatives are available.

Objective PM68 Encourage the development of multi-functional buildings which are not used exclusively by any one group.

To identify sites within the LAP areas for specific uses at this time, may act to unintentionally restrict development on these lands for other types of community infrastructure and would be unduly restrictive. It is considered that the provision of community facilities is adequately covered by the existing land-use zoning and objectives within the LAP and Draft Development Plan and it is therefore considered unnecessary and inappropriate to add specific designations to sites until such time as detailed Masterplans / planning applications are under preparation.

Recommendation No change.

7.4 Ballymastone Education and Recreation Campus

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A number of submissions referred to the Sports Clubs at Ballymastone and the need to improve access to these facilities. One submission detailed a Masterplan for the Ballymastone lands with new pitches, clubhouses, parking, access issues all identified. A number of submissions also requested the development of the Masterplan for the Ballymastone lands as soon as possible.

Response Ballymastone Education and Recreation Hub The proposed Ballymastone Educational and Recreational Campus will provide additional facilities for the population of the Peninsula anchored by the consolidation of the two existing sports clubs at this location and the development of new education facilities. The development of this campus will be led by the Council in partnership with local organisations, clubs, the Dept. of Education and the local community. It would not be appropriate to designate a specific location or use for specific community facilities within the Ballymastone LAP or the other LAP areas until planning application / Masterplan stage.

The Council welcomes the combined submission from St Patrick’s GAA Club, St Ita’s Athletic Football Club and Lambay Sports and Athletics Club, who submitted a preliminary Masterplan proposal which included a suggested short, medium and long term vision for the development of an integrated sports centre at this location. This document will be considered in the overall preparation of a detailed Masterplan for this area, which will include inter alia education, recreation and sporting facilities.

It should be noted that the designated campus lands at Ballymastone will accommodate the expansion and consolidation of active recreation facilities to form a significant Active Recreational Hub, including a new all-weather pitch, athletics track and other sporting facilities. The facilities proposed here will support and strengthen existing recreational facilities (St Pats and St Ita’s football clubs) and will be accessible to existing and proposed residential communities. School site provision is also included at this location. As noted above, a Masterplan for this area will guide its development in the future. The preparation of this Masterplan is included prior to the commencement of Phase 3 development and it is noted in Table 9.1. that it is an objective of the Council to: ‘prepare a Masterplan for ‘Ballymastone Educational and Recreational Campus’ to facilitate the development for community, education (primary and post primary school sites), recreation and sporting facilities at Ballymastone, including a youth activity space for the Donabate Peninsula, as required.’

It is an objective of this LAP to improve access to the existing sporting facilities at St Ita’s and St Pat’s Football Clubs, in support of the proposed recreational hub at this location. This is supported in the Draft LAP with the inclusion of Objective 8.3, which reads as follows:

Objective 8.3 Improve vehicular and pedestrian access to St Ita’s and St Pat’s Football Club facilities.

An extension southwards of the existing road serving The Links is proposed to connect the Ballymastone area with the Balcarrick Road, which will provide an important local link route 54

within Donabate, whilst also allowing the planned development of lands accessed from it. This local road will also provide an alternative route to the Main Street for movement between the Portrane Road and Balcarrick Road. A new Campus Link Road is proposed to traverse the LAP lands in an east-west direction from The Links Estate, providing a suitable point for traffic accessing the Education / Recreation Hub from the west. Figure 8.3 of the Draft LAP illustrates the indicative layout for the Ballymastone LAP lands.

A number of objectives within the Draft LAP support the provision of the Ballymastone Education and Recreation Campus and associated road infrastructure, including:

‘Objective 6.2 Provide an education, sporting, recreation and community development in a campus environment at Ballymastone which supports the consolidation of existing sporting facilities and includes an All-Weather pitch, new school development together with shared supporting infrastructure, in line with an agreed Masterplan.’

Objective 8.2 Prepare a Campus Masterplan to support the creation of an Educational and Recreational hub at Ballymastone to include the consolidation of existing sporting facilities in this area and to co-locate new recreational amenities adjacent to new school site facilities, supporting the Fingal Schools Model. The entrance gates and setting together with the old tree- lined avenue leading to Ballymastone which forms the original right-of-way to Portrane Demesne shall be preserved in any development in this area. The Masterplan, including any new development, shall take account of the Architectural Conservation Area at Portrane Demesne (St Ita’s Hospital) where these lands adjoin this sensitive landscape.

It is not considered necessary to insert any additional text / objectives to the Draft LAP.

Recommendation No change.

7.5 Graveyard Submissions received requested the expansion of the existing graveyard in Donabate and noted that more facilities are needed, including parking.

Response There is sufficient capacity in the existing graveyard to cater for the forecast demand over the lifetime of the proposed Donabate LAP. Having regard to this existing capacity, the Council will continue to review and consider future graveyard provision for the area.

The lands to the north and west of the existing cemetery in Donabate are zoned Objective ‘RS’ (residential) and the lands to the south and east are zoned Objective ‘RA’ (new residential communities). To reserve ‘RA’ zoned lands for the expansion of the existing graveyard at this location is considered to be an inefficient use of zoned

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residential land at this prime location within easy access of high quality public transport, the commercial centre of Donabate, schools and community facilities.

Furthermore, having regard to the high water table in the area, a full technical assessment examining the suitability of potential sites, including the feasibility of extending the existing facility, would have to be undertaken in advance of a decision being taken.

Notwithstanding the above, Objectives PM87 and PM88 in the Draft Fingal Development Plan 2017-2023 address the provision of burial grounds across the County. These Objectives state:

‘Objective PM87 Provide and facilitate the development of additional burial grounds, including green graveyards / natural burial grounds in areas across Fingal as required during the life of the Development Plan and which preferably have good public transport links, taking cognisance of the needs of multi-faith and non- religious communities.

‘Objective PM88 ‘Ensure burial grounds are managed and maintained in a manner which respects their cultural heritage and which provides safety and universal access.’

The Council will continue to facilitate and work with other bodies who wish to develop or expand burial grounds. It is not considered appropriate to reserve residentially zoned land so close to the centre of Donabate Village for an expansion to the existing graveyard facilities at this time.

Recommendation It is recommended that Fingal County Council, having regard to the capacity of the existing graveyard facility in Donabate, continue to review and carry out an assessment of land availability and suitability for future graveyard provision in the area.

7.6 Tourism Opportunities A number of submissions requested the development of a Donabate Portrane Heritage Trail as part of the LAP. The issue of bike stations for a public bike scheme at key public transport points including Newbridge Demesne was also raised in submissions received. One submission suggested the inclusion of a café, bicycle rental scheme at Newbridge Demesne with a number of submissions requesting the enhancement of the visitor experience and amenities at Newbridge House and Demesne. It is submitted that Fingal should liaise with the current owners of Turvey Golf Club in consultation with local community to develop a tourism / recreation use at this location and that Fingal should explore the potential for a co-ordinated tourism approach between the Council and all current Golf Clubs on the peninsula.

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Response Fingal promotes walking and cycling as an efficient, healthy, and environmentally- friendly mode of transport by securing the development of a network of direct, comfortable, convenient and safe cycle routes and footpaths, particularly in urban areas. The Council will work in co-operation with the NTA to implement the Draft Greater Dublin Area Cycle Network Plan subject to detailed engineering design and the mitigation measures presented in the SEA and Natura Impact Statement accompanying the NTA Draft Plan.

Objective 3.7 in the Draft LAP seeks to ‘Provide for good quality bicycle parking facilities at key locations within the LAP lands such as the Corballis Local Centre and the Ballymastone Campus, in accordance with Fingal Development Plan standards.’

