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Manager’s Report Draft Dublin City Development Plan 2011 - 2017 Volume 2

May 2010 MANAGER’S REPORT Draft Dublin City Development Plan 2011-2017

Table of Contents

CHAPTER PAGE

PART 1 – INTRODUCTION 5 PART 2 - SUBMISSION BY MINISTER FOR THE ENVIRONMENT, HERITAGE & LOCAL GOVERNMENT & MANAGER’S RESPONSE AND RECOMMENDATIONS 11 PART 3 - SUMMARY OF SUBMISSIONS AND MANAGER’S RESPONSE AND RECOMMENDATIONS 17 1 BACKGROUND TO MAKING THE PLAN 19 2 CONTEXT FOR THE DEVELOPMENT PLAN 23 3 DEVELOPMENT PLAN STRATEGY TO 2017 27 4 SHAPING THE CITY 49 5 CONNECTING AND SUSTAINING THE CITY’S INFRASTRUCTURE 57 6 GREENING THE CITY 91 7 FOSTERING DUBLIN’S CHARACTER AND CULTURE 105 8 MAKING DUBLIN THE HEART OF THE REGION 133 9 REVITALISING THE CITY’S ECONOMY 137 10 STRENGTHENING THE CITY AS THE NATIONAL RETAIL DESTINATION 151 11 PROVIDING QUALITY HOMES IN A COMPACT CITY 161 12 CREATING GOOD NEIGHBOURHOODS AND SUCCESSFUL COMMUNITIES 171 13 IMPLEMENTATION 179 14 DEVELOPMENT MANAGEMENT 183 15 LAND USE ZONING (including Site Specific Zoning submissions) 189 16 GUIDING PRINCIPLES 341 17 DEVELOPMENT STANDARDS 347

APPENDIX PAGE

2. National, Regional and Local Strategies 381 3. The Housing Strategy 382 4. The Retail Strategy 383 5. Travel Plans 386 6. Transport Assessment 387 7. Strategic Cycle Network 388 8. Road Standards for Various Classes of Development 389 11. Proposed Architectural Conservation Areas (ACAs) 390 12. Stone Setts to Be Retained Restored or Introduced 392 13. Paved Areas and Streets with Granite Kerbing 393 14. Guidelines for Waste Storage Facilities 394 15. Flood Defence Infrastructure 395 16. Guidelines for Telecommunications Antennae 396 17. Seveso 2 Sites 397 19. Safety Design Guidelines 398 20. Access for All 399 21. Guidelines for Student Accommodation 400 22. Guidelines for Aparthotels 401 23. Guidelines for Residential Extensions 402 25. Outdoor Advertising Strategy 404 26. Sustainability Indicators 408 27. Land Use Definitions 409 Glossary of Terms and Phrases 411 Record of Protected Structures 413 Process Issues 419 Consultation Issues 421 Miscellaneous Issues 423 PART 4 - SUMMARY OF SUBMISSIONS IN RELATION TO DRAFT ENVIRONMENTAL REPORT AND APPROPRIATE ASSESSMENT AND MANAGER’S RESPONSE AND RECOMMENDATIONS 425 Strategic Environmental Assessment 427 Appropriate Assessment 467

Part 1:

Introduction

The Manager’s Report on the Submissions to the Draft Dublin City Development Plan 2011 – 2017.

Prepared in accordance with Section 12(4) of the Planning and Development Act 2000

This Report forms part of the statutory procedure for the preparation of a City Development Plan, as required by the Planning and Development Act, 2000, as amended.

The purpose of the Report is -

To report on the written submissions/observations received following the public display of the Draft Dublin City Development Plan 2011 – 2017,

To set out the Manager’s response to the issues raised in the submissions/observations,

To make recommendations on changes to the Draft Plan, as appropriate.

The Report is now submitted to the Members for their consideration in three volumes as follows;

I. A list of the persons or bodies who made submissions/observations (Volume One)

II. A summary of the issues raised by them, and the recommendation of the Manager to the issues raised (Volume Two)

III. Volume Three contains a set of the Draft Development Plan Maps indicating where submissions recommended changes to zonings.

The layout of this report is similar to the Draft Plan in that each topic is dealt with in identical chapter order for ease of reference. In instances where there are no submissions on a particular topic, the corresponding section does not appear in this report.

In the event of minor typographical errors or discrepancies, these will be amended in the Draft Plan accordingly. Similarly, where draft plans or policy documents, prepared by other bodies, have been up-dated or approved during the development plan preparation process, these will be amended accordingly in the final Development Plan.

Submissions 1,208 submissions were received during the public display period of the Draft Plan. The Council wishes to express its appreciation to those who made submissions, viewed the displays or attended the information meetings. The submissions are set out in Volume 1 in numerical and alphabetical order indicating the issues raised and the relevant Chapter No / Appendix in the Draft Plan and the Manager’s Report.

A CD-Rom has been prepared containing the full text of all the written submissions/observations received during the public display period of Draft Development Plan which has been included for the Members. A hard copy of each submission is available in the Planning Department.

Each submission was fully considered and has been summarised in the Manager’s Report. The wide ranges of issues raised have been grouped under each topic in chapter order.

On-line Consultation The Draft Development Plan and accompanying SEA / AA Documents were placed on a website specially designed for consultation on the Draft Plan, including a video installation on the role of a development plan and a summary of the proposed vision for the city along with the key priorities set out to achieve that vision. The website included a facility to make submissions on-line and 342 such submissions were received through website link. A further 265 were submitted by e-mail.

In addition, the internet-based discussion forum, Boards.ie, was used to host a number of discussion threads on topics featured in the Draft Plan and to stimulate debate in advance of the closing date for submissions. Generally, there was praise for using Boards.ie as a consultation mechanism. Dublin City Council initiated 12 separate threads including for example, ‘Shopping in Dublin’ and ‘Cycling and Walking in Dublin’. These 12 threads received a total of 11,326 views and resulted in 179 replies. A summary of the thread discussions is available on the CD-ROM.

Sectoral Group Discussions & Dublin Debate The consultation programme for the Draft Plan also included a number of discussions held with sectoral interest groups during February 2010. The sectoral discussions culminated in a Dublin Debate held in the Round Room at the Mansion House on 25th February 2010. The purpose of the four sectoral group sessions and final debate was to explore the issues raised in the Draft Development Plan, and to bring forward constructive ways of improving the Plan for the benefit of the city.

A brief summary of each of the sectoral group sessions and the Dublin Debate is available on the CD-ROM which accompanies this Report. A list of the sectoral groups invited is attached at the end of this Appendix.

Strategic Environmental Assessment (SEA) & Appropriate Assessment (AA) The SEA & AA process have been integrated into the plan-making process. Consultation with the general public and the prescribed environmental authorities was undertaken on the Environmental Report and Appropriate Assessment Report of the Draft Plan. The Manager’s Report includes a summary and consideration of all submissions on SEA & AA.

In addition, the proposed amendments arising from the Manager’s Recommendations have been screened and assessed for the purposes of SEA & AA. The Environmental Report and Appropriate Assessment Report will be modified to take account of any material amendments and additional mitigatory measures, if necessary, by way of Addendums. These addendums will form part of the second public display in relation to material amendments on the Draft Plan.

Next Steps The Members shall consider the Draft Plan and the Manager’s Report and such consideration shall be completed within twelve weeks of the submission of the Report to the Members. Where, following consideration of the Draft Development Plan and the Manager’s Report, it appears to the Members that the Draft should be accepted or amended, they may by resolution, accept or amend the draft and make the development plan accordingly.

Should amendments be proposed which would constitute material alterations to the Draft Plan, there is a further public display period giving people an opportunity to comment on the proposed amendments only. This is followed by the preparation of a Manager’s Report for Members on any submissions or observations received. Members may then make the Development Plan with or without the proposed amendments, or with modifications to the proposed amendments, as they consider appropriate. Timetable To assist Members in their consideration of the Draft Plan and the Manager’s Report on the submissions received, Information Sessions for Members only have been arranged as follows during May/June :-

AREA DATE VENUE South East Monday 31st May, 2010 Room 19, Block 4, 5.00 p.m. – 7.00 p.m. Floor 3, Civic Offices. South Central Tuesday, 1st June, Room 19, Block 4, 10.00 a.m. – 12.00 noon Floor 3, Civic Offices. Central Wednesday, 2 June, 2010 Room 19, Block 4, 10.00 a.m. – 12.00 noon Floor 3, Civic Offices. North West Thursday, 3rd June, 2010 Room 19, Block 4, 10.00 a.m. – 12.00 noon Floor 3, Civic Offices. North Central Friday, 4th June 2010 Room 19, Block 4, 10.00 a.m. – 12.00 noon Floor 3, Civic Offices.

Members are welcome to attend all Information Sessions. Officials from the Planning Department will be present to deal with any queries.

The Manager’s Report on the submissions/observations received and the Draft Plan will be considered at a Special Meeting of the City Council on the 26th July, 2010 and any unfinished business to adjourned Special Meetings of Council between 27th to 30th July, 2010, as deemed necessary. The consideration of the Draft Plan and the Manager’s Report must be completed by 6th August 2010, twelve weeks after the submission of the Manager’s Report to the Members. The timetable for the completion of the review is set out below: -

Time Table for completion of Development Plan process

17th May, 2010 – 30th July, 2010 Consideration by Council of Manager’s Report and Draft Plan

31st July, 2010 – 19th August, 2010 Prepare Proposed Amendment of the Draft Development Plan (3 weeks max.)

20th August, 2010 – 17th September, 2010 Public Notice and Display of Proposed Amendment of the Draft Development Plan (4 weeks )

18th September, 2010 – 14th October, 2010 Prepare Manager’s Report on submissions received to 2nd Display Consideration by Council of the 15th October, 2010 – 26th November, 2010 Amendment and Manager’s Report (6 weeks max.) and adoption of Development Plan

24th December, 2010 Development Plan comes into effect

Part 2:

Submission from the Department of Environment, Heritage & Local Government and Manager’s Response and Recommendations

Submission: Department of Environment Heritage and Local Government

Submission No: 2912, 2997

Summary of Issues General: The DoEHLG on behalf of the Minister supports the long-term strategic approach and strong emphasis on sustainability which underpin the Draft Plan. It also welcomes the degree to which national and regional policies have been included in the plan; the focus on promoting economic development in Dublin as a national Gateway City; the focus on water supply and wastewater infrastructure; the emphasis on quality residential development while achieving higher densities in areas well-served by public transport; and the user-friendly dedicated development plan website.

Core Strategy: The DoEHLG refers to the Planning & Development (Amendment) Bill and the forthcoming requirement that all development plans include a core strategy which sets out the policy links between the regional planning guidelines and the development plan on the one hand, and between the development plan and its constituent local area plans on the other. On this basis, the submission observes that elements of the Housing Strategy in Appendix 3 of the Draft Plan should be included in the Core Strategy, such as population and housing targets. It also recommends that the Core Strategy should be a self-contained section at the beginning of the Plan.

Building Heights: The Department welcomes the guidance in relation to the location and design of taller buildings, but states that the Plan should be more clear on the purpose of the guidance. In particular, it states that there should be more clarity on whether the purpose of the plan is to specify locations in which such taller buildings may be considered as part of delivering higher densities. It also advises that there may be a need to clarify terms with regard to the definitions of low-rise and mid-rise categories.

Architectural Heritage: The DoEHLG welcomes the commitment to the protection of the architectural heritage as set out in the various policies and objectives of the Draft Plan.

The Department also recommends a consistent approach to the use of terminology in the policies and objectives relating to architectural heritage. It recommends that it be made clear in the Plan that all structures of industrial heritage-merit also form part of the architectural heritage of the city and where appropriate be included in the Record of Protected Structures (RPS).

The submission also queries Dublin City Council’s Register for Buildings at Risk, on the basis that this implies that the adverse impacts on protected structures will only be addressed when a building is at risk and that there is no provision for any such concept in Part IV of Planning and Development Act, 2000. It recommends that the reference to a formal ‘buildings at risk’ register be removed from the Draft Plan.

In terms of the Strategic Environmental Assessment (SEA), the Department observes that the only SEA Indicator for architectural heritage is the ‘percentage of protected structures at risk’ and considers that this approach appears to be entirely negative. It advises that other indicators, such as conservation grants, should be used in the Plan and Environmental Report (ER).

Nature Conservation: The Department welcomes the protection given to the Natural Heritage including designated sites, habitats and species. However, it queries whether a policy affords protection to sites proposed for designation but not yet designated or how the policy would impact on sites which may have boundary changes in the future (Policy GC25).

The Department refers to the policies and objectives which it considers have the potential to impact on the natural heritage. These include those relating to cycleways and pathways and the lighting of them; amenity uses of beaches; water based activities; flood relief measures; the Eastern By-Pass; the future Greater Dublin Water Supply and the Greater Dublin Strategic Drainage Study.

SEA & AA: The Department observes that the SEA has only assessed the impact of policies and not of objectives and requests clarification on whether objectives are included in the assessment of the policies.

The Department’s submission outlines the policies and objectives which it considers would have the potential to impact on the natural heritage, such as the Sutton to Sandycove (S2S) Scheme; the Eastern By-Pass; and the proposed second wastewater treatment plant. As these projects are likely to impact on the Natura 2000 Sites, it recommends that the cumulative impacts be assessed in liaison with the two adjoining local authorities. In addition, it suggests that the policy regarding the future water supply may involve bringing water from the Shannon and whilst acknowledging that this project has been subject to SEA and AA, advises that this issue needs to be addressed in the SEA of the Draft Plan.

The Department makes similar comments in relation to AA with regard to the S2S, the Eastern By-Pass, the WWTP and the drinking water strategy. It also makes specific comments on screening decisions with recommendations to screen-in a number of policies.

Archaeology: The DoEHLG considers that the separation of policies and objectives in Chapter 7 from the general policy in the development standards section is unhelpful and that clarification is needed on the current status of the Dublin City Heritage Plan. In addition, it would like to see references to sites and monuments legislation; the designated sites in the Record of Monuments and Places; Ministerial policy documents on archaeological heritage; National Policy on Town Defences; and the Department’s policy with regard to shipwrecks. The Department also advises that the plan should include a list of monuments in the Ownership or Guardianship of the Minister and the Council.

Eastern By Pass: In a separate submission, the DoEHLG advises that the advance of the Eastern Bypass is not envisaged under the Renewed Programme for Government.

The National Roads Authority (NRA) states that the Eastern By-Pass would complete a full ring motorway for the city and alleviate north-south through-city congestion (Submission No. 2209).

Manager’s Response Each of the issues raised in the Department’s submissions have been given full consideration and are comprehensively addressed in the relevant chapter topic sections of this report. This approach allows for an integrated assessment of submission issues in the context of the issues raised by other prescribed bodies or statutory agencies, and in the context of the overall Plan. However, for ease of reference, the following outlines the recommendations of the Manager in relation to the main issues raised.

Manager’s Recommendation General: The Department’s comments in support of the development plan approach are welcome and this report seeks to ensure that this overall approach in included in the Plan.

Core Strategy: The Core Strategy has been revised to demonstrate the consistency between the plan and higher level policies, to set out details of population targets and allocations, together with the relationships between the housing, settlement and retail strategies of the Plan, all in conjunction with public transport provision. The text of this amended chapter is set out at the end of Section 3 of this Report (See Chapter 3).

Building Heights: The Department’s support for the guidance on building heights is welcome. Nonetheless, a number of minor amendments are recommended to provide further clarity as to the meaning of terms and definitions, with further elaboration on the definition for low-rise buildings. In addition, the report clarifies that it is policy to promote taller building in a very limited number of locations for economic and identity reasons only and not as a mechanism to contribute to higher densities (See Chapters 4 & 17).

Architectural Heritage: In response to the Department’s comments, a number of text changes are recommended to ensure consistency in the terminology of the Draft Plan and the Planning and Development Acts. Amendments to policies are also recommended to include specific reference to industrial heritage.

In relation to the Buildings at Risk Register, the report clarifies that this is a positive instrument and is a means of prioritising protected structures which are suffering from neglect for advice on repairs and maintenance to be given to owners, as well as targeting conservation grants. It is a mechanism for targeting public resources and funds in a fair and non-discriminative manner and has been applied successfully for a number of years (See Chapter 7.2).

For SEA, four additional indicators for cultural heritage as an environmental receptor are recommended, as suggested by the DoEHLG.

Nature Conservation: In response to the comments on designated sites, species and habitats, it is recommended to revise the wording of Policy GC25 to afford protection to sites that may be designated in the future or existing sites that may be subject to boundary changes. In relation to the policies and objectives which have the potential to impact on the natural heritage as considered by the Minister, these are addressed fully under the topic headings of SEA and AA (See AA & SEA Sections of this Report).

SEA & AA: The report clarifies that all policies were screened for the purposes of SEA & AA and that the objectives in the Draft Plan essentially represent the means of achieving the policies at a strategic level. Notwithstanding this approach and in the absence of specific direction on this issue in the national guidelines, it is acknowledged that there are a small number of objectives which may require independent screening to establish their potential impact in terms of likely significant impacts on the environment in the case of SEA and on Natura 2000 Sites for AA.

In addition, it is recommended to amend the relevant policies of the draft plan and to update the Environmental Report (ER) and Appropriate Assessment (AA) Report accordingly, to ensure a consistency of approach and an assessment of the cumulative impact of various transboundary projects which are regional in nature. In this regard, Dublin City Council liaised with the relevant adjoining authorities: Dun Laoghaire Rathdown and Fingal County Councils.

With specific regard to AA, the Manager’s report recommends as appropriate to review the screening exercise for a number of policies and to update the screening assessment accordingly for Policy SI41 (second wastewater treatment plant) and SI47 (flood defence infrastructure). In terms of the Eastern By-Pass, this report clarifies that the precise alignment and design is pending determination and will be subject to an in-depth assessment of the potential impact on Natura 2000 Sites at individual project level. It also refers to the AA of the Draft Plan which acknowledges the potential negative impacts of this project and provides mitigatory measures.

Archaeology: It is recommended to include some new policies on archaeology, together with a new appendix to set out the list of ministerial policy documents on archaeology and additional supporting text to refer to zones of archaeological interest and the relevant legislation which affords protection, to address such issues as raised by the Minister.

Eastern By-Pass & Renewed Programme for Government: The Eastern-Bypass is a strategic element of regional policy as set out in the Draft Regional Planning Guidelines for the Greater Dublin Area 2010-2022 in order to provide an overall integrated multi-modal transport network to support the growth of the Dublin City Metropolitan Area, including Dublin Port. Dublin City Council’s Draft Plan must have regard to the Regional Planning Guidelines (RPGs) as set out in Section 27 of the Planning and Development Act, 2000. It is also relevant that the Planning and Development Bill 2009, seeks to strengthen consistency between regional guidelines and development plans.

Part 3:

Summary of Submissions and Manager’s Response and Recommendations

Chapter 1 Background to Making the Plan Submission Number(s): 2060, 2227, 2609, 2641, 2661, 2799, 2809, 2837, 2839, 2907, 2909, 2918, 2931, 2932, 2935, 2978, 2980, 3125, 3159, 3160

Section: 1.1 Statutory Context

Summary of Issues The Department of Transport welcomes the references to Smarter Travel in Chapter 5 (Connecting & Sustaining the City‟s Infrastructure), but request that reference should be made to the policy document at the outset of the Plan and also in Appendix 2 as part of National, Regional and Local Guidance.

The Dublin Chamber of Commerce submits that the Plan must be seamlessly integrated with the Regional Planning Guidelines, the Development Plans of the three County Councils, the Master Plan of the DDDA and the legislation governing the National Transportation Authority.

One submission queries how the Plan accords with the National Spatial Strategy (NSS), given that it seeks to develop the city as a hub and that the NSS promotes decentralisation and hubs outside the city. Manager's Response The comments made by the Department‟s of Transport are noted and it is considered appropriate to include a reference to the policy document „Smarter Travel - A Sustainable Future‟ at the very outset of the plan and also include a synopsis of the document in Appendix 2.

The Draft Plan has been prepared with regard to relevant national and regional guidance as demonstrated in the Core Strategy, Chapter 3. In particular, the Draft Plan reflects the settlement strategy as set out in the RPGs and National Transportation Authority's emphasis on effective land-use and public transport integration. Furthermore, full cognisance is taken of the regional context and adjoining local authorities in Chapter 8: Making Dublin the Heart of the Region. Manager's Recommendation Insert New Text Section 1.1, Para 2, Line 3, Page 4, after National Climate Change Strategy; „Smarter Travel - A Sustainable Future‟

Insert the following text into Appendix 2, P. 253 as New Section after Transport 21 Section;

Smarter Travel - A Sustainable Transport Future. The Government‟s Smarter Travel – A Sustainable Transport Future, 2009 is the transport policy for Ireland for the period 2009-2020. The policy recognises the vital importance of continued investment in transport to ensure a competitive economy, but it also sets out the necessary steps to ensure the use of more sustainable transport modes such as walking, cycling and public transport. It is a response to the unsustainable growth in demand for road transport with regard to congestion; local air pollution; climate change; security of energy supply and quality of life. The over- arching aim is that by 2020 future population and economic growth will occur predominantly in sustainable compact urban and rural areas.

The main objectives are to reduce dependency on car travel and long distance commuting, increase public transport modal share and encourage walking and cycling, improve quality of life and accessibility for all, improve economic competitiveness through increased efficiency of the transport system, reducing greenhouse gas emissions and dependency on fossil fuels.

Section: 1.2 Consultation

Summary of Issues One submission contends that the pre-draft consultation was not taken into account in the making of the Plan. A further submission states that having the Draft Plan on line was very useful and that the public library sessions were very helpful, but questions why there were no public meetings. It also considers that staff should be available at the My City Exhibition to answer queries. Manager's Response The pre-draft consultation consisted of a comprehensive public consultation process with publication of newspaper notices inviting written submissions, an issues paper to stimulate debate, public consultation workshops, an on-line discussion thread and correspondence and contact with sectoral groups, service providers and prescribed bodies. The Manager‟s Report on the Pre-Draft Consultation (12 May 2009) sets out of the main issues raised in each of the consultation methods and includes the Manager‟s Opinion and Recommended Policies for inclusion in the Draft Plan. The pre-draft consultation issues were addressed and considered in this manner, in accordance with the statutory requirements of the Section 11 of the Planning & Development Act, 2000.

The positive comments in support of the use of the web and the value of the public library sessions are noted. Further consideration will be given to appropriate mechanisms to fully engage with citizens at the implementation stage of the Plan, as indicated throughout the Draft Plan in Chapter 1 (Section 1.3), Chapter 3 (Section 3.3.3) and Chapter 13 (Section 13.1). Manager's Recommendation Retain as existing

Section: 1.4 Form and Content of this Development Plan

Summary of Issues A number of submissions refer to miscellaneous issues in relation to the format of the Draft Plan. These include requests or suggestions for the following: an index to enable cross-referencing; a glossary to explain technical terms; cross-referencing throughout the plan; all maps and diagrams to be included on the contents page; a list of all plans and reports referenced throughout the plan; a separate chapter on the built heritage; and a separate list of all policies and objectives for ease of reference. One submission states that the maps are difficult to read, another states that they should be produced at a larger scale for public display purposes. There is also a request to publish the precise boundaries of the inner city, the outer city, areas selected for high-rise, transport routes and nodes.

A further comment is that there is no clear distinction as to what constitutes a policy and what constitutes an objective.

A number of submissions state that the language is ambiguous, whilst others recommend that the plan should avoid being too prescriptive in implementation. Manager's Response It is considered that an index would be beneficial as per that in the current 2005-2011 Development Plan and it is considered appropriate to include same on final adoption of the Plan.

In terms of a glossary, the Draft Plan already includes a comprehensive glossary of terms (Pages 360-370).

The Draft Plan includes cross-referencing between policy chapters, standards and appendices in so far as practicable and feasible. The final document will be extensively cross referenced.

It is recommended that a list of the figures which form part of the written statement, be set out as part of the contents page. These figures are diagrammatic concept maps only, the purpose of which is to illustrate strategic policy in an indicative manner, whilst the printing and colour quality will improve for the final publication.

The built heritage is given full and equal recognition alongside culture in Chapter 7: Fostering Dublin‟s Character & Culture. The topic is dealt with as comprehensively as previous development plans. The purpose of the new approach is to reflect the synergies between the built heritage and culture.

In the interests of brevity, it is not considered appropriate to include a separate list of all policies and objectives as part of the development plan document. All policies and objectives are grouped under relevant issues within each chapter of the draft plan for ease of reference. For similar reasons, it would not be appropriate to include a list of all referenced documents. Appendix 1 & 2 of the Plan list all non-statutory plans and higher level national and regional plans or policies respectively and this is considered sufficient. All such documents are available on relevant websites.

The distinction between policies and objectives is given a full explanation in the Glossary of Terms, Page 367.

Map K of the Development delineates the precise boundaries of the Inner City/Outer City, the Key Developing Areas and Key District Centres, whilst the key transport routes and nodes are shown on Figure 2 (Core Strategy) & Figure 7 (City Centre Integrated Transport). It is not considered necessary to show the boundaries of the areas identified as appropriate for height as the majority of these relate these to Key Developing Areas (10), whilst two of the remaining areas, Clonshaugh and George‟s Quay will be treated as low-rise pending the preparation of an LAP / SDZ / Schematic Masterplan. Furthermore, Section 16.4.1 of the Guiding Principles for Height state that each of the identified areas will be subject to a Local Area Plan, Schematic Masterplan or Section 25 Scheme. The preparation of such plans will involve public consultation and determine plan boundaries where necessary.

The language of the plan reflects the statutory requirement to address strategic policy issues and development management issues by way of standards for development. In this regard, it seeks to strike a balance between high level policy and the prescriptive nature of standards. Manager's Recommendation Insert Index (On Final Adoption of the Plan) after Glossary, Page 370

Insert Further Cross-References as Appropriate

Insert a List of Figures (Fig 1- Fig 22) into Table of Contents Chapter 2 Context for the Development Plan Submission Number(s): 2171, 2229, 2610, 2611, 2612, 2613, 2614, 2615, 2616, 2617, 2618, 2619, 2622, 2829, 2909, 2959, 2964, 2966, 3001, 3003, 3094, 3101, 3159

Section: 2.0 Context for the Development Plan

Summary of Issues One submission states that this section fails to recognise the economic recession. Another submits that the reference to Pelletstown as a mixed-use neighbourhood is incorrect on the basis that the mixed-use element has either failed or is non-existent on the east side and the physical infrastructure to create and maintain neighbourhoods and communities is absent. Manager's Response The Draft Plan acknowledges at the very outset the current challenging economic circumstance and in this respect the theme of economic recovery imbues the whole plan. Specifically, Section 2.0 states that “Following fifteen years of unprecedented growth, which has transformed the city, the recent economic downturn must be grasped as an opportunity to create a shared vision for a long term recovery, for the benefit of the city, the region and country”.

The reference a new mixed-use neighbourhood in Pelletstown is made in the context of new emerging residential communities in Key Developing Areas in the Outer City. It is considered valid to retain this reference in acknowledgment of the new emerging community at Pelletstown and the objective to deliver a vibrant mixed-use element which may be partially achieved to date. Furthermore, the Core Strategy, prioritises the preparation of a Local Area Plan (LAP) for Pelletstown as a Key Developing Area. Manager's Recommendation Retain as existing

Section: 2.1 A New Approach

Summary of Issues The Environmental Protection Agency (EPA) commends the proactive approach of the plan in terms of environmental sustainability and the focus on ensuring an improved quality of life, particularly the new approach to addressing these issues through the Framework for Sustainable Dublin and the Six Themes. A further submission states that this section of the plan should clearly state that the development of the city is focused on serving the needs of its citizens. Manager's Response The EPA‟s supportive comments on the plan are welcome. In relation to the request for a specific reference on serving the needs of citizens, it is relevant to note that this section already includes such a specific statement which is as follows: “This Development Plan sets out a new approach to meet the needs and aspirations of the citizens of Dublin and the country in the long term” (Section 2.1, Page 7). Furthermore, there is a strong emphasis on the needs on citizens throughout the plan in terms of the vision, engagement with city stakeholders and on-going collaboration throughout the implementation stage. Manager's Recommendation Retain as existing.

Section: 2.2 The Six Themes

Summary of Issues A number of submissions call for additional thematic issues to be added to the six themes. A few contend that that the provisions for protection of built heritage is considerably weakened in draft plan and at a minimum built heritage should be one of the six themes. One submission states that the six themes are not sufficiently centred on supporting growth and employment, whilst a further submission calls for a political theme to address collaboration with the adjoining local authorities to create a better City Region with strong links to similar City Regions across the EU. Meanwhile, a submission by a residents‟ association sets out in a comprehensive fashion, the application of the six themes at a local level in relation to village and community issues. Manager's Response The six themes were devised to offer an integrated thematic approach to promote a more sustainable urban model with residents having a wealth of choices for living, working, socialising and enjoying the city‟s amenities. The built heritage directly relates to the cultural themes and employment or growth relates directly to the economic theme, whilst each of these issues is also given prominence in Chapters 7 Fostering the City‟s Character & Culture and Chapter 8: Revitalising the City‟s Economy.

The proposal for a political theme to ensure appropriate collaboration, in fact sits with the Framework For Sustainable Dublin (FSD) which gives recognition to organisational and institutional networks, as well as the need for engagement with citizens and collective support.

The application of the six-themes to a local level village by way of illustration is commended. Manager's Recommendation Retain as existing.

Section: 2.3 Sustainable Dublin

Summary of Issues In relation to the Sustainable Dublin Approach, two submissions consider that the challenges of peak oil and climate change should inform the Plan. One of these states that there are serious omissions in the approach in that it addresses climate change primarily through flood defence issues and that the approach should be broadened to relate to planning applications, whereby applicants must demonstrate proposals to reduce carbon emissions and vulnerability to climate change. Manager's Response The Section on Sustainable Dublin sets out the reasons for this approach, including the need to reduce emissions and to increase the resilience of the city‟s economy, with reference also to the need to make the transition to a low-carbon economy. The challenge of peak oil is implicit in this. However, it is possible to include a specific reference to same.

