Executive Summary

 This submission is made by Downey Planning, on behalf of Ian McGuinness and other landowners, and is submitted to Fingal County Council in the context of the Pre-Draft Fingal Development Plan 2017-2023, currently on public display;

 It is understood that Fingal County Council only consider strategic, ‘bigger-picture’ submissions at this stage. Thus, this submission focuses on the settlement strategy of the County with particular emphasis placed on the future development of Lusk town;

 Fingal County Council recognise the need for additional housing within the County, with an estimated 41,000 new housing units required within the lifetime of the new Development Plan to coincide with the County’s growing population;

 This submission draws particular attention to the principles of sustainable development and the importance of creating residential communities within close proximity of existing public transportation nodes, and as such demonstrates how the town of Lusk represents an ideal location in this regard;

 The most logical form of development for Lusk town is the expansion of the town’s development boundary in an easterly direction towards Lusk Railway Station as opposed to M1 motorway located to the west;

 Any strategic development proposal will not result in the merging of Lusk and Rush as the existing railway line acts as the natural boundary of both settlements. Lusk is located within 1km of the railway line, whilst Rush is located some 3.5km from this public transport infrastructure.

This planning submission is made in response to the statutory review of the Fingal County Development Plan. Stage 1, known as the ‘Pre-Draft’ stage, requires submissions to be of a strategic nature or what the Chief Executives have detailed (Pg.2) ‘the consideration of the “big picture” issues’. Accordingly, this submission has been prepared in the context of ‘Strategic Planning Issues’ which are detailed throughout this submissions to highlight some cross cutting themes that should be examined at the initial stage of the formulation of this important document which will steer development within Fingal until 2023. Whilst there might be mention of specific areas or locations, we wish to note that the submission contained herein is of a strategic content and is not site specific at this stage. We would therefore respectfully request that Fingal County Council consider the strategic content within this planning submission. Downey Planning would like to thank the Council for the opportunity to make this submission, on behalf of our clients whom are strategic landowners, business operators and residents of the Fingal area.

© Downey Planning 2015

Rush

c.3.5km Rush to Train Station

Train Station c.1km Lusk to Train Station

Lusk

Submission to Pre Draft Fingal Development Plan 2017-2023 Lands at Lusk on behalf of Ian Mc Guinness & other landowners

Table of Contents

Executive Summary...... 1 1.0 Introduction ...... 3 2.0 Planning Legislation ...... 3 3.0 Fingal Development Plan 2017-2023 Pre-Draft Consultation Booklet ...... 4 4.0 Planning Submission ...... 4 4.1 Planning Context ...... 4 4.1.1 National Spatial Strategy ...... 4 4.1.2 Regional Planning Guidelines for the Greater Dublin Area 2010-2022...... 5 4.1.3 Fingal Development Plan 2011-2017 ...... 5 4.1.4 Lusk Local Area Plan ...... 5 4.2 Future Development of Lusk ...... 5 5.0 Conclusion ...... 6

Downey Planning Document Control Name Date Version Prepared by Eva Bridgeman MIPI 06 May 2015 V_01_DRAFT Senior Planner Prepared by Eva Bridgeman MIPI 13 May 2015 V_02_DRAFT Senior Planner Approved by John Downey MIPI MRTPI 14 May 2015 V_03_FINAL Director