The Council will promote and encourage the development of bicycle parking and bicycle rental schemes, where appropriate and support their inclusion as part of tourism infrastructure in the County.

Newbridge House and Demesne Newbridge Demesne is an outstanding asset to the new and established communities of Donabate. The Demesne and its associated facilities are a highly valued community and tourism resource, with significant potential for further tourism and recreational development in the future, subject to availability of resources. There is a museum, adventure playground, café / tearooms, pet farm, walled gardens and a variety of woodland and garden walks, which are a key attraction for the local and visiting community.

The Fingal Tourism Strategy 2015-2018 notes strategic objectives to improve the visitor experience at Newbridge Demesne. A €1.5m investment programme is underway at Newbridge Demesne to provide a new visitor reception area, an enlarged, upgraded coffee shop and an educational facility to cater for school tours. The Demesne also hosts a number of events during the year including Christmas and Easter family activities and ‘The Flavours of Fingal’ County Show, which is held in the Summer and attracts approximately 100,000 people annually to the area. Improved and ongoing advertising, marketing, branding and event management is increasing the number of visitors attracted to the facility. It is considered that the estate has the capacity to offer a range of experiences for different target groups that will improve its attractiveness as a regional tourist destination for visitors.

It is recognised that the House and Demesne needs significant investment if it is to fulfil its potential as a community resource and at the same time protect the significance of the heritage of the site. Any future development of this area will be informed by the Newbridge House and Demesne Conservation Plan (to be published in 2016). This document devises an Action Plan for the Demesne and makes recommendations for improvements in the area. A new local objective has been included within Chapter 4 of the Draft Fingal Development Plan 2017-2023, which reads as:

‘Objective DONABATE 17 57

Promote and enhance the visitor experience and amenities at Newbridge House and Demesne within the context of the demesne’s heritage importance and values.’

It is recommended that a similarly worded objective is added to Section 6 of the Draft LAP, to promote and enhance the visitor experience and amenities at Newbridge House and Demesne and to ensure consistency with the Draft Fingal Development Plan 2017- 2023.

Fingal Coastal Way As previously noted in Section 3.2 of this CE Report, the Fingal Coastal Way is envisaged as a greenway, carrying day trippers / tourists along the Fingal coastal corridor in an eco-friendly way, offering an opportunity to showcase the beauty and heritage of the area whilst providing important economic-related development and employment. The tourism potential of the Coastal Way is recognized and it will provide a link with existing pedestrian/cycle routes (including the proposed Broadmeadow Way, the Malahide- Sutton cycleway, etc), Dart and suburban rail stations in the wider Fingal area as well as the Dublin City environs that borders Fingal, thereby opening up the coastal corridor not only to residents of Fingal but to residents of Dublin City. A number of objectives are included within the Draft LAP and the Draft Fingal Development Plan 2017-2023 to support the construction and completion of the Fingal Coastal Way. The Council is committed to providing this route through objectives contained within the Fingal Development Plan and the Fingal Tourism Strategy.

Donabate-Portrane Heritage Trail The suggested proposal for a Donabate Portrane Heritage Trail is welcomed. The matter is sufficiently addressed in Objective ED67 and CH16 of the Draft Fingal Development Plan 2017-2023, which reads as follows:

Objective ED67 Support walking groups and local communities to develop walking trails in towns and villages both for the enjoyment of local people and as an attractor for visitors to the area, promoting local economic development.

Objective CH16 Support the growth of cultural tourism in the county, including the potential for niche heritage-based tourism products by facilitating the development of heritage events, infrastructure such as heritage trails, walkways and cycleways etc. and activities such as community excavation.

It is recommended that a new local objective is added to Section 6 of the Donabate LAP, to read as follows:

‘Objective 6.13 Support the local communities of Donabate and Portrane to develop a Donabate-Portrane Heritage Trail both for the enjoyment of local people and as an attractor for visitors to the area, promoting local economic development.’ 58

Recommendation It is recommended that the following new objectives are added to Section 6 of the Donabate LAP, to read as follows:

‘Objective 6.13 Support the local communities of Donabate and Portrane to develop a Donabate-Portrane Heritage Trail both for the enjoyment of local people and as an attractor for visitors to the area, promoting local economic development.’

‘Objective 6.14 ‘Promote and enhance the visitor experience and amenities at Newbridge House and Demesne within the context of the Demesne’s heritage importance and values.’

7.7 Employment Submissions received note the need for the designation of a site for a Business Park close to Village and for employment opportunities to be created. One submission also requests that reference be made to the Fingal Local Economic and Community Plan 2016-2021 in the Draft LAP.

Response It is acknowledged in the LAP that there is a general lack of employment and business opportunities on the Peninsula. The majority of the those living in Donabate and Portrane commute to Swords, Dublin Airport and the City Centre to their places of work, with a low level of local employment opportunities in the area. Existing local employment principally comprises the schools and services / shops in the Main Street with some other local employment in Turvey Business Park, with seasonal jobs on farms in the area.

The new LAP development areas offer a good opportunity to develop new businesses and employment in the area. However, as noted in response to Section 5.1 above, it is the strategy of the LAP to support the consolidation of the existing village in Donabate as the focus for retail, commercial and services development. This will be supported by the creation of strong road, cycle and pedestrian links to the Village and planned geographical expansion of the new housing areas. The new development areas are all less than 1km from the village core and their population will be integrated into the established functioning of the village for shopping and services activity. The development of the LAP lands and the resultant increase in population will encourage and support the re-development of infill and vacant / undeveloped sites in the Village Centre and the LAP will encourage new retail and economic opportunities to locate in Donabate urban centre. No competing centres are proposed at Corballis or Ballymastone.

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It is a strategic aim of the Draft LAP to ‘support Donabate Village as the primary location for commercial, retail, community and cultural development serving the Town and Peninsula generally’.

A new local neighbourhood centre is proposed in Corballis adjoining the primary school and it is intended to serve the local needs of the new housing population only. Retail floorspace at Corballis will accommodate a number of smaller, local retail units.

The Draft Fingal Development Plan 2017-2023 also includes the following objective, which supports the consolidation of Donabate Village:

Objective DONABATE 2: “Channel and concentrate the development of additional commercial, social, community and civic facilities within the town centre and promote high quality urban design in such development.”

Overall, there is significant potential for an increase in floorspace and the growth of the village area through site assembly and development of derelict/underutilised sites in the future. The development of the LAP lands and the resultant increase in population will encourage and support the re-development of infill and vacant / undeveloped sites for new employment and business opportunities.

The lands at Turvey (west of Donabate Village) are zoned Objective ‘GE’ (General Employment) and also offer potential business development and employment opportunities for the existing and future population of Donabate. The Draft Fingal Development Plan 2017-2023 includes the following objective:

‘Objective DONABATE 11 Prepare and implement a Masterplan for lands at Turvey (see Map Sheet 7, MP 7.A). A detailed flood risk assessment will be carried out for these lands to address potential flood risk and propose mitigation measures.’

Live-Work Units From discussions with the local community at public consultation evenings, there would appear to be a proportion of the local population working from home either on a full time or part time basis. The Draft LAP includes for the provision of small-scale purpose- designed live-work units, within and adjacent to the smaller local centre at Corballis, which will provide small scale employment opportunities within the LAP lands at this location.