The need to address climate change imbues the entire Plan as the over-arching philosophy and in terms of policies and standards, extending to all aspects including the green economy, sustainable building design, energy efficiency standards, green networks and SUDs, sustainable transport modes. It is simply inaccurate to state that it is confined to flood defence issues. Manager's Recommendation Amend Text Section 2.3, Para 3, Line Page 8 From: A shift in behavioural patterns, renewable energy sources and sustainable infrastructure is critical for the city to make its contribution to emissions reduction and to increase the resilience of the city‟s economy.

To: A shift in behavioural patterns, renewable energy sources and sustainable infrastructure is critical for the city to make its contribution to emissions reduction, to address the challenges of peak oil and to increase the resilience of the city‟s economy.

Chapter 3 Development Plan Strategy to 2017 Submission Number(s): , 2005, 2009, 2107, 2151, 2164, 2167, 2171, 2199, 2204, 2209, 2227, 2235, 2245, 2248, 2259, 2293, 2298, 2603, 2604, 2608, 2609, 2610, 2611, 2612, 2613, 2614, 2615, 2616, 2617, 2618, 2619, 2622, 2641, 2649, 2653, 2654, 2661, 2677, 2741, 2747, 2797, 2804, 2834, 2841, 2860, 2870, 2881, 2891, 2892, 2897, 2898, 2912, 2913, 2917, 2919, 2932, 2946, 2947, 2957, 2962, 2964, 2965, 2968, 2972, 2973, 2974, 3003, 3016, 3019, 3021, 3026, 3032, 3040, 3041, 3046, 3070, 3077, 3079, 3097, 3101, 3124, 3125, 3135, 3142, 3145, 3159, 3160, 3161, 3164, 3171, 3181, 3186, 3188

Section: 3.1 The Vision for Dublin

Summary of Issues A number of submissions express strong support for the vision including the Department of the Environment, Heritage and Local Government (DoEHLG), the National Roads Authority (NRA), the Office of Public Works (OPW), Dublin Civic Trust and the Grangegorman Development Agency (GDA). In particular, the DoEHLG supports the long-term strategic approach and the strong emphasis on sustainability which underpin the Draft Plan, whilst the OPW considers that it mirrors many of its objectives from an environmental, heritage, recreational and sustainability aspect. Meanwhile, the National Council for the Blind Ireland (NCBI) request that the vision include a statement regarding accessibility for people with disabilities.

A few submissions contend that the plan does not reflect the current economic circumstances or oversupply conditions, whilst others state that there needs to be a greater focus on operational issues that affect the city such as public transport. A further submission proposes that the vision statement be published separately as an expressive engaging publication and should be the subject of an international design competition. Manager's Response The support for the vision is welcome.

It is not considered appropriate to make specific reference to accessibility for people with disabilities in the vision statement given the approach of universal design in the plan. Accessibility for all is integrated throughout the policies, objectives and standards of the Plan, including movement and transport, civic spaces and the public realm and neighbourhood facilities (e.g. Chapter 17.7 and Appendix 20).

There is merit in the proposal for separate publication of the vision and full consideration will be given to this as a potential means of communicating the vision at plan implementation stage.

Chapters 1, 2 & 3 at the outset of the Plan all refer to the economic context of the Draft Plan. Meanwhile, Chapter 9 specifically seeks to revitalise the city‟s economy. Manager's Recommendation Retain as existing. Section: 3.2 The Core Strategy to 2017

Summary of Issues The DoEHLG refers to the Planning & Development (Amendment) Bill and the forthcoming requirement that all development plans include a core strategy which sets out the policy links between the regional planning guidelines and the development plan on the one hand, and between the development plan and its constituent local area plans on the other. In particular, it states that the core strategy will set out regional population and housing targets as they apply to the area of the planning authority, in order to provide an evidence-based approach to zoning provision and settlement and housing strategies within the Development Plan. On this basis, the submission observes that key data are only to be found in the Housing Strategy in Appendix 3 of the Draft Plan. It also recommends that such a core strategy be included as an early chapter in the Plan and to avoid duplicating the phrase „core strategy‟ for the purposes of elaboration on the vision statement on the basis that such use of terminology may create confusion in relation to the statutory core strategy on enactment of the Bill.

The National Transport Authority (NTA) supports the overall thrust of the Plan on the basis of a number of aspects as set out in the Core Strategy, including consolidation of development within the city centre, consolidation of development within a hierarchy of centres and along public transport corridors outside the city centre and the application of minimum residential densities.

Dublin Docklands Development Authority (DDDA) fully supports the three strands of the core strategy and states that any new planning schemes will be informed by the core strategy.

A further submission welcomes the introduction of a core strategy, but recommends a statement of compliance to demonstrate how the plan is consistent with the Draft Regional Planning Guidelines and the National Spatial Strategy and especially so in terms of population projections to provide a strategic approach to zoning and phasing of development.

A non-governmental organisation contends that the Core Strategy is merely a spatial strategy and does not meet the requirements of the Planning & Development Bill. Manager's Response It is considered appropriate to amend the core strategy to reflect the comments of the DoEHLG. In this regard, the core strategy has been amended to demonstrate the consistency between the plan and higher level policies, to set out details of population targets and allocations, the relationships between the housing, settlement and retail strategies of the plan, in conjunction with public transport provision.

It is also considered appropriate to amend the chapter title to include „Core Strategy‟. Manager's Recommendation Amend Text of Chapter 3 to meet requirements of the DoEHLG.

NOTE: The new text is shown at the end of this Chapter of the Manager's Report under the heading 'Revised Text of Chapter 3'. Section: 3.2.1.1 Shaping the City - Urban Form and Structure

Summary of Issues A number of submissions raise concerns regarding the extent of derelict, vacant or under-utilised properties in the Inner City. The Lord Major‟s Commission on Employment submits that realising the potential of under-utilised or vacant sites should be a core strategy of the plan and that it should be objective of the plan to undertake an assessment of the challenges, barriers and opportunities of regeneration with a series of recommendations for action. Meanwhile, another submission suggests incentives, such as the relaxation of development contributions, for brownfield or in-fill development.

The National Transport Authority (NTA) advises that the importance of accessibility by public transport, walking and cycling, needs to influence the scale of the higher order centres outside the City Centre. It submits that the relationship between accessibility and scale needs to be more clearly defined in the plan, on the basis that each of the 8 Key District Centres (KDCs) demonstrates different levels of public transport accessibility. It further advises that the location of high-density / trip intensive uses should be focused on areas with high levels of public transport accessibility and that it is important that these qualities are reflected in any such areas identified in the draft plan such as the Key District Centres, Key Developing Areas and economic corridors.

Several submissions support the concept of Key Developing Areas (KDAs) and Key District Centres (KDCs), some calling for further detail on how these will be developed or enhanced. A number of submissions express support for the designation of particular KDAs such as Grangegorman, Naas Road, Digital Hub and Pelletstown. Two residents‟ associations request the removal of Ballsbridge and Rathmines from the list of KDCs. Another submission states that Ballsbridge should be designated as either a KDA or KDC. It is also submitted that Ballsbridge should be included as either a Key Developing Area or Key District Centre where existing and granted developments are recognised and where increased heights above 6 storeys for office and residential are permitted in principle.

One submission states that the polycentric approach along the M50 Motorway will undermine employment densities in the City Centre and exacerbate traffic congestion, citing also that the approach is not consistent with the Draft RPGs for the GDA.

A further submission requests that the DART Underground be shown on the Core Strategy Map (Figure 2), as extending from Docklands to Inchicore, rather than Connolly to Heuston. Manager's Response The Inner City is identified as a KDA and priority is given to the regeneration and renewal of the Inner City by way of the core strategy with policies and objectives throughout the Plan supporting consolidation, housing regeneration sites, the City Centre as an attractive place for city-living and audits of vacant and derelict sites.

The Settlement Strategy as set out in the Draft Plan Core Strategy takes full cognisance of public transport accessibility. All of the KDAs locations correspond to high levels of rail-based public transport accessibility, either existing or planned under Transport 21. Similarly, all of the KDCs, closely align to public transport rail corridors, with the exception of two, Finglas and Ballymun, which perform important social and regeneration functions. It is considered that this approach fully accords with the Government‟s Smarter Travel Policy Document and the RPGs. Rathmines, as a primarily established centre with relatively limited capacity for expansion, forms an important focal point and service centre for the surrounding community. It is considered appropriate to retain that as a KDC. Ballsbridge is not designated as a KDC in the Draft Plan and this matter was given consideration at pre- draft stage. Area-specific guidance for each of the KDCs would be more appropriately dealt with by way of local area plans or schematic masterplans.

The Core Strategy supports the consolidation and intensification of the City as part of the Metropolitan Area with an emphasis on sustainable transport. The reference to the polycentric approach to corridors extending into the regions, relates to an emerging collaborative approach with adjoining local authorities in the city-region. The role of the City Centre as the economic driver for the region and state is acknowledged and supported in the Plan. Manager's Recommendation Amend Figure 2 'Core Strategy' to show DART Underground from Docklands to Inchicore.

Section: 3.2.1.2 Connecting and Sustaining the City’s Infrastructure

Summary of Issues The Chartered Institute of Logistics and Transport submits that the Plan should define the locality of land-use and densities, and propose planned infrastructure that will support land use-zoning and proposed development intensification, advising that when implemented, the content of the Plan as such will pre-determine the pattern and broad volume of movement of people and goods.

Another submission expresses strong support for the critical role of providing essential infrastructure for the intensification of the City and the identification of strong centres focused on public transport nodes for height and density. Manager's Response Effective land-use and transport integration is a key priority of this draft plan as demonstrated in the core strategy with the close alignment of the settlement strategy and strategic public transport infrastructure, in accordance with the Government‟s Smarter Travel Policy, the RPGs and the NSS. This approach informs the designation of KDAs and KDCs, land-use zonings and over-arching policies with an emphasis on mixed-use compact neighbourhoods in a sustainable city.

The support for intensification of the City at key transport nodes and growth centres is noted. Manager's Recommendation Retain as existing.

Section: 3.2.1.3 Greening the City - Landscape, Biodiversity, Open Space and Recreation

Summary of Issues The RIAI requests that this section include reference to the need to identify and consolidate those areas of land use for the purposes of resilience in the future, for example, for food security. Manager's Response The Draft Plan acknowledges the importance of open space and green infrastructure to the City‟s resilience to climate change. I acknowledges the benefits of green space for carbon soakage, bio-diversity and SUDs, as well as its essential role in the intensification of the City for amenity and quality of life reasons. It also promotes the concepts of allotments in open spaces, city parks and temporary sites. Meanwhile, the Strategic Green Network seeks to secure linkage of green spaces and routes. This approach is supported by policies, and objectives, as well as a series of Guiding Principles on Green Infrastructure (Chapter 16). It is considered these mechanisms are sufficient. Manager's Recommendation Retain as existing.

Section: 3.2.1.4 Fostering the City’s Character and Culture

Summary of Issues The Civic Trust supports the Core Strategy and recognition of the City‟s key assets such as the built heritage which serve to make Dublin a unique and distinctive city. The Irish Theatre Institute (ITI) strongly supports the approach and objective to provide public art across all art forms in the City Centre, but requests that the wording of the Core Strategy, Strand 1 be amended to reflect the importance of culture to the economy of the city and to the lives of citizen‟s, inserting the following: „culturally rich, sustainable and diverse‟.

One submission requests that the text which refers to the removal of structures from the Record of Protected Structures (RPS) upon designation as part of an Architectural Conservation Area (ACA) be omitted as this would result in loss of building fabric and pastiche. Manager's Response The support for this element of the Core Strategy is noted.

Culture is given prominence in the Core Strategy Strand 1, with reference to cultural interaction as part of a mixed-use and dynamic city, whilst further prominence is given to it in the priority and chapter title „Fostering the City‟s Character & Culture. Sustainability is inherent to a compact city, whilst diversity is addressed by social inclusiveness in Core Strategy Strand 2. All the strands are interwoven and it is considered that the wording adequately addresses the issues.

The proposal to remove structures from the RPS on designation of ACAs, relates to areas where the character of the streetscape is of primary importance, rather than the interior or fabric of the individual structures. Appendix 11 clarifies this issue further, stating that the relevant structures derived from List 2 of the 1999 Development Plan and are not of sufficient interest to warrant individual inclusion on the RPS under the 2000 Act, but that designation as ACAs offers the protection and enhancement of these historic streetscapes. Manager's Recommendation Retain as existing. Section: 3.2.2.1 Making Dublin the Heart of the City Region

Summary of Issues A submission strongly supports the consolidation of the city with regard to the role of the city as the economic driver for the Greater Dublin Area and the Country. Manager's Response The support for consolidation of the city is noted. Manager's Recommendation Retain as existing.

Section: 3.2.2.2 Revitalising the City’s Economy

Summary of Issues Statutory agencies and national institutions, including third level colleges and hospitals, support the designation of the three economic corridors. Specifically, the Dublin Airport Authority (DAA) welcomes recognition of the Metro North Economic Corridor. Similarly, the universities endorse the Southern Economic Corridor emphasising that the approach accords with the Innovation Alliance between UCD & TCD. Grangegorman Development Agency (GDA) also expresses support for the economic corridors with reference to the role of clusters and corridors in regeneration. There is also support for the South-Western Corridor in the context of the Digital Hub Initiative.

A significant number of submissions express concern that there is no definition of the economic corridors and that the significance or implications of the corridors is unclear and so will be utilised by the development sector to increase the scale and intensity of development. On this basis, submissions request that references to the economic corridors be omitted from the Plan. Others call for the corridors to be shown on zoning maps.

Some submissions query the rationale of the three economic corridors with reference to a lack of consistency in terms of the designation criteria, whilst, there is another proposal that the South Western Corridor needs specific attention to encourage the establishment of third level activity.

Two submissions request clarification that Ballsbridge is within an economic corridor. A further submission suggests a fourth economic corridor as critical to the consolidation of the City‟s tertiary or services economy and that this would be an eastern economic corridor to the Docklands.

Note: The issues raised above also reflect those made in relation to Chapter 9. Manager's Response In response to the concerns on the potential negative impacts of the economic corridors and also the particular support from the university and hospital institutions, it is considered that the term economic corridors be replaced with „innovation corridors‟. This approach accords with government policy on promotion of a smart, green economy focused on innovation and also is a more accurate reflection of the clustering of knowledge, research and media industries along each of the corridors, such as the third level colleges (UCD, TCD, NCAD, DCU, DIT), hospitals (Mater, St. Vincent‟s, St. James) and digital media enterprises (Digital Hub, RTE). In terms of the proposal for an eastern corridor, it is considered that the Docklands is effectively with the city centre cluster and so does not require separate designation, as each corridor emanates and links with the City Centre.

In the interests of clarity, a text amendment should state that these innovation corridors have no implications for a departure from general zoning or standards provisions (This reflects Motion 1018 of Special Meeting of Council 25 November 2009 as agreed relating to removal of any text that implies re-zoning in economic corridors and to insert a statement to clarify the corridors have no implications for zoning or standards). Manager's Recommendation Amend Text in Chapters 3 & 9 & All Text References in Plan From: Economic Corridors

To: Innovation Corridors

Amend Text in Section 3.2.2.2, P. 17 From: The core strategy promotes three new economic corridors radiating from the city centre – Northwards to Dublin Airport, including clusters and growth centres such as Grangegorman, the Mater, DCU and Ballymun Southwards from Trinity College to UCD, primarily as a knowledge and innovation corridor Westwards from Heuston, including the Digital Hub, NCAD, St. James Hospital, Park West, Cherry Orchard, the Naas Road Developing Area and extending into the wider Metropolitan Area to incorporate new urban centres such as Adamstown

These three corridors form part of a proposed innovation network to lever growth across the city region.

To: This priority promotes three new innovation corridors radiating from the city centre – Northwards to Dublin Airport, including clusters, knowledge, research and growth centres such as Grangegorman, the Mater, DCU and Ballymun Southwards from Trinity College to UCD, primarily as a knowledge and innovation corridor including RTE as the national media centre and St. Vincent’s Hospital Westwards from Heuston, including the Digital Hub, NCAD, St. James Hospital, Park West, Cherry Orchard, the Naas Road Developing Area and extending into the wider Metropolitan Area to incorporate new urban centres such as Adamstown

These three corridors form part of a proposed innovation network to lever growth across the city region, and support government policy to foster innovation and a smart economy.

Insert the following text at end of last paragraph, Section 3.2.2.2 (p. 17): In this context and in the interests of clarity, the innovation corridors have no additional implications for zoning or standards. Section: 3.2.2.3 Strengthening the City as the National Retail Destination

Summary of Issues One submission states that good accessibility of the City Centre for cars is insufficiently highlighted in this section and the retail chapter. Manager's Response It is a priority of the Draft Plan to actively pursue a modal shift to more sustainable modes of transport with an emphasis on walking, cycling and public transport. The accessibility of city centre to private vehicles for short-term parking to cater for shoppers and other commercial needs is acknowledged and addressed in the Plan by way of car-parking standards and other proactive measures. It would be contrary to national policy to prioritise the accessibility of private vehicles at the expense of public transport. Manager's Recommendation Retain as existing.

Section: 3.2.3.1 Promoting Quality Homes

Summary of Issues One submission considers that this section, as a strategic overview, should reflect the importance of family housing for the City. In particular, it states that dwelling units must include larger size apartments with good private amenity spaces in the form of roof gardens or internal balconies and that consideration be given to the provision of family housing in the City Centre in high density formats with private amenity space and possibly car parking. Manager's Response The need for family homes in the City is fully acknowledged in this section. Specifically, it refers to the need for „mixed tenure neighbourhoods, catering for a wide range of family types. It also emphasises the need for quality housing that „is suitable for citizens throughout their lives and adaptable to people‟s changing circumstances‟. Chapters 11 & 17 elaborate on what constitutes a quality homes by way of policies and a comprehensive range of standards on residential development. It is not considered appropriate to refer to specific standards in this section of the Draft Plan. Manager's Recommendation Retain as existing.

Section: 3.3.1 Area-Specific Plans

Summary of Issues A number of submissions request the preparation of statutory local area plans for specific areas which include the following: Ballsbridge, Harold‟s Cross, Stoneybatter, East Wall, Poppintree Industrial Estate, Clonshaugh, Navan Road, the North Inner City east of Gardiner Street and Pelletstown. Other submissions call for a prioritisation of the review of the Pelletstown Action Plan.

The National Roads Authority (NRA) requests consultation on the preparation of local areas plans, studies and other development framework plans and requests that a statutory approach be taken in respect of proposals for economic corridors.

The GAA submits that local area plans should contain specific reference to age- appropriate facilities with assessment of need, location, and means of access with regard to land-use and public transportation.

One submission requests the City Council to prepare a framework plan for the Poolbeg Area in absence of a Section 25 Scheme and for all areas identified as Strategic Development and Regeneration Areas (SDRAs) within the DDDA Masterplan Area but subject to a Section 25 scheme. Manager's Response The Draft Plan sets out a schedule of local area plans which reflects a prioritisation of the KDAs as the key locations for significant quantum of growth and infrastructure provision. This approach is in accordance with the recommendations of the DoEHLG on the Core Strategy.

Local Area Plans (LAPs) in addition to those set out in the schedule may be prepared, but it is considered appropriate to determine these during the lifetime of the plan on a needs or priority basis and as resources permit.

All statutory plans and relevant proposals will be referred to the NRA as a prescribed body.The GAA will have an opportunity to inform local area plans through the consultation process, whilst the principles of the land-use and transportation are fully integrated into the Development Plan which in turn will inform LAPs.

Section 16.3 & 16.4 of the Plan sets out a series of Guiding Principles which relate to the SDRAs & Areas identified as appropriate for height, including the Poolbeg Area and other areas of the DDDA. It is considered this approach is appropriate with regard to the Docklands Masterplan 2008, Draft Poolbeg Planning Scheme and other Schemes. This may be reviewed during the life of the Plan.

Schematic Masterplans or Village Improvement Plans have been identified strategically and will be prepared based on necessity, priority and resource over the life of the Development Plan. It is not considered appropriate to increase the number of plans based on the submissions received and the planning rationale set out. Manager's Recommendation Retain as existing.

Section: 3.3.5 Engagement with City Stakeholders

Summary of Issues To progress engagement with city stakeholders, one submission proposes a development principle which includes building social capital, to yield a social dividend. Another suggests that on completion of the Development Plan, the City Council and communities should work together to devise and implement a series of key performance indicators and operational plans to make the vision a reality. Similarly, a further submission states that the communication and involvement of citizens is key to a successful plan. Manager's Response The comments on social capital, community engagement and performance indicators are welcome and it would be beneficial to harness such interest for the purposes of active involvement at implementation stage. The Plan acknowledges the importance of engagement with citizens and external agencies as set out in the Framework for Sustainable Dublin (FSD) Approach and the Implementation Chapter (Chapters 2 & 13). Manager's Recommendation Retain as existing.

Section: Revised Text of Chapter 3

Summary of Issues The comments of the DoEHLG, as set out in Section 3.2, requires that the core strategy be amended to accord more fully with the Planning & Development (Amendment) Bill. Manager's Response As stated as Section 3.2, the text of Chapter 3 should be amended to demonstrate the consistency between the plan and higher level policies and is set out in the recommendation below. Manager's Recommendation Replace the existing text of CHAPTER 3 with the following:

CHAPTER 3: DEVELOPMENT PLAN VISION & CORE STRATEGY

This Chapter has three main Sections: (1) The Vision for Dublin; (2) The Core Strategy; and (3) Translating the Core Strategy into Development Plan Priorities.

3.1 THE VISION FOR DUBLIN

This City Development Plan arrives at a time of economic uncertainty at national and global level, following fifteen years of economic growth and regeneration that has transformed the Capital City economically, socially, and physically. The current economic downturn is an opportunity to create a vision for the City that will not only facilitate recovery but will seek to ensure that this recovery takes place in a coherent, sustainable manner for the benefit of the City, the Region and the Country.

It would be folly to adopt projections from either the economic boom years or the recent downturn as the basis for a vision for the City. Instead, the City must, collectively through its citizens and civic leaders, develop a shared vision of what sort of city we aspire to, not in the six-year lifetime of a development plan, but over the next 25 to 30 years. It is only by developing a shared vision for Dublin that we can deliver the core strategies of each successive Development Plan as crucial stepping stones towards the long term vision. This Development Plan is not so much based on short- term forecasts, but on „backcasting‟ from the 30-year vision. Without a vision which enjoys broad support, short-term, often competing interests will prevail, ultimately to the detriment of the City.

The vision for the City is that;

Within the next 25 to 30 years, Dublin will have an established international reputation as one of the most sustainable, dynamic and resourceful city regions in Europe. Dublin, through the shared vision of its citizens and civic leaders, will be a beautiful, compact city, with a distinct character, a vibrant culture and a diverse, smart, green, innovation-based economy. It will be a socially inclusive city of urban neighbourhoods, all connected by an exemplary public transport, cycling and walking system and interwoven with a quality bio-diverse greenspace network. In short, the vision is for a capital city where people will seek to live, work and experience as matter of choice.

This long term vision is based on the principles of sustainable development contained in the Framework for Sustainable Dublin (FSD) and also on the 6 Themes Approach utilised by Dublin City Council in the formulation and implementation of policy. In utilising this approach, the City Council can ensure that these 6 fundamental elements of successful urban development are incorporated into the vision for the future of the City.

3.2 THE CORE STRATEGY

It is the Core Strategy of this Development Plan to achieve the vision in a manner that is consistent with the guidance, strategies and policies at national and regional level. In particular, the National Spatial Strategy 2002-2020 (NSS), the Draft Regional Planning Guidelines for the Greater Dublin Area 2010-2020 (RPGs) and the Government‟s Smarter Travel - A Sustainable Transport Future 2009-2020, all guide and direct the fundamentals of the City Council‟s housing, settlement and retail strategies, which in turn are integrated into the overall Development Plan Strategy for 2011-2017. A summary of the national and regional policies which inform this Plan is set out in Appendix 2.

3.2.1 Development Plan Consistency with the National Spatial Strategy (NSS) & the Regional Planning Guidelines (RPGs)

National Spatial Strategy (NSS)

The National Spatial Strategy (NSS) sets out the strategic planning framework for the future development of Ireland. It recognises that Dublin, as the Capital City, plays a vital national role and that the performance of its economy is essential to the success and competitiveness of the national economy. In order to sustain this role as the engine of the economy, it advocates the physical consolidation of Dublin, supported by effective land-use and transportation policies, as an essential requirement for a competitive Dublin.

The NSS places particular emphasis on the physical consolidation of the Metropolitan Area, which incorporates the entire functional area of Dublin City Council. This necessitates the sustainable development of all vacant, derelict, and under-used lands with a focus on areas close to public transport corridors as well as areas of under- utilised physical and social infrastructure. There is also an emphasis in the NSS on supporting the City‟s capacity for employment and innovation and achieving intensification without compromising amenity or environmental quality.

Draft Regional Planning Guidelines (RPGs)

The Draft Regional Planning Guidelines (RPGs) for the Greater Dublin Area translates the national strategy to regional level with an emphasis on Dublin as the driver of national development and the need to physically consolidate the growth of the Metropolitan Area, with clear direction for greater integration of land-use and transport planning. The RPGs settlement hierarchy seeks to prioritise and focus investment and growth to achieve integration in services, infrastructure, transport, economic activity and new housing.

There is a clear link between both the National Spatial Strategy & Regional Planning Guidelines and the Dublin City Development Plan 2011-2017, as well as with the plans and policies which complement and support their implementation such as the National Development Plan 2007-2013; National Climate Change Strategy 2007-2012; Transport 21 & Smarter Travel.

Dublin City Development Plan

All the policies and objectives of this Dublin City Development Plan flow from and are consistent with these higher-level national and regional policies in that they promote intensification and consolidation of Dublin City, all of which lies within the Metropolitan Area. This will be achieved by way of in-fill and brownfield development; regeneration and renewal of the inner city; redevelopment of strategic regeneration areas; and the use of higher densities especially in public transport catchments. These measures support an effective public transport system and the emergence of a critical mass for the city to compete at an international level and fulfil its role as the national gateway and driver of the national economy.

The Development Plan policies also underpin the creation of a compact city with mixed-use environments, sustainable neighbourhoods and green infrastructure, to reduce the city‟s reliance of fossil fuels and provide for carbon soakage, all in accordance with the National Climate Change Strategy.

In tandem with policies for a competitive and compact city, the Plan addresses amenity and quality of life issues with a strategic and strong policy emphasis on the delivery of quality homes, sustainable neighbourhoods to support successful communities, timely social infrastructure provision and a city-wide green network with links to the city-region.

3.2.2 Housing Strategy (See Appendix 3)

The Housing Strategy for Dublin City is based on the settlement strategy, minimum population targets and housing unit allocations as emerging under the Draft RPGs 2010-2022 (See Table 1). The available zoned residential land under this plan equates to circa 503 hectares (Ha) which is capable of meeting the RPGs housing unit allocation of 42,400 Units for Dublin City for the period 2006-2016, while also allowing for a fifty per cent „headroom‟ as advised in the DoEHLG Guidelines on Development Plans (2007).

The minimum population targets and housing unit allocations as prescribed under the Draft RPGs relate to an initial 10-year period of 2006-2016 and a longer-term projection from 2016-2022. To align these targets and unit allocations to the period of this Development Plan, it is necessary to take cognisance of house completions for the years 2006-2010. The completions for these years, with a notable decline in the past few years (2007-2010), equate to circa 19,700 units, which results in a requirement for Dublin City to deliver circa 22,700 units for the period 2011-2016. The average annual requirement for the period thereafter is 9,064. Therefore, the housing unit allocation for the lifetime of this plan is 31,700 units (approx) (See Table 2 below).

The RPGs calculations and assessment of housing demand take full account of the relatively high vacancy rates and excess of housing stock particularly for the short- term up to 2016, but it is also essential that each local authority makes adequate provision for housing supply and is in a good position for economic recovery in the medium to long term.

Dublin City Council is fully committed to supporting the physical consolidation of the Metropolitan Area and will continue to manage its available zoned residential land in a sustainable manner to accommodate the regional housing allocation figure, to provide for a quality compact city and an effective public transport system.

Table 1: Draft RPGs 2010-2022 Population Targets & Housing Allocation for Dublin City

2006 Census Figures 2016 RPGS 2022 RPGs

Population Target 506,211 563,512 606,110

Housing Allocation 223,098 265,519 319,903

Note: Population targets & unit allocations will be amended if necessary to reflect final RPGs

Table 2: Housing Unit Allocations For Dublin City Council

Draft RPGs Allocation 2006-2016 42,400

DCC House Completions 2006-2010 19,700

Remaining RPG Allocation 2006-2016 22,700

Draft RPGs Allocation 2017-2022 54,384

Annual Average Requirement 2017-2022 9,064

DCC Target 2011-2017 31,764

Note: 2010 House Completions Estimate from DoEHLG Quarterly / Annual Housing Statistics 2009

3.2.3 Settlement Strategy The RPG Settlement Strategy for the Metropolitan Area includes a strong policy emphasis on the need to gain maximum benefit from existing assets, such as public transport and social infrastructure, through the continuation of consolidation and increasing densities within the existing built footprint of the city. A further key aspect is that future expansion, whether housing or mixed-uses, occurs in tandem with high- quality rail-based public transport and on a phased basis within the context of integrated Local Area Plans (LAPs).

Dublin City in its entirety lies within the Metropolitan Area and the RPGs give direction to Dublin City as the „Gateway Core‟ for high-intensity clusters, brownfield development, urban renewal and regeneration.