1.0 Introduction (3) (a) As soon as may be after giving notice under this section of its intention to review a development plan and to prepare a new development plan, a planning authority shall take whatever additional measures it In accordance with Section 9, 10, 11 and 12 of the Planning and Development Act 2000 (as amended), Downey considers necessary to consult with the general public and other interested bodies. Planning, Chartered Town Planners, 1 Westland Square, Pearse Street, Dublin 2, wish to make this submission on the “Pre-Draft Fingal County Development Plan 2017-2023” to Fingal County Council on behalf of Ian McGuinness (b) Without prejudice to the generality of paragraph (a), a planning authority shall hold public meetings and other landowners, C/O Ian McGuinness, Ravensgate, Balheary Avenue, Swords, Co. Dublin. This written and seek written submissions regarding all or any aspect of the proposed development plan and may invite submission is being made in response to an invitation for comments from interested parties by Fingal County oral submissions to be made to the planning authority regarding the plan. Council, and is submitted within the specified timeframe for submissions (15th May 2015) as detailed within the (c) In addition to paragraphs (a) and (b), a planning authority shall take whatever measures it considers Consultation Booklet prepared by the Planning Authority. necessary to consult with the providers of energy, telecommunications, transport and any other relevant This submission specifically relates to the County’s Settlement Strategy, and demonstrates the importance of infrastructure and of education, health, policing and other services in order to ascertain any long-term providing future housing development along public transportation nodes such as Lusk. The requirement for plans for the provision of the infrastructure and services in the area of the planning authority and the housing units to coincide with the projected population increase of Fingal must be recognised and addressed, and providers shall furnish the necessary information to the planning authority. as such the future development of Lusk towards the railway line as opposed to the M1 motorway and R132 Road, (4) (a) Not later than 16 weeks after giving notice under subsection (1), the manager of a planning authority represents a proposal which is underpinned by the principles of sustainable development. shall prepare a report on any submissions or observations received under subsection (2) or (3) and the 2.0 Planning Legislation matters arising out of any consultations under subsection (3).

Section 9 of the Planning and Development Act 2000 (as amended) provides that, subject to the requirements set (b) A report under paragraph (a) shall— out in Section 9, 10 and 11 of the Act, that a planning authority must adopt a new Development Plan every six (i) list the persons or bodies who made submissions or observations under this section as well as any years. The contents of the Development Plan are set out within Section 10 of the Planning and Development Act persons or bodies consulted by the authority, 2000 (as amended) and must include a strategy for the proper planning and sustainable development of the area of the Development Plan and shall consist of a written statement and a plan or plans indicating the development (ii) summarise the issues raised in the submissions and during the consultations, where appropriate, objectives for the area in question. The process for the preparation of the draft Development Plan is contained (iii) give the opinion of the manager to the issues raised, taking account of the proper planning and within Section 11 of the Planning and Development Act 2000 (as amended) which states: sustainable development of the area, the statutory obligations of any local authority in the area, and “11.—(1) Not later than 4 years after the making of a development plan, a planning authority shall give any relevant policies or objectives for the time being of the Government or of any Minister of the notice of its intention to review its existing development plan and to prepare a new development plan for Government, and (iv) state the manager’s recommendations on the policies to be included in the draft its area. development plan.

(2) A notice under subsection (1) shall be given to the Minister, any prescribed authorities, any adjoining (c) A report under paragraph (a) shall be submitted to the members of the planning authority, or to a planning authorities, the Board, any relevant regional authority and any town commissioners and city and committee of the planning authority, as may be decided by the members of the authority, for their county development boards within the functional area of the authority and shall be published in one or consideration. more newspapers circulating in the area to which the development plan relates and shall— (d) Following the consideration of a report under paragraph (c), the members of the planning authority or (a) state that the planning authority intends to review the existing development plan and to prepare a new of the committee, as the case may be, may issue directions to the manager regarding the preparation of development plan, the draft development plan, and any such directions must take account of the statutory obligations of any local authority in the area and any relevant policies or objectives for the time being of the Government or (b) indicate that submissions or observations regarding the review of the existing plan and the preparation of any Minister of the Government, and the manager shall comply with any such directions. of a new development plan may be made in writing to the planning authority within a specified period (which shall not be less than 8 weeks), (e) Directions under paragraph (d) shall be issued not later than 10 weeks after the submission of a report in accordance with paragraph (c). (c) indicate the time during which and the place or places where any background papers or draft proposals (if any) regarding the review of the existing plan and the preparation of the new development plan may (f) In issuing directions under paragraph (d), the members shall be restricted to considering the proper be inspected. planning and sustainable development of the area to which the development plan relates.