The lands to the rear of the Smyths Pub are zoned Town Centre (Objective ‘TC’) in the FDP 2011-17 and in the Draft Fingal Development Plan 2017-2023 and are identified for regeneration in the Donabate Urban Centre Strategy (2010). They will provide a strategic route to the village core from Corballis LAP lands to the south but also offer potential for strong integration of new development into the fabric of the Village. The future development of these lands as an extension to the commercial area of the village will be encouraged by ensuring that there is flexibility to allow mixed uses to locate in this area. The LAP will support the development of flexible live-work units on lands 60 proximate to these zoned ‘TC’ lands (i.e. buildings that can accommodate conversion between business and residential uses). This can be accommodated in design terms by increased floor to ceiling heights for ground floor units, strong public realm and public interface for buildings, flexible elevational treatments and will encourage the organic growth of the commercial area of the village. Objective 6.8 of the Draft LAP states:

‘Objective 6.8 Require development in Ballymastone and Corballis neighbourhoods to provide flexible ‘live & work’ residential units at appropriate locations. These units shall be capable of conversion in part to appropriate commercial use in tandem with residential use and to permit appropriate home-based economic activities that do not result in loss of amenity in terms of traffic generation, residential amenity, noise levels and visual amenity.’

The development of small businesses can play an important role in promoting local employment opportunities. In the early stages of business start-up it is sometimes necessary or appropriate for enterprises to be run from home. Examples of enterprises which may be suitable for location in live-work units include photography studios, arts and crafts industries, home-based economic activities, architecture and graphic design studios, software development and animation companies, i.e. limited public access to avoid any negative impact on residential amenity or parking / traffic in this area. These type of units offer potential tenants and residents flexibility and use-evolution as the need arises.

The Corballis and Ballymastone development areas also offer potential to provide this sustainable form of development integrated into the more traditional housing format. Opportunities shall be explored within the LAP lands to facilitate such home-based economic activity, when considering the design of new houses and the layout of new housing neighbourhoods. Home-based economic activity will be encouraged but will be subject to impact on residential amenity and other relevant development management criteria.

The Planning Authority will also encourage the provision of shared serviced office space where people working remotely can rent desk space on a short-term basis. Appropriate locations include the Donabate Village Centre and Corballis local neighbourhood centre.

It is therefore envisaged that any future employment / business uses within the plan lands will be small scale in nature having regard to the residential zoning objective of the plan lands and the focus on retail and commercial development to locate within the Village Centre.

Fingal Local Economic and Community Plan (LECP) 2016-2021 The suggestion to include a reference to Fingal’s Local Community and Economic Plan is welcomed. This Plan was adopted in December 2015 and it is the first integrated economic and community development plan for the County. It is designed to promote and support the economic and the local and community development of Fingal over the period 2016-2021. For the first time there will be an integrated plan to help the local 61 economy and communities to achieve balanced growth. Fingal LECP is designed to identify and prioritise the objectives and actions needed to promote and support the economic development and the local and community development of the county. The LECP is not an operational plan, but seeks to achieve its objectives by working in partnership with all of the key economic and community development stakeholders that serve the county, including Fingal County Council.

The LECP has a six year time frame and its contents are required to align with Fingal Development Plan. It is envisaged that the LECP will provide a focussed emphasis on local economic development including actions and measures to ensure its promotion and facilitation. One of the objectives of the LECP is to ‘Consolidate the development and protect the unique identities of the settlements of Howth, Sutton, Baldoyle, Portmarnock, Malahide, Donabate, Lusk, Rush and Skerries’ which is consistent with policies and objectives included within the Draft LAP and the Draft Fingal Development Plan 2017-2023.

The Draft Fingal Development Plan 2017-2023 also contains the following policy:

‘Objective ED16 Liaise and coordinate with Fingal’s Local Community Development Committee, the Economic Development and Enterprise SPC and the Local Enterprise Office to ensure that themes and goals included in the Local Economic Community Plan are supported by policies and objectives in the Development Plan, as appropriate.’

It is recommended that additional text is added to the ‘Section 6.2 Economic Infrastructure’ of the Draft Donabate LAP and that a new objective is also included in Section 6.

Recommendation Include the following written text into Section 6 of the Draft LAP (after ‘6.2.2 Live-Work Units’):

6.2.3 Fingal Local Economic and Community Plan (LECP) 2016-2021 This Plan was adopted in December 2015 and it is the first integrated economic and community development plan for the County. The plan is built upon the understanding that economic, local and community development are mutually supportive in building sustainable communities with strong local economies. The plan promotes a collaborative leadership approach across a broad range of publically funded agencies and civil society stakeholders to achieve improved outcomes and impacts for citizens, businesses and communities. This is the first LECP for the Fingal local authority area. It is designed to promote and support the economic and the local and community development of Fingal over the period 2016-2021. Fingal LECP is designed to identify and prioritise the objectives and actions needed to promote and support the economic development and the local and community development of the county. The LECP is not an operational plan, but seeks to achieve its objectives by working in partnership with all of the key economic 62

and community development stakeholders that serve the county, including Fingal County Council.

The LECP has a six year time frame and its contents are required to align with Fingal Development Plan. It is envisaged that the LECP will provide a focussed emphasis on local economic development including actions and measures to ensure its promotion and facilitation. One of the objectives of the LECP is to ‘Consolidate the development and protect the unique identities of the settlements of Howth, Sutton, Baldoyle, Portmarnock, Malahide, Donabate, Lusk, Rush and Skerries’ which is consistent with policies and objectives included within this LAP and with the Draft Fingal Development Plan 2017-2023.

And insert new Objective 6.15 to read as follows:

Objective 6.15 Liaise and coordinate with Fingal’s Local Community Development Committee, the Economic Development and Enterprise SPC and the Local Enterprise Office to ensure that themes and goals included in the Local Economic Community Plan are supported by policies and objectives in the LAP, as appropriate.

8.0 ENVIRONMENT

8.1 Protection of Malahide and Rogerstown Estuaries Submissions received note concern regarding the impact on Malahide and Rogerstown Estuaries. The impact of walkways on the Estuaries needs to be considered and one submission recommended that appropriate environmental buffer zones be provided on lands adjacent to the coast / estuaries to continue to provide suitable habitat for protected species and to also serve as an additional flood alleviation measure. Submissions note that the proposed greenway routes have the potential to significantly negatively impact on Rogerstown and Malahide Estuaries, particularly the indicative routes across both estuaries. Further discussion on these routes is required.

It is submitted that the Ecological Buffer Zone extends into the southern portion of the Corballis LAP lands and that there should be no development permitted on these lands.

The submission received from the EPA acknowledges that the Plan provides for the protection of environmental sensitivities and promotes sustainable development and notes that ‘this can be seen through the inclusion of many specific objecitvfes relating to the protection of designated European sites, such as Malahide Estuary (SAC / SPA) and Rogerstown Estuary (SAC / SPA), provision / protection of green infrastructure, provision of additional cycling / pedestrian routes, promotion of increased use public transport, linking provision of appropriate infrastructure to zoning / developments of lands.’

Response

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Impact of Walking / Cycling Routes on the Estuaries A submission was made by the National Parks and Wildlife Service of the Department of Arts, Heritage and the Gaeltacht in relation to the Draft Donabate LAP. The submission raises concerns in relation to a number of issues including the potential for the walking and cycling routes identified in the Draft LAP to cause adverse impacts to Natura 2000 sites.

The Draft Plan provides for a number of walking and cycling routes which will provide for a variety of users. While the Council fully recognises the disturbance risks to Natura 2000 sites from walking and cycling, the walking and cycling routes proposed are designed to manage and alleviate amenity pressure on the adjacent Natura 2000 sites. These measures work in tandem with a range of other proposals to minimise the risks of adverse impacts to Natura 2000 sites. It should be noted that the precise nature and location of the walking and cycling routes has not been established at this stage and the routes shown in the Draft LAP are indicative and subject to further detailed assessment.