The Development Plan incorporates these principles in a settlement hierarchy which prioritises the Inner City, Key Developing Areas, Key District Centres and Strategic Development & Regeneration Areas. This hierarchy focuses investment and growth into identified locations to achieve integration in services, infrastructure, public transport, economic activity and new residential development (See Figure 2).

For the Inner City, the plan seeks to strengthen and consolidate the robust city-centre mixed-use zoning area (Z5), with active promotion of the inner city as an attractive place for urban living, the delivery of housing regeneration projects, the emergence of spatial clusters of economic specialisms, public realm improvements and the strengthening of the retail core, all supported by multiple levels of public transport accessibility in the city centre.

The Plan designates 9 Key Developing Areas (KDAs) in addition to the Inner City. These represent significant areas of the inner and outer city with substantial development capacity and the potential to deliver the residential, employment and recreational needs of the city, such as Pelletstown, North Fringe and Naas Road Lands, whilst several will support the economic or cultural specialisms essential for the growth and diversification of the city‟s economy, namely, the Docklands, Digital Hub/Liberties, Grangegorman and Heuston. All of the KDA locations correspond to high levels of rail-based public transport accessibility, whether existing or planned under Transport 21 (Figure 2). The majority of KDAs relate to a zoning objective which seeks the social, economic, physical development or rejuvenation of an area with residential, employment and mixed-uses (Z14). The Table below sets out the relative share of housing growth and identifies the employment / commercial capacity of each KDA (See Table 3).

Table 3:

KDAs Housing Units Zoned Commercial / (Estimate) Employment Lands (Estimate) 1 Inner City 6,340 475 Ha 2 North Fringe 4,000 170 Ha 3 Ballymun 3,950 60 Ha 4 Pelletstown 1,800 41 Ha 5 Park West / Cherryorchard 2,000 121 Ha 6 Naas Road Lands 2,100 63 Ha 7 Docklands 1,950 207 Ha 8 Digital Hub / Liberties 1,200 59 Ha 9 Heuston 1,200 49 Ha 10 Grangegorman / Phibsborough 800 34 Ha Rest of City 6,340 350 Ha* Total 31,700 1,629 Ha

Note: Housing Units & Commercial Capacity are not mutually exclusive given the mixed-use approach to land-use zoning Note: The "Rest of City" includes circa 1,000 units of in-fill development (Schemes < 20 Units)

Within the Inner City and Key Developing Areas, there are a number of Strategic Development & Regeneration Areas (SDRAs). These are important brownfield sites with the potential to deliver a significant quantum of mixed-uses and create synergies to regenerate their respective areas. The Plan prioritises the renewal and regeneration of these areas through a series of Guiding Principles (See Section 16.3)

The Key District Centres (KDCs) represent the top-tier of urban centres outside the City Centre, a number of which form part of the larger KDAs. Each of the 8 KDCs (formerly Prime Urban Centres) underpin a wider area and act as strong spatial hubs providing a comprehensive range of commercial and community services to the surrounding populations. All of the designated KDCs closely align to public transport rail corridors, with the exception of two (Finglas and Northside) which perform an important regeneration role for local communities. This Development Plan will reinforce the KDCs as sustainable anchors for the suburbs and will create a new KDC at Naas Road, instead of the Crumlin Shopping Centre and retain all other KDCs from the Development Plan 2005-2011. The KDCs are as follows:

Key District Centres

1. North Fringe East & West 2. Northside 3. Ballymun 4. Finglas 5. Ballyfermot 6. Naas Road 7. Rathmines 8. Phibsborough

This settlement hierarchy and land-use zoning approach reflects the over-arching objective to achieve sustainable development with mixed-use neighbourhoods throughout the city in close proximity to employment, local services and high quality public transport in accordance with national and regional guidance (See Core Strategy Figure 2).

3.2.4 Retail Strategy The Retail Strategy for Dublin City is to consolidate the city centre retail core as the premier retail destination in the state, to promote an upper tier of retail development in the Key District Centres and a lower tier of District Centres to cater for surrounding communities. Below this tier, the strategy provides for daily shopping needs and local services of a residential community in Neighbourhood Centres. This approach reflects the settlement strategy for the City and is consistent with the Retail Strategy for the Greater Dublin Area 2008-2016 (Appendix 4).

3.2.5 Public Transport This Development Plan seeks to ensure the further integration of land-use and transportation and fully accords with the provisions of Transport 21 and the Smarter Travel. In particular, it supports the DART Underground and Metro to achieve a consolidated Metropolitan Area. Significantly, a mixed-use, sustainable approach to city-living with an emphasis on quality, compact neighbourhoods, transcends the land- use zoning and overarching policies of the Plan. The Plan pursues a sequential approach to securing a modal shift from private modes of transport to alternative modes in favour of walking, cycling and public transport. The settlement and retail strategy align closely with sustainable transport policies in this Plan.

3.2.6 Core Strategy and SEA / AA This Core Strategy has also been informed by Strategic Environmental Assessment (SEA) & Appropriate Assessment (AA), undertaken as parallel processes in tandem with each stage of the Development Plan, thereby ensuring full integration and consideration of environmental issues throughout the plan-making process. This represents a further iteration of environmental assessments at development plan level, given that the higher level RPGs has also been subject to a separate SEA & AA.

3.2.7 Delivering the Core Strategy

To deliver the Core Strategy a number of mechanisms will be employed as follows:

3.2.7.1 Area-Specific Plans Dublin City Council will prepare area-specific guidance for the Key Developing Areas and Key District Centres, using the appropriate mechanisms of Local Area Plans and Schematic Masterplans. Local Area Plans will be prepared for areas subject to large- scale development within the lifetime of this Plan. A schedule of statutory plans is set out below, having regard to the Core Strategy, in particular the need to promote the Inner City and the Key Developing Areas (KDAs), all of which lie within the Metropolitan Area (See Table 4). The rationale for selection of these plan areas also has regard to the national guidance that LAPs are particularly suited to areas undergoing significant development (DoEHLG Guidelines on Sustainable Residential Development, 2007).

Two Local Area Plans, for Phibsborough and the Liberties, were approved by the City Council in 2008 and 2009 respectively. In addition, there are a number of area-specific non-statutory Framework Plans in the City approved for Development Management and guidance purposes (See Appendix 1). A review will also be undertaken of a number of existing Framework Plans within the Inner City and for areas of significant development capacity in the Outer City.

Table 4: Schedule of Local Area Plans / Statutory Plans to Deliver the Core Strategy

1. North Fringe Review (LAP) 2. Ballymun Transboundary (LAP) 3. Pelletstown (LAP) 4. Park West / Cherry Orchard (LAP) 5. Docklands (DDDA Masterplan & Section 25s) 6. Heuston & Environs (LAP) 7. Grangegorman (SDZ)

3.2.7.2 Zonings and Standards The zoning and standard provisions of this Plan have been devised to support the delivery of the Core Strategy. In particular, the zoning provisions ensure adequate land to meet the population targets and economic role of the City as the National Gateway; intensification along public transport corridors and a mixed-use approach to zonings (Z4, Z5, Z6, Z10, Z14) to underpin a compact and sustainable city The standards reinforce this approach with clear guidance for quality residential development, successful neighbourhoods and green infrastructure as essential elements of the intensification of the City.

3.2.7.3 Framework for Sustainable Dublin To make sure that the Core Strategy reduces the city‟s eco-footprint and addresses the key factors of climate change, it will be delivered through a systematic approach to sustainability. This approach – the Framework for Sustainable Dublin (FSD) - is based on best international practice and is tailored to the needs of Dublin City. The approach places sustainability along with the six-themes as the over-arching philosophy that informs the Core Strategy and all the policies and objectives of the Development Plan. It also recognises the need for collective support and a partnership approach to successfully achieve the Vision for a Sustainable City.

3.2.7.4 Monitoring Indicators This is a dynamic Plan that will be actively implemented. In order to consistently and properly track progress, priority is given to monitoring and implementing its strategies, policies and objectives. A set of measurable indicators to measure progress on the implementation of the Plan have been devised. The Strategic Environmental Assessment and Appropriate Assessment, which have informed the policies in the Development Plan, will also be monitored. An Annual Report to the City Council will be prepared to demonstrate progress. 3.2.7.5 Engagement with City Stakeholders Engagement around the vision and implementation of the Plan is essential to achieving a Sustainable Dublin. Through existing networks and bodies, engagement with citizens, thinkers, agencies and other stakeholders will be effected and a two-way communication on the Plan and its delivery will be established. The Council will also utilise mechanisms such as networks and new technologies to engage with as many people and communities as possible.

3.3 TRANSLATING THE CORE STRATEGY INTO DEVELOPMENT PLAN PRIORITIES For the purposes of guiding this Plan, both the long-term vision and the core strategy as set out above, can be translated into three strongly interwoven strands, to ensure Dublin becomes;

A compact, quality, green, well-connected city, which generates a dynamic, mixed use environment for living, working, social and cultural interaction A smart city, creating real long term economic recovery A city of sustainable neighbourhoods and socially inclusive communities

These three strands are essential to realise the deliver the core strategy for Dublin. The three strands are each made up of a number of priorities, as follows:

STRAND 1: A compact, quality, green, well-connected city, which generates a dynamic, mixed use environment for living, working and cultural interaction. PRIORITIES Shaping the City structure, including the Inner City Connecting and sustaining the City‟s infrastructure Greening the City Fostering Dublin‟s character and culture

STRAND 2: A smart city, creating real long term economic recovery PRIORITIES Making Dublin the heart of the region Revitalising the City‟s economy Strengthening the City as the national retail destination

STRAND 3: A city of sustainable neighbourhoods and socially inclusive communities PRIORITIES Providing quality homes in a compact city Creating good neighbourhoods and successful communities

The Core Strategy will guide development in both policy and spatial terms. Delivered together, the 9 priorities represent an integrated and holistic approach to the delivery of essential infrastructure and services within an over-arching sustainable framework. The Core Strategy supports the long-term vision for the City and will act as an important stepping-stone towards realising that longer term vision.

The application of the Core Strategy in spatial terms across the City is shown on the Core Strategy Map (Figure 2). 3.3.1 CORE STRATEGY STRAND 1

A compact, quality, green, well-connected city, which generates a dynamic, mixed use environment for living, working and cultural interaction.

3.3.1.1 Shaping the City – Urban Form and Structure (See Chapter 4) It is a central aim of the Core Strategy to consolidate and enhance the Inner City in order to augment its crucial role at the heart of the Capital City and the City Region. The Inner City of Dublin is the most connected destination in the Country and at international level, and supports a dynamic range of economic, educational and cultural clusters, together with a growing residential population. It is a central part of the Core Strategy to enhance the links between the existing and emerging clusters in the City, and to create synergies that extend along the three proposed innovation corridors into the wider region, as depicted on the Core Strategy map. The strategy in the last plan of extending the Inner City eastwards and westwards, towards the Docklands and Heuston respectively is now complemented with a strategy for the quality consolidation of the Inner City, protecting heritage while promoting diversity. The structure of the city will be augmented by the development of the Key Developing Areas (KDAs) and the Key District Centres (KDCs).

This key priority places a renewed emphasis on how quality urban design, based on the principles of good urban spaces, active streets, and a sustainable mix of uses will contribute to the vision of a compact, green city with an enduring economy and quality neighbourhoods.

An emphasis on the contribution that good streets and architecture can make to regeneration and a re-affirmation that Dublin will remain a predominantly low rise city with defined height in limited locations is also central to this priority. This Development Plan contains „Guiding Principles‟ in relation to the public realm, to good architecture and to those limited areas where higher buildings will be allowed.

3.3.1.2 Connecting and Sustaining the City’s Infrastructure (See Chapter 5) Connecting the City through a network of transport infrastructure that makes it easy to move around and, by making it accessible allows the City to intensify and grow. Providing infrastructure that delivers essential services in an effective and sustainable way is essential to the efficient functioning and development of the City. These infrastructures underpin and facilitate the delivery of all the other priorities.

Movement and Transport In order to create a more sustainable City, this priority pursues a modal shift from private modes of transport, to public transport, cycling and walking and extends the use of Travel Plans. It prioritises the delivery of proposals under Transport 21 and seeks to progress strategic projects in conjunction with the National Transport Authority. It is also a priority to facilitate sustainable accessibility and legibility within the City Centre by-recasting the public domain in favour of the needs of pedestrians, the mobility impaired and cyclists, as well as the creation of a network of strategic green routes within the City and extending into the Region, catering also for recreational and amenity needs and quality of life as part of a compact city.

Services Infrastructure This priority places an emphasis on achieving a clean, healthy city with improvements in air and water quality and bio-diversity value, the use of renewable energy sources, green technologies and sustainable urban drainage systems as integral elements of the City‟s infrastructure. This emphasis on sustainable infrastructure will help to mitigate climate change, protect and improve watercourses and ecosystems and support the creation of a green network. The active pursuit of flood risk management strategies and sustainable urban drainage systems also enables the City to adapt to climate change. There is also strong support for the provision of wastewater facilities to allow the City to consolidate as a city region.

3.3.1.3 Greening the City – Landscape, Biodiversity, Open Space & Recreation (Ch 6) A key priority of this Development Plan is to re-inforce the importance of green infrastructure, recreation and biodiversity as a vital component of a compact city. The introduction of a green infrastructure strategy reflects an integrated approach to the City‟s open space, recreational, landscape and biodiversity assets.

Policies emphasise the importance of green corridors and connections between those areas, extending from the coast to the countryside.

Active and passive recreation as part of a healthy city is also promoted, in addition to recognition of the value of the two iconic sports stadia, Croke Park and Lansdowne Aviva to the City.

3.3.1.4 Fostering the City’s Character and Culture (See Chapter 7) Through this priority the Development Plan fully recognises that Dublin‟s built and natural heritage is both a major contributor to the City‟s character and is unique resource that attracts tourism and the creative economies. In developing the City‟s cultural resources, this priority positions Dublin City Council as the driver behind the new cultural strategy for the City, to promote the cultural alliances between the Arts Council and other cultural groups. This priority also provides for a concerted effort to upgrade the public domain in the City to facilitate festivals, events and enjoyable movement between the City‟s cultural attractions. There are also policies to promote artists accommodation in new development and to allow for cultural uses in residential areas.

The City‟s built heritage makes it unique. Key to the approach of this Plan is the balancing of the needs of a growing, dynamic city with the need to protect and conserve the elements that give the City its identity.

The Plan seeks to rejuvenate the North Georgian Squares to complement those on the south side. It is also proposed to extend the Architectural Conservation Area (ACA) designation to a number of late 19th Century terraced housing areas, where the character of the streetscape is of prime importance, rather than the interior of the individual houses. In these cases where a streetscape ACA is designated, individual properties which should be removed from the Record of Protected Structures will be identified.

3.3.2 CORE STRATEGY STRAND 2

A smart city, creating real long term economic recovery.

3.3.2.1 Making Dublin the Heart of the City Region (See Chapter 8) It is of crucial importance that Dublin, as the National Gateway, employing almost half a million people, generates the critical mass to operate as a city region in Europe and worldwide. Dublin must operate effectively at regional, national and international level to attract creative talent and foreign investment. It is only by developing a strong city region, with polycentric economic clusters around a central city core that the necessary critical mass to compete and collaborate with other cities can be achieved.

This approach forms the basis of this priority, together with the government policy for a „smart‟ economy. For the first time, the four Local Authorities in the Dublin City Region have collaborated to produce an Economic Development Action Plan for the Dublin City Region, which the respective Development Plans will help deliver. Other initiatives pursued in this Development Plan include three new economic corridors extending from the City Core into the sub-region, and a Creative Alliance between the business community, employment agencies, third level educational sector and the Regional Authority, which have multiple benefits for the whole country.

3.3.2.2 Revitalising the City’s Economy (See Chapter 9) This priority seeks to stimulate the long term economic renewal of the City, consolidating and strengthening the role of Dublin as the main economic engine in the state and putting Dublin at the heart of the region. Through the Framework for a Sustainable Dublin (FSD), it seeks to develop sustainable employment in the areas of innovation, digital industries, science and leading edge green / clean technologies.

This priority promotes three new innovation corridors radiating from the City Centre – Northwards to Dublin Airport, including clusters, knowledge, research and growth centres such as Grangegorman, the Mater, DCU and Ballymun Southwards from Trinity College to UCD, primarily as a knowledge and innovation corridor including RTE as the national media centre and St. Vincent‟s Hospital Westwards from Heuston, including the Digital Hub, NCAD, St. James Hospital, Park West, Cherry Orchard, the Naas Road Developing Area and extending into the wider Metropolitan Area to incorporate new urban centres such as Adamstown These three corridors form part of a proposed innovation network to lever growth across the city region, levering on and support government policy to foster innovation and a smart economy.

The land-use zoning provisions in this Development Plan provide a range of zones to cater for the diverse economic needs of the City. Strategic Z6 lands zoned for employment and enterprise uses will be retained for employment uses and lands zoned for mixed use have been extended to areas throughout the city. Live work units are promoted in a wide range of zones, all to facilitate employment, close to public transport. In this context and in the interests of clarity, the innovation corridors have no additional implications for zoning or standards.

3.3.2.3 Strengthening the City as the National Retail Destination (See Chapter 10) Despite the growth of suburban shopping centres, Dublin City still retains its position as the prime retail destination in the Region and the State. This priority of the Development Plan seeks to retain and indeed recapture market share through a variety of policies and initiatives, all in accordance with the Regional Retail Guidelines.

This priority will facilitate healthy competition by providing for a variety of floorplates in the retail core, without compromising the architectural quality or retail heritage of Grafton Street or O‟Connell Street, while promoting other streets to ensure vitality.

Making it easier to access the city centre retail core is an important element of this key strategy. It is proposed to develop linkages between the north and south retail cores, via the new bridges over the Liffey and via Westmoreland Street. The proposed Luas lines and DART underground will increase the connectivity of the city centre to the suburbs and should be exploited to attract more retail trade.

The creation of new streets and street based shopping is essential to the sustainability and expansion of the City‟s retail offer. The Development Plan supports the joint Business Improvement Districts (BIDs) initiative to improve the quality of the shopping streets in the city. Providing quality shopping facilities for neighbourhoods across the city is also recognised as essential for sustainable communities. This priority also identifies a number of Key District Centres in the Outer City where retailing will be promoted.

3.3.3 CORE STRATEGY STRAND 3

A city of sustainable neighbourhoods and socially inclusive communities

3.3.3.1 Promoting Quality Homes (See Chapter 11) Consistent with creating a compact city and with Dublin‟s role in the Region, the continued, sustainable management of land zoned for housing is a central element of this priority. This will be done in a way that reduces urban sprawl and provides for a quality compact city of mixed tenure neighbourhoods, catering for a wide range of family types, including older people. It is part of the Core Strategy to manage the release of the 503 Ha of zoned and serviced residential lands as a scarce resource and in a sustainable manner so that the housing needs of the City are met.

The provision of quality housing within the City, that is suitable for citizens throughout their lives and adaptable to people‟s changing circumstances is fundamental in creating a compact city with sustainable neighbourhoods. Requiring apartment schemes to have good local facilities, and that large schemes are phased to ensure support infrastructure is provided in tandem with residential development will assist in achieving this key strategy. An emphasis on effective property management for both apartment and housing complexes will also improve the quality of residential development. Expediting the regeneration of those disadvantaged areas which remain in the City as sustainable neighbourhoods is also central to this approach.

Providing quality homes for all citizens includes the provision of social and affordable housing. The delivery of the Housing Strategy contained within this Development Plan will help meet the needs of those on lower incomes and those in special circumstances across the city.

3.3.3.2 Creating Good Neighbourhoods and Successful Communities (See Chapter 12) The creation of good, sustainable neighbourhoods which support thriving communities and provide for a wide range of household types, age groups and tenures with community facilities close by is a priority of this Plan. In order to achieve this, criteria and standards for good neighbourhoods are a central part of this strategy. These Principles are intended to ensure, for example, that infrastructure such as schools, shops and childcare facilities are provided in a phased and co-ordinated manner. The creation of good neighbourhoods and socially inclusive communities applies to both the Inner and Outer City.

The importance of local neighbourhood shopping centres within walking distance of residential communities is re-affirmed in this key strategy. Guiding Principles to promote the regeneration of certain social housing areas into attractive mixed use neighbourhoods is also included in the Plan. Significantly, the Development Plan puts a new emphasis on Institutional Lands as an important community resource for the city in providing educational, recreational, community and health facilities, for both the city and local neighbourhoods. The Plan protects these lands as a strategic asset for the city.

The purpose of the above nine priorities is to ensure effective delivery of the Core Strategy. These priorities are elaborated on further in the following chapters of the Development Plan, with a range of supporting policies and objectives (See Chapters 4-12).

Chapter 4 Shaping the City Submission Number(s): 2003, 2006, 2008, 2011, 2012, 2014, 2019, 2033, 2052, 2072, 2074, 2075, 2079, 2107, 2114, 2119, 2123, 2133, 2157, 2164, 2167, 2168, 2171, 2184, 2189, 2199, 2200, 2201, 2204, 2235, 2241, 2242, 2243, 2251, 2252, 2254, 2255, 2259, 2261, 2267, 2271, 2291, 2293, 2298, 2312, 2333, 2608, 2609, 2610, 2611, 2612, 2613, 2614, 2615, 2616, 2617, 2618, 2619, 2640, 2645, 2653, 2664, 2757, 2769, 2790, 2792, 2794, 2807, 2809, 2811, 2815, 2836, 2837, 2841, 2860, 2869, 2875, 2884, 2891, 2892, 2893, 2897, 2900, 2918, 2926, 2942, 2950, 2957, 2960, 2965, 2966, 2974, 2975, 2990, 2995, 2997, 3003, 3006, 3008, 3019, 3021, 3026, 3033, 3034, 3040, 3041, 3046, 3077, 3080, 3081, 3094, 3096, 3101, 3107, 3124, 3135, 3142, 3149, 3158, 3159, 3161, 3162, 3164, 3165, 3167, 3171, 3182, 3202

Section: 4.3 The Strategic Approach

Summary of Issues The issues raised relating to the strategic approach taken in the Plan covered a broad area. Some supported the approach taken and were in agreement on the challenges facing the city. Others state that the Plan appears overly focused on developing areas such as Docklands, Pelletstown and the North Fringe and does not prioritise established areas such as Clontarf in terms of transport, green areas etc. The expansion of green infrastructure is requested. Strategic Development Zones (SDZs) are suggested as a mechanism to be used to achieve sustainable planning, organisation and development for new Dublin City Regions. The protection of the city‟s unique character, scale and density is highlighted as a key issue with a wish for Dublin to remain predominantly a low rise, high density city. The National Disability Authority requests that the Plan reference the National Disability Strategy, the Barcelona Declaration and the UN Convention on the Rights of Persons with Disabilities. Manager's Response The designation of areas or sites as SDZs (such as the proposed Grangegorman SDZ) is a function of Government. The strategic approach taken in the Plan is to promote sustainable mixed use development in appropriate areas of the city through land use zoning and through designations such as Key Developing Areas, Key District Centres. This strategic approach is further enhanced through the use of local area plans and other land use plans which deliver area specific guidance, and are considered to be the appropriate mechanism to provide a robust framework for future development in the city. The Plan sets out that land use plans will be prepared for both the inner and outer city over the life of the Development Plan. This approach will safeguard existing character and ensure future development has regard to existing urban form and structure. Given that Chapter 4 deals strategically with forming and shaping the city, it is not considered appropriate to incorporate the comments of the NDA here, as these matters are dealt with throughout the Plan. (Section 17.7 and Appendix 20) Manager's Recommendation Retain as existing. Section: 4.4.1.1 Approach to the Inner City (see glossary)

Summary of Issues A large proportion of submissions received relate to the provision of land use plans including local area plans. Some submissions support the approach taken while many suggest further areas of the city which would be suitable for the development of area specific plans such as Ballybough, Rialto or Rathgar. Submissions seek a commitment to the implementation of existing and future plans. It is also requested that clarity is given with respect to the role or primacy of the Local Area Plan in the overall planning hierarchy.

Submissions raise the issue of dereliction and vacant buildings. A number of innovative suggestions for future uses are proposed such as use for allotments or urban agriculture. Other submissions highlight measures to stimulate redevelopment such as the residential use of upper floors of buildings.

A number of submissions seek the amendment of Maps or „Figures‟ in the Development Plan to provide greater clarity and detail in relation to the information displayed, to correct discrepancies or inconsistencies or to include new information such as pedestrian routes or character areas. Manager's Response To deliver the Core Strategy, a number of Local Area Plans, Schematic Masterplans and other land use plans will be prepared based on necessity, priority and resources over the life of the Development Plan. The plans identified have been chosen strategically and are set out in the Development Plan at page 19, 30 and 250. Plans will not be prepared for every area of the city in an uncoordinated way. Two Local Area Plans, the Phibsborough and the Liberties LAPs, were approved by the City Council in 2008 and 2009 respectively and have been incorporated in the Draft Plan. Plans will be implemented in accordance with Dublin City Council‟s corporate approach which is currently being drawn up.

The Planning and Development Acts state that Local Area Plans must be consistent with the provisions of the Development Plan. Decisions on planning applications must indicate compliance with the provisions of the Local Area Plan in force, in addition to the Development Plan. Where a Local Area Plan conflicts with the provisions of a Development Plan, the provision of the Local Area Plan ceases to have effect. Local Area Plans are subordinate to Development Plans.

There are a number of policies, objectives and standards in the Plan which provide sufficient emphasis to facilitate the redevelopment of vacant, derelict and underutilised sites in the city. Objective SCO4 commits Dublin City Council to carry out an audit of vacant and derelicts sites in the city and to expedite their redevelopment and reinstatement as part of the city. Policy GC15 sets out that Dublin City Council will support the provision of community gardens/allotments/ local markets/pocket parks, where feasible and in particular as temporary uses on vacant, under-utilised or derelict sites in the city. Section 17.9.7 states that standards for infill housing may be relaxed by the Planning Authority Infill Housing in the interest of ensuring that vacant, derelict and underutilised land in the inner and outer city is developed.

The „Figures‟ in the written text of the Development Plan are schematic by nature in order to graphically illustrate how different elements of the Plan vision will be implemented in abstract rather than realistic terms to aid comprehension. The vast majority of submissions related to the specific detail of the content and would not readily illuminate the information set out if included. Manager's Recommendation Amend Figures 3, 4 and 5 in the Plan to introduce greater clarity and provide the most up to date information available.

Section: 4.4.1.2 Approach to the Docklands and Port

Summary of Issues The key issues raised in the majority of submissions relate to the treatment of Dublin Port in the Plan, with particular concern that the approach would give rise to uncertainty and divert investment. Concern was expressed regarding suggestions that the port will be relocated with many submissions opposed. Some submissions express support for the relocation of the port. Manager's Response The Draft Plan does not propose a relocation of Dublin Port but seeks to plan for the medium to long term vision to relocate the port elsewhere in the region as set out in the Dublin City Council Study, Dublin Bay, An Integrated Economic Cultural and Social Vision for Sustainable Development (2007). In view of the concerns raised in the submissions, it is proposed to reemphasise the importance of Dublin Port to the City in the Development Plan. It is also proposed to omit the reference to the fact that proposals regarding the Port will be dependent on an outcome from the Dublin Bay Task Force.

See also Section 17.22. Manager's Recommendation Replace third paragraph of Section 4.4.1.2 with the following;

Dublin City Council fully supports and recognises the important role of Dublin Port in the economic life of the city and the Region and the consequent need in economic competitiveness and employment terms to facilitate port activities which may involve port development or relocation in the longer term. Dublin Port will have a significant role to play in the future development and growth of the city and it is considered prudent to plan the structure of this part of the city, including the proposed public transport network, to fully integrate with the developing new city structure and character, while having regard to the Dublin City Council Study, “Dublin Bay, An Integrated Economic Cultural and Social Vision for Sustainable Development (2007)”.

Replace first bullet point of 17.22 to omit reference to Dublin Bay Task Force. New wording will read as follows;

Recognition of the important role of Dublin Port in the economic life of the City and the Region and the consequent need in economic and employment terms to facilitate port development or relocation.

See also Section 17.22.

Section: 4.4.2.1 Approach to the Inner Suburbs and Outer City

Summary of Issues The submissions request the removal of all references to economic corridors in the Plan as it is stated that applicants will seek to utilise this concept to gain an increased intensity of development in these locations to the detriment of local character. Once submission calls for the introduction of a further corridor to the east.

A number of submissions refer to Objective SCO9 and call for identified Schematic Masterplans or Village Improvement Plans to be prioritised or expanded. Other submissions request the inclusion of further areas such as Kilbarrack or Donaghmede. Manager's Response Economic Corridors are defined in the Plan as routes connecting a number of centres between which frequent interactions in business occur. Economic Corridors have no land use zoning implications. The Manager‟s Response to Motion 1018 et al. included a statement that in the Draft Plan, the designation of the three economic corridors does not have any additional implications in terms of zoning or standards. Given that the corridors are a mean of progressing innovation and research, between the universities and business, it is considered more accurate to call these corridors „Innovation Corridors‟. In the interests of clarity, a text amendment will be introduced to state that these innovation corridors have no implications for departures from general zoning or standards provision. Please refer to section 3.2.2.2 of the Managers Report for further detail.

Schematic Masterplans or Village Improvement Plans have been identified strategically and will be prepared based on necessity, priority and resources over the life of the Development Plan. It is not considered appropriate to increase the number of Plans based on the submissions received and the planning rationale set out. Manager's Recommendation Replace the phrase „Economic Corridors‟ with „Innovation Corridors‟ throughout the Plan.

Refer also to Manager‟s Recommendation at Chapter 3, Section 3.2.2.2.,Chapter 9, Section 9.4.4, and Chapter 8, Section 8.4.5.