(5) (a) The manager shall, not later than 12 weeks following the receipt of any directions under subsection architectural heritage are key areas of this resource to be strengthened within the forthcoming (4)(d), prepare a draft development plan and submit it to the members of the planning authority for their Development Plan. consideration. 6. Natural Heritage – The Development Plan coincides with the Fingal Diversity Plan which seeks to protect (b) The members of a planning authority shall, as soon as may be, consider the draft development plan the natural heritage of Fingal through the development of the Final Ecological network which sets out a submitted by the manager in accordance with paragraph (a). spatial framework for nature conservation and management. Management of the natural heritage of Fingal will be an integral element of the Fingal Development Plan 2017-2023. (c) Where the draft development plan has been considered in accordance with paragraph (b), it shall be

deemed to be the draft development plan, unless, within 8 weeks of the submission of the draft 7. Cultural Heritage – Cultural Heritage encompasses monuments, history, folklore and traditions that give development plan under paragraph (a), the planning authority, by resolution, amends that draft a sense of identity and place. The Development Plan seeks to protect structures of historical or cultural development plan. significance in accordance with the requirements of the Planning and Development Act 2000 (as This submission to the pre-draft of the Development Plan is being made in accordance with Section 11 (2)(b) and amended). Policies for their protection will form a key element of the Development Plan. 3(b) of the Planning and Development Act 2000 (as amended) and is being submitted within the specified timeframe (15th May 2015) as set out in the Fingal Development Plan 2017-2023 Consultation Booklet. 8. Impacts on the Environment – Strategic Environmental Assessment, Appropriate Assessment and Flood Risk Assessments must be carried out which in turn will inform the policies of the Development Plan. 3.0 Fingal Development Plan 2017-2023 Pre-Draft Consultation Booklet This submission relates to the County’s Settlement Strategy; Placemaking and Communities; and Infrastructure Fingal County Council have published a Pre-Draft Consultation Booklet in relation to the Fingal County and Movement. It is recognised that over the next six years, Fingal expect to accommodate an additional 41,000 Development Plan 2017-2023. Noting that the Development Plan sets out the key policies and objectives for the housing units. This submission draws particular attention to the principles of sustainable development and the entire lands within the functional area of Fingal County Council, the purpose of this booklet is to outline the key importance of creating residential communities within close proximity of existing public transportation nodes. The themes/issues to be investigated at this stage in the preparation of the Development Plan. The booklet sets out 8 town of Lusk represents an ideal location for the adoption of such principles. The future development of Lusk key themes as follows: should be encouraged towards the railway station, located to the east of the town, as opposed to the M1 motorway to the west (which would promote dependency on car based travel). 1. Settlement Strategy – Over the Plan period, Fingal expect to accommodate an additional 41,000 new housing units. How this housing target is to be met will be a key consideration for the new Development 4.0 Planning Submission Plan. Providing an appropriate scale and type of housing development which respects and enhances the character of the urban and rural areas will be a key challenge. 4.1 Planning Context 4.1.1 National Spatial Strategy

2. Placemaking & Communities – The Development Plan contains policies and objectives which ultimately The National Spatial Strategy (NSS) is a twenty year national planning influence the sense of place, identity and character of areas. Good quality public realm and the design of framework designed to achieve a better balance of social, economic, open spaces can respect and enhance the character and distinctiveness of an area. The type of facilities physical development and population growth between the regions. provided, their location, building heights etc. all contribute to creating attractive neighbourhoods, towns and villages and are a key consideration in the long term development of Fingal. It is designed to improve the effectiveness of public investment in infrastructure and other relevant services around the country resulting in 3. Infrastructure & Movement – Integration between land use and transport is a key consideration in an improved quality of life, a strong competitive economic position and choosing where to live or locate a business. Promoting walking, cycling and public transport in conjunction high quality environments. with good road infrastructure are key considerations within any Development Plan. The NSS identifies Gateways and Hubs and recognises many other country and larger towns as playing a critical 4. Economic Development – Fostering employment opportunities within the functional area of Fingal is role in the spatial structure of Ireland in order to realise balanced regional growth. The NSS recognises the pivotal essential. Employment opportunities must be provided to coincide with the projected population increase role of the Greater Dublin Area (GDA) to the overall economic well-being of Ireland and seeks to build upon the associated with the 41,000 new households anticipated within the lifetime of the plan and to counteract performance of the GDA and to consolidate Dublin in its physical area. Sustainable development is at the heart of the proportion of residents travelling out of Fingal to work. the National Spatial Strategy.