Both the overall approach of the Draft LAP in relation to the protection of Natura 2000 sites and the objectives and supporting text of the Draft LAP have been assessed in the Draft Natura Impact Report (see Appendix 3, Section 5). This has concluded that the majority of objectives in the Draft LAP are either likely to have no impact on Natura 2000 sites or to have a positive impact. In relation to a small number of objectives it has been concluded that there is potential for adverse impacts to arise in relation to Natura 2000 sites which are dependent on the way in which these objectives are implemented. In relation to these objectives, mitigation measures have been proposed which address these issues in the Draft NIR (Appendix 3, Section 6). These include, inter alia, mitigation measures in relation to the precise location and design of walking and cycling routes which will be incorporated into the final LAP.

In addition to the above the following is recommended:

Objective 6.10 to be amended to read as follows:

Promote and facilitate the development of the Fingal Coastal way as a local and tourist amenity, promoting the archaeological and cultural heritage of the area and associated events in appropriate locations, subject to Screening for Appropriate Assessment.

An additional objective to be included after Objective 4.13 as follows:

Undertake an early assessment (beginning in 2016), including appropriate assessment, of the walking and cycling routes proposed near Rogerstown and Malahide Estuaries, including the crossing points of the estuaries, to establish viable routes and design options.

The proposed green routes through the LAP lands and the Fingal Coastal Way will integrate nature, amenities and open space on the Peninsula lands. As outlined in Section 4.1.3 of the LAP, appropriate mitigation measures will be required to protect

64 sensitive landscape and ecology and to minimise disturbance to protected habitats and species both during design, construction and operation and maintenance aspects.

Ecological Buffer Zone Ecological Buffer Zones are included within Section 5.4.2 of the Draft LAP and are located adjacent to the LAP lands at Corballis, Turvey and Rahillion with the ecological buffer zone extending into the southern portion of the Corballis LAP lands. These zones are established to protect the Rogerstown and Malahide Estuaries SAC and SPA from the adverse effects of development, by providing suitable habitat for key species such as birds and providing for compatible land-uses around the designated sites. The Fingal Biodiversity Action Plan 2010-2015 recognises the importance of the buffer zone around the estuaries. These areas will be developed as multi-functional landscapes where agricultural land-use is maintained and, where appropriate, combined with nature conservation targets and low intensity recreational use. Intensive recreational uses are not considered appropriate within the ecological buffer zones.

It is proposed to provide a Nature Park within the Ecological Buffer Zone lands south of Corballis LAP lands. The submission received from the EPA notes that it would be useful to provide an appropriate buffer zone in lands adjacent to the coast / estuaries to continue to provide suitable habitat for protected species and to serve as an additional flood alleviation measure. The proposed Nature Park at Corballis will provide a buffer zone between the LAP lands and Malahide Estuary. A cattle grazing programme is proposed for this wetland site together with its use as a Nature Park with managed public access. This Nature Park will be developed in tandem with development and will be important in providing a managed buffer between urban development and the important coastal habitats. This will ensure the impact of new development is properly managed and separated from close proximity to the coastline. The LAP includes the following objectives:

‘Objective 4.5 Provide, as part of the Fingal Coastal Way, an agreed and appropriately designed combined pedestrian and cycle route, with linkages to the proposed GDA Cycle Network, minimizing access points and signage to avoid disturbance to ecologically sensitive locations and ensuring the integrity of the protected habitats and species within Rogerstown and Malahide Estuaries and the ecological buffer zones within the plan lands.

Objective 4.13 Protect the functions of the ecological buffer zones and ensure proposals for development have no significant adverse impact on the habitats and species of interest located therein.’

Where required, all walkways proposed (coastal or inland) will consider the requirements of the EIA, Habitats, Floods and Water Framework Directives.

Recommendation Amend Objective 6.10 of the Draft Plan to read as follows:

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‘Objective 6.10 Promote and facilitate the development of the Fingal Coastal way as a local and tourist amenity, promoting the archaeological and cultural heritage of the area and associated events in appropriate locations, subject to Screening for Appropriate Assessment.’

Insert a new objective to be included after Objective 4.13 of the Draft LAP, to read as follows:

‘Objective 4.14 Undertake an early assessment (beginning in 2016), including appropriate assessment, of the walking and cycling routes proposed near Rogerstown and Malahide Estuaries, including the crossing points of the estuaries, to establish viable routes and design options.’

8.2 Coastal Erosion The issue of coastal erosion, particularly at The Burrow, Portrane was noted in submissions received. The impact of coastal erosion on the Coastal Walk was also highlighted.

Response Whilst the defined LAP boundaries do not include any areas of coastline, it is acknowledged that the issue of coastal erosion in the Burrow and wider Fingal area needs to be addressed, specifically in the context of the proposed Fingal Coastal Way and other coastal walkways identified on the Peninsula.

It is noted that there are a significant number of objectives in the Draft Fingal Development Plan 2017-2023 relating to the protection of Fingal’s sensitive coastal estuarine area as outlined below;

‘Objective SW01 Protect and enhance the County’s floodplains, wetlands and coastal areas subject to flooding as vital green infrastructure which provides space for storage and conveyance of floodwater, enabling flood risk to be more effectively managed and reducing the need to provide flood defences in the future.

Objective SW02 Allow no new development within floodplains other than development which satisfies the justification test, as outlined in the Planning System and Flood Risk Management Guidelines 2009 for Planning Authorities (or any updated guidelines).

Objective SW07 Implement the Planning System and Flood Risk Management-Guidelines for Planning Authorities (DoEHLG/OPW 2009) or any updated version of these 66

guidelines. For lands identified in the SFRA, located in the following areas: Courtlough; Ballymadun; Rowlestown; Ballyboghil; Coolatrath; Milverton, Skerries; Channell Road, Rush; Blakescross; Lanestown/Turvey; Lissenhall, Swords; Balheary, Swords; Village/Marina Area, Malahide; Streamstown, Malahide; Balgriffin; Damastown, Macetown and Clonee, Blanchardstown; Mulhuddart, Blanchardstown; The Burrow, Portrane; and Strand Road, Howth a site-specific Flood Risk Assessment to an appropriate level of detail, addressing all potential sources of flood risk, is required, demonstrating compliance with the aforementioned Guidelines or any updated version of these guidelines, paying particular attention to residual flood risks and any proposed site specific flood management measures. Objective NH50 Objective NH50 Ensure the County’s natural coastal defences, such as beaches, sand dunes, salt marshes and estuary lands, are protected and are not compromised by inappropriate works or development.

Objective NH51 Where coastal erosion is considered a threat to existing properties, explore the technical and economical feasibility of coastal adaption and coastal retreat management options.

Objective NH52 Employ soft engineering techniques as an alternative to hard coastal defence works, wherever possible.

Objective NH53 Identify, prioritise and implement necessary coastal protection works subject to the availability of resources, whilst ensuring a high level of protection for natural habitats and features, and ensure due regard is paid to visual and other environmental considerations in the design of any such coastal protection works.

Objective NH54 Undertake erosion risk management studies for high risk areas so that the longterm erosion risks to property can be clearly identified long before the risk may be expected to occur.

Objective NH55 Develop a coastal erosion policy for Fingal based on best international practice to outline how the Council will deal with existing properties at risk of erosion and how future coastal erosion problems will be managed having regard to national climate change legislation, mitigation and adaptation policies, and the need to protect the environment.’