Section: 4.4.3.1 Urban Density

Summary of Issues A large number of submissions raise issues that relate to overall policy on density. Submissions received in support of policy on density consider that increased density can be a way to consolidate the City and tackle urban sprawl. Support is conditional on high quality design, where increased density will not impact on the surrounding character and will be determined by the existing pattern and scale of development in an area.

Submissions opposed to increased densities state that Dublin is not a low density city and is already higher in density than cities such as Amsterdam, Stockholm and Copenhagen. There is concern that increasing densities will negatively impact on the character and scale of existing areas, and are in fact unnecessary given the amount of vacancy in the city. It is requested that policy guidance on density be amended to ensure any increase in density will not impact negatively on the surrounding environment. Manager's Response Section 4.4.3.1 of the Plan sets out general policy on density. It is clearly set out that increased sustainable densities will be promoted in line with national and regional requirements to consolidate the Dublin Metropolitan Area given the diminishing supply of undeveloped land in the city and that in all cases, appropriate density levels are dependent on scheme design, location and context. A number of safeguards have been built into the Plan at Chapter 17, including the criteria and standards for good neighbourhoods, quality urban design and excellence in architecture. The sustainable densities set out will therefore ensure due consideration is given the protection of surrounding residents, households and communities in any development proposal. Manager's Recommendation Retain as existing.

Refer also to Chapter 17.

Section: 4.4.4.1 Approach to Taller Buildings

Summary of Issues A large proportion of the overall submissions received relate to taller buildings. Similar to the submissions received on density, some express support for the policy set out while other express strong opposition. Submissions in support state that well designed taller buildings can enhance the city, provide landmarks, are necessary to facilitate economic development and can support the provision of public transport infrastructure. Some of the submissions call for higher maximum permitted heights as the height limitations set out could impact on the development of the city from an economic and social perspective, driving development outside of the city and the country.

Submissions opposed to the policy to guide the development of taller building in the city raise a broad and varied range of issues. In summary the majority of submissions support maintaining the low rise character of Dublin. There is clear objection to the development of taller buildings as it is felt that this will impact on heritage, character and residential amenity. Further submissions seek a refinement of policy and introduction of safeguards to protect sensitive areas or protected structures where height must be determined with reference to existing heights in the area or by some other measure. Manager's Response Section 4.4.4.1 sets out the overall policy approach to taller buildings in the city. The strategic policy approach taken is considered to be balanced, reasonable and equitable, acknowledging Dublin as a low rise city while also recognising the importance of Dublin City as a capital city, competing with other city regions internationally. The policy approach is to maintain the city as low rise, including residential and conservation areas, and to provide for taller buildings in a very limited number of identified and appropriate locations in order to promote investment, vitality and identity. Taller buildings are confined to certain areas precisely so the low rise character of the overall city can be retained. The protection of Dublin as a predominantly low rise city is enshrined in the policy guidance and safeguards set out in Section 4.4.4.1, and in tandem with Chapter 17 provide a framework to adjudicate on the many development proposals for taller buildings that will arise over the life of the Development Plan. It is essential that the Development Plan provide a robust policy framework to respond to such proposals in a coordinated manner. Manager's Recommendation Retain as existing.

Refer also to Chapter 17, Section 17.6. Section: 4.4.5 The Public Realm

Summary of Issues The submissions received raise a variety of issues considered relevant to the Public Realm including maintenance, street cleaning, anti-social behaviour, creation of new civic spaces and the improvement of existing spaces. In particular, litter and antisocial activities on the Liffey Quays are highlighted as having a negative impact on tourism. Some submissions suggest improvements that will enhance the public realm such as flower planters, benches and publicly accessible viewing platforms to key buildings such as Liberty Hall. Manager's Response The public realm encompasses a variety of elements including public owned streets, parks, publicly accessible spaces, as well as civic buildings and facilities. Policy guidance related to the Public Realm in the Development Plan has been formulated to respond to the issues raised, which in general terms are recognised as major barriers to the promotion of Dublin City a clean, safe attractive environment for tourists and the city‟s varied communities. The development of the Public Realm Strategy (as set out at SCO10) in addition to other objectives will address issues of design, delivery, maintenance and management, in addition to identifying specific projects that will radically improve the pedestrian experience. Issues such as street cleaning, policing and maintenance are beyond the remit of the Plan but are recognised as key issues in the experience of the public realm. Manager's Recommendation Retain as existing.

Section: 4.4.6 Outdoor Advertising Strategy (See Appendix 25 and Fig. 22)

Summary of Issues The submission on this issue wishes the Development Plan to address the issue of garish, neon signage on shopfronts in Architectural Conservation Areas. Manager's Response Section 4.4.6 of the Development Plan outlines that a strategy has been developed for commercial advertising in the public domain. This is included at Appendix 25 and will form the basis of a practical policy to be applied to all proposals for outdoor adverting, including that which is located in an Architectural Conservation Area. In addition, national legislation governing Architectural Conservations Area is sufficient in scope to deal with advertising that is deemed to be inappropriate. Manager's Recommendation Retain as existing.

Section: 4.4.7 Pedestrian Wayfinding System

Summary of Issues The submission relating to this issue is supportive of the proposed pedestrian wayfinding system. Manager's Response The comments made in the submission are noted. Manager's Recommendation Retain as existing.

Section: 4.4.9 Urban Form and Architecture

Summary of Issues The Office of Public Works (OPW) states that the plan should acknowledge and promote the government policy on architecture as set out in „Government Policy on Architecture 2009-2015‟ and advises that higher quality architecture can give greater distinctiveness to the built environment.

The remaining submissions request that Dublin City Council retain a list of architecturally poor buildings for prioritised redevelopment, restrict the amount of development by single architects and turn the North Quays into a tree lined boulevard. Manager's Response It is considered appropriate to reference „Government Policy on Architecture 2009-2015‟ on foot of the submission made by the OPW. The retention of a list of architecturally poor buildings and restriction on the amount of development carried out by single architects is legally beyond the power of the Development Plan. Objective SCO1 states that Dublin City Council will prepare a Local Area Plan for the Liffey Quays in the lifetime of this Plan in order to develop the public realm of the river and anchor it as a central civic spine. Detailed design proposals will be considered in this future plan. Manager's Recommendation Insert the following as an additional paragraph at Section 4.4.9 Urban Form and Architecture;

The Government Policy on Architecture 2009-2015 seeks to promote awareness and understanding of the contribution of good design to civic life. It recognises that architectural quality is measured by a building‟s contextual and environmental response in addition to the aesthetic qualities of the individual building. The policy places an emphasis on the imperative to develop and maintain communities in a sustainable manner through the protection of the built heritage, the adaptation and reuse of the existing building stock, the application of urban and landscape design, urban and building conservation and architectural quality criteria at every level in the planning process. Dublin City Council will assist the Department of Environment, Heritage and Local Government in the implementation of the actions identified over the life of the Development Plan.

Chapter 5 Connecting and Sustaining the Citys Infrastructure Submission Number(s): 2003, 2008, 2010, 2017, 2024, 2028, 2035, 2036, 2037, 2039, 2040, 2043, 2044, 2047, 2054, 2057, 2058, 2059, 2061, 2062, 2063, 2064, 2065, 2067, 2068, 2072, 2075, 2086, 2092, 2095, 2100, 2105, 2106, 2109, 2110, 2114, 2115, 2118, 2122, 2123, 2124, 2131, 2136, 2153, 2154, 2155, 2156, 2160, 2162, 2164, 2167, 2197, 2199, 2204, 2205, 2209, 2210, 2211, 2212, 2229, 2235, 2249, 2252, 2253, 2254, 2258, 2261, 2270, 2271, 2278, 2291, 2293, 2297, 2298, 2327, 2333, 2604, 2620, 2622, 2626, 2627, 2629, 2647, 2648, 2653, 2654, 2655, 2664, 2669, 2673, 2675, 2677, 2695, 2745, 2761, 2762, 2763, 2769, 2770, 2780, 2783, 2784, 2786, 2787, 2788, 2790, 2794, 2795, 2800, 2802, 2807, 2809, 2810, 2811, 2813, 2814, 2815, 2819, 2820, 2827, 2829, 2831, 2834, 2836, 2837, 2838, 2847, 2848, 2871, 2872, 2874, 2876, 2881, 2884, 2891, 2892, 2897, 2899, 2900, 2902, 2908, 2909, 2910, 2911, 2912, 2914, 2918, 2932, 2935, 2938, 2943, 2944, 2945, 2950, 2952, 2955, 2956, 2959, 2965, 2966, 2967, 2968, 2972, 2973, 2974, 2976, 2977, 2978, 2983, 2987, 2996, 3000, 3001, 3003, 3017, 3018, 3019, 3023, 3024, 3025, 3026, 3027, 3028, 3032, 3034, 3035, 3041, 3061, 3069, 3094, 3096, 3100, 3101, 3124, 3132, 3142, 3143, 3144, 3147, 3149, 3153, 3158, 3159, 3164, 3167, 3169, 3184, 3193, 3212, 3213

Section: 5.1 Movement and Transport

Summary of Issues The Department of Transport welcomes the references to the Smarter Travel Policy in Chapter 5. It is requested that reference be made to the policy at the outset of the document and also in Appendix 2 as part of National, Regional and Local Guidance.

The Strategic Transport Plan „2030 Vision‟ is being developed by the National Transport Authority for the Greater Dublin Area and will be a key influence on transport planning in the region when completed. It is requested that reference to the „2030 Vision‟ and its potential impacts for Dublin City Council should be made in Chapter 5. Manager's Response Dublin City Council has prepared the Draft Plan in the context of the new Government policy framework „Smarter Travel - A Sustainable Transport Future‟ which represents a new transport policy for Ireland for the period from 2009 - 2020. Dublin City Council recognises that the National Transport Authority‟s forthcoming „2030 Vision‟ will be a long-term plan for transport in the Greater Dublin Area and will be at the heart of all transport planning in the region. It is considered necessary to amend the Draft Plan to strengthen linkage to „Smarter Travel - A Sustainable Transport Future‟ and to „2030 Vision‟. Reference to the Smarter Travel Policy in Appendix 2 of the Plan has been provided for Chapter 1 of this report. Manager's Recommendation Insert new text at chapter 5, Section 5.1 after the 2nd paragraph as follows: 2030 Vision is the name given to the Strategic Transport Plan being developed by the National Transport Authority (NTA) for the Greater Dublin Area. It will be at the heart of all transport planning in the region until 2030 and will replace the Dublin Transportation Office‟s, „A Platform for Change‟. Dublin City Council will take the necessary steps ensure the Dublin City Development Plan is consistent with the NTAs „2030 Vision‟.

See also Chapter 1, Section 1.1 Manager's Recommendation.

Section: 5.1.2 Challenges

Summary of Issues A key issued raised in the submissions is the stated inconsistency of the Draft Plan with the provisions of the Regional Planning Guidelines and the Dublin Transportation Office‟s „A Platform for Change‟ with respect to proposals to relocate Dublin Port and the role of Dublin Port as the Plan solely considers the movement of people and not the movement of goods. In addition, by proposing the relocation of Dublin Port, Dublin City Council is not assisting the Government in meeting its Kyoto obligations as highlighted in the Indecon Report which shows the relocation of the port will have significant increases in CO2 emissions.

An Taisce considers that the main action Dublin City Council needs to undertake is the maintenance of road surfaces, with particular emphasis on regular inspections by cycling engineers. The situation has become acute in 2010 with cyclists now discouraged from using this mode due to the widespread presence of potholes and ruts. A specific policy/objective of the Council must therefore be to maintain road and street surfaces highlighting that cyclists and pedestrians are most discouraged and discommoded by such deterioration. Manager's Response The strategic and future importance of Dublin Port is recognised in Chapter 4, "Shaping the City", Chapter 8, „Making Dublin the Heart of the Region‟ and in Chapter 17, „Development Standards‟ of the Draft Plan and is dealt with in greater detail in the Manger‟s Report under those headings. Section 5.1.2 deals with the movement of people with respect to the challenge of reducing reliance on the private car in favour of more sustainable travel modes. Section 5.1.4.9 deals with traffic management in the city and includes sufficient and appropriate policy/objectives to address the varying needs of the city through the day including service, delivery and the movement of goods in order to ensure accessibility.

Dublin City Council is committed to improving cycling and pedestrian facilities over the lifetime of the Development Plan throughout the Dublin City Area and recognises that there is a direct correlation between the quality and actual usage of such infrastructure. The Draft Plan already contains sufficient policy and objectives at Section 5.1.4.4 and 5.1.4.5 relating to the improvement of cycling and pedestrian infrastructure. The day to day maintenance of such infrastructure is an operational matter and beyond the scope of the Development Plan which much remain strategic in its focus. Manager's Recommendation Retain as existing.

Section: 5.1.3 The Strategic Approach (See Fig. 6, 7, 8.)

Summary of Issues The issues raised with the Strategic Approach taken with respect to movement and transport are varied. An Taisce considers that the City Council should stop planning for a growth in overall journeys within the city, but start planning for a decline in journeys and especially in car usage, and the evolution of self-sustaining neighbourhoods within the city. Infrastructural resources should prioritise zero and low energy transport forms, i.e. cycling and walking. There should be an increase width of bus and cycle lanes and allocation of dedicated bus lanes for the entire length of the route wherever possible.

Other submissions seek a recognition of the link between urban village planning and public transport, as well as the need for a link between the local government structure and the existence of 'urban villages'. It is stated that these „urban villages‟ need to be served by a mesh-like route map of transport. This would counteract the congestion caused by the private car. It is stated that the Draft Plan should provide a hierarchy of transportation priorities beginning with integration and inter-connection of existing public transport services, improvement of all bus services, including QBCs and finally Metro North.

The potential of water based transport to the Liffey, Dublin Port and to Dublin bay is raised. It is considered that greater priority should be given to the utilisation of the Liffey as a mode of transport and to the use of water ferries for commuters from Dun Laoghaire to Dublin Port / Malahide or Howth, or on the River Liffey. Manager's Response The Draft Plan is fully focused on the integration of land use and transportation to reduce the need to travel and facilitate successful and sustainable mixed use urban development. Section 5.1.3 sets out the strategic approach to tackling congestion and promoting more sustainable development and travel patterns. Policy SI1 sets out how Dublin City Council will link land use and transportation to accommodate the movement needs of the city in a sustainable manner, thereby reducing reliance on the private car.

The Draft Plan only caters for a growth in passenger journeys through sustainable transport modes, walking and cycling in accordance with the Government‟s Smarter Travel- A Sustainable Transport Future. The effective integration of land use and transport as proposed in the Plan will generate and reinforce sustainable settlement patterns and minimise the need for and use of the private car. The prioritisation of resources for transport projects as well as detailed elements of infrastructural works is a matter beyond the strategic remit of the Plan.

Given the limited potential of the Liffey to act as a potential transport mode within the Plan area, the policy approach taken is to harness the full potential of the city‟s landscape structure to create a continuous green network at a strategic scale on a city and regional level. This will involve the creation of new opportunities for public access and pedestrian and cycle linkages and routes between key amenity resources such as the River Liffey and Dublin Bay. It is an objective of the Draft Plan to prepare a Local Area Plan for the Liffey Quays in order to develop the public realm of the river and anchor it as a central civic spine. In the Docklands area, where the Liffey is fully navigable, the potential for water based transport is being exploited through the DDDA Master Plan. Tourist ferries are supported on the Liffey while commuter ferries operated until the opening of the new Samuel Beckett Bridge. Within the city, Transport 21 infrastructural works will deliver a fully integrated transport system for Dublin. Manager's Recommendation Retain as existing. Section: 5.1.4.1 Integrated Land Use and Transportation

Summary of Issues The National Transport Authority highlights that various large scale public transport projects are provided for under Transport 21. In this context the National Transport Authority would recommend that the Development Plan include a policy which states that areas around the busiest interchanges, nodes and stations be guided by development frameworks for interchanges.

There is concern regarding the achievement of true landuse and transportation integration. Integrating land use and transportation planning and development is seen as one facet of achieving 'smart growth' and healthy sustainable development. It is recommended that Dublin City Council prepare a Land Use and Transportation Study to accompany the Plan in order to effectively evaluate how its land use decisions effect the transportation system and provide viable options for people to access goods, and services, thus improving their quality of life.

Submissions highlight that SIO1 should be a policy rather than an objective suggesting the addition of additional wording that future transportation networks fit into the existing character of housing and other buildings along route corridors. Manager's Response It is proposed to introduce new text in line with policy recommendation of the National Transport Authority.

The Draft Plan has been produced in compliance with the Development Plan Guidelines for Planning Authorities 2007 (DoEHLG), addressing the key areas of interrelationship between land use and transportation. The land use and transportation strategy set out in the Plan takes an integrated approach to land use considerations and the transport policies and objectives set out in Chapter 5, Connecting and Sustaining the City‟s Infrastructure, have been informed by and are consistent with national and regional guidelines. Ongoing monitoring and evaluation of the Plan as provided for in Chapter 13, Implementation, will ensure the means by which the city‟s progress towards sustainability can be effectively measured and evaluated.

Objective SIO1, which is supported by Policy SI1, is specific, measurable and achievable, and therefore fulfils the requirements for classification as an „objective‟ of the Plan. The difference between policy and objective is further elaborated in the Glossary of the Plan. The addition of further „development‟ guidance in Objective SIO1 is not warranted having regard to the interlinkage between each section of the Plan and in particular to Chapter 16, Guiding Principles and Chapter 17, Development Standards which must be complied with in the case of all development proposals. Manager's Recommendation Amend Objective SIO1; From: To encourage intensification and mixed use development along public transport corridors and at transport nodes where sufficient public transport capacity and accessibility exists to meet the sustainable transport requirements of the development, having regard to the conservation policies (including the Z2 Conservation Areas) set out elsewhere in the Plan.

To: To encourage intensification and mixed use development along public transport corridors and at transport nodes where sufficient public transport capacity and accessibility exists to meet the sustainable transport requirements of the development, having regard to the conservation policies (including the Z2 Conservation Areas) set out elsewhere in the Plan. Dublin City Council will seek to prepare LAPs or Schematic Master Plans at key transport nodes where deemed appropriate in order to guide future development and to safeguard investment in public transport infrastructure.

Section: 5.1.4.2 Promoting Modal Change

Summary of Issues The submissions highlight a number of approaches that could be taken to promote greater modal change in the city. It is suggested that Dublin City Council should introduce a car free zone in certain areas of the city centre, possibly one Sunday every month in order to encourage cycling and enable families to cycle, roller-blade or walk along the Liffey Quays or around the city centre. Further approaches include the introduction of congestion charging for driving into the city centre, new technologies that facilitate commuter car sharing, greater maintenance of road surfaces, reduction in speed limits, extension of the 30kph zone and various traffic claming measures to enhance cycling and walking. Manager's Response The Draft Plan promotes modal change to sustainable transport options through the delivery of enhanced public transport, pedestrian and cyclist infrastructure. The introduction of a „car free day‟ in the city centre would have many implications beyond the scope of the Plan and would be more appropriately dealt with through the relevant Strategic Policy Committee to enable a citywide debate to be undertaken on the proposal. The emphasis of Objective SIO2 (to investigate car clubs) is considered sufficient. The issue of road works and maintenance is an operational matter and beyond the strategic scope of the Development Plan. Any extension or alteration of the 30kph speed limit would also be more appropriately debated through the Strategic Policy Committee in advance of full Council consideration. Manager's Recommendation Retain as existing.

Refer proposal for car free day to Transportation and Traffic Strategic Policy Committee.

Section: 5.1.4.3 Public Transport

Summary of Issues Many of the submissions received relate to Transport 21 Projects such as Metro North, Luas Extension and the Dart Underground and the need for public transport improvement generally. The main theme across the majority of these submissions is the key requirement to achieve an integrated and comprehensive public transport system for the city within the life of the Development Plan as a priority by 2017. It is stated that this could be achieved by linking the Luas Red and Green lines and with the completion of the Metro, amongst other measures such as network expansion.

There is concern that proposals for Luas and Dart Underground will only serve limited areas and will not deliver access to public transport for all areas of the city. Network expansion or delivery of local bus services, bus rapid transit or other rail connections could provide much needed connectivity.

The Railway Procurement Agency note Policy SI5 which states that any proposed future Luas line in the vicinity of Brighton Square and Brighton Road residential conservation areas must have full regard to the conservation and amenity value of the conservation area and that this be reflected in any EIS. It is stated as „unusual‟ that there is a particular policy for this conservation area over other conservation areas in the city. The Agency are disappointed that this policy was included in the Draft Plan. Others submissions ask for the expansion of Policy SI5 to cover further areas of the city or the removal of proposed Luas routes from Brighton Square and Brighton Road altogether.

Iarnród Éireann express support for the provisions of the Draft Plan and have highlighted a number of areas that could be refined such as Section 3.2.1.2 which should to refer to „Inchicore and Docklands‟ not „Heuston and Connolly‟ and a reference to a Suburban Rail Interconnector which has been renamed as the Dart Underground.

Some of the submissions received object to elements of the Transport 21 proposals due to possible disruption that may be experienced during the construction and operational phase of projects, or to dereliction along route corridors that may occur due to delays in delivery. The concerns are generally raised by business owners.

The introduction of integrated ticketing and the provision of realtime travel information systems across all transport modes is seen as essential to motivate greater modal change to public transport.

A key concern also raised is the quality of the bus service in the city with calls for a full Dublin Bus network re-evaluation. Some of the submissions raise issues related to specific route proposals or alterations, or to the parking and management of the fleet on a day to day basis. There are also submissions which advocate proposals for enhanced QBC design in the form of Bus Rapid Transit schemes or strategies. Dublin Bus in particular advocates that enhanced QBC design in the form of Bus Rapid Transit should feature in the Plan. The Quality Bus Network Project Office supports policies and objectives that relate to Bus Priority. It is suggested that Policy SI18 be reworded to include reference to 'bus priority measures'.

A number of submissions seek the amendment of Map J and other „Figures‟ of the Development Plan to provide greater clarity and detail in relation to proposed and existing transport routes, linkages and stations.

There is a call for some Park-and-Ride site within the City boundaries, but outside the canals. Donnybrook Bus Garage is suggested as an ideal location.

It is stated that the Draft Plan sets very unrealistic targets for modal shift to public transport. The core objectives of Transport 21 and proposals for an Eastern Bypass must be integrated in the Development Plan before these targets can be reached. Manager's Response Dublin City Council is not directly responsible for public transport provision. The provision and improvement of public transport, including Transport 21 projects such as the Metro and Luas falls under the remit of other agencies such as Dublin Bus, Irish Rail, the Railway Procurement Agency and the National Transport Authority. Dublin City Council has pledged support for the Transport 21 programme in the Development Plan by seeking to facilitate public transport provision and improvement through measures such as promoting land use policies which support public transport including higher density sustainable development at public transport corridors and nodes, as well as other traffic management measures. Dublin City Council will work with the National Transport Authority, transport providers and communities to ensure the delivery of a reliable, accessible and integrated public transport system that supports the effective functioning of the city. Dublin City Council will manage restrictions on the use of road space during construction works to mitigate the impact of Transport 21 project construction as per Section 5.1.4.9 of the Plan. Matters and clarifications raised by service providers, etc will be taken on board as a matter of course.

Policy SI5 which refers to Brighton Square and Brighton Road was included in the Draft Plan by way of Councillor‟s Motion at the Special Meeting of the City Council on the 25th November 2009. In view of the RPA submission, it is considered appropriate to omit the policy.

Policy SIO4 commits Dublin City Council to the facilitation and implementation of Integrated Ticketing and Real Time Passenger Information systems across the public transport network in association with relevant transport providers and agencies. The Railway Procurement Agency currently has responsibility for the development of integrated ticketing. Dublin City Council is collaborating with Dublin Bus to implement an infrastructure of bus stop information display units that will display real time predictions of bus arrival times at bus stops. Dublin Bus is currently carrying out a fundamental network review.

In view of the submission made by Dublin Bus it is considered relevant to include a policy regarding the feasibility of developing Bus Rapid Transit Systems within the Greater Dublin Area.

Policy SI18 deals with road capacity improvements with an objective to provide provision for public transport considerations. The existing wording is considered sufficient to encompass „bus priority measures‟ as part of public transport provision.

Relevant Map and Figures in the Plan will be amended to indicate the full extent of Transport 21 public transportation proposals in addition to existing routes and to provide greater clarity and legibility where necessary.

Objective SIO6 supports the provision of Park and Ride facilities at suitable locations in liaison with other Local Authorities.

The targets for modal shift to public transport at section 5.1.2 were introduced to the Draft Plan by way of Councillor‟s Motion at the Special Meeting of the City Council on the 25th November 2009. Manager's Recommendation Amend Section 3.2.1.2 From: Connolly to Heuston

To: Docklands to Inchicore.

Amend Appendix 2, Page 253 From: Suburban Rail Interconnector

To: Dart Underground. Add additional Policy after SIO7 To support relevant transport agencies, providers and adjoining local authorities in assessing the feasibility of developing Bus Rapid Transit systems within the Greater Dublin Area.

Amend Figures 2 and 7 to indicate the full extent of Transport 21 public transportation proposals in addition to existing routes and to provide greater clarity and legibility where possible.

Omit Policy SI5. That any future proposed Luas Line in the vicinity of Brighton Road / Brighton Square Residential Conservation Areas, must have full regard to the conservation and amenity value of the Conservation Area and that this should be reflected in any Environmental Impact Statement.

Section: 5.1.4.4 Cycling

Summary of Issues The majority of submissions with issues pertaining to cycling consider that it is essential that high quality and well maintained cycle routes are developed within the city. The quality of existing cycling infrastructure is considered to be unacceptable with a high level of dissatisfaction expressed regarding the quality, design and safety of existing routes, in addition to actual route location. Support is expressed for new routes and various measures to incentivise cycling and generally to create a route network and city environment that is amenable to cyclists.

A large number of the submissions are supportive of the „dublinbikes‟ scheme. It is stated that the scheme should be expanded with additional stations and bicycles provided in other areas of the city. Various examples of appropriate locations for future stations have been suggested. It is also suggested that private bicycle parking could be provided at stations to capitalise on the increased security and surveillance provided by „dublinbikes‟.

Opposing views are apparent in some of the submissions regarding the provision of cycle routes with both support and opposition for segregation, integration, shared surface and on-road routes. Some submissions deal with issues relating to ongoing maintenance of cycling infrastructure, enforcement of road regulations and the introduction of enhanced legislation to give priority and protection to cyclists.

Submissions have also raised the issue of cycle parking provision and location. Enhanced quality and availability has been suggested for various uses and locations such as transport nodes, interchanges and supermarkets.

To ensure targets for cycling are consistent it is suggested that Section 5.1.4.4 is amended. It is further suggested that increased cycle parking requirements should be provided in addition to raising the financial contribution in lieu of providing cycle parking spaces from €400 to €2000, so as to provide an incentive to developers to provide parking facilities as part of the development. It is requested that an additional objective be provided as follows; „to create traffic calmed residential neighbourhoods where children can safely learn cycling skills through play‟. Manager's Response Dublin City Council has committed to improving cycling facilities over the life of the Development Plan through measures such as improved cycling infrastructure, traffic management and calming, ensuring cyclist‟s needs are integrated into development proposals and by preparing a new Dublin City Cycle Strategy. The emphasis on cycling policy in the Draft Plan has been shaped by and is consistent with the National Cycling Policy Framework. It is considered that the existing policies and objectives in the Plan will be key to achieving a city where people have the opportunity and confidence to choose to cycle, supported by a coherent and improved cycle network.

Objective SIO16 details that Dublin City Council will monitor the success of the „dublinbikes‟ scheme and will seek to expand the scheme to the entire city.

Objective SIO10 details that Dublin City Council prepare a cycle parking strategy to provide guidance on the nature, quantum and location of new cycle parking facilities in the city address cycle parking needs at public transport stops and interchange as well as other key destinations and attractions. This new strategy will complement the enhanced provisions in the Draft Development Plan at Chapter 17.41 to 17.2 regarding cycle parking ratios and facilities.

A number of submissions raised issues regarding the enforcement of road regulations, maintenance. These matters are beyond the remit of the Plan. Manager's Recommendation Retain as existing.

See also Chapter 17, Section 17.41, which also refers to cycling issues.

Section: 5.1.4.5 Walking

Summary of Issues In general, the submissions that relate to walking consider that there is insufficient provision for pedestrians in the City. Many submissions highlight that there are serious issues regarding the quality of pedestrian infrastructure which must be addressed in order to motivate greater numbers of people to walk. Pedestrian safety can be enhanced by further traffic calming, reduction in traffic lanes and footpath expansion and extension. This would benefit all users, but in particular, the elderly, parents with children and the mobility or visually impaired.

One of the recurring themes is the current waiting time allocated to pedestrians at crossing points. In addition, many submissions request upgrade of crossing points or construction of new crossings in various locations through the City.

A number of submissions suggest new pedestrian routes that should be provided in the Plan. Some examples include a pontoon or tidal walk on the Liffey, routes to Croke Park and the Aviva Stadium and more direct linkages between Grafton Street and O‟Connell Street. Other submissions call for further areas of the City Centre to be pedestrianised

In terms of future development proposals, it is requested that all future development be required to strongly support walkable communities where future residents can access normally required services by walking a reasonable distance. Some of the submissions raised issues that are beyond the strategic remit of the Plan such as maintenance or bye-law enforcement. Manager's Response Dublin City Council has committed to improving the pedestrian environment in the City and developing a high quality, safe and well sign posted network of pedestrian routes and infrastructure through Policy SI9 in the Draft Plan. New pedestrian routes will be identified in tandem with the development of the proposed Wayfinding System, and through the commencement of the Public Realm Strategy. The latter will address issues of design, delivery and management in addition to identifying specific projects that will radically improve the pedestrian experience.