5. Green Infrastructure – Fingal’s natural capital including parks, wildlife, coastlines etc. is a resource and a form of infrastructure that requires policies for its protection, creation and management. Biodiversity,

parks, open space and recreation, landscape, sustainable water management and archaeological and

4.1.2 Regional Planning Guidelines for the Greater Dublin Area 2010-2022 4.1.4 Lusk Local Area Plan

The Regional Planning Guidelines for the Greater Dublin Area 2010-2022 aim to direct The Lusk Local Area Plan (LAP) which was published in 2009 recognises the the future growth of the Greater Dublin Area over the medium to long term. The RPGs unprecedented growth that Lusk has experienced in recent years, with a population inform and direct the City and County Development Plans of each of the Councils in the increase of 113% for the inter-censal period 2002 to 2006. Greater Dublin Area. They provide a policy link between national policies and guidance This was the highest increase of any town in the entire country. This growth was also and Local Authority planning policies and decisions. The RPGs aid each of the Councils in the Greater Dublin Area in working together for the better planning of the whole area reflected in the housing stock with an increase of 175% over the same period. It was of Dublin and the surrounding Mid-East Region. noted that the majority of newcomers to the town were young commuters.

Lusk is located within the Hinterland Area and is identified as a Moderate Sustainable Since the adoption of the LAP, Lusk has seen a continuous increase in its population, evidenced by the increase from 5,236 in 2006 to 7,022 in 2011 (a 34.1% increase). This increase in population is being driven by Lusk’s Growth Town under the Regional Planning Guidelines 2010-2022. For the hinterland areas, each Council should aim for the majority of new housing provided for through proximity to Dublin City and the high quality transport links that are within its vicinity, including the M1 motorway zoning and policies to be directed towards the Growth Towns, particularly towards towns with rail based public and, more importantly, Lusk Railway Station, which provides a commuter rail service to and from Dublin city centre. transport. Lusk is such a town. However, the LAP recognises that the links between the railway station and Lusk are inadequate with no The RPGs recommend focusing the expansion of housing development, employment and associated lands in close proximity to key high capacity planned or existing public transport. It is essential that critical mass is built up in designated cycle lane at present, and states that “the station is a crucial element in contributing to a sustainable suitable locations to support the capacity requirements that make particular public transport investments feasible, form of residential development, which promotes public transport”. Thus, there is an urgent need to improve links to and from the station. sustainable and cost effective. 4.2 Future Development of Lusk The delivery of housing needs to follow sustainable models by avoiding low density car based development forms and be focussed on medium densities which will support and be integrated with a range of community facilities It is anticipated that as the economy of Dublin continues to grow, further demand and pressure for housing in the within accessible walking distances. Where lands are close to public transport nodes/stations or QBC corridors the Dublin suburbs and commuter towns such as Lusk will occur. The most sustainable form of development is to density and connectivity of developments should directly support increased population being able to benefit from integrate planning and land use to ensure that future residential developments, with associated local amenities good transport links. and services, are located within walking/cycling distance of high quality public transport corridors such as railway 4.1.3 Fingal Development Plan 2011-2017 stations and other key services.

The Fingal County Development Plan 2011-2017 recognises Lusk as a Moderate In order to achieve this, the natural and logical form of development for Lusk is to expand in an easterly direction Sustainable Growth Town in the Hinterland Area as per the Regional Planning towards the railway station. This will help to create sustainable communities that are pedestrian and people Guidelines 2010-2022. The Plan also acknowledges the village’s rapid growth to orientated and not dominated by and designed primarily for the private car. town status which has occurred within the last 10 years. Notwithstanding this, the Lusk LAP also recognises the current shortfall of business/employment opportunities Fingal County Council’s development strategy for the town is to consolidate the within the area and as such promotes the provision of employment zoned lands to alleviate the need to commute planned growth of Lusk and ensure that a sufficient quantum of retail and local for work. The landbank in close proximity to the railway station also represents an appropriate location to provide long-term employment opportunities for the local population. However, this landbank to the east is zoned ‘RU – services are located within the town core to serve the growing population. It is felt Rural’, part of which is in the ownership of our clients (Refer to Fig. 1). The objective for such zoned lands is as that this will assist in the prevention of unsustainable commuting patterns. follows: The distinct physical separation of Lusk and Rush as separate towns is a fundamental principle of the Council’s development strategy. It is also an objective of the Council “protect and promote in a balanced way, the development of agriculture and rural-related enterprise, biodiversity, the rural landscape, and the built and cultural heritage”. to implement the adopted Lusk Local Area Plan. Downey Planning are of the professional opinion that this is an underutilisation of strategically located lands given The Development Plan has numerous objectives regarding transportation and new development. Objectives which the Council will seek to support include the provision of high density and mixed use development along public their short walking distance from Lusk Railway Station, a high quality, public transportation node. It must also be transport corridors where public transport capacity and accessibility exists; and promotion of sustainable noted that such lands are served by existing foul sewer, water supply, etc. and have accessibility to service utilities. development of walking, cycling, and public transport as an alternative to the private car.