Given the strategic nature of erosion and policies required for same, it is not considered necessary to repeat the above objectives within the LAP as they are included within the

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Draft Fingal Development Plan 2017-2023, which proposes the development and implementation of a coastal erosion policy for the County.

Recommendation No change.

8.3 SEA / ER / NIR Submissions note that the SEA, ER and NIR should include reference to the cumulative impact of legal hunting in Malahide Estuary by foreshore licence holders and the threats arising from illegal hunting in both Malahide and Rogerstown Estuaries.

The submission from the EPA suggests that it may be useful to consider other potential alternatives in the Environmental Report to ensure that zoned lands are achieving the aims of the plan. In addition, a reference is made to clarification of ‘Alternative C’ within the Proposed Monitoring Indicators under Material Assets.

Response The threats arising from illegal hunting in the Estuaries was raised in one submission received from the NPWS. It is our understanding that the NPWS issue the licenses for the shooting and the enforcement of this issue also lies with the NPWS.

The development of realistic alternatives as required is constrained by the existing zoning of lands in the Fingal Development Plan. The reference to ‘Alternative C’ is an error and will be amended in the Final Environmental Report.

Any amendments will be screened in accordance with the relevant regulations and an SEA Statement will be prepared following adoption of the LAP.

Recommendation No change.

8.4 Dublin Bay Biosphere Reserve One submission requested that reference be made to the UNESCO designated biosphere reserve for Dublin Bay, which lies adjacent to the Plan area.

Response The Draft Fingal Development Plan 2017-2023 contains the following information on the Dublin Bay Biosphere Reserve:

Dublin Bay Biosphere Reserve Biosphere Reserves are places where nature and people connect. They are areas which are internationally recognised for their biological diversity yet also actively managed to promote a positive relationship between people and nature. The Dublin Bay Biosphere Reserve is a special designation awarded by the United Nations Educational, Scientific and Cultural

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Organisation (UNESCO). It is part of a global network of 651 Biosphere Reserves in 120 countries. The Biosphere designation does not add or detract from the regulatory framework already in place for the Bay but is designed to assist stakeholders in finding sustainable solutions to the management of the Bay which ensure good outcomes for both people and nature. The Biosphere is managed by the Dublin Bay Biosphere Partnership which includes Fingal County Council, Dublin City Council, Dun Laoghaire- Rathdown County Council, Dublin Port, National Parks & wildlife Service and local community groups and NGOs. The partnership is working to promote the protection of habitats and species, to support education and research within the site and to support a sustainable economy for people living and working in the area.

Objective NH45 Participate in and actively support the work of the Dublin Bay Biosphere Partnership.

Objective NH46 Develop and implement a Biosphere work program within the County in support of the work of the Dublin Bay Biosphere Partnership.

Section 5.3 of the Draft LAP includes information relating to Biodiversity and Flora and Fauna. It is considered that reference could be made within the text at this location to the Dublin Bay Biosphere Reserve.

It is not considered necessary to insert any further detail or objectives within the Draft Donabate LAP as the Biosphere is adequately covered within the Draft Fingal Development Plan 2017-2023.

Recommendation It is recommended that the following text be inserted after the last sentence of the first paragraph under 5.3 Flora and Fauna (page 50 of the Draft Plan):

‘The Dublin Bay Biosphere Reserve is a special designation awarded by the United Nations Educational, Scientific and Cultural Organisation (UNESCO). The Biosphere is managed by the Dublin Bay Biosphere Partnership which includes Fingal County Council, Dublin City Council, Dun Laoghaire-Rathdown County Council, Dublin Port, National Parks & wildlife Service and local community groups and NGOs.‘

8.5 Other Include reference to bats in Section 8.3.8. The definition of Green Infrastructure needs to be clarified.

References to the National Parks and Wildlife Service should be amended to read National Parks and Wildlife Service of the Department of Arts, Heritage and the Gaeltacht. 69

Response All references to the National Parks and Wildlife Service (NPWS) will be amended to read as ‘National Parks and Wildlife Service of the Department of Arts, Heritage and the Gaeltacht’ (NPWS).

The Planning Authority welcome the request to include a reference to bats in Section 8.3.8 and it is recommended that the text in this section of the LAP be amended to read as follows:

‘However, significant lighting can have a negative impact on sensitive coastal landscapes. To minimise the environmental impact of public lighting in sensitive coastal areas and on species including birds and bats, lighting must be of a sufficient level but of a reduced impact. Any lighting proposed close to sensitive Natura sites will be subject to Appropriate Assessment and assessment of bird and bat movements within the plan lands and the wider area during dark hours.’

Green Infrastructure (GI) The Draft LAP notes the following in relation to GI in Section 4.1.1:

Green Infrastructure (GI) is the network of green spaces and natural elements that intersperse and connect our cities and towns. It is the open spaces, waterways, gardens, woodlands, green corridors, wildlife habitats, natural heritage and open countryside. The emergence of green infrastructure planning is a response to the growing recognition of the many benefits which natural amenities and green spaces provide to society and the need to plan for its protection, provision and management. It is crucial to meet the growing demands of environmental legislation and EU Directives that relate to water quality, flooding, habitats, birds, Strategic Environmental Assessment (SEA), Appropriate Assessment (AA) and environmental liability. Importantly, GI provides an opportunity to ensure that our natural amenities and open spaces are provided, protected and managed in tandem with plans for growth and development. The FDP 2011-2017 is explicit in its commitment to the advancement of green infrastructure networks throughout the County. It incorporates five themes for which there are a number of specific objectives as set out in the Development Plan.

The Draft Fingal Development Plan 2017-2023 also provides a detailed Green Infrastructure (GI) Strategy for the County in Section 8.3. It is the Council’s intention to develop a GI Strategy for the County in consultation will all key stakeholders and with the public during the lifetime of the Development Plan. The Strategy will identify key green infrastructure aims and objectives for Fingal taking account of the priority projects identified in the Development Plan and it will provide for the delivery of these projects including the provision of appropriate funding mechanisms.

It is acknowledged that the term ‘Green Infrastructure’ incorporates a wide range of issues including biodiversity, parks and open space, sustainable water management, architectural and archaeological heritage and landscape. 70

The Draft LAP does not purport to provide a definition for ‘Green Infrastructure’. Section 4.0 of the Draft LAP is entitled ‘Green Infrastructure’ and it seeks to address provision for greenways, open space and recreation for the LAP lands and surrounding areas. The wider green infrastructure issues including landscape, sustainable water management and biodiversity are addressed elsewhere in the LAP, whilst the overall strategy of the LAP is to ensure coherence exists between all elements of GI.

It is not considered necessary to insert any further detail regarding GI or to attempt to define it in the context of the LAP. There are a number of existing GI policies and objectives contained within the Draft Donabate LAP, the existing FDP 2011-2017 and the Draft FDP 2017-2023.

Recommendation Update all references to NPWS to refer to the National Parks and Wildlife Services of the Department of Arts, Heritage and the Gaeltacht.

Amend Section 8.3.8 of the Draft LAP to read as:

‘However, significant lighting can have a negative impact on sensitive coastal landscapes. To minimise the environmental impact of public lighting in sensitive coastal areas and on species including birds and bats, lighting must be of a sufficient level but of a reduced impact. Any lighting proposed close to sensitive Natura sites will be subject to Appropriate Assessment and assessment of bird and bat movements within the plan lands and the wider area during dark hours.’

9.0 SUSTAINABILITY One submission notes the lack of sustainability within the LAP. Other submissions suggest that rainwater butt collectors should be mandatory in all new developments and that all new build should be eco housing and incorporate sustainable techniques.

The importance of sustainable design in new school buildings was noted and the need to achieve an A3 building energy rating was highlighted.