Opportunities for increased pedestrian priority will be pursued in tandem with traffic management initiatives in the City. Pedestrian priority and infrastructure development and improvement are dealt with in strategic terms through Objectives SC10 to SC13 and SIO20 to SIO27. Section 5.1.4.2, Objectives SIO46 and SIO48 include direct provision for the needs of vulnerable road users based on the principles of Universal Design. This includes prioritising the introduction of tactile paving, ramps and kerb dishing at appropriate locations including pedestrian crossings and public transport stops and stations. Objective RDO1 details the intention of Dublin City Council to implement environmental and other improvements set out in the Retail Core Framework Plan, such as improving facilities for pedestrians, a high quality street environment and better links between the shopping area and new routes, with the refurbishment and extension of the key pedestrian street network including the repaving of the Grafton Street Pedestrian Spine and Liffey Street Upper and Lower. Detailed management and maintenance issues such as traffic light sequencing are operational matters and cannot readily be considered in detail through the Development Plan. Manager's Recommendation Retain as existing.

Section: 5.1.4.6 Mobility Management & Travel Planning

Summary of Issues Submissions that related directly to Mobility Management and Travel Planning requests that a new objective be added to encourage individual citizens to adopt personal Travel Plans to move towards sustainable transport modes. The Taxi Regulator notes that taxis can be considered as a back up for car sharing in Travel Plans and Transport Assessments. Manager's Response A Travel Plan essentially consists of a package of measures, initiatives and incentives aimed at encouraging a target group of people to shift from travelling individually by private car to walking, cycling, public transport and car-sharing. The Plan sets out percentage targets for modal splits to be achieved over a specified time period. The application of the Travel Plan concept for individuals is not feasible or warranted. It is highlighted that the Draft Plan already promotes modal change to sustainable transport options through a variety of measures including but not limited to the delivery of enhanced public transport provision and improved pedestrian and cyclist infrastructure. The comments of the Taxi Regulator are noted. Manager's Recommendation Retain as existing.

Section: 5.1.4.7 Car Parking

Summary of Issues A major issue raised relates to inadequate provision for retail car parking. It is stated that the Plan needs to emphasise the need to cater for the car shopper and to ensure the City Centre retail core is accessible to this type of shopper. A more targeted and explicit policy is required to recognise the role and importance of the car shopper as an economic imperative. Emphasis should concentrate on short to medium term parking. A caveat should be introduced into the Plan which allows additional car parking where it can be demonstrated that the surrounding road network is capable of accommodating the volume of traffic likely to be generated by the proposal.

A number of submissions were received relating directly to parking restrictions in particular locations in the city. Some wished parking restrictions to be eased, while others expressed concern that the existing parking regimes in an area might be altered to the detriment of people who have no access to off-street car parking. Submissions also called for permit parking to be introduced to safeguard residential parking some areas. Some concerns were raised with respect to enforcement of parking regulations around the city and the excessive coach parking on Mountjoy Square. Further issues raised include providing additional Park and Ride facilities similar to the Red Cow roundabout. The Taxi Regulator requests that consideration be given to the development of taxi holding areas. Manager's Response Chapter 17.40.11 clearly states that public on-street parking is a necessary facility for shopping and business premises and is recognised as essential to the day-to-day functioning of the city. Proactive parking policies set out in the Plan ensure that pricing of on-street spaces is geared to short stay parking. Dublin City Council will continue to discourage commuter car parking and seek to ensure adequate parking provision for short-term shopping, business and leisure purposes. The Draft Plan provides policy guidance on car parking to provide car parking as part of the overall sustainable transport needs of the City. Policy SI12 makes it clear that Dublin City Council will discourage commuter parking but will facilitate parking provision to serve short term uses such as retail. In view of the issues raised, it is proposed to refine guidance in Chapter 17, Section 17.40 to allow a relaxation of maximum parking standards to support the sustainable development of a regeneration area.

Policy SIO6 details that Dublin City Council will liaise with adjoining local authorities regarding the provision of Park and Ride sites at appropriate locations that would support sustainable transportation policies and promote sustainable commuting patterns. Objective SIO32 gives an undertaking to develop bus parks in selected locations so as to eliminate the hazards of bus parking in residential and other areas. The comments of the Taxi Regulator regarding the development of taxi holding areas are noted. Parking Control Zones as per Map J of the Development Plan were reviewed and considered to be appropriate. The Planning Authority retains the discretion to decide the appropriate level of car parking in all cases having regard to particular uses and site circumstances. Issues relating to car parking restrictions in particular areas including designation, alteration and permit parking are not dealt with through the Development Plan but under Dublin City Council Parking Control Bye- Laws. Matters relating to the enforcement of parking regulations are beyond the scope of the Development Plan. Manager's Recommendation Amend Objective SIO32 in Section 5.1.4.7 Car Parking From: To develop lorry parks and bus parks in selected areas in co-operation with private enterprise so as to eliminate the hazards of unsuitable lorry and bus parking in residential and other areas.

To: To develop lorry parks, bus parks and taxi holding areas in selected areas where deemed necessary and in co-operation with private enterprise so as to eliminate the hazards of unsuitable lorry, bus and taxi parking in residential and other areas.

Amend Section 17.40 with addition of the following text in fourth paragraph after "boundary areas"; "Or where necessary for the sustainable development of a regeneration area (see section 16.3)."

Please also refer to Section 17.40 of the Manager‟s Report which also refers to car parking.

Section: 5.1.4.8 Road Capacity Improvements

Summary of Issues Submissions raise various points regarding road proposals and existing traffic management in the city. Some submissions request additional road improvement schemes to be included such as proposals for a new outer orbital motorway route.

A number of submissions received relate to proposals for a road overbridge at Ratoath Road/ Reilly‟s Bridge. Some submissions oppose the proposal in its entirety, while others strongly support it as a solution to traffic congestion and access problems in the area. Concern is also expressed regarding local traffic management in the area and traffic management measures that may be introduced following completion of the proposed overbridge.

Submissions were received both for and against proposals for an Eastern By-Pass and Policy SI17 which supports the provision of a By-Pass by way of a bored tunnel under Sandymount and Merrion Strand and Booterstown Marsh. The National Roads Authority recommends that the Draft Plan be amended to include for the NRA‟s Corridor Protection Study for Eastern Bypass Corridor and Mapping. The NRA also requests that the wording „by way of a bored tunnel under Sandymount and Merrion Strand and Booterstown Marsh‟, be removed from Policy SI17 relating to the proposed Eastern Bypass. The Dublin Port Company welcomes the proposal provided the By- Pass is linked to the southern section of the M50, adding that the Draft Plan does not take adequate account of the transport needs of freight at Dublin Port in the future. The Department of Environment, Heritage and Local Government states that the advance of the Eastern Bypass is not envisaged under the Renewed Programme for Government and that the SEA and AA should have regard to accumulative impacts (See SEA and AA Sections). Manager's Response Only priority road capacity improvement proposals that are achievable within a reasonable time frame and subject to the availability of resources have been included in the Plan. All of the key road capacity improvements identified are required to facilitate the sustainable movement of goods and people and form a core element of sustainable transportation policy.

Variation 40 of the existing City Development Plan, „Ratoath Road Realignment and Overbridge east of Reilly‟s Bridge was adopted by Dublin City Council on November 2nd 2009 and is considered to be the stated position of Dublin City Council in relation to Reilly‟s Bridge. No departure from the adopted variation is deemed to be warranted in the Draft Plan.

Policy SI17 (Eastern By-Pass Route) is similar to that in the 2005 Development Plan. The provision of an Eastern By-Pass is a strategic element of Regional Policy to provide an overall integrated multi-modal transport network to support the growth of the Dublin City urban area, including Dublin Port. The proposal is included as strategy in the DTOs „A Platform for Change 2000-2016‟ and in the Draft and current Regional Planning Guidelines for the Greater Dublin Area, to which the Draft Plan must have regard, as set out at Section 27 of the Planning and Development Act. It should be noted that the Planning and Development (Amendment Bill 2009) seeks to amend Section 27 of the Principal Act so that “A planning authority shall ensure, when making a development plan, that the plan is consistent with any regional planning guidelines in force for its area”. Therefore, in recognition of the long term possible strategic importance this project has in meeting future transport needs and economic growth, it is considered appropriate to retain Policy SI17. A feasibility and corridor study has been undertaken by the NRA, however in view of the long term nature of the proposal, the pending completion of the National Transportation Authority Strategy, and in recognition of the preference of Dublin City Council for a bored tunnel route option, it is not considered appropriate to include details of land reservations or other such measures in the Development Plan. However, it is recommended that the policy be amended to provide for the cumulative impacts now incorporated into the SEA & AA. Manager's Recommendation Retain as existing. See recommendation 2(f) in Managers Response in the AA.

Section: 5.1.4.9 Traffic Management

Summary of Issues The National Transport Authority submits that it will produce a strategic traffic management plan for the Greater Dublin Area. The National Transport Authority supports the various traffic management strategies referenced in the Draft Plan adding that they should be carried out on the basis of the strategic traffic management plan.

The majority of submissions received relate to local traffic management issues. The issues raised are varied and include support for traffic claming proposals, roundabouts, signage, speed limits, design of loading bays, use of bus lanes by cars, increasing the number of zebra crossings, congestion caused by taxis, etc. Concerns are expressed that the construction of infrastructure such as the Dart Underground and additional Luas lines will impact on business, cause congestion and discourage people from visiting the City Centre. Road maintenance is also an issue that has been raised as a major concern. Manager's Response The comments of the National Transport Authority are noted. The focus of the Draft Plan at Section 5.1.4.9, Traffic Management, is to seek to improve the management and control of traffic in the city to increase sustainable accessibility, to improve road safety and to minimise the adverse environmental impacts of the transport system. A number of traffic management initiatives and objectives have been identified and included in the Plan to achieve these goals. The objectives include implementing the City Centre Transport Plan, reviewing traffic management plans and speed limits in the vicinity of schools, implementing a Regional Traffic Management Strategy in addition to other measures. The Development Plan cannot deal with localised traffic management issues and must remain strategic in focus; however the number and range of traffic management objectives identified in the Plan is sufficient to address the issues/concerns raised in the submissions. Issues such as maintenance of road surfaces, traffic signage, etc, are generally operational matters or fall with under the Road Traffic Acts and Regulations. Manager's Recommendation Retain as existing.

Section: 5.1.4.10 Environmental And Road Safety Impacts Of Traffic

Summary of Issues The submissions received request the inclusion of additional policies/objectives relating to the provision of electrical charging facilities for electric vehicles. Provision should include facilities for short term charging as well as overnight charging. It is suggested that 10% of parking spaces be given over for metered fast charging with the remainder of spaces constructed to be capable of accommodating future charging points as required. It is also requested that where shared surfaces or homezones are considered, that footpaths be retained where vehicular traffic is present. Manager's Response In support of the Government‟s Electric Transport Programme and as part of a number of initiatives to tackle the adverse environmental impacts of traffic in the City, Policy SIO45 has been included in the Plan and sets out that Dublin City Council will examine measures that will facilitate the roll-out of charging infrastructure for electric vehicles. This includes advance planning for the suitable layout and location of the facilitating infrastructure. Policy SIO45 provides the necessary emphasis and flexibility to respond to future demands and developments in relation to electric charging infrastructure and electric vehicle technology. The application of specific development standards is not considered necessary at this point.

Objectives SIO45 and SIO76 seek to promote shared surfaces and homezones. These are residential streets in which the road space is shared between drivers and other road users with the wider needs and safety of residents, including people who walk and cycle, prioritised over car drivers. The detailed design of such areas is not a matter for the Development Plan, although it should be noted that interaction between all users can take place and generally means an absence of footpaths. Manager's Recommendation Retain as existing.

Section: 5.1.4.11 Dublin Port Tunnel Structural Safety

Summary of Issues One submission relates to this issue and expresses concern that the Development Plan sets out so few explicit conditions for development adjacent to, or on top of, the Port Tunnel. A development assessment should be required for development within 30m of the tunnel and not 6m as set out. The Draft Plan therefore impacts on the viability of the Whitehall Framework Plan. Manager's Response Policy SI 20 and Appendix 9 require the submission of a Development Assessment from within 6m of the outer edge of the Port Tunnel Bore. This is based on the recommendation of the National Roads Authority and is in addition to the Dublin Port Tunnel Guidance Notes available from Dublin City Council which were also commissioned by the NRA. The existing policy/appendix is sufficient to safeguard the structural integrity of the Port Tunnel. It is not considered that the Draft Plan impacts on the viability of the Whitehall Framework Plan in this respect. Manager's Recommendation Retain as existing.

Section: 5.1.4.12 Accessibility For All

Summary of Issues One of the main themes arising in the submissions is the need to ensure equal assess to travel and transport and an accessible environment for all citizens, including those with disabilities. To ensure that the pedestrian environment is accessible for people with disabilities it is requested that the Irish Wheelchair Association‟s „Best Practice Guidelines – Designing Accessible Environments‟ should be given consideration in the Development Plan. The IWA requests that the Development Plan incorporate a number of key actions with regard to travel and transport to ensure equal access for people with disabilities in all aspects of the travel and transport in the city, including the need for an integrated approach to transportation and accessibility. The Taxi Regulator requests inclusion of facilities for the mobility impaired at taxi ranks.

The National Council for the Blind of Ireland wish new rail stations to be fully accessible for people with disabilities. Universal design and accessibility in the planning of transport projects should refer to the importance of ensuring there is a seamless accessible interface between accessible transport and the surrounding environment. The Council highlights that the Draft Part M Technical Guidance Document contains a requirement for designated disabled car parking spaces of a least 5% with the minimum provision of a least one space. In addition, the design of junctions and corner radii should aim to minimise the length of a roadway a pedestrian has to traverse, as long roadway crossings can be hazardous for people with disabilities. Manager's Response The Draft Plan supports the development of a pedestrian network inclusive of facilities for people with mobility impairment and/or disabilities and has incorporated a number of measures to ensure equal access for people with disabilities to all aspects of travel and transport.

Objective SIO46 relates to the development an accessible city centre network based on the principle of Universal Design. In terms of access to travel and transport, this will involve working closely with the relevant transport agencies/providers. Universal Design involves the design and composition of indoor and outdoor physical environments so that they can be accessed and used to the greatest extent possible by all people regardless of their age, size or disability. Objective SIO47 states that parking for people with disabilities will be provided in excess or minimum requirements (4%) where this is deemed to be appropriate. In view of the issues raised, it is considered appropriate to insert amended text as set out below. Manager's Recommendation Amend Objective SIO48 at Section 5.1.4.12 From: To prioritise the introduction of tactile paving, ramps and kerb dishing at appropriate locations including pedestrian crossings, bus stops and rail platforms

To: To prioritise the introduction of tactile paving, ramps and kerb dishing at appropriate locations including pedestrian crossings, taxi ranks, bus stops and rail platforms

Replace the existing text at Section 17.40.5 Disabled Car Parking ; From: „4% of car parking spaces provided should be set aside for disabled car parking‟

With; Where car parking is provided, whether for residents, employees, visitors or others, a number of car-parking spaces for people with disabilities should be provided on a proportional basis. At least 5% of the total number of spaces should be designated car-parking spaces, with a minimum provision of at least one such space. Section: 5.2.2 Challenges

Summary of Issues The Environmental Protection Agency recommends that reference be made to the Dublin Region Water Supply Project in the context of the projected water shortages.

It is suggested that the Draft Plan fails to state any specific measures that will be implemented to resolve the absence of fresh water and wastewater capacity.

One submission requests that Dublin City Council commit to the servicing of zoned lands and the provision of key infrastructure projects to ensure that a shortfall of serviced, zoned, and ready to go lands does not occur during the lifetime of the new Plan, particularly given the Plan's objectives in terms of new development.

Another submission states that a delay in the roll out of infrastructure and the servicing of lands for strategic commercial and residential development will impact negatively on the development of the City in the longer term. Manager's Response This section of the Development Plan recognises the importance of securing a long term water supply for the Dublin Region. There is no objection to referencing the Dublin Water Supply Project.

The Draft Development Plan sets out a number of policies and objectives relating to water supply and wastewater. Studies are in progress to identify a new water supply source to avoid shortages of drinking water in the future. It is also a policy (SI40) to provide additional and improved wastewater treatment capacity. Policy SI41 supports the development of a second wastewater treatment plant and outer orbital sewer to serve the Dublin Region.

Dublin City Council is committed to providing and delivering infrastructural services, which will enhance the quality of the city‟s environment and also facilitate sustainable economic development. Manager's Recommendation Amend the text from page 54 (first paragraph of section) From: Studies are in progress to identify a new water supply source to avoid shortages of drinking water in the future.

To: The Dublin Region Water Supply Project is in progress to identify a new water supply source to avoid shortages of drinking water in the future.

Amend the text from page 55 (first paragraph) From: Progress in developing the North Dublin Wastewater Treatments Works and orbital sewer by Fingal County Council as part of the Greater Dublin Strategic Drainage Strategy is essential to the future growth of the Dublin Region.

To: Progress in the development of the Greater Dublin Regional Wastewater Treatment Plant, Marine Outfall and Orbital Sewer to be located in the northern part of the Greater Dublin Area is essential to the future growth of the Dublin Region.

Section: 5.2.3 The Strategic Approach (See Fig. 9)

Summary of Issues The Environmental Protection Agency suggest that this section should include adaptation to climate change impacts along with water conservation and addressing infrastructural losses which are being addressed through the policies and objectives set out in further sections. It is also stated by the EPA that the plan should include provisions to promote the implementation of Dublin City Councils Water Services Strategic Plan 2009. Manager's Response The Dublin City Council Water Services Strategic Plan 2009 deals with the issues of water supply, drainage and flooding and other environmental considerations. Therefore it is considered appropriate to ensure that the recommendations and actions of both the Water Services Plan and the Climate Change Adaptation Plan are implemented. Manager's Recommendation Insert new bullet points in section 5.2.3 on page 55 to read as follows:

Ensure the implementation of the recommendations and actions of the Dublin City Council Water Services Strategic Plan 2009. Improve the city's resilence and ability to adapt to climate change.

Section: 5.2.4.1 Towards A Sustainable Dublin

Summary of Issues It is suggested that Objective SIO50 (to achieve the emission targets set out in the Climate Change Strategy) should be considered a policy of the development plan and not an objective. Manager's Response It is considered that SIO50 should remain as an objective in the Draft Plan. Policy SI23 states that it is a policy of Dublin City Council to have regard to the Climate Change Strategy for Dublin City, which is a strategic level policy. Objective SIO50 accordingly seeks to achieve the targets set out in the Climate Change Strategy. Manager's Recommendation Retain as existing.

Section: 5.2.4.2 Dublin City as a Leader on Climate Change

Summary of Issues The Environmental Protection Agency suggests that this section should include reference to adaptation measures along with a change to the title of this section to be called “ Climate Change and Mitigation”.

One submission states that the Development Plan should address the adaptations needed to address the impacts of climate change including sea level rise, changing weather patterns.

A submission from Codema calls for the Inclusion of the policies from the Climate Change Strategy for Dublin City relating to the mapping of the proprosed district heating network and the promotion of a carbon neutral Sustainable Communities demonstration project in each of the five city areas. Manager's Response Dublin City Council is cognisant of the importance of adaptation measures as well as mitigation measures in relation to tackling climate change as highlighted by the Environmental Protection Agency. Adaption measures such as flood resilient design and construction and sustainable urban drainage systems have an important role to play. Dublin City Council recognises the importance of such measures and this is reinforced by Policy SI49 which requires the use of sustainable urban drainage systems in all new developments. Therefore it is considered appropriate to make specific reference to these measures in Section 5.2.4.2

It is a policy of the Draft Development Plan (SI23) to have regard to the Climate Change Strategy for Dublin City. Section 5.2.4.16 refers to District Heating and Policy SI59 supports the development of a district heating network for Dublin. A map of the areas which can be served by the proposed district heating network is available in the Dublin Sustainable Energy Action Plan which aims to prioritise and elaborate on the main energy-related actions from the Climate Change Strategy. Therefore, it is considered that the existing references to district heating and the Climate Change Strategy in the Draft Plan are sufficient.

It is considered that Objective SIO51 which seeks to initiate and support carbon neutral projects in conjunction with local communities deals with the second issue raised by Codema. Manager's Recommendation Insert new text to the fourth line in section 5.2.4.2 on page 56 directly after the word “technologies” as follows:

Climate Change adaption measures such as flood resilient design and construction and the use of sustainable urban drainage systems have an important role to play in dealing with the effects of climate change and Dublin City Council promotes the use of such techniques.

Section: 5.2.4.3 Waste Management

Summary of Issues The Environmental Protection Agency suggests that the Development Plan should seek to incorporate relevant guidance and legislation.

It is requested that Policy SI32 (ensure the polluter pays principle is applied) be amended by making due provision for lower income households including those of unemployed families and senior citizens.

It is suggested that a new objective should be added to this section worded as follows; "To protect the public realm built environment, to implement an annual Graffiti Control and Removal Plan in each area of Dublin City." It is submitted that the requirement of objective SI056 (public recycling facilities in commercial developments in excess of 1000m2) is excessive.

Policy SI057 is supported however one submission contends that a minimum percentage of recycled or reused materials should be indicated in the Plan to create a standard threshold. It is also suggested that this objective should be expanded to include a Site Waste Management Plan (SWMP) in accordance with 'Best Practice Guidelines on the preparation of Waste Management Plans for construction & Demolition Projects (June 2006).

A number of submissions raise the issue of litter. It is suggested that a greater enforcement of litter laws, and more litter wardens are required along with the issuing of fines to any person found littering. One submission calls for a new objective which seeks to increase the number of litter bins in the City.

It is also submitted that the Plan should expand in more detail the Council's plan for a single waste management plan for the City Region. Manager's Response It is considered that Policy SI27 which supports the principles of good waste management deals adequately with the issues raised by the EPA in regard to waste management at strategic policy level.

It is not considered appropriate to amend the wording of policy SI32 as it would be contrary to the polluter pays principle which is part of the national waste management policy since 1998. This means that the generator of the waste is obliged to ensure that the waste is properly managed. Furthermore this policy was directly transposed from the 2005 Development Plan.

The Litter Management Plan produced by Dublin City Council in 2008 has a dedicated section relating to graffiti cleaning/removal and graffiti art. It is an objective of the Draft Development Plan to implement the litter management plan and therefore it is considered that the issue raised is dealt with adequately.

It is acknowledged that the wording of objective SIO56 is onerous and all new commercial developments may not be suitable to provide public recycling facilities. Accordingly it is considered appropriate to amend the wording of this policy to allow a certain degree of flexibility when assessing a development proposal.

Due to the wide varying building stock/typologies and sites within the administrative area of Dublin City it would be difficult to include a requirement to have a minimum percentage of recycled or reused materials which would apply to all situations. It is therefore considered inappropriate to include a standard threshold in the Development Plan. It should also be noted that a standard planning condition is attached to the grant of planning permission for larger projects which requires construction and demolition waste management plans to be prepared and submitted to and agreed to in writing by the planning authority prior to the commencement of development. This is considered sufficient to deal with the issues raised.

The issue of litter enforcement and provision of new litter bins in the city is outside the scope of the Development Plan. Manager's Recommendation Amend the wording of Objective SIO56 From: It is an objective of Dublin City Council to ensure the provision of adequately sized public recycling facilities in new commercial developments in excess of 1000m2.

To: It is an objective of Dublin City Council to seek the provision of adequately sized public recycling facilities in new commercial developments where appropriate

Section: 5.2.4.4 Water Supply

Summary of Issues The Environmental Protection Agency suggests that this section should make reference to the Dublin Region Water Supply Project in the context of the projected water shortages along with a cross reference to Dublin City Council‟s Water Services Strategic Plan where relevant. The EPA also submits that there would be merit in considering inserting a policy/objective for water shortage and drought management scenarios arising from extremes of temperature. The EPA also suggests that the plan should implement the European Communities Drinking Water Regulations 2007.

Another submission requests that new policies be inserted as follows: "In conjunction with other local authorities in the Greater Dublin area and across Ireland, to build new water reservoirs, treatment reservoirs and delivery pipelines to ensure that the Dublin region has an additional 20% reserve water supply by 2020." After Policy SI38, add a new Policy: "To complete the installation of the new North East Bay water pipeline to improve - water pressure and provision across North Central and North East Dublin in close cooperation with Fingal and other local authorities."

It is also suggested to amend Objective SI062, to include after "Dublin Region" add; "and throughout Ireland." Manager's Response It is considered appropriate to make reference to the Dublin Region Water Supply Project and the Dublin City Water Services Strategic Plan 2009 in this section as requested by the EPA. Policy SI37 states that all reasonable steps will be taken to put in place adequate strategic service storage to facilitate the efficient and effective management of the water supply system. It is considered that this policy deals adequately with the issue raised by the EPA regarding water shortage and drought management scenarios.

Policy SI36 states that it is the policy of Dublin City Council to comply with directions issued by the EPA in its role as water regulator. It is considered that this policy covers the drinking water regulations.

It is considered inappropriate to insert new polices as requested as policy SI33 deals with the issues raised adequately. Furthermore, the issue relating to water pressure and the requirement of a “North East Bay water pipeline” is outside the scope of the Development Plan. Manager's Recommendation Insert new text in section 5.2.4.4 Water Supply page 57 to the first line directly before the word “Supply” as follows: The Dublin City Council Water Services Strategic Plan 2009 sets out the vision for water supply services in the Dublin Region.

Insert new text in section 5.2.4.4 Water Supply page 57 to the fifth line directly after the word “Plan” as follows: The Dublin Region Water Supply Project is in progress to identify a new water supply source to avoid shortages of drinking water in the future.

Insert new text in section 5.2.4.4 Water Supply page 58 to the second line directly after the word “conservation” as follows: ..and the capacity of the existing water supply infrastructure to supply the proposed development.

Section: 5.2.4.5 Natural Watercourses

Summary of Issues The EPA suggests that policy SI39 should be expanded to include the wider objectives of the Water Framework Directive, which include achieving by 2015 good ecological potential and good chemical status for all water bodies. The Agency also suggests that reference should be made to the planned pollution reduction programmes for priority substances required under S.I No. 272 of 2009. The EPA also requests that the Plan should inculde a clear policy for the protection of groundwater resources.

Furthermore, it is requested that a policy be inserted to address potential water contamination during construction operations i.e. temporary effects on the water quality of Dublin Bay.

One submission submits that the water quality in Chapelizod village is 3 (Scale of 1-5), but that 4 could be easily attained on better management of local authority waste water treatment plants upstream of Chapelizod. Manager's Response It is agreed that policy SI39 should be amended to include the wider objectives of the Water Framework Directive. The Environmental Objectives (Surface Water Regulations) which came into effect on 30 July 2009 are a horizontal instrument in that they have significant implications across a range of existing legislation and they address the requirements of the Water Framework, Dangerous Substances and Priority Substances Directives. It is considered appropriate to reference these regulations in section 5.2.4.5

The issue raised by the EPA in relation to groundwater is noted and it is agreed that the Draft Plan should include a policy for the protection of groundwater resources.

The issue raised by the EPA regarding water contamination during construction projects is considered to be an enforcement issue and outside the scope of the Development Plan.

The issue of water quality in Chapelizod village is noted. However, the issue raised is outside the scope of the Development Plan. Manager's Recommendation Amend Policy SI39 From: It is the policy of Dublin City Council to promote the achievement of good ecological status in all natural waterbodies in the City.

To: It is the policy of Dublin City Council to promote the achievement of good ecological status, good ecological potential and good chemical status for all waterbodies in the city by 2015 in accordance with The Water Framework Directive Insert the following text to section 5.2.4.5 on page 59 directly after the word “country” as follows: “The Environmental Objectives (Surface Water Regulations) which came into effect on 30 July 2009 are a horizontal instrument in that they have significant implications across a range of existing legislation and they address the requirements of the Water Framework, Dangerous Substances and Priority Substances Directives.”

Insert new policy directly after SI39 to read as folows: It is the policy of Dublin City Council to protect the city's ground water resources in accordance with The Water Framework Directive.

Section: 5.2.4.6 Wastewater

Summary of Issues The EPA states that Policy SI40 should include a stronger commitment than “promote” regarding the upgrade of wastewater infrastructure and suggest the use of the term “ensure” should be considered. It is also stated that the objectives listed should include the requirement to comply with the EPA Wastewater Discharge Regulations.

Another submission raises the issue of grey water reuse in addition to rainwater harvesting. It is also suggested that a sewer from Ballymore Eustace to Blessington and Citywest, discharging at Ringsend should be installed.

One submission raised an issue regarding drainage problems in an area of the North Inner City. Manager's Response The issues raised regarding specific proposals and drainage problems are noted. However, such issues are outside the scope of the Development Plan.

It is considered appropriate to strengthen the wording of Policy SI40 as highlighted by the EPA. It is recognised that the Draft Plan does not include an objective which requires the local authority to comply with the EPA Wastewater Discharge Regulations. Accordingly, it is considered appropriate to insert a new objective in the wastewater section. Manager's Recommendation Amend the wording of Policy SI40 From: It is the policy of Dublin City Council to promote the upgrading of wastewater infrastructure and to facilitate the provision and safeguarding of infrastructure corridors required to facilitate sustainable development in the city and region.

To: It is the policy of Dublin City Council to ensure the upgrading of wastewater infrastructure and to facilitate the provision and safeguarding of infrastructure corridors required to facilitate sustainable development in the city and region.

Insert a new objective to section 5.2.4.5 on page 60 directly below Objective SIO71 to read as follows: It is an objective of Dublin City Council to require that all developments should include a Wastewater Discharge Plan to accompany any application demonstrating to the satisfaction of the Planning Authority that the proposed discharge of waste water from the proposed development, in conjunction with existing discharges, would not cause non compliance with the combined approach as defined in the Waste Water Discharge (Authorisation) Regulations 2007.