confirmed that Irish Rail are assessing the electrification of the line as far north as Drogheda, with the project being assessed in terms of the company’s future capital investment. The Minister for Transport, Tourism and Sport, Deputy Paschal Donohoe, has also stated that subject to funding availability, some projects which are part of the overall DART Underground Programme, and which have capacity benefits in and of themselves, may proceed over the next number of years. One such project would be the extension of the DART network from Malahide to Balbriggan.

On this basis, Downey Planning respectfully request that when preparing the Draft Fingal Development Plan 2017- 2023, the Council consider these lands at Lusk and their contribution to the overall achievement of the County’s settlement strategy i.e. the provision for an additional 41,000 housing units for the County’s growing population. Downey Planning and our clients, Ian McGuinness and other landowners, would be happy to discuss the planning rationale for this important area with Fingal County Council’s Development Plan team in due course.

Fig. 1 – Fingal Development Plan Zoning Map

It is also noted that the Housing Department of Fingal County Council has recently applied for planning permission for a subsequent phase of residential development within close proximity of this possible development expansion zone. Enabling future connectivity towards the railway station would enable pedestrian permeability resulting in shorter walking distances to this vital public transport node. This would promote the principles of sustainable development through the creation of pedestrian friendly development which encourages a modal shift away from the private car and instead, the utilisation of a valuable resource, the railway station.

This approach is a more sustainable form of development for Lusk as it focuses development around public transportation nodes and hubs, such as railway stations, rather than in a linear pattern along roads. The railway line could act as the long-term development boundary for Lusk, thus ensuring that the distinct physical separation Fig. 2 – Possible Development Expansion Zone and Pedestrian Connections from Lusk to Railway Station between Lusk and Rush is maintained.

It is also important to note that the National Transport Authority recently 5.0 Conclusion published the “Integrated Implementation Plan 2013-2018” which states in Section 9.10 that the “electrification and re-signalling of the northern line  Fingal County Council recognise the need for additional housing within the County, with an estimated 41,000 between Malahide and Balbriggan, together with a turn-back facility at new housing units required within the lifetime of the new Development Plan; Balbriggan, would enable DART services to be extended northwards to Balbriggan. This is an integral project of the overall DART Underground  This submission draws particular attention to the principles of sustainable development and the importance programme”. of creating residential communities within close proximity of existing public transportation nodes, and as such demonstrates how the town of Lusk represents an ideal location for the adoption of such principles; Furthermore, announcements in late 2014, including at a meeting held by Fingal’s own transport committee, which Irish Rail officials attended,

 It is vitally important that new housing development, with associated local amenities and services, is provided in close proximity to existing public transportation nodes such as QBCs and Railway Stations. Along such nodes, medium to high density development should be encouraged;

 The most sustainable form of development for Lusk town is the expansion of the town’s development boundary in an easterly direction towards Lusk Railway Station. This will help to create sustainable communities that are pedestrian and people orientated and not dominated by and designed primarily for the private car;

 However, this potential development expansion zone is currently hampered by the fact that the lands to the east of Lusk are insufficiently zoned to provide for residential development with associated local amenities and services, and as such Downey Planning respectfully request that Fingal County Council reassess the future development of Lusk in the context of this planning submission.