The importance of energy saving, climate change, provision of green roofs in new developments was also raised in a number of submissions.

One submission requested the LAP to provide for energy standards in buildings constructed, that are similar to those adopted in other LAPs around Fingal.

Response A primary focus for this LAP is that development contributes to the achievement of energy efficient and high quality sustainable neighbourhoods in the plan area while recognising the highly sensitive receiving environments.

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Section 1 of the Draft LAP contains a number of policies and objectives in relation to the Council’s commitment to the delivery of sustainable development through the promotion of high quality sustainable forms of design incorporating green design techniques, energy efficient buildings and lifelong adaptable homes and the optimum use of public transport and walking and cycling, green connected routes, linear corridors; and protection of the natural environment.

The issue of climate change, energy efficiency and renewable energy technologies is addressed in Section 1.7 of the Draft LAP. Predictions for the effects of climate change in the future have also been included in the SUDs Strategy of the LAP (Appendix 5).

Sustainability and the LAP The LAP through its many aims and objectives incorporates the following sustainable principles, which are outlined on page 11 of the Draft LAP:

• ‘Optimal use of land through the consolidation of Donabate Village and development of lands adjoining the train station.

• Maximising opportunities for open space, green connected networks and protection of the natural environment as defining characteristics of the developing area.

• Development of a movement and transport strategy which minimises trip generation and promotes cycling, walking, public transport, and sustainable modes of transport through the area.

• Sustainable approaches to housing developments through design, layout, specifications and a mix of house types.

• Promotion of high standards of energy efficiency in housing and commercial developments and use of alternative energy techniques.

• Creation of sustainable communities through integration of the new communities which will develop at Corballis and Ballymastone with the established community in Donabate and the integration of social and community facilities in both the developing and established areas to provide people with the services / facilities they need close to their homes to encourage lifetime residency and vibrant communities and places.

• Promotion of the area’s tourism resources in a sustainable and environmentally sensitive manner.

• Ensure the timely delivery of social, community and physical infrastructure and amenities in tandem with the phased development and residential growth of the area.’

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Fingal is also committed to developing sustainable building requirements to promote a shift to energy efficient, low environmental impact buildings. Good design is the key to achieving the optimum energy performance of buildings at no extra cost. The Planning Authority will promote a consistently high Building Energy Rating (BER) for all new developments and the standards applied to the LAP lands will be consistent with the standards outlined in the Draft Fingal Development Plan 2017-2023 and any subsequent Government Guidance / Building Control Regulations.

The Planning Authority seeks to ensure that all development in the LAP lands will contribute positively towards a reduction in energy consumption and the associated carbon footprint.

The Draft LAP includes the following objective:

‘Objective 1.2 Incorporate environmentally sustainable design principles in the design and construction of all buildings in the plan area. New buildings shall strive to reduce the energy and water demand through: • Careful consideration of building orientation, form, massing and fenestration to make the most of passive solar gain for space heating. • Use of insulation to reduce heat loss from draughts and uncontrolled ventilation. • Reduced water use through rainwater harvesting and recycling of rainwater. • Use of materials with low embodied energy and consider incorporating environmentally ‘smart’ materials that can minimise energy use by responding to changing external conditions. ‘

The submission received from the Department of Education and Skills notes that they are at the forefront of design with respect to sustainable energy efficiency in school buildings and that the Department’s Technical Guidance Documents sets the benchmark for sustainable design in school buildings, with a clear focus on energy efficiency. Schools that are designed and built in accordance with the Department’s technical guidance documents must achieve an A3 Building Energy Rating. New school design within the LAP lands will be required to conform to this standard.

The submission from the Department of Education and Skills also requests that all educational buildings be specifically excluded from the requirement to use Green Roof Technology (in the interests of teaching and learning and in the interest of not reducing the viability of rain water harvesting and not imposing unnecessary maintenance and operational costs on schools). This is acceptable to the Council and any future school development will be referred to the Department for advice in terms of latest technology and school design guidance.

It is considered that sustainability is an underlying theme throughout the LAP and that there are a number of relevant policies and objectives included to promote sustainable design principles in the design and development of the new LAP areas.

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Recommendation No change.

10.0 MISCELLANEOUS 10.1 St Ita’s Development A number of submissions received referred to the St Ita’s Development and the impact on the Peninsula in terms of traffic and construction issues. One submission also suggested a community use for St Ita’s Historic Walled Garden and requested that its restoration be included within LAP.

Response A number of submissions referred to the permitted development at St Ita’s Hospital. Planning permission was granted by An Bord Pleanala for the proposed 170 bed National Forensic Mental Health Services Hospital (Order No. PL06F. PA0037), subject to 14 no. conditions. The HSE was formally required to lodge compliance submissions for agreement with the Council in writing prior to the commencement of development. The process of compliance approval is nearing completion covering such matters such as the Mobility Management Plan (condition no. 4), Construction Traffic Management Plan (condition no. 12) and the Construction Stage Environmental Management Plan (condition no. 13) to address the specific traffic related issues. Furthermore, a schedule of remedial works which include footpath widening and improvements to the R126 on the west side of the railway bridge is planned, the HSE is required to contribute to the cost of these works.

In response to the submissions suggesting a community use for St Ita’s Historic Walled Garden, it is noted that the HSE propose to carry out essential maintenance works to the walled garden as stated in Section 5 of the Conservation Walled Garden Report, February 2015 which formed part of the approved NFMHs Hospital Development. The longer term aim of the HSE as stated in this report is to bring the walled gardens back into use as a therapeutic garden serving the NFMHS. Providing for community use would not be appropriate in the context of the overall site’s primary function as a mental healthcare facility.

Submissions received queried the timeline for construction and commencement of construction for the NFMHS Hospital. The advanced works contact for the NFMHSH has commenced. The main construction contract is expected to commence later this year. Development is expected to be completed in 2018.

Recommendation No change.

10.2 Culture & Heritage Language Heritage – a number of submissions highlighted the importance of the Irish language and noted that the naming of new schemes should reflect local history, folklore and / or place names in the Irish language. It is submitted that Fingal should promote use of Irish language on shopfronts, etc 74

Submissions noted that a marine slipway for recreational use is required and another submission requested the restoration of a red brick beach shelter in Balcarrick.

Other submissions noted the need to protect the stone buildings adjacent to Smyths Pub and to protect the old Milestone on the R126 near Donabate Square as part of this LAP.

The protection and enhancement of the settings of St Catherine’s Castle and Bob’s Castle in Portrane and the promotion and restoration of the Martello Tower at Donabate is highlighted in other submissions received.

The re-instatement of the water pump at the lands opposite the entrance to Donabate Grave Yard and the provision of a bench at this location was noted in another submission.

Response Irish Language The Council is committed to developing a more socially inclusive society and promoting participation and access for all. Under Section 11 and 15 of the Official Languages Act 2003, The Minister for Arts, Heritage & the Gaeltacht has confirmed the 2nd Irish Language Scheme (which commenced in February 2015, and it shall remain in force for a period of 3 years), the primary objective of which is to ensure better availability and a higher standard of public services through the Irish language. Fingal is committed to the promotion of Irish within the Council and to the assessment on an ongoing basis of the level of demand for services in Irish. The Council also has an Irish Language Officer.

The importance and promotion of the Irish Language is acknowledged and the Draft Fingal Development Plan 2017-2023 includes the following new text and objectives to be included within Chapter 10:

‘The use of the Irish language as part of everyday life is encouraged. Approximately 38% of the population of Fingal could speak Irish in 2011 (www.cso.ie). In this regard, the Council has an important role to play in the promotion of the language in the County. The Draft Development Plan can support and provide the land-use and spatial dimension to promote and protect the linguistic and cultural heritage of the area. The Council will continue to support initiatives at County level to strengthen bilingualism in the County.