Amend the text of the third line of section 5.2.4.6 on page 59 as follows: From: “North Dublin Wastewater Treatment Plan and Orbital Sewer”

To: “Greater Dublin Regional WastewaterTreatment Plant, Marine Outfall and Orbital Sewer”

Amend the wording of Policy SI41 From: It is the policy of Dublin City Council in co-operation with the relevant agencies to support the development of a second wastewater treatment plant and outer orbital sewer to serve the Dublin Region as part of the Greater Dublin Strategic Drainage Strategy.

To: It is the policy of Dublin City Council to support the development of the Greater Dublin Regional Wastewater Treatment Plant, Marine Outfall and Orbital Sewer to be located in the northern part of the Greater Dublin Area to serve the Dublin Region as part of the Greater Dublin Strategic Drainage Strategy.

Section: 5.2.4.7 Flood Management

Summary of Issues The Office of Public Works welcomes Policy SI45. However there will be other areas of the City at risk of flooding which have not flooded in recent years. The OPW would like to see flood risk assessment and flood risk management extended over all areas of the City that are at risk of flooding. The OPW also drew attention to the requirements of the EU 'Floods' Directive 2007/60/EU.

The EPA suggests that this section should be closely aligned with measures in the ERBD and the Floods Directive. The EPA also suggests that consideration should also be given to the inclusion of a policy/objective in relation to the Dublin Coastal Flood Protection Project/Study and the SAFER Project.

The EPA also recommends that the Pan should promote the appropriate zoning of lands and restriction of use in areas liable to flooding.

It is requested to add to the wording of Objective SIO72 (requiring flood risk assessments in accordance with DOEHLG guidelines) as follows; "All plans for Key District Centres and Key Developing Areas must be accompanied by a full Area Hydrology Analysis and development on flood plains and coastal polders will not be permitted."

A number of submissions raise the issue of flood plains. It is stated that flood plains should be shown on Development Plan maps and there should be no development on flood plains. The EPA states that the Guidelines for Planning Authorities on Flood Risk are advising that the maps in the Development Plan should delineate areas of flood risk and the degree of risk. At a minimum, this section should refer to an information source where such location maps are available. One submission highlights that flooding is an increased risk in the East Wall area. It is submitted that the changing patterns to the river and estuary must be monitored to detect and negate risks. The works of the Flood partnerships must be strengthened and continued. Another submission raised the issue of recent flooding in the area of Clonskeagh Bridge and it is also stated that the area of land surrounding O‟Shea‟s Public House should remain a flood plain. Manager's Response The OPW operates the National Flood Hazard Mapping Website which shows information on a map about places that may be at risk from flooding. Flood maps can provide useful information to planners and the public to identify areas at risk of flooding and make decisions about land use and development.In light of a number of submissions regarding flood maps it is considered appropriate to include reference to this website in the text of this section.

The Dublin Coastal Flood Protection Project is referenced in the main text of this section and accordingly it is considered unwarranted to include a specific objective of same.

Dublin City Council has been working in cooperation with the OPW to put in place appropriate studies and policies to address the risk of flooding in the city. It is considered that policy SI45 relating to flood risk assessment and management deals with the issue raised adequately.

Dublin City Council is in agreement with the EPA that this section should be closely aligned with measures in the ERBD and the Floods Directive. The Dublin City Council Water Services Strategic Plan 2009 is the current strategic plan in place for Dublin City and sets out objectives in relation to flood risk management which includes an objective to meet the requirements of the Floods Directive. Furthermore it should be noted that policy SI44 seeks to assist the OPW in developing catchment based flood risk management plans which will in turn assist in meeting the requirements of the Floods Directive.

It is considered that objective SIO72 deals adequately with the issue of requiring applicants to submit a flood risk assessment in accordance with the Department of Environment Guidelines. Therefore it is not warranted to amend this objective.

In light of the adoption of the Planning System and Flood Risk Management Guidelines in recent months by the Department of Environment, Heritage and Local Government it is considered appropriate to update references to these guidelines accordingly.

The issues raised relating to flooding issues in particular areas of the city are an operational and management issue and outside the remit of the development plan. Manager's Recommendation Insert the following text to the fourth line of section 5.2.4.7 on page 60 directly after the word “management”: The OPW Flood Hazard Maps show information on a map about places that may be at risk from flooding. See www.floodmaps.ie for details.

Insert the following text to the beginning of the third paragraph of section 5.2.4.7 on page 60 directly before the word “Dublin”: The Dublin City Council Water Services Strategic Plan 2009 is the current strategic plan in place for Dublin City and sets out a number of objectives in relation to flood risk management including an objective to meet the requirements of the Floods Directive.

Section: 5.2.4.8 Sustainable Urban Drainage Systems (SUDS)

Summary of Issues One submission suggests that objective SIO49 (the requirement of the use of SUDS in all new developments) could include reference to Guidance on permeable paving for front gardens.

The EPA suggests that SUDS policies and objectives proposed in the Draft Plan should be fully aligned with any wider climate change adaption measures, flood risk management plans and the Eastern River Basin District to avoid undesirable upstream, downstream impacts. Manager's Response Chapter 16 of the Development Plan sets out green infrastructure guiding principles including the use of sustainable urban drainage systems. The requirement of the use of permeable paving is dealt with in this section of the plan.

Dublin City Council is cognisant of the relationship of sustainable urban drainage policies and objectives proposed in the Draft Plan with wider climate change adaption measures, flood risk management plans and the Eastern River Management Plan. The submission for the EPA is noted in this regard. Manager's Recommendation Retain as existing.

Section: 5.2.4.9 Air Quality

Summary of Issues The EPA requests that a specific policy/objective should be included in this section, referring to the implementation of specific aspects of the air quality management plan relevant to Dublin City. Furthermore it is requested that SI50 be amended to promote compliance with air quality targets.

One submission expresses concerns regarding extractor fans which exit their fumes out the side of the building which leads to smells outside buildings at balcony level.

One submission calls for an addition to Policy SI50 (monitoring air quality) to ensure that such monitoring will be carried out by a significant number of monitoring stations well dispersed around the City. Manager's Response The issue of fumes emanating from uses such as restaurants etc particularly in mixed use developments is recognised by Dublin City Council. An objective is included in the Draft Plan (SIO74) which seeks to encourage the use of internal ducting to facilitate air extraction/ventilation units in new developments to protect residential amenity. Furthermore, Dublin City Council places planning conditions on permissions for development proposals where air quality issues are prevalent. This is considered sufficient to deal with the issue raised.

It is considered appropriate to amend Policy SI50 in accordance with the request from the Environmental Protection Agency along with the insertion of an objective referring to the Air Quality Management Plan 2008-2012. Manager's Recommendation Amend Policy SI50 From: It is the policy of Dublin City Council to monitor air quality in accordance with national and EU policy directives on air quality.

To: It is the policy of Dublin City Council to monitor and improve air quality in accordance with national and EU policy directives on air quality and where appropriate promote compliance with established targets.

Insert new objective directly after objective SIO74 on page 62 to read as follows: It is an objective of Dublin City Council to implement the Dublin Regional Air Quality Management Plan 2008-2012 in cooperation with the other Local Authorities in Dublin.

Section: 5.2.4.10 Noise Pollution

Summary of Issues It is suggested that new policies be inserted to ensure that any future residential developments, particularly apartment developments, will conform to the highest levels of acoustic insulation.

And that "Given an apparent failure to invigilate Building Regulations on many apartment and Duplex homes in the North Fringe policy be included to ensure that developers there carry out remedial works to install effective noise insulation of all separate housing units to the highest Irish and EU standards."

It is further suggested that all proposals for development should be submitted with information on the noise which will be generated. Emphasis should be on strategies to eliminate noise at source. Permission for apartment buildings should be conditioned such that noise generated within the apartment should not be audible externally or in the adjoining apartments. Manager's Response The issue of acoustic insulation in developments is a building control matter and does not come under the planning code. Building control legislation and planning legislation are independent of each other and one set of legislation should not be used to achieve the goals of the other. It is therefore not warranted to insert a new policy into the Development Plan regarding acoustic insulation. The issue of noise generated within apartments and the impacts on adjoining apartments is however recognised. Page 211 sets out the development standards for insulation of residential units. It is considered this deals adequately with the issue raised.

The issue of enforcement of Building Regulations is outside the scope of the Development Plan and therefore it is considered inappropriate to insert a new policy after SI51 as requested. Manager's Recommendation Retain as existing.

Section: 5.2.4. SEVESO Establishments / Industry - Control of Major Accident Hazards Directive (SEVESO II Directive)

Summary of Issues The Health and Safety Authority suggests that reference should be made to policy document „Policy and Approach of the Health and Safety Authority to COMAH Risk- based land Use Planning along with the following: - Policy in relation to major hazard sites reflecting Article 12 of Directive 105/2003/EC and a policy on siting of same - Consultation distances supplied by the Health & Safety Authority to Dublin City Council - Mention of all notified sites

The Health and Safety Authority also note that: - Dublin WTE Ltd is located in Dublin 4 - Irish Distillers is a lower tier site located close to Tibbett & Britten

The Dublin Port Company supports policy SI54 (to have regard to the SEVESO directive). Manager's Response Section 5.2.4 of the Draft Development Plan relates to SEVESO establishments and includes a policy in relation to major hazard sites reflecting Article 12 of Directive 105/2003/EC. Appendix 17 lists all the SEVESO establishments within the administrative area of Dublin City Council including consultation distances supplied by the Health & Safety Authority. Furthermore the SEVESO establishments which are located outside the City Council area but are within consultation distance of areas within the city are also listed.

The anomalies highlighted by the Health and Safety Authority in relation to Appendix 17 are noted.

Dublin City Council acknowledges the submissions received in support of policy SI54. Manager's Recommendation Amend the second bullet point of Appendix 17 and replace “Dublin 3” with “Dublin 4”

Section: 5.2.4.12 Telecommunications

Summary of Issues Need to have quick and effective enforcement against unauthorised mobile phone masts such as instant dismantling and confiscation of unauthorised equipment.

It is requested to amend Policy SI55 as follows: after "learning" add; "while requiring telecoms to co locate facilities as a general rule."

One submission calls for a change to the approach related to broadband, to focus on what the Council can deliver such as the availability in targeted City Centre locations and focus on short term delivery (not in the lifetime of the Plan). Another submission welcomes the policies in the area of telecommunications infrastructure, namely proposal S155 and SI082. There is also a call for WIFI/broadband access on all forms of public transport in Dublin City and ultimately nationwide. Manager's Response The issue of enforcement of unauthorised mobile phone masts is outside the scope of the Development Plan.

Appendix 16 of the Draft Development Plan sets out guidelines on telecommunications antennae. Regard was had to the DOEHLG Guidance Document for Planning Authorities "Telecommunications Antennae and Support Structures" when drafting the wording of appendix 16. There is a dedicated section regarding the sharing of installations between operators and the guidelines state that applicants must satisfy Dublin City Council that they have made every reasonable effort to share with other operators. Therefore, it is not warranted to amend policy SI55.

Dublin City Council is not a direct provider of telecommunications infrastructure but can facilitate the development of such infrastructure. Objective SIO82 was introduced into the Draft Development Plan by way of a motion at a Special Meeting of the City Council on 25th November 20009. Therefore it is not considered unnecessary to amend the objective.

Dublin City Council acknowledges the submission supporting Policy SI55 and Objective SIO82. The issue of broadband/WIFI access on public transport is outside the scope of the Development Plan. Manager's Recommendation Retain as existing.

Section: 5.2.4.14 Energy Supply

Summary of Issues The Irish Wind Energy Association and Eirgrid request that the City Development Plan incorporates an overall objective to comply with the government's renewable generation target for 2020 to meet 40% of electricity consumption from renewable energy resources. Thus indicating a commitment to achieving this target and recognising the need to achieve this will require the upgrading and strengthening of the Grid.

The ESB submission appreciates the acknowledgement of the need to support the extension and reinforcement of the electricity network. The submission also states that the ESB should be consulted as soon as possible in the development process to ensure that the required infrastructure is in place to meet the development needs and provision should be made in developments for HV substations.

A submission from the ESB also raises the issue of the importance of ESB properties at Poolbeg/ North Wall stating that they are critical and sensitive land uses of national importance to enable continuation of established power generation.

Wind Energy Direct request an inclusion in the development plan of the concept of autoproduction and a framework for supporting applications by established and new commercial enterprises where autoproduction generation is sought. There should be an objective in the Plan that Dublin City Council support existing and established businesses and industries who wish to use wind energy to serve their own needs subject to proper planning and sustainable development.

Irish Environmental Network submits that Dublin should prepare an Energy Masterplan and that it should introduce new guidelines and targets for the use of renewable energy as well as energy efficiency in buildings.

Eirgrid feels that it is imperative that the Development Plan support provision for high voltage electrical infrastructure including high voltage transformer stations and new overhead transmission power lines. It is reiterated that the optimum means for transportation of electricity is via overhead line as opposed to underground. Manager's Response There is no objection to the inclusion of an objective supporting the targets for renewable generation so that these targets are met. It is therefore considered appropriate to insert a new objective to Section 5.2.4.15 to support the government targets of having 40% of electricity consumption generated from renewable energy sources by the year 2020.

The issue of consultation with the ESB in relation to development proposals to ensure that the required infrastructure is in place is a development management issue. The issue of supporting existing and established businesses and industries who wish to use wind energy to serve their own needs is considered to be adequately dealt with by Policies SI57 and SI58.

The request for Dublin City Council to introduce an Energy Masterplan is outside the scope of the Development Plan. However, it should be noted that Dublin City Council in association with Codema has prepared the Dublin City Sustainable Energy Action Plan which is currently in draft format and was recently the subject of public consultation.

Dublin City Council recognises the importance of the energy needs of the Greater Dublin Area. Providing for energy needs is not the remit of Dublin City Council. Dublin City Council supports the upgrading of the network and this is reflected by Policy SI57. It is considered appropriate to include a statement in the text of Section 5.2.4.14 which reaffirms that Dublin City Council will support the major service providers, where it is proposed to enhance or upgrade the network.

Eirgrid suggests that the optimum means for transportation of electricity is via overhead lines rather than underground. This element of the submission is noted. Manager's Recommendation Insert new Objective to section 5.2.4.14 directly after Policy SI57 on page 65 to read as follows: It is an objective of Dublin City Council to support the government targets of having 40% of electricity consumption generated from renewable energy sources by the year 2020.  Insert new text in Section 5.2.4.14 after the fifth line as follows: “Dublin City Council is cognisant of the future requirements of the service providers in relation to enhancing and upgrading existing facilitates or networks. Where possible, Dublin City Council will support the statutory providers of national grid infrastructure by safeguarding strategic corridors where identified from other developments which might inhibit the provision of energy supply networks.” Section: 5.2.4.15 Energy Efficiency

Summary of Issues The EPA suggests including a policy/objective to promote the implementation of the Dublin Sustainable Energy Action Plan.

The Royal Institute of Architects of Ireland suggests that specific energy performance standards of new buildings should be restricted to National Standards i.e. Building Regulations.

There should be provision of more efficient energy supply in areas of regeneration and existing buildings e.g. encourage the location of community located CHP.

Low energy or reduced use options should be investigated for lighting sports facilities. The Development Plan could include a policy to minimise any superfluous lighting at night particularly with regarding to commercial premises not in use at night but permanently lit. This would also provide a strong visual image illustrating Dublin City's commitment to a low carbon reality.

It is also requested to amend Policy SI58 promoting energy efficiency to include reference to existing and new developments; to amend objective SI085 on sustainable design to include detailed specification of building materials and to amend objective SIO886 to include the wording “existing and new”. Manager's Response Energy performance standards are set by Building Regulations which are outside the remit of the Development Plan. However, Dublin City Council is cognisant of the benefits of improved energy efficiency in buildings and this is reflected in section 5.2.4.16 of the Draft Plan which promotes energy efficiency, energy conservation and the use of renewable energy in development.

Dublin City Council actively supports the development of energy efficient initiatives such as district heating and combined heat and power as stated in policy SI59. Dublin City Council is leading by good example in the Council‟s own major social housing schemes in Ballymun Regeneration and Fatima Mansions, where the energy and environmental specifications are well in excess of normal practice for the industry. In addition, a number of innovative and very high specification projects, such as at York Street, are being built by the Council. These, supported by „The House of Tomorrow‟, and other national programmes, serve to demonstrate future possibilities for improved energy and sustainability standards in housing. It is therefore considered that Section 5.2.4.14 and Section 5.2.4.16 adequately deal with this issue.

The issue of superfluous lighting in commercial premises not in use at night time is noted. However, this issue is outside the scope of the Development Plan. Manager's Recommendation Amend Policy SI58 From: It is the policy of Dublin City Council to promote energy efficiency, energy conservation, and the use of renewable energy in development.

To: It is the policy of Dublin City Council to promote energy efficiency, energy conservation, and the use of renewable energy in existing and new developments.

Amend Objective SIO86 From: It is an objective of Dublin City Council to ensure high standards of energy efficiency in developments and encouraging developers, owners and tenants to improve the environmental performance of the building stock, including the deployment of renewable energy.

To: It is an objective of Dublin City Council to ensure high standards of energy efficiency in existing and new developments and to encourage developers, owners and tenants to improve the environmental performance of the building stock, including the deployment of renewable energy.

Insert new objective directly after objective SIO86 to read as follows: It is an objective of Dublin City Council to promote the implementation of the Dublin Sustainable Energy Action Plan.

Section: 5.2.4.16 District Heating & Combined Heat and Power

Summary of Issues It is suggested that the Development Plan should state that references to district heating in the Plan cannot be considered as an endorsement of a district heating system supplied from the Poolbeg Incinerator or by a new additional boiler plant at Poolbeg. Manager's Response The District Heating Network for Dublin is at an early stage and a feasibility study on the implementation of such a network has been undertaken. It is intended that the major heat producers, including the existing power stations will be encouraged to contribute to the scheme. Dublin City Council supports the development of energy efficient initiatives and policy SI59 reflects this in the Draft Development Plan. A Development Plan must have regard to the objectives of the Waste Management Plan for its area. Manager's Recommendation Retain as existing.

Section: Other Issues Part 2

Summary of Issues Meath County Council has highlighted that the Proposed Kilshane Transfer Station is at Kilshane, Fingal (not Co. Meath) as indicated in Figure 9.

The EPA suggests that the plan should incorporate a policy to ensure the requirement of the Bathing Water Regulations is complied with.

One submission enquires as to what the plans are for services such as ESB, water supply etc in the area of Pelletstown. Another submission states that the incinerator project should be abandoned.

A submission from the Green Party recommends that Dublin City Council prepare an Infrastructure Capacity Study to determine the infrastructural requirements for the existing population identify any deficiencies and outline costed proposals to bridge the gap. In addition, the infrastructural requirements necessary to meet the needs of the future population should also be identified and costed. This Infrastructure Capacity Study could also inform the equitable review of the Dublin City Council's Development Contributions Scheme and essentially provide the Council with a Business Plan for the Plan period. Manager's Response Figure 9 illustrates the location of existing and proposed regional infrastructure within the Greater Dublin Region. There are anomalies in Figure 9 as highlighted in a submission from Meath County Council. It is considered appropriate to amend Figure 9 accordingly.

The other issues raised are outside the scope of the Development Plan. However, it is recommended that the issue raised by the Green party which requests Dublin City Council to prepare an Infrastructure Capacity Study be referred to the Environment and Engineering Strategic Policy Committee for consideration. Manager's Recommendation Amend Figure 9 to; Illustrate Proposed Kilshane Transfer Station within the administrative area of Fingal County Council; Insert the word “proposed” before Ballyogan Transfer Station and Ballymount Transfer Station and; Remove dot indicating location of the proposed Waste Water Treatment Plant.

Refer the request to prepare an Infrastructure Capacity Study to the Environment and Engineering Strategic Policy Committee.

Chapter 6 Greening the City Submission Number(s): 2030, 2035, 2038, 2042, 2043, 2044, 2053, 2076, 2086, 2104, 2110, 2120, 2199, 2229, 2248, 2263, 2269, 2275, 2278, 2285, 2286, 2333, 2604, 2622, 2653, 2657, 2664, 2750, 2761, 2769, 2771, 2794, 2802, 2809, 2811, 2814, 2827, 2833, 2836, 2841, 2847, 2860, 2884, 2897, 2912, 2914, 2932, 2934, 2943, 2944, 2966, 2967, 2968, 2970, 2972, 2998, 2999, 3009, 3019, 3035, 3094, 3096, 3100, 3101, 3110, 3124, 3131, 3133, 3144, 3147, 3148, 3159, 3170, 3174, 3176, 3177

Section: 6.4.1 Green Infrastructure Network / Strategy

Summary of Issues Submissions received relating to the green network and strategy express a diverse range of views. Some of these submissions expressed their support for the green infrastructure network while others have suggested certain, mainly localised, amendments, to the network.

In relation to specific sites and locations the following issues were raised; The Office of Public Works (OPW) stated that (i) A route through OPW‟s lands at the Botanic Gardens cannot be supported as the integrity of the landscape and security here are paramount, (ii) There is potential for a green space connection linking the Esplanade / Croppies Acre and Parkgate Street to the Phoenix Park, (iii) Amend Figure 10 to include proposed green link from the Royal Canal to the Grand Canal through the route as outlined in Objective GC02 and (iv) Revise Objective GC035 to incorporate the proposed pedestrian linkage to the Phoenix Park as listed in Objective GC034 The Grangegorman Development Agency (GDA) welcomes the inclusion of the site as part of the strategic cycle network and that major elements of their Masterplan such as green fingers, the fields etc all sit comfortably with the Green Infrastructure Network/Strategy Omit St. Vincent‟s Street West as a green link pedestrian / cycle zone Complete the greening of the North Fringe Main Boulevard Provide a new pedestrian / cycle bridge across Clontarf Estuary as part of the S2S route Omit the cycle corridor in the north port area Emphasise the green route of the N32, Clare Hall Avenue and Grange Road Improve the pedestrian route from the City Centre to Grand Canal Square Incorporate lands adjoining the River Dodder into a linear park, create a cycling and walking route along its banks and prepare an Environmental Management Plan for the river Create a green corridor linking to the Dublin Mountains Clarify the LUAS BXD line which is indicated as a green route

In more general terms it is submitted that the nodes in the green infrastructure network could be useful for green industries, training programmes, food security programmes etc. A number of requests are made for linear parks, including along waterways, linking parks etc. and a further suggestion is made that green boundary hedges in lieu of block or steel fencing along public footpaths should be provided. It is also suggested that a number of „green‟ developments should be permitted developments e.g. the conversion of an existing roof to brown/green/farmed roof.

In relation to Green Infrastructure, the issue of green roofs is raised in a number of submissions with suggestions that the task force also investigate the potential for the conversion of existing roofs to green roofs and that an objective should be added to GCO3 investigating investigating the potential for generating renewable energy using photovoltaic panels on roof tops and south-facing walls. It is also suggested that development levies should be reduced for all building where the roof is designed to support organic food production. Manager's Response In response to those concerns raised by The OPW, it is recommended that the OPW should be consulted in relation to the development of any green route / corridor running through or close to lands under its control.

It is also envisaged that the green network will extend beyond the city‟s administrative boundary and into the wider Dublin region are per Policy GC8. This will facilitate the creation of a green corridor linking to the Dublin Mountains.

In relation to the OPW's submission relating to Figure 10 it is recommended that Figure 10 be amended accordingly in the interest of clarity.

The request in another submission to include the Phoenix Park linkage as part of the green linkage set out in GC035 is not a possible option currently until the feasibility study referred to in GC034 (b) has been finalised.

A number of submissions request some less strategic areas to be included in the green network. The Green Route Strategy sets out indicative routes at a strategic level. During the lifetime of the Plan consideration will be given to specific routes, including those referred to in the submissions received. Furthermore, the exact detail of planting at implementation stage will have regard to local characteristics of an area.

The provision of green boundary hedges in lieu of block or steel fencing along public footpaths is set out and adequately addressed in the Draft Plan.

In relation to submissions on particular rivers in the city it should be noted that the Plan contains policy to protect the unique amenities of all rivers within and forming boundaries to the administrative area of the city and to establish River Basin Management Plans, as per policy GC17. This is in addition to further policies in the plan to protect and improve the city‟s waterways - see Policies GC18, GC19, Specific Objectives - GC018, GC019, GC020, GC021 along with policy in Chapter 5 to achieve a high quality integrated network. An objective is also set out to develop new cycle links and to initiate the Dodder Bridge Scheme subject to funding during the lifetime of the Development Plan. In relation to liner parks along rivers, there are a number of policies and objectives existing in the draft plan to cater for this e.g. GC3 and GC6 and objectives GC02 and GC05. No hanges are recommended to the Daft Pan in this regard.

Development for roof cover changes to green roofs etc. would be permitted in principle.

The Draft Plan promotes and supports the development of allotments and community gardens (GC15) which adequately deal with the issue.

Through the Framework for Sustainable Dublin (FSD), the draft development plan seeks to develop sustainable employment in areas of leading edge green / clean technologies and promotion of green industry is dealt with adequately in Chapter 9.

The issue of development levies, and the reduction of same for green roof food production, is outside the scope of a Development Plan.

The issue of generating energy through photovoltaic panels etc is more appropriately dealt with under the section of the plan on Sustainable Building Design i.e. Section 11.4.3. However it should be noted that the Green Infrastructure Guiding Principles emphasis best-practice solutions with principles set out for sustainable site design, Sustainable Urban Drainage Systems (SUDs), sustainable buildings, green roofs etc. Manager's Recommendation Amend Figure 10 page 68 to include the green route detailed in Objective GC02(ii) i.e. the interconnection of the Royal Canal to the Grand Canal via the Phoenix Park

Reword Objective GCO02(ii) page 72 From: To provide a pedestrian and cycle-way link interconnecting the Royal Canal to the Grand Canal via the Phoenix Park

To: To provide a pedestrian and cycle-way link interconnecting the Royal Canal to the Grand Canal via the Phoenix Park in consultation with the Office of Public Works

Reword Objective GCO2(iii) page 72 From: To provide a continuous cycleway connecting the Phoenix Park and Heuston Station to the proposed S2S route along the city‟s quays

To: To provide a continuous cycleway connecting the Phoenix Park and Heuston Station to the proposed S2S route along the city‟s quays in consultation with the Office of Public Works

Reword Objective GCO2 (v) page 72 From: To seek to provide a pedestrian bridge and cycling green links connecting the Royal Canal and the Tolka Valley via a route through Botanic Gardens / Prospect Cemetery and a route in the vicinity of Holy Cross College (or routes as close as practically possible)

To: To seek to provide a pedestrian bridge and cycling green links connecting the Royal Canal and the Tolka Valley via a route through Botanic Gardens / Prospect Cemetery and a route in the vicinity of Holy Cross College (or routes as close as practically possible) in consultation with the Office of Public Works

Amend Objective GC05 page 72 From: Where lands along waterways are in private ownership, it shall be an objective in any development proposal, to secure public access along the waterway

To: To develop linear parks along waterways and to link existing parks and open space in order to provide green corridors throughout the city. Where lands along waterways are in private ownership, it shall be an objective in any development proposal, to secure public access along the waterway

Amend Objective GC03 From: To establish an interdepartmental task force on green roofing within the City Council to examine the suitability of various technical designs of green roof for new developments in the city

To: To establish an interdepartmental task force on green roofing within the City Council to examine the suitability of various technical designs of green roof for new and existing developments in the city.

Section: 6.4.2 Landscape

Summary of Issues Submissions under this section suggest that the Plan should contain policy to protect existing trees and green areas and a number of requests are made for additional trees to be planted in specific areas of the city. Submissions also request that trees be more supportive of biodiversity, represent a diversity of species etc. and that residents be involved in tree planting programmes.

Support is expressed for the study on Views and Prospects and a suggestion is made that it be linked to the historic core and policies on high buildings.

Submissions also request specific areas to be designated as Landscape Conservation Areas /Conservation Areas/Special Amenity Areas Orders (SAAOs)/ Landscape of Character and that Tree Preservation Orders should be investigated for institutional lands.

The OPW request the inclusion of an objective for the Phoenix Park.

There is a specific request for the survey of landmark trees undertaken by Pembroke Estate residents to be incorporated into the plan while a further submission requests that the existing mature trees at the north-west corner of Mount Tallant Avenue and Harold‟s Cross Road be retained as a Specific Objective in the Plan. Manager's Response Preservation of landscape character is the subject of numerous policies, objectives, zoning objectives and amenity designations in the draft plan. There are objectives to include the undertaking of a Views and Prospects study, to designate Special Amenity Areas, to advance additional TPOs and to investigate areas for their suitability for designation as Landscape Conservation Area. This approach is also supported by the land-use zoning provisions.

In relation to strategic landscapes, it is recommended that an objective be included for Phoenix Park.

In relation to those submissions requesting that specifically that the canals be designated Landscape Conservation Areas or landscapes of character it should be noted that The Royal and Grand Canals, the Tolka River and valley, as well as numerous other areas in the city are designated in the draft plan as Conservation Areas on the zoning objective maps. The canals are also designated as Proposed Natural Heritage Areas (pNHAs) offering them further protection. In response to the various submissions requiring protection of certain trees / groups of trees in various locations of the city, it should be noted that the draft plan has incorporated policy to advance additional TPOs where appropriate. Surveys and analyses will be undertaken during the lifetime of the 2011 – 2017 to determine where additional TPOs would be appropriate as per Policy GC010.

In response to submissions requesting tree planting or adequate maintenance of trees in various locations in the city, it should be noted that Policy GC9 has been incorporated into the plan which states that it is the policy of Dublin City Council “To continue to protect the landscape and existing green spaces for both the existing community and for future generations”. This policy is supported by Objectives GC09, GC010, GC011, GC012, GC013 and GC014, all relating to trees in the urban landscape. Objective GC011 specifically relates to the management of street and roadside trees. It is, however, recommended to strengthen Policy GC9 to allow for enhancement, as well as protection, of the landscape.

In response to requests that communities be involved in tree planting Objective GC014 states that planting will be carried out by Dublin City Council in consultation with residents.