Objective CH50 Highlight the profile of the Irish language in the urban and rural environment and support the Irish language by facilitating the provision of Irish language facilities.

Objective CH51 Ensure that the naming of mixed residential and mixed use schemes reflect local history, folklore and/or place names and are stated in the Irish language. 75

Objective CH52 Encourage the use and promotion of historical and current townland names in the urban and rural environment in both the Irish and English languages, with a view to supporting the provision of townlands place names markers/signage.

Objective CH53 Support the use of the Irish language on shopfronts.

Objective CH54 Promote Irish language and traditional culture and the cultural and language heritage of new Irish /migrant communities in Fingal and support events celebrating our cultural diversity. Objec55 Objective CH55 Promotion of our language and culture is essential to the development of our County. Fingal Development Plan 2017-2023 promotes the established Coiste Gaeilge Comhairle Fhine Gall, a Fingal County Irish Language Committee, which promotes the use of the Irish language, the development of Seachtain na Gaeilge and encourages the use of Gaeilge on shop fronts.

To reflect the inclusion of the above Objectives within the Draft Fingal Development Plan 2017-2023 and to strengthen and promote Fingal’s support of the Irish Language, it is recommended that additional text and objectives are inserted into the Draft LAP.

Conservation St Catherine’s Castle, Bob’s Castle and Martello Tower at Donabate Beach The submissions relating to the protection and enhancement of St Catherine’s Castle, Bob’s Castle and the Martello Tower are noted and welcomed. The Draft Fingal Development Plan 2017 proposes the inclusion of a number of new objectives relating to these Protected Structures, including:

New objective for Donabate in Chapter 4 of the Draft Plan, to read as follows:

‘OBJECTIVE Donabate 18 Promote the restoration of the Martello Tower at Donabate Beach.

‘OBJECTIVE Portrane 8 Protect and enhance the setting of: (a) Stella’s Tower(Bobs Castle) and examine the feasibility of developing it as a local community, tourism and cultural heritage amenity; (b) St. Catherine’s Church.’

As these protected structures are located outside of the LAP boundary for Donabate, it is not considered necessary to repeat the above objectives, as they are already included within the Draft Fingal Development Plan 2017-2023.

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Old Stone Buildings – Adjacent to Smyths Pub The character of the old stone buildings adjacent to Smyth’s Pub is acknowledged by the Council. Smyth’s Pub is included on Fingal’s Record of Protected Structures (RPS No. 509) and is described as: ‘House, Barns & Out-offices’. These old stone buildings are thus included within this complex of protected structures at this location. The Council will therefore consider any development proposals for these buildings in the context of their inclusion within the RPS.

Old Milestone on the R126 It is not considered necessary to include the protection of old Milestone on the R126 near Donabate Square as part of this LAP. This milestone is not currently included within the Record of Protected Structures. However, the conservation department have included this structure in a review of additions to Fingal’s Record of Protected Structures.

Water Pump opposite the Graveyard The submission to re-instate the water pump at the lands opposite the entrance to Donabate graveyard and provide a bench at this location is noted. There are no current proposals to re-instate a water pump at this location. The Donabate Urban Centre Strategy (June 2010) addresses a number of issues which are of importance to the town centre and public realm including seating, planting, etc. Furthermore, Donabate Urban Framework Plan, when complete, will provide further details in relation to pedestrian safety, public realm, streetscape, etc.

Marine Slipway and Beach Shelter at Balcarrick The protection of a beach shelter at Balcarrick and the provision of a marine slipway to access the water for recreational use is noted in submissions received. As the LAP boundaries do not include the coastline, it would not be possible identify a specific site along the Estuary for a slipway. Furthermore, it is considered that these matters will be addressed as part of a wider study of the Fingal coastline to identify potential sites to accommodate marina development, including ancillary development such as slipways. Objective ED72 of the Draft Fingal Development Plan 2017 -2023 addresses this issue:

‘Objective ED78 Undertake a feasibility study of the Fingal coastline to identify potential sites to accommodate marina development relevant to recreational pursuits and requirements. As part of the study the impact on the receiving marine environment, including the coastline, will be assessed and Screening for Appropriate Assessment undertaken.’

Section 10.6 of this report ‘Public Realm Strategy’ also refers.

Recommendation Insert the following text to the written statement at the end of Section 8.0 (following Section 8.3.8):

8.3.9 Irish Language

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The use of the Irish language as part of everyday life is encouraged. Approximately 38% of the population of Fingal could speak Irish in 2011 (www.cso.ie). In this regard, the Council has an important role to play in the promotion of the language in the County. This LAP can support and provide the land-use and spatial dimension to promote and protect the linguistic and cultural heritage of the area. It is an objective of this LAP to ensure that the naming of new residential and mixed use schemes reflect local history, folklore and/or place names and are stated in the Irish language, where appropriate.

Insert new Objective 8.16 in Section 8 to reflect Fingal’s promotion and support of the Irish Language and to ensure consistency with new policies and objectives inserted into the Draft Fingal Development Plan 2017-2023.

Objective 8.16 Ensure that the naming of new residential and mixed use schemes reflect local history, folklore and/or place names and are stated in the Irish language, where appropriate.

10.3 Public Consultation Submissions received note the lack of public participation and lack of meaningful consultation with the community. It is submitted that Fingal did not carry out proper public consultation and that holding two mid-week evenings of public consultation was not sufficient.

It is also submitted that joined up thinking is needed within Council Departments

Response The legislative framework and planning context for the preparation of this LAP is outlined in Section 1.2 of the Draft LAP.

The public consultation process was conducted in accordance with the Planning and Development Act, 2000 (as amended). The level of public consultation in the LAP preparation process has been comprehensive and inclusive. Every effort was made to ensure that all members of the public and stakeholders had an opportunity to have their say in an open, accessible and transparent way. The LAP is therefore consistent with the Planning and Development Acts and the ‘Local Area Plan - Guidelines for Planning Authorities 2013’.

The planning legislation sets out the broad requirements for consultation, which include consultation with prescribed bodies, key stakeholders, including local residents, public sector agencies, non-governmental agencies, local community groups and commercial and business interests. The Donabate LAP process is also consistent with the statutory period for public display of the Draft LAP and receipt and consideration of observations and submissions.

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Statutory Local Area Plans provide for proper consultation with the public and statutory consultees, and are subject to approval by elected members. There are two key phases in the process of making a local area plan:

• A non-statutory • background data gathering process, where data and information (evidence) essential to preparing the local area plan is assembled including information on population, employment, economic development, physical and social infrastructure, heritage, flood risk assessment etc.; and

• The • statutory process – as set out in the legislation with its various elements of statutory notices, issues papers, draft, amended draft and final documents.

In 2011, Fingal published a Strategic Issues Paper entitled ‘Having Your Say’. This Paper was published to assist the public in making a submission and invited the local community and various stakeholders to submit their views regarding the shaping of the future development of Donabate (18 no. submissions were received). The making of the LAP was postponed at this time to give further opportunity to better understand and reflect on-going changes in terms of the country’s economy and in particular the construction sector.

The preparation of the Draft LAP re-commenced in 2013 and the Planning Department held an Information Evening / Workshop for the local community and interested stakeholders on Tuesday 10th December 2013 in Donabate Community College. Public notices were placed in local newspapers and in strategic locations within the village. Notification regarding the consultation period was also placed in the Donabate-Portrane Community Council newsletter, which was distributed to all households on the Peninsula. The Planning Department also contacted those parties (local community and statutory consultees) who had previously made submissions in 2011.

This Information Evening / Workshop was well attended and 30 no. submissions were received.

The consultation phase of the Fingal Development Plan 2017-2023 commenced in March 2015 with public submissions received on a range of strategic issues. Several submissions were received in relation to Donabate which re-emphasised many of the important issues raised at the earlier LAP information evenings.

The Draft LAP was on public display from 1st December 2015 to 21st January 2016, and was available to view online (www.fingal.ie); in the Council offices in both Swords and Blanchardstown and it was also on display locally in the Donabatre-Portrane Community Library. There were 65 no. submissions received within this statutory timeframe. During this public display period a further 2 no. Public Consultation events were held in Donabate-Portrane Community Library (on the afternoon of 16th December 2015 and the evening of Wednesday 6th January 2016).

Statutory Consultees who have been contacted at various stages in the LAP process include: the Department of Education and Skills; Infrastructure providers such as the relevant infrastructure sections of Fingal County Council and, as appropriate, the NTA, 79

TII, CIE, Irish Water; Utility providers such as Eircom, Eirgrid / ESB Networks, An Bord Gais; the Department of Environment, Community and Local Government, the National Parks and Wildlife Service of the Department of Arts, Heritage and the Gaeltacht in relation to AA, the EPA in relation to SEA, the OPW in relation to flood and flood risk- related matters, and a wide range of other bodies and groups.

The Council recognises the importance of ‘joined-up’ thinking, cooperation and planning between different Council Departments and this LAP was prepared in close consultation with a number of Council sections including Strategic Infrastructure (Water Services and Roads), Operations, Heritage, Housing and the Biodiversity Officer. Furthermore, the Planning Department engages with other internal departments across a range of issues on an on-going basis.

It is considered that the Council has engaged in extensive public consultation with local residents, community groups, stakeholders and prescribed bodies over the past few years in the preparation of the Draft LAP for Donabate.

Recommendation No change.

10.4 LAP Boundary Some submissions received noted that the LAP excludes Portrane and other areas outside of LAP boundaries. The exclusion of residential housing developments along the Portrane Road was noted and these should be included as part of LAP and included in future housing totals. There is an over-emphasis in the Plan on Donabate, to the detriment of Portrane.

Response This Local Area Plan sets out the optimal development strategy for the proper planning and sustainable development of the undeveloped residentially zoned lands at Donabate. The boundaries of the LAP lands remain unchanged from those outlined in the previous LAP in 2006 and these boundaries are defined by the Development Plan process and subsequent zoning of lands. The LAP lands are zoned Objective ‘RA’, which seeks to ‘Provide for new residential communities in accordance with approved local area plans and subject to the provision of the necessary social and physical infrastructure’ in the FDP 2011-2017. These LAP lands were also zoned for new residential development under the FDP 2005-2011. The current vision for this zoning objective is to ‘Ensure the provision of high quality new residential environments with good layout and design, with adequate public transport and cycle links and within walking distance of community facilities. Provide an appropriate mix of house sizes, types and tenures in order to meet household needs and to promote balanced communities.’

It is acknowledged that Donabate and Portrane share many local amenities and facilities including schools, library, sports clubs, community centre, etc. However, it is an objective of the LAP and the Draft Fingal Development Plan 2017-2023 to maintain a strong visual and physical separation between these two settlements. Donabate is categorised as a Moderate Sustainable Growth Town, whereas Portrane is identified as a

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small village. The policies and objectives for each would therefore differ and they are best dealt with under separate, more focussed strategic planning documents. Urban Framework Plans are scheduled to be prepared for both Portrane and Donabate.

The proposed Urban Framework Plan for the centre of Portrane village will include the undeveloped residential zoned land to the south of Portrane village to guide and inform future development, whilst providing for the protection of the visual amenities and special character of the area located within an ACA at St. Ita’s hospital, the St. Ita’s Hospital and Portrane Demense ACA and adjoining another ACA at Grey Square.

The Planning Authority is not in a position to amend the boundaries of the LAP as these are dictated by the zoning of the lands, as adopted in the Fingal Development Plans.

Recommendation No change.

10.5 Donabate Urban Framework Plan Urban Framework Plan to be completed for Donabate within one year of adoption of LAP. Public realm strategy and traffic management strategy also required.

Response It is an objective of the Draft Fingal Devleopment Plan 2017-2023 to prepare an Urban Framework Plan for Donabate, which is supported by the inclusion of the objective below:

‘Objective DONABATE 9 Prepare an Urban Framework Plan for Donabate (including a Public Realm and Integrated Traffic Management Strategy) to guide and inform future development, to include measures to improve and promote the public realm of the Village.’

The scope and extent of an Urban Framework Plan is not defined, but they are intended to be advisory plans with a long term vision for the future, which allows sufficient flexibility to manage change in changing circumstances of society, economy, environment and culture. Urban Framework Plans will provide a vision for the area, within the structure of the Fingal Development Plan 2017-2023. Among the topics that these frameworks will examine is a vision for each centre, the identification of areas where there is potential for change, development opportunities, provision for improved access to public transport, a framework for urban design, and the integration of natural heritage and biodiversity where appropriate.

In this regard, there is no requirement to specify the need for Public Realm Strategy or Integrated Traffic Management Strategies as it is implicit that these be included in any Urban Framework Plan where it was considered that they would be of benefit.

The Introduction of a one-year time limit for the preparation of the plan is not considered appropriate as it would set an undesirable precedent in the context of the 81

plans and studies the Council has committed to prepare across the County over the lifetime of the Development Plan.

Recommendation To accord with the policies and objectives contained within the Draft Fingal Development Plan 2017, it is considered appropriate to insert a new objective to Section 6 of the Draft LAP, making reference to the Urban Framework Plan for Donabate, to read as follows:

‘Objective 6.16 Prepare an Urban Framework Plan for Donabate (including a Public Realm and Integrated Traffic Management Strategy) to guide and inform future development, to include measures to improve and promote the public realm of the Village.’

10.6 Public Realm Strategy A number of submissions referred to the need for a public realm strategy for Donabate Beach and for Portrane Beach and Tower Bay. Provide car parking at Donabate beach.

Response The areas referred to above are not included within the identified LAP zoned lands. A Public Realm Strategy is a guidance document which will focus on a defined area, usually a town or village centre, and will comprise many of the elements which make an area an attractive place in which to live, work and visit. Public Realm Strategies have been prepared for Balbriggan and Malahide to date. Further Public Realm Strategies will be developed for different areas throughout the County.

It is considered that issues relating to the beaches at Donabate, including public access and facilities, parking, etc, are adequately covered under policies and objectives included within the Draft Fingal Development Plan 2017-2023, including:

‘Objective NH63 Encourage the development of facilities for maritime fishing and leisure developments where the siting of such installations and their supporting infrastructure will not have a significant adverse impact on the natural or cultural heritage or detract from the visual amenity and environmental quality and stability of an area, or public access to beaches.

Objective NH64 Protect beaches, access to beaches and designated bathing areas as valuable local amenities and as a tourism resource.’

It is considered that Objectives NH61 and NH62 above provide for the protection of all beaches, designated areas, access to beaches and bathing areas, and bathing waters as valuable local amenities and as a tourism resource. In addition several objectives in the Natural Heritage Chapter address the protection of biodiversity and coastal dune

82 systems. It is not therefore considered necessary or appropriate to include a specific objective in relation to these beaches within the Draft LAP.

Recommendation No change.

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