It is the intention that the Views and Prospects Study will incorporate the historic core as per submission request. Manager's Recommendation Insert New Objective on Page 73 before GC06 as follows: To protect and conserve the historic landscape of the Phoenix Park and its archaeological, archtiectural and natural heritage whilst facilitating visitor access, education and interpretation, facilitating the sustainable use of the park‟s resources for recreation and other appropriate activities, encouraging research and maintaining its sense of peace and tranquillity

Amend Objective GC08 page 73 From: To seek the designation of Sandymount and Merrion Strands and also Irishtown Nature Park as Special Amenity Areas and to prepare a Special Amenity Area Order

To: To seek the designation of The Liffey Valley (from Islandbridge to the city boundary), Sandymount and Merrion Strands and also Irishtown Nature Park as Special Amenity Areas and to prepare Special Amenity Area Orders (SAAOs) for same

Amend Objective GC06 page 73 From: To investigate the following areas with a view to determining their suitability for designation as Landscape Conservation Areas (i) Phoenix Park, (ii) North Bull Island, (iii) The Botanic Gardens, and (iv) St. Anne‟s Park

To: To investigate the following areas with a view to determining their suitability for designation as Landscape Conservation Areas (i) Phoenix Park, (ii) North Bull Island, (iii) The Botanic Gardens, and (iv) St. Anne‟s Park and to examine the potential for other Landscape Conservation Areas as appropriate during the lifetime of the development plan Amend Policy GC9 page 73 From: To continue to protect the landscape and existing green spaces for both the existing community and future generations

To: To continue to protect and enhance the landscape through sustainable planning and design for both the existing community and for future generations in accordance with the principles of the European Landscape Convention

Section: 6.4.3 Open Space

Summary of Issues A significant number of submissions received request improved and/or additional open spaces, in specific areas. A small number of observers request that private lands should be held in trust/purchased and converted into public parks / amenity spaces while another suggests that the Plan contain policy prohibiting developers from building on amenity spaces. The need for additional provision of public toilets is also raised as an issue.

A significant number of submissions are concerned with allotments and community gardens with some of these submissions requesting that allotments should be developed on undeveloped lands / vacant sites, that more of an emphasis should be placed on community gardens and that certain types of development should be considered permitted development if they relate to allotments.

All rights of way should be fully known and placed on the public records and the development plan should contain feasibility studies for the inclusion of explicit maps and a register to such lands. Manager's Response In relation to open space, there is an acute awareness, as acknowledged in the draft plan, of the need to protect open spaces as well as the need to create new sustainable, accessible open spaces.

The City Council is also aware of the fact, that there are areas across the city where additional and/or improved open spaces are required. To this end numerous policies and objectives have been incorporated into the draft plan, namely Policy GC12 (provision of sufficient public open space in new developments), Policy GC13 (provision of additional spaces in areas currently deficient in public open space), GC14 (to to manage and protect public open spaces). These policies are in addition to a number of policies for a strategic green network, protection and improvement of natural landscapes and amenities, additional play and recreational facilities, in addition to Specific Objectives for development of parks, green links, linear parks and river walks etc. Furthermore, standards for public open space requirements in new developments have been set out in Chapter 17.

In addition there is a requirement for developers of Z12 lands to provide accessible public open space. Furthermore, land zoning objective Z9 seeks to preserve, provide and improve recreational amenity and open space and green networks, while developers developing lands zoned Z15 are required to retain a minimum of 25% of the site as accessible public open space and to consider the potential of the development to contribute to the green network. Having regard to the foregoing, it is considered that Chapter 6 comprehensively addresses the issue of protecting, enhancing and expanding green space in the city. In relation to those submissions received on allotments and community gardens, policyGC15 is included in the Draft Plan, i.e. to support the provision of community gardens, allotments etc including as temporary uses on derelict sites. In order to distinguish between community gardens and allotments, it is recommended that definitions of both terms be included in the glossary of the Plan which will highlight the educational aspect of community gardens.

Mindful of the need for more public toilets in the city, an objective has been incorporated into the development plan as per GC015.

Issues raised in relation to LAP areas will be addressed through the implementation of LAPs.

The reduction of derelict site taxes for owners of derelict sites that convert the sites into allotments is outside the scope of a development plan.

The issue of rights-of-way is a complex matter involving legal and property rights issues. Manager's Recommendation Insert definitions of „allotment‟ and „community garden‟ into the Glossary of Terms and Phrases (beginning on page 360) as follows: „Allotment: Small plots of land which are let to individuals for the cultivation of vegetables and plants‟ „Community Garden: A community garden generally has the characteristics of being made by, and for members of the local community. When successful they are also inclusive, so that the young and old can use the area of play, learning, meeting, and socialising, as well as gardening. (The Dublin City Guide to Community Gardening)

Include a new standard for community gardens and allotments in the development plan Section 17.9 B1 The Scheme – All Residential Development page 214 that; Consideration should be given to the provision of community gardens and/or allotments in new developments.

Section: 6.4.4 Rivers, Canals, and the Coastline

Summary of Issues The Dublin Docklands Development Authority request that the River Regeneration Strategy 2001 be considered.

One submission suggests developing the potential of city beaches as an important amenity and the view is also expressed that recreational activities should be encouraged on navigable waterways.

With regard to the City Canals, plans to encourage more walking and cycling along the canals are welcomed in submissions while there was also a request to recognise the tourism potential of the canals. One submission requests a Local Area Plan for the Royal and Grand Canals to deal with the issue of towpaths, boardwalks, retails stands, lighting, recreation etc. Emphasis should be placed on active consultation with stakeholders with an interest in the canals and the general cleanliness of canals, streams and rivers is also raised. The status of the Dublin Canals Study (2009) is also requested. Manager's Response The draft development plan contains a number of policies to protect and improve the amenity and biodiversity value of the canals, canals and coastline.

In response to those submissions on the canals, rivers and coast it should be noted that GC18 and GC20 support the development of recreational amenities on the canals and along the coast. These policies are for the benefit both of the city‟s citizens and visitors, including tourists, to the city.

It is considered that there is merit in including a policy supporting sustainable the development of recreational amenities on the rivers, estuaries, canal and coast.

Dublin City Council also concurs with the suggestion that support for the implementation of the Dublin Docklands Development Authority‟s River Regeneration Strategy should be highlighted in the plan.

The Dublin Canals Study is a non-statutory plan and is available to the public. It is considered appropriate to include it in the list of non-statutory plans set out in Appendix 1.

The cleaning of the rivers, drains, canals, streams etc is not a matter for the development plan. Manager's Recommendation Amend Policy GC20 page 75 From: To develop sustainable coastal recreational amenities to enhance appreciation of coastal natural assets

To: To develop sustainable coastal, estuarine, canal and riverine recreational amenities to enhance appreciation of the natural assets of the coast, estuaries, rivers and canals

Include new objective, GC021A Section 6.4.4 page 75 as follows: To support Dublin Docklands Development Authority in the implementation of the Dublin Docklands Development Authority River Liffey Regeneration Strategy and Campshire Vision, 2001

Insert Bullet Point to Appendix 1, Schedule of Non-Statutory Plans; City Canals Plan (when adopted).

Section: 6.4.5 Dublin Bay

Summary of Issues Three submissions received refer directly to Dublin Bay and requested that the draft plan recognise the economic importance of Dublin Port and to encourage sustainable port development and that feasibility studies for the rehabilitation of the existing bathing infrastructure and proposals for augmenting those facilities with new public amenities and related coastal structures be included. The possibility of achieving Policy GC21(to co-operate with the Dublin Bay Task Force) is questioned by the Port Company in their submission. Manager's Response The draft development plan in Section 17.22 recognises the economic importance of the Port.

The aim of Policy GC21 is for Dublin City Council to work towards a coastal zone management framework and the policy acknowledges that co-operation between multiple agencies is necessary.

It is intended that the Coastal Zone Management Plan would take in the areas containing the derelict and/or abandoned baths, bathing facilities etc. No changes to the draft plan are therefore recommended in this regard. Manager's Recommendation Retain as exisiting.

Section: 6.4.6 Biodiversity

Summary of Issues The Department of Environment, Heritage and Local Government welcomes the protection given to the natural heritage. A query is raised in relation to Policy GC25 i.e. if policy affords protection to sites proposed for designation and how this policy would impact on sites which may have boundary changes in the future.

One submission requests that when trees are planted that they are more supportive of biodiversity and represent a variety of species and another submission states that there should not be any reclamation of the SPA/SAC beaches for the S2S. Manager's Response It is considered that there is merit in amending policy GC25 to make it clear that protection is offered to sites that are proposed to be designated as well as allowing for protection in the event of changes to the boundary.

The S2S has yet to be subjected to a detailed design proposal. However the S2S will be rigoursly assessed to ensure that it will not impact negatively upon any designated sites. Manager's Recommendation Policy GC25 (page 76) be amended From: To conserve and manage all Natural Heritage Areas, Special Areas of Conservation and Special Protection Area identified and designated by the Department of Environment, Heritage and Local Government

To: To conserve and manage all Natural Heritage Areas, Special Areas of Conservation and Special Protection Area identified and designated, or proposed to be designated, by the Department of Environment, Heritage and Local Government. These designations will allow for protection in the event of any approved boundary changes by the Department of Environment, Heritage and Local Government.

Section: 6.4.7 Sport, Recreation and Play

Summary of Issues A large number of submissions refer to the perceived lack of play and sports facilities in the City and request an increase in the number of facilities as well as improvements to existing facilities and a broader range of equipment and functionality. Facilities should be accessible to all ages, cultures and abilities. In this regard, all aspects of recreational facilities should be accessible including all associated facilities such as car parks, entrances, buildings, gym equipment.

In terms of design, it is also submitted that consultation with children at early stages is requested. The Irish Wheelchair Association (IWA) also submit that the tender process for indoor and outdoor play areas should stipulate that funding will only be available for suitably accessible buildings, facilities and equipment.

The problem of anti-social behaviour in existing recreational buildings and parks is raised in a number of submissions.

A request is also made to recognise the important role sporting clubs play in enhancing the life of the community. A strategy to develop Dublin as a centre of European sporting events was also requested as is the development of recreational training, informal training in alternative sports (e.g. mountaineering etc.) and facilities for such sports.

Some submissions raise the fact that a number of Dublin City Council-owned swimming pools are closing down and requests are also made for new pools in the City.

A specific request is made seeking the transfer of the playing field at Cathal Brugha Barracks from the Department of Defence to Dublin City Council on a leasehold basis and that Dublin City Council would manage the playing field in conjunction with the new Rathmines Leisure Centre. Manager's Response In relation to the perceived deficit of play/recreational spaces and areas in the city, a large number of specific policies has been included in the draft plan to increase the provision of children‟s play facilities (Policy GC29), children‟s playgrounds (GC30), specialist play facilities (GC33), multi-functional recreational facilities for the general population (GC34), recreational lands (GC35) etc. In areas where a proven deficit exists, the City Council will work with the providers of such facilities, including schools, institutions and private operators, to ensure access to the local population as expressed in Policy GC34.

Furthermore, the City Council has recently produced an inter-agency, inter- departmental city play plan, entitled „City of Dublin Play Plan‟. Policies GC30 and GC31 of the draft plan support the application of this Play Plan.

Dublin City Council recognises the public demand for more specialised equipment. To this end the draft plan contains Policy GC33 (the provision of specialist play facilities). To clarify the meaning of „specialist play facilities‟ the policy can be amended to make direct reference to such facilities.

Furthermore, Dublin City Council‟s Dublin Sport and Active Recreation Strategy 2009-2016 outlines how the Council can work with interested parties to deliver high quality and sustainable sport and recreation services. To this end, the draft development plan contains Policy GC36 (regard to be had to the objectives of the sports strategy).

In relation to the issue of MUGAs and other facilities being provided for different cultures and abilities, the objective of the City Council is that recreational spaces and play areas are available for all cultures and would suit all abilities. Accessibility is also a priority for the City Council with numerous policies and objectives included in the draft plan e.g. SC20, SI19, SI046, SI47, SI48, FC32, NC23, Section 17.2, Appendix 20 etc. Supporting text could be amended in Section 6.4.7 to make specific reference to accessiblility and diversity. There is also merit amending policy GC30 to highlight the need for accessibility in the area of recreation and play.

It should also be noted that Dublin City Council‟s Policy on Children‟s Play. The Plan contains many initiatives, including the need for more consultation with children. It is recommended that Policies GC30 and GC31 are amended to reflect the recently updated plan title.

In relation to the importance of sporting clubs in the city, supporting text can be added into the plan. It is also Council policy to seek the retention of all sporting facilities in the City.

Notwithstanding the issue of the closure of the swimming pools it should be noted that an objective has been included on the plan for Dublin City Council to continue with its programme of refurbishment and redevelopment of its existing swimming pools.

The following are operational matters and outside the scope of a development plan: publicly-provided recreational play areas accessibility issues raised in relation to the tender process Transfer of the playing field at Cathal Brugha Barracks The upgrading of trails and lighting in public parks Anti-social behaviour in existing parks and facilities The issue of training in the area of play The addition of any new playground schemes into the list of Parks and Open Spaces set out under Objective GC033(relates to area specific parks, open spaces and amenities) is matter to be referred to the relevant SPC in the first instance Manager's Recommendation Amend Policy GC33 From: To recognise and support the role of the private sector in providing specialist play facilities, both indoor and outdoor, and subject to zoning specifications

To: To recognise and support the role of the private sector in providing specialist play facilities including climbing walls, table tennis tables etc, both indoor and outdoor, and subject to zoning specifications

Insert New Objective GCO23A page 78 as follows: To encourage and facilitate the introduction of adult amenities in parks such as table tennis tables, outdoor gyms. basketball courts, bowling greens etc

Amend supporting text in Section 6.4.7 page 77 From: Facilities for both formal and informal recreation and catering for all ages are required

To: Accessible facilities for both formal and informal recreation and catering for persons at all stages in their lifecycle, all abilities and diverse cultures are required

Amend Policy GC30 page 77 From: To provide children‟s playgrounds to an appropriate standard of amenity and safety and to create safe places for socialising and informal play and for connecting with nature and art, having regard to Dublin City Council Policy on Children‟s Play

To: To provide children‟s playgrounds to an appropriate standard of amenity, safety and accessibility and to create safe and accessible places for socialising and informal play and for connecting with nature and art, having regard to City of Dublin Play Plan

Insert the following new text as the 2nd sentence in the 1st paragraph of Section 6.4.7. page 77: Dublin Council acknowledges the very important role that sporting and social clubs play in enhancing the social and recreational life of the city‟s communities

Section: 6.4.8 Specific Objectives

Summary of Issues A large number of submissions request area and site-specific improvements to open spaces, parks etc. The following site-specific requests are made:

Publish the Dodder Framework Plan Retain and amend specific objective GCO33 to include the words “To promote and actively pursue” a number of parks specified under this objective including the development of Scully‟s Field, Clonskeagh Amend GCO33 to include a specific objective regarding the expansion of Mount Bernard Park and installation of a playground as per the Mountjoy LAP Extend the linear parks on the north bank of the River Liffey (at Donore Harriers) and include as a specific objective in GCO34 Revise specific objective GCO34 as it is misleading and inaccurate regarding the link between the Memorial Gardens and Phoenix Park Remove GCO35 as it impacts upon the development potential along Goldenbridge Walk and conflicts with safe vehicular movement Acquire the steel bridge behind Darty Dye Works in order fulfil Objective GCO38 Add a specific objective to investigate the upgrading of the green area at Ontario Terrace Include Chapelizod in the list of amenity areas to be developed Add the Scout‟s Den to the list of amenity sites to be developed Add Rathfarnham to Ringsend Dodder Route Devise an amenity-based plan for Alfie Byrne Road Implement the long-term plans for a linear park along the Tolka Valley Improve the amenity value of the open space on the western side of the junction of St. Alban‟s Park and Ailesbury Gardens Manager's Response A relatively significant number of submissions related specifically to the River Dodder. There are a number of relevant policies and objectives improve the Dodder including the development of a Framework Plan as per GC038, development of a linear park (GC033), restoration of weirs (GC018), construction of the Dodder Bridge (SI034), continuation of the development of a liner park (GC033). It is considered that the implementation of these policies and objectives will have significant positive impacts on the River Dodder. In relation to the request to purchase the steel bridge at Dartry Dye Works, the purchasing of sites is an operational matter and is outside the scope of a development plan.

It is an objective to pursue the development of the park known as Scully‟s Field as stated as part of Specific Objective GC033. Since this site is privately owned there is likely to be constraints in actively pursuing a public park.

The development plan contains many policies and objectives to improve, and provide additional green spaces and networks. Site-specific requests for improvements to green spaces are not a matter for the development plan but rather an operational matter or more appropriately dealt with by a Local Plan level. However, it is considered that there is merit in amending Policy GC14 (management of public open spaces) slightly to highlight the need to generally enhance and improve green spaces throughout the city.

In relation to any possible local impediments as a result of the provision of green routes/ corridors it should be noted that these will be dealt with at implementation stage.

In relation to the submissions referring to the content of Local Area Plans to be included in the development plan, it should be noted that the provisions of the adopted Local Area Plans e.g. the Phibsborough / Mountjoy Local Area Plan and the Liberties Local Area Plan have been fully incorporated into the draft Development Plan. Manager's Recommendation Amend Policy GC14 (page 74) From: To continue to manage and protect public open spaces to meet the social, recreational, conservational and ecological needs of the city and to consider the development of appropriate complementary facilities which do not detract from the amenities of spaces

To: To continue to manage, protect and/or enhance public open spaces to meet the social, recreational, conservational and ecological needs of the city and to consider the development of appropriate complementary facilities which do not detract from the amenities of spaces

Chapter 7 Fostering Dublin’s Character and Culture Submission Number(s): 2007, 2009, 2010, 2013, 2016, 2018, 2029, 2030, 2033, 2044, 2045, 2051, 2056, 2075, 2076, 2083, 2093, 2113, 2120, 2135, 2136, 2152, 2157, 2162, 2169, 2171, 2172, 2173, 2174, 2175, 2176, 2177, 2178, 2179, 2180, 2181, 2182, 2185, 2192, 2193, 2196, 2199, 2205, 2207, 2208, 2210, 2212, 2213, 2214, 2215, 2216, 2217, 2218, 2219, 2220, 2221, 2222, 2223, 2224, 2225, 2227, 2228, 2229, 2235, 2239, 2242, 2243, 2244, 2250, 2251, 2252, 2259, 2261, 2274, 2277, 2290, 2291, 2293, 2298, 2299, 2300, 2301, 2304, 2305, 2306, 2307, 2309, 2310, 2311, 2312, 2313, 2314, 2315, 2316, 2317, 2318, 2319, 2320, 2321, 2322, 2323, 2324, 2325, 2326, 2333, 2604, 2608, 2609, 2622, 2623, 2630, 2631, 2632, 2633, 2634, 2635, 2636, 2637, 2638, 2641, 2646, 2652, 2653, 2658, 2661, 2670, 2672, 2675, 2679, 2680, 2681, 2682, 2683, 2684, 2685, 2686, 2687, 2688, 2689, 2690, 2691, 2692, 2693, 2694, 2696, 2697, 2698, 2699, 2700, 2701, 2702, 2703, 2704, 2705, 2706, 2707, 2708, 2709, 2710, 2711, 2712, 2713, 2714, 2715, 2716, 2717, 2718, 2719, 2720, 2721, 2722, 2725, 2726, 2727, 2728, 2729, 2730, 2731, 2732, 2733, 2734, 2735, 2736, 2737, 2738, 2739, 2740, 2743, 2751, 2757, 2762, 2763, 2765, 2770, 2779, 2781, 2782, 2784, 2789, 2794, 2796, 2799, 2802, 2803, 2808, 2809, 2811, 2815, 2817, 2820, 2823, 2824, 2825, 2826, 2827, 2828, 2829, 2830, 2832, 2841, 2843, 2845, 2846, 2847, 2849, 2850, 2851, 2853, 2855, 2856, 2857, 2858, 2859, 2860, 2861, 2862, 2863, 2864, 2865, 2866, 2867, 2875, 2891, 2897, 2900, 2901, 2912, 2913, 2914, 2918, 2932, 2935, 2939, 2941, 2943, 2959, 2964, 2973, 2974, 2980, 3004, 3005, 3011, 3012, 3015, 3016, 3019, 3021, 3035, 3038, 3041, 3045, 3048, 3061, 3068, 3075, 3077, 3080, 3094, 3095, 3096, 3097, 3101, 3124, 3129, 3142, 3144, 3145, 3154, 3158, 3159, 3160, 3161, 3163, 3169, 3171, 3172, 3173, 3180, 3182, 3192, 3193, 3194, 3212

Section: 7.1.5.1 Leading the Cultural Development of Dublin City

Summary of Issues Submissions on this topic suggest that the title of the chapter be changed to „Fostering Dublin‟s (Unique) Culture‟ and that the Cultural Strategy be included as an appendix in the Plan. In terms of partnership, it is suggested that the delivery of the Cultural Strategy in partnership with other cultural stakeholders should be emphasised and also that limiting the collaborative approach only to cultural bodies in the city may be restrictive. A number of submissions commend the cultural leadership and partnership approach set out.

One submission suggests that there is a need for more public and productive engagement between Dublin City Council and actors in the city at all levels and that the city council should seek to foster a sense of the citizens‟ ownership and entitlement to the city‟s culture. Manager's Response The title of the chapter is intended to reflect the cultural richness of the city. Dublin City Council recognises the term „Culture‟ as a broad and inclusive category covering all forms of creative expression including the arts, heritage, way of life, values etc. However it is considered that there is merit in making explicit reference to the character of the City to ensure that the focus on heritage is retained.

A Cultural Strategy has recently been devised by Dublin City Council in partnership with key cultural stakeholders and collaborative delivery is essential. It is considered that there is merit in putting an emphasis on the fact that Dublin City Council will be delivering the strategy along with a diverse range of other stakeholders, inside and outside of the City area.

It is not considered necessary or appropriate to include the Cultural Strategy as an appendix. The strategy will be made freely available by Dublin City Council once finalised.

It is accepted that collaborating with cultural bodies based in the City only may be construed as a somewhat restrictive approach. It is recommended that the policy be amended to allow for a wider process of partnership across the City and beyond its administrative boundaries.

In relation to greater public engagement it should be noted that Policy FC1 sets out the vision to lead a shared vision of culture in collaboration with other cultural institutions and bodies and Objective FC02 supports a Cultural Alliance for the City. The Cultural Alliance will be made up a diverse range of cultural partners. Furthermore, the Cultural Strategy sets out a number of priorities relating to greater cultural engagement with the citizens of the city. Manager's Recommendation Amend the first paragraph of Section 7.1.2 page 84 From: The City Council in partnership with key cultural stakeholders has devised a Cultural Strategy 2009-2017, setting out a shared vision for the city‟s future and positioning the City Council as the leader of a new cultural approach in the city. The collaborative delivery of the Cultural Strategy is essential to further strengthening the city‟s cultural life

To: The City Council in partnership with key cultural stakeholders has devised a Cultural Strategy 2010 - 2017, setting out a shared vision for the city‟s future and positioning the City Council as the leader of a new cultural approach in the city. The strategy will be delivered in partnership with key and other cultural stakeholders. This collaborative delivery of the Cultural Strategy is essential to further strengthening the city‟s cultural life

Amend Policy FC1 on page 85

From: To lead and support the development of a shared vision for culture in the city in collaboration with cultural institutions and other cultural bodies across Dublin City

To: To lead and support the development of a shared vision for culture in the city in collaboration with cultural institutions and cultural bodies based both citywide and nationally Section: 7.1.5.2 Protecting and Enhancing Dublin City’s Cultural Assets

Summary of Issues The significant majority of submissions in relation to culture, make reference to this section of the chapter.

A large number of submissions strongly object to the standard that requires estate names and public roads to be stated in Irish only. Support is expressed in a number of submissions for an Irish language centre and cluster, with one submission stating that the cluster should be in Smithfield.

The view is expressed in a number of submissions, including that of the Grangegorman Development Agency, that additional cultural facilities and tourist options are required, including cultural centres for non-nationals, a 400 – 500 seat municipal theatre, a science museum and that empty units should be given over to artists to use shopfronts to display arts. It is also requested that owners of such properties be exempted from rates in exchange for their use as temporary art display venues. Some area-specific suggestions are also made, such as the reinstatement of the concert hall in the Town Hall, Rathmines.

It is suggested that lighting in the city could be vastly improved and that this could improve the array of cultural possibilities in the city.

Support is expressed for the focus on affordable workspaces for artists and the possibility of including such spaces as part of the allocation to 20% social and affordable housing was raised.

The opinion is expressed in one submission that FCO8 to designate a Dublin Day, is an odd objective as the city already has a Dublin Day in Bloom‟s Day. Manager's Response In response to the significant number of submissions received in relation the Irish language, there are a number of policies and objectives throughout the plan in order to fulfil the aims of raising the profile of the Irish language in the urban environment, namely Objectives FC07, FC010, FC014 and Policy FC11. The specific issue of irish only naming of places / estates / public roads etc., this issue is set as out in a number of sections throughout the draft plan.

It is considered that it is appropriate in a city, where English is the most widely understood and spoken language, that the names of street and roads, new residential and mixed use schemes are stated in English, as well as Irish. The naming of estates in Irish only is inappropriate and Dublin City Council should implement a naming policy that reflects the diversity of the city and multitude of identities and preferred languages held dear by its residents.

It is therefore recommended, as requested in the significant number of submission received, that Policy FC07 and the associated standard in Section 17.9.2 be amended to reflect the diversity of the city‟s population.

In relation to requests for specific types of cultural facilities, it is acknowledged in the draft development plan that there is some shortage of cultural facilities. To this end many policies have been incorporated into the draft plan to enhance the provision of cultural facilities in the city, namely FC7, FC8, FC9, FC12, FC13 and Objectives FC05, FC06, FC07. It is considered that the draft plan adequately addresses the issue in question and no changes to the plan are recommended in this regard.

In response to those submissions requesting that empty units be given over to artists, the direct provision of units to artists is an operational matter. However, it is considered that there is merit in including a new objective in the plan supporting and facilitating the use of vacant properties as artists‟ works and performance spaces on a temporary basis through the development management process.

Further to submissions at pre-draft stage in relation to lighting in the city, the draft plan recognises the need to enhance lighting in the city and to this end has incorporated objectives SI022, policy SI53, objective SI053, objective FC025, Section 17.6.3 relating to lighting design and levels and futher guidance on lighting is given in Appendix 10 and Appendix 19

In relation to the ongoing maintenance of public lighting this is an operational matter and is outside the remit of the Development Plan.

In response to the request in one submission that the concert hall be reinstated in the town hall in Rathmines, it should be noted that the development plan is a strategic document, and not site-specific. However, the issue has been considered in the Rathmines Local Action Plan, 2009.

With reference to that submission stating that the city currently has a Dublin Day i.e. Bloom‟s Day, it should be noted that while the draft plan supports the selection of a Dublin Day, the actual decision on the day itself will be a matter for the Arts, Culture, Leisure and Youth Affairs Strategic Policy Committee.

In response to the query as to whether affordable live-work units / studios for artists can be provided under Part V of the 2000 Planning and Development Act, it should be noted that the provisions of Part V of the act do not extend to the provision of housing for specific professions. Any amendment to this is outside the scope of a development plan.

The issue of exempting property owners from commercial rates is outside the scope of a development plan. Manager's Recommendation Amend Objective FC07 page 87 From: To ensure that the naming of new residential and mixed used schemes reflect local history, folklore and / or places names and are stated in Irish To: To ensure that the naming of new residential and mixed used schemes reflect local historical or cultural associations, history, folklore and / or places names and are stated in both English and Irish where appropriate.

Amend the last two sentences Section 17.9.2 page 218 From:: Such estate names shall be in the Irish language only and shall reflect the history and topography of the area in which they are located. The names of public roads shall be in the Irish language only.

To: Such estate names should be stated in both English and Irish where appropriate and shall reflect the historical or cultural associations or the topography of the area in which they are located. The names of public roads should be stated in both English and Irish where appropriate.

Include New Objective, FC06A, on page 87 as follows: To support and facilitate the change of use of vacant commercial units to publicly accessible cultural work spaces, performance venues, art galleries etc on a temporary basis through the development management process.

Section: 7.1.5.3 Cultural Hubs and Quarters

Summary of Issues A number of submissions express views and/or make suggestions for amendments to the cultural quarters, cultural attractions and Figures 12 and 13 of the plan. Support is expressed for the cultural clusters in a significant number of submissions.

The Office of Public Works (OPW) states that the development plan should promote and reinforce many of the cultural quarters that exist and encourage their connectivity to the city centre through pedestrian links, information points and visual links. The OPW also suggests that consideration should be given to expanding the Heuston / Museum Quarter to include Arbour Hill, the Magazine Fort, Kilmainham Jail, the War Memorial Gardens, as well as the historical connections with the Phoenix park, the National Museum and the Royal Hospital; and that a Military History Route/Trail could be included to include these attractions.

The Dublin City Business Association (DCBA) suggests that Mountjoy Square, Kings Inns, Black Hall Place, Henrietta Street, Fitzwilliam Square, Iveagh Gardens should be included in the Georgian Quarter and also suggests that the medieval quarter should be included.

Other suggestions for areas to be included or emphasised are Botanic Gardens and Glasnevin Cemetary as destinations; functional quarters e.g. the legal and financial quarters; Smithfield as a cultural destination; greater emphasis on and enhancement of the links between the quarters on the north and south of the River Liffey; more prominence should be given to the areas north of the city. One submission suggestst that Temple Bar is given too much prominence

The Dublin Docklands Development Authority request that the ongoing cultural and tourist facilities as represented in the Master Plan for the Docklands 2008 be included in the City Council‟s Development Plan.

It is suggested in one submission that the names and/or boundaries of the cultural quarters as represented in Figure 13 be amended to more accurately reflect the cultural attractions as set out in Figure 12. Manager's Response In respect to many submissions on the issue of cultural quarters, it is agreed that there is merit in the highlighting the desire to continue to improve their connectivity to the city centre, and to each other, through pedestrian links, information points, visual links, themed trails etc. In this regard, it should be noted that objectives on this very issue are already incorporated into the plan mainly, SC014 (Pedestrian Wayfinding), FC016 (Legible Dublin).

With regard to amendments to the maps indicating „Main Cultural Attractions‟ and „Main Cultural Quarters‟ (Figures 12 and 13 respectively), it should be noted, that the draft development plan contains a number of figures indicating the city‟s most pronounced cultural assets, namely Figures 5, 12, 13 and 14. It is considered that it would be beneficial to amend Figure 13 to include additional attractions.

Also on the same issue, in order to further align Figures 5, 13 and 14, to highlight further the cultural activity on the north side of the city and to take on board the views expressed by the DDDA , it is recommended that the extent of the Cultural Quarters should be amended slightly and some of the quarters renamed to reflect the character and underlying heritage of the areas involved.

In response to those submissions requesting that Smithfield be referred to and given more attention in the chapter, it is considered that this can be achieved by making reference to Smithfield in Sections 7.1.1 and Section 7.1.5.3. Manager's Recommendation Amend Figure 12 to include the following additional cultural attractions: Farmleigh, Phoenix Park Visitor Centre, Number 29 – Georgian House Museum, National Photographic Archive, James Joyce Cultural Centre, Casino Marino, Áras an Uachtaráin Botanic Gardens and Cemetery Wood Quay Venue & My City Exhibition

Amend Figure 13 to highlight in greater detail the cultural assets on the north side of the city and to ensure closer alignment with the Character Areas as illustrated in Figure 5 and the Built Heritage as illustrated in Figure 14: North and South Docklands The North Georgian City and O‟Connell Street (to include Mountjoy Square and Garden of Remembrance) The South Georgian City and Trinity College (to include Fitzwilliam Square, Iveagh Gardens, St. Stephen‟s Green) Temple Bar The Old City (Medieval City) - north and south of the River Liffey The Liberties Smithfield & Collins Barracks linking to Phoenix Park Heuston Gateway Quarter (to include Heuston/Kilmainham/Arbour Hill and links with Phoenix Park)

Amend supporting text in Section 7.1.1 Achievements pg. 84 From: Other cultural quarters are emerging such as Heuston Gateway and the cultural cluster in the environs of Merrion Square, while Temple Bar continues to provide the city with a distinctive cultural edge and excitement

To: Other cultural quarters are emerging such as Heuston Gateway, the cultural cluster in the environs of Merrion Square and Smithfield, while Temple Bar continues to provide the city with a distinctive edge and excitement

Amend the 2nd sentence of supporting text in Section 7.1.5.3 Cultural Hubs and Quarters page 87 From: Cultural clusters are emerging around Parnell Square, Heuston Gateway and The Liberties and the City Council will continue to support their development

To: Cultural clusters are emerging around Parnell Square, Heuston Gateway, The Liberties, Smithfield and the City Council will continue to support their development

Section: 7.1.5.4 Culture and the Economy

Summary of Issues Support is expressed in submissions for the plan‟s focus on culture and the economy. The Lord Mayor‟s Commission on Employment suggests that the recommendations of Dublin Tourism‟s Cultural Tourism Strategy should be implemented.

The submission from the Dublin Docklands Development Authority states that the authority is seeking the development of six tourism nodes promoting a cluster of tourism, arts and culture facilities, in George‟s Dock, Spencer Dock/North Wall Quay, Grand Canal Square, Point Village, Britain Quay and Poolbeg areas as set out in the DDDA Master Plan 2008

One submission contends that the city needs a landmark building with accompanying observation deck to promote tourism. Manager's Response The Cultural Tourism Strategy referred to in the submission from the Lord Mayor‟s Commission on Employment is entitled Dublin Tourism Cultural Tourism Committee (CTC) Strategy and Action Plan 2009 – 2011. The majority of actions set out in the strategy are operational and procedural actions for the CTC itself. Notwithstanding this, it is considered that the draft plan fully supports the planning-related actions set in the strategy such as those relating to signage, cultural quarters, along with policies to improve the urban environment and pedestrian and bus linkages between key cultural attractions. No amendments to the draft plan are considered necessary.

In response to the submission from the Dublin Docklands Development Authority, the Draft Development Plan as existing supports the Docklands‟ tourism nodes through the designation of the north and south docklands areas as cultural quarters. The development of these quarters are further supported Policy FC16. Support is also offered for the cultural quarters through the landuse zoning objectives and the designation of a Strategic Development and Regeneration Area (SDRA 6) for this part of the city. No amendments to the draft plan are therefore required.

In relation to high buildings as tourist attractions, the draft development plan supports the provision of cultural facilities / cultural venues at suitably prominent and accessible locations in proposals for high buildings as per Section 17.6.3 of the draft plan. No change to the draft development plan is therefore required. Manager's Recommendation Retain as existing.

Section: 7.1.5.5 Culture in the Public Domain

Summary of Issues The National Council for the Blind in Ireland (NCBI) request that access routes are kept clear when cultural exhibitions are held in public streets / squares / parks. In terms of the quality of the urban environment, it is suggested that pedestrian and bus linkages between key visitor attractions should be improved. Improved management of public events with regard to noise and nuisance is requested and it is submitted that venues likes Croke Park and that the 02 should work with the communities to ensure cleaning after the events and there is meaningful consultation with communities in the area. A site-specific request to cease entertainment events in Smithfield on the basis that it is unfair to the residents was received.

A number of submissions request the provision of art in new private developments (as opposed to only in publicly-funded development under the Percent for Art scheme).

A specific suggestion for a new policy is made: “To continue to animate the public domain through the delivery of an annual event programme in collaboration with key event and festival partners”. Manager's Response In response to the submission by the NCBI, it should be noted that Dublin City Council events are mainly organised by the City Council‟s Events Unit ensuring that access routes etc are kept clear during events. This is an operational and not within the remit of a development plan.

The noise and litter generated at events and the reduction of same in venues such as those mentioned in the submissions i.e. Croke Park, O2 etc. are primarily operational and management matters. However, an objective has been incorporated into Chapter 5 of the draft plan to develop a traffic management and environmental protection plan for sports stadia in consultation with relevant transport and sporting bodies (SI042). It is recommended that objective SI042 be expanded to make reference to cultural events.

In relation to the suggestion that the quality of the urban environment, including bus and rail links, between cultural attractions be improved, it should be noted that these issues are comprehensively addressed through a substantial amount of policies and objectives in Chapter 4, Chapter 5, Chapter 16 (under Guiding Principles for Public Realm).

In response to the suggestion that pieces of public art should be included in private schemes, this issue is addressed by Policy FC23 (encourage the provision of public art through the Development Management process) and by Objective FC017 (the inclusion of public art in all major development schemes in the city).

In relation to rolling out of events, while the actual organising and running of an event programme is an operational matter it is considered that the Draft Development Plan would benefit from emphasising the support for festivals in the city by way of the insertion of a new objective. Events are also recognised as important economic drivers for the City in Chapter 9 of the Draft Plan.

The cessation of events in Smithfield as requested in one particular submission, is outside the scope of a Development Plan. The management of events in Smithfield is primarily an operational matter. Manager's Recommendation Amend Objective SIO42 on page 51

From To develop a traffic management and environmental protection plan for Sports Stadia in consultation with relevant transport and sporting bodies

To: To develop a traffic management and environmental protection plan for sports stadia and significant cultural events in consultation with relevant transport, sporting and cultural bodies

Include new Objective FC017A page 89 as follows: To continue to animate the public domain by facilitating and supporting the delivery of an annual events programme by Dublin City Council in collaboration with key event and festival partners, whilst protecting the residential amenities of the surrounding area.

Section: 7.2 Built Heritage

Summary of Issues A number of submissions suggest amendments to Figure 14 including that the full extent of the North Georgian City Area be illustrated. The OPW have stated that a number of their properties have been excluded. The RIAI suggest a number of changes to the titling. Manager's Response There is an error on Figure 14 in that the full extent of the North Georgian City Area is not illustrated. The map should be revised accordinlgy. Regarding the exclusion of properties, the purpose of the map as suggested by its heading is to identify the MAIN features of the built heritage and the main landmarks in the city. The map is for illustrative purposes only and not intended to show every feature of the built heritage in the city. Manager's Recommendation Amend Figure 14 to:

Illustrate the full extent of the North Georgian Area Change the titling under Landmarks in the case of No. 18 from Rotunda Hospital to Parnell Square and No. 20 from Kings‟ Inns to Kings‟ Inns/Henrietta Street.

Section: 7.2.3 Challenges

Summary of Issues It is suggested that the heritage and tourism potential of Victorian and Edwardian architecture, not just Georgian, should be referred to and protected.

Section 7.2.3 "Challenges" states that "This does not imply that Georgian or historic Dublin should be a 'museum piece ' the historic fabric requires sensitive modern infill projects, complementary buildings which mutually respect their surroundings." The RIAI comment that while the sentiment is laudable, confining it to Georgian and historic Dublin excludes other periods particularly the more recent past.

Submission also support the 'challenge' to unlock the tourism potential of the medieval city and the Liberties. COVA states that Chapelizod has been excluded and also that it is not included in the list of existing ACAs. Manager's Response Victorian and Edwardian areas are generally protected by the Z2 residential zoning and a number of these areas have been considered for ACA protection (Appendix 11). However text could be amended to give recognition to these periods.

It is not considered necessary to amend the statement referred to by the MAI as it does not exclude any building period.

The first paragraph on Pg. 92 refers to the challenge of promoting and conserving the characteristics of these historic villages which includes the historic village of Chapelizod. Chapelizod appears in the list of designated ACAs under Section 7.2.1 Achievements. Manager's Recommendation Amend text under Section 7.2

From The built heritage contributes significantly to the city's identity and to the richness and diversity of its urban fabric. The street pattern, local architectural features, the form of buildings and spaces, civic buildings within set pieces of urban design and the industrial buildings of traditional enterprises all contribute to the city's character, reinforcing its identity and contributing to creating the sense of place necessary for the development of the city.

To: The built heritage contributes significantly to the city‟s identity and to the richness and diversity of its urban fabric. The street pattern, local architectural features, the form of buildings and spaces, civic buildings within set pieces of urban design, the unique Georgian Squares and streets together with the larger areas of Victorian and Edwardian architecture both north and south of the canals, and the industrial buildings of traditional enterprises all contribute to the city‟s character, reinforcing its identity and contributing to creating the sense of place necessary for the development of the city.

Section: 7.2.4 The Strategic Approach

Summary of Issues The OPW submits that it manages a number of properties that can contribute to the development of integrated tourism policies, and in partnership with DCC can reinforce the character, cultural significance and tourism potential of historic areas in the city. Manager's Response Partnerships with different agencies is a valuable and effective mechanism in the enhancement of the tourist potential of the city‟s built heritage and should be acknowledged in the Plan. Manager's Recommendation Insert the following New Policy under Section 7.2.5.1:

To co-operate and facilitate partnerships with relevant agencies for the continued development of integrated policies in order to reinforce the character, cultural significance and tourism potential of the historic areas in the city.

Section: 7.2.5.1 Promoting Sustainable Development in Conservation

Summary of Issues One submission refers to the neglect of 19th century city outside of canals. The RIAI consider that policies in relation to the North Georgian Core are poor, and that the impact that large modern developments have on protected structures is not addressed. The OPW seek clarity between the terms heritage buildings, historic buildings, protected structures and other buildings of architectural/historic merit.

It is also submitted that the Draft Plan should be changed to re-instate all provision from the current plan which protect the built heritage. It is suggested that Section 7.2 be amended to acknowledge the role of designed landscapes as part of the built heritage of the city and that it should include mention of the designed landscapes of the Phoenix Park including the buildings of Decimus Burton as significant elements of the Built Heritage.

Other submissions suggest that the Plan should contain a strong commitment to planning enforcement in the area of protected structures and that policies and objectives to reverse the process of inappropriate interventions which have materially damaged the form and character of historic buildings, streets and squares should be included with specific reference to Rathmines. It is submitted that that single storey commercial units in the former front gardens of 19th century terraces of urban significance should be removed. Manager's Response The majority of the 19th Century building stock are either within the Z2 or Z8 conservation areas, and are frequently protected structures, and as such are offered considerable protection. Dublin City Council‟s strategic and overarching approach to protecting and enhancing the north city‟s built heritage includes emphasising the regeneration of the North Georgian Core to its former cultural and historic importance so as to leverage economic and social benefits for the entire city (Policy FC42). Specific areas will be further targeted through the City Heritage Plan for future plans and programmes which will have their own individual policies and objectives. The standards section under 17.10.1 and 17.10.2 provides detailed safeguards against the issue of potential impacts of development on the setting of protected structures. It is agreed that clarity should be provided in the text to address the terminology of historic building/heritage building/historic merit.

All policies and objectives in the current plan were reviewed and the appropriate policies and objectives have been carried forward and/or updated as necessary and were included as requested by several motions at pre-draft stage

The Phoenix Park is a National Monument and therefore has the greatest level of protection afforded to it including the structures within it. Furthermore Objective GCO6 refers to investigating areas including the Phoenix Park with a view to determining their suitability for Landscape Conservation Area status.

The purpose of the Development Plan is to guide development, Dublin City Council does not have the authority to „reverse‟ development which has been long established. Enforcement action is taken against unauthorised development. In accordance with Planning Legislation all development including that related to protected structures must be carried out and completed in accordance with the planning permissions granted.

The Development Plan provides guiding principles which promotes best practice in all cases. The single storey commercial units in the former front gardens of 19th century terraces in Rathmines are established uses and form part of the commercial core of the village. Manager's Recommendation Amend paragraph under 7.2.5.1

From The retention, rehabilitation and reuse of old buildings can play a pivotal role in the sustainable development of the city. In many cases they make a positive contribution to both streetscape and sense of place. Dublin City Council will promote the sustainable use of historic buildings and protected structures both through development management and guidance to building owners.

To: The retention, rehabilitation and reuse of the built heritage can play a pivotal role in the sustainable development of the city. In many cases they make a positive contribution to both streetscape and sense of place. Dublin City Council will promote the sustainable use of the city‟s built heritage including protected structures both through development management and guidance to building owners.

Amend Policy FC26

From: To seek the preservation of historic buildings in the city that make a positive contribution to the character, appearance and quality of local streetscapes and the sustainable development of the city

To: To seek the protection of the built heritage of the city that makes a positive contribution to the character, appearance and quality of local streetscapes and the sustainable development of the city.

Amend Policy FC27

From: To include those structures considered to be of special architectural, historical, archaeological, artistic, cultural, scientific, social or technical interest in the Record of Protected Structures. To protect historic structures on the Record of Protected Structures, their curtilage and the setting from any works that would cause loss or damage to their special character

To: To include those structures considered to be of special architectural, historical, archaeological, artistic, cultural, scientific, social or technical interest in the Record of Protected Structures. To protect these structures, their curtilage and the setting from any works that would cause loss or damage to their special character.

Amend Section 7.2.5.2 title

From Historic Buildings and Protected Structures

To Protected Structures and the Built Heritage.

Section: 7.2.5.2 Historic Buildings and Protected Structures

Summary of Issues It is submitted that any building which has been passed for inclusion onto the Record of Protected Structures by an Area Committee should be brought to a full City Council meeting at the next available opportunity to ensure the process is completed.

It is also suggested that a new policymbe inserted after FC35. To ensure that any development in the area of a protected structure does not detract from the visual amenity of the protected structure One submission requests that rainwater harvesting and thermal heating from underground must be considered in conservation areas. While another refers to energy ratings in Architectural Conservation Areas and the presumption of the policy should be that all residential buildings in ACAs may be upgraded to BER B rating or higher. Other submissions require that all the historic material, roofs, walls, windows, doors and floors and ceilings are an essential part of the cultural patrimony and should be kept intact and that old buildings should be renovated and painted.

The RIAI state that Policy FC31 should be extended to buildings in ACAs. Suggest FC29 and FC34 should be combined. Objective FCO21 – this must be a critical review of the RPS that removes those structures that should not be there.

A submission suggests that the Council keep a list of significant buildings at risk which will be prioritised for development with fast track planning and reduced development levies.

The DoEHLG requests that the text for Objective FCO26 should be reviewed as it considers that the text implies that the planning authority will only address adverse impact on protected structures when matters have got to such a state that they have to be included in a „buildings at risk‟ register. Further Objective FCO26 should be reworded to substitute the words “action may be taken” with “action taken”.

It is suggested that 20th century buildings should also be protected and specific policy be included. It is contended that Objective FCO22 should be reconsidered and amended as the RPS is too prescriptive for the meaningful conservation of buildings of significance from the late twentieth century. It is suggested that a comprehensive study should be the basis for selection.

Submission states that the return to original use of townhouses as single family dwellings, or sensitive subdivision of houses into generous period apartments as is the practice in Paris, Amsterdam and other continental cities, should be pursued thereafter the Plan.

Regarding FCO23, the RIAI suggest that other buildings should also be considered. A seperate submission states that FCO23 in its current format is considered overtly restrictive and contrary to the proper planning and sustainable development of the area as it specifically allows only one use (i.e. the existing café use) in the building (Bewley‟s, 78/79 Grafton Street) and fails to take account of potential changes in the market situation which are a material consideration in the drafting of development plans, as acknowledged in the Development Plan Guidelines for Planning Authorities (DOEHLG, June 2007, paragraphs 3.14, 3.18).

The EPA has requested that Policy FC33 be amended to include a reference to energy efficiency. Manager's Response Systems are in place to ensure that all buildings which are to be added or deleted to the RPS go forward to the next full City Council meeting to comply with the statutory deadlines set out in the process.

Section 17.10.2 of the Plan provides guidance in considering applications for development within the curtilage of a protected structure. Regard must be made to the proximity of any new development to the main protected structure, any other buildings of heritage value and the wider context of the site or structure (Section 17.10.8.1) Further protection is provided by virtue of the fact that the majority of the protected structures in the city are located within Z2 or Z8 conservation areas.

Dublin City Council is fully committed to encouraging the efficient use of energy and the use of renewable energy in new and refurbished buildings throughout the city, in accordance with the energy efficiency policies, objectives and standards throughout this Development Plan. ACAs usually contain a large number of protected structures which are exempt from the provisions of the BER. However, guidance for the upgrading of structures for energy efficiency with regard to protected structures and historic buildings is promoted through Objective FCO24.

The RPS, ACAs and the zoning of certain areas as Z2 and Z8 provides protection for the special architectural character and setting of buildings in these areas. In particular, policy FC35 promotes the use of planned maintenance programmes and the preparation of conservation/management plans to avoid loss of historic building fabric and authenticity through inappropriate repair work. It is the overarching policy of Dublin City Council to seek the preservation of the built heritage and also provide assistance in the form of conservation grant.

Conservation grants are provided under Section 80 of the Planning and Development Act 2000 which relate to works to protected structures only. There is no provision in the Act for a grant scheme in relation to ACAs. It is agreed that Policy FC34 should be amended as the current wording is confusing. It is intended that a thorough and critical review of the RPS will be carried out during the life of the Plan.

A Buildings at Risk Register is in place (Objective FCO26) for protected structures which are suffering from neglect. There are approximately 150 buildings on the register and they are targeted for conservation grants. The owners are given advice on repairs and maintenance of their buildings. The condition of the buildings are closely monitored. The time frame on planning applications is set in legislation and level of development contribution is outside the scope of a Development Plan. The BAR is a positive instrument. It is a positive means of prioritising these buildings and a mechanism for targeting public money in a fair and non-discriminative manner. It is a policy that has been applied successfully for a number of years.

Section 7.2 of the Development Plan contains policies and objectives to protect and enhance the built heritage. Objective FCO22 provides for the protection of 20th century buildings, however further clarification is required.

Through the residential zonings of Z1, Z2 and Z8 Dublin City Council promote predominantly residential use in such areas.

Grafton St has been designated an area of Special Planning Control and Section 1.1.3 of this scheme states that a number of uses on Grafton Street are of special significance through their long association with the street. It is an objective of the Scheme of Special Planning Control to protect these particular uses, which contribute so much to the special and unique character of the area. It is considered that Objective FCO23 provides important complimentary protection for this building as advocated in the Special Planning Control Scheme. The protection of existing and last use is further highlighted through Policy FC29.

It is considered that Policy FC33 should be amended in accordance with the EPA‟s request. Manager's Recommendation Amend Policy FC34 From: To actively encourage uses which are compatible with the character of protected structures.

To: To consider new uses which are compatible with the character of protected structures.

Amend Objective FCO26 From: To maintain a register of Buildings at Risk in which protected structures at risk from neglect or wilful damage will be entered and actions may be taken to ensure their survival

To: To maintain a register of Buildings at Risk in which protected structures at risk from neglect or wilful damage will be entered and actions will be taken to ensure their survival.

Amend Policy FCO22 From: To identify and protect exceptional buildings of the late twentieth century, by inclusion in the RPS.

To: To identify and assess exceptional buildings of the late twentieth century, and to categorise, prioritise and where appropriate, add to the RPS. Dublin City Council will produce guidelines and offer advice for protection and appropriate refurbishment.

Amend Policy FC33 From: To protect the special interest and character of protected structures while complying with the requirements of fire safety

To: To protect the special interest and character of protected structures while complying with the requirements of fire safety and energy improvements.

Section: 7.2.5.3 Conservation Areas

Summary of Issues Support is expressed for the Z2 and Z8 zonings in the Plan and for the commitment to continue to prioritise the assessment of appropriate areas, streets and squares for designation as ACAs and to re-designate existing non-statutory conservation areas as ACA.

An Taisce has requested that the Plan should designate more areas for ACAs and Areas of Special Control. Another requests that the number of ACA's in the north inner city be extended.

Another submission requests that a systematic review of all potential areas for ACAs should be carried out at this stage in accordance with the criteria outlined in Policy FC36. The RIAI state that to protect the special character of the city‟s conservation areas through the term „uniqueness‟ applied to an areas‟ built fabric should be removed – each area will have unique buildings in abundance.

There are requests to amend the development plan to ensure that the provisions relating to ACAs and protected structures are as agreed under the Phibsboro/Mountjoy Local Area Plan.

It is submitted that Mountjoy Square Park is in serious need of remediation, with an imperative to restore this historic open space to a configuration that compliments the "character" of Mountjoy Square.

It is suggested that reference to the provisions of Section 29 of the Disability Act 2009 be added to the section on Built Heritage.

One submission requests that the ACA status of Charleville Road be retained.

It is submitted that the blanket conservation area designation over much of the south Georgian city is restricting the opportunities to create modern high quality architectural designs. In the specific case of the urban block at Wilton Place, in order to facilitate the managed and integrated redevelopment of the site it is requested that the Conservation Area designation be removed.

It is submitted that the ACA boundary for the Marino ACA is incorrect on the Draft Map.

A number of submissions put forward specific areas for ACA designation. In particular a large number of submissions were received for Mountjoy Square (27 submissions) and Iveagh Gardens (144). Other areas suggested include:

Mid 19th Century Pembroke Estate Archaeological and Ecclesiastical ACA for Crumlin Village Mountjoy Square – including North Great Georges Street, Gardiner Place, Upper Gardiner St, Temple St/Hardwicke St, St. George‟s Church and Eccles St. The Linear Park (Old Canal spur to Guinness Brewery) between Griffith Bridge and the end of James Walk. Royal Canal Corridor Sandymount – from the village to Merrion Gates Georgian Squares and Environs, Victorian Squares and some areas on the north of the city, including but not limited to Marino, Mount Brown, Middle Third, Lindsay/Iona Road, Hampstead, Shandon Park and the Phoenix Park Iveagh Gardens, Crumlin Railway Estate, Inchicore The eastern part of Rathdown Park, Terenure, and the adjoining Rathfarnham Road Belgrave Square, Grosvenor Square and Brighton Square Phibsboro and surroundings (NCR, Whitworth Road to Drumcondra), Ballsbridge and Merrion

It is submitted that the word „onerous‟ should be removed with reference to ownership of a protected structure (Objective FCO27) and should be replaced with a more positive phrase. Manager's Response All designated ACAs are carried over to the next Development Plan and it is an objective to designate more ACAs and to consider areas for Special Planning Control. The North Georgian Core has been identified for regeneration and enhancement under Policy FC42

It is agreed that the wording of the 3rd bullet point of FC36 regarding uniqueness of an area is inappropriate and should be revised.

No ACAs were formally adopted under the Phibsborough LAP. The LAP states that the extent of the ACAs and properties to be included will be part of further research and on site assessment. This has been undertaken and the Draft Plan proposes ACAs for the following areas as set out in the LAP: Phibsborough Centre, Great Western Square and Environs and Blessington Basin and Environs. (See APP 11)

Works are set to commence to begin repair of the railings of Mountjoy Square Park. The removal of railings has been referred to the Enforcement Section.

Policy FC39 includes provision for access for all and makes reference to “as far as practicable”. A reference to the Disability Act 2009 should be included.

Charleville Road is not a designated ACA – it is zoned Z2 Residential Conservation Area which is retained in the Draft Plan.

The conservation area designation in south Georgian area of the city is integral to the protection of the built heritage of the city and should be retained.

The boundary for the designated Marino ACA on the draft map is incorrect and will be rectified.

To qualify for ACA designation it must be clearly established that an area is of special architectural, historical, archaeological, artistic, cultural, scientific, social or technical interest or value or contributes to the appreciation of protected structures. The decision to designate an area as an ACA will also be determined having regard to the criteria set down in Policy FC36 of the Draft Plan and will be based on a detailed architectural, historical and morphological analysis of the area which is firmly grounded in a proper building inventory. This evaluation is currently ongoing and having regard to the extensive built heritage of the city, it would be premature to identify the prioritised areas for designation pending completion of the evaluation process.

It is agreed that the text should be amended to remove the negative connotations in relation to ownership of protected structures. Manager's Recommendation Amend 3rd bullet point of FC36 From: The uniqueness and relative importance of an area‟s built fabric having regard to the extent of that particular type of architecture/ building form in Dublin City

To: The distinctiveness and relative importance of an area‟s built fabric having regard to the extent of that particular type of architecture/building form in Dublin City.

Amend FC39 From: To protect the special interest and character of protected structures and Architectural Conservation Areas while striving to meet the requirements for access for all in as far as practicable To: To protect the special interest and character of protected structures and Architectural Conservation Areas while striving to meet the requirements for access for all in as far as practicable in accordance with Section 29 of the Disability Act 2009.

Amend the Marino ACA boundary to the correct version.

Amend FCO27 From: To designate additional Architectural Conservation Areas, including residential, suburban areas of the city with the specific objective of reducing buildings in these areas which are listed on the Record of Protected Structures, as appropriate. (Any buildings selected for deletion from the RPS will be of local rather than of regional significance. These ACAs will protect primarily the front facades and streetscape character and will remove the onerous obligations that protected structure status confers on owners and occupiers of such buildings) (See Appendix 11)

To: To designate additional Architectural Conservation Areas, including residential, suburban areas of the city with the specific objective of reducing buildings in these areas which are listed on the Record of Protected Structures, as appropriate. (Any buildings selected for deletion from the RPS will be of local rather than of regional significance. These ACAs will protect primarily the front facades and streetscape character and will remove the protected structure status of such buildings (See Appendix 11)

Section: 7.2.5.4 Historic Urban Villages, Streets and Public Buildings

Summary of Issues It is submitted that a vision for each Georgian square in the city should be worked upon during the life of the development plan and a suggestion to remove bus termini at these locations should be considered. Dublin City Business Association states that the tourist potential of Dublin's squares needs to be realised as an economic resource. It is also requested that the Plan define the Georgian Mile.

The RIAI suggest that Policy FC45 should include some reference to methodology to define and record the historic villages. Another submission requests that Policy FC44 should be amended to ensure retention of the historic street pattern.

Objective FCO30 (upgrade the Mansion House) should be specifically related to the Government Policy Document on Architecture with regard to policy for buildings of architectural heritage value in Dublin City Council care.

A submission states that A Village Design Statement (VDS) for Sandymount is in progress and it is requested that a statement be included in the Plan to illustrate this fact. Manager's Response It is agreed that the enhancement and protection of the Georgian Squares should be given more prominence in the Development Plan. The potential to remove bus termini will be taken into account in any study. Reference should be made to the Georgian Squares under Section 9.4.7 to highlight the tourist potential of these areas. A definition for the North Georgian Mile should be included in the Glossary Section. It is agreed that a statement of methodology should be added to Policy FC45. It is considered that policy FC44 in its current form is clear in its intention and should be retained as existing.

Dublin City Council is the present custodian of the Mansion House, which has been the centre of civic hospitality since it was purchased by the City Corporation in 1720. It has been upgrading and repairing its building fabric on a continuous basis. The Council proceeded in June 2008 to commission a conservation and development strategy for the Mansion House. This initiative predated the publication of the Government Policy on Architecture 2009-2015. Subsequently this study was undertaken and completed by the City Council in July 2009 and Objective FC030 relates to the conservation strategy for the buildings arising from this study. Further Policy FC46 of the Plan ensures that significant heritage buildings owned by the Council are protected and enhanced.

The Sandymount VDS should be added to the Plans proposed under SC09. Manager's Recommendation Amend Policy RE28, as set out at Chapter 9, Section 9.4.6

Amend title of 7.2.5.4 From: Historic Urban Villages, Streets and Public Buildings. To: 7.2.5.4 Historic Urban Villages, Streets, Squares and Public Buildings

Amend Policy FC43 From: To protect and enhance the important civic design character of Dublin‟s Quays and historic public spaces

To: To protect and enhance the important civic design character of Dublin‟s Quays, Squares and historic public spaces.

Insert the following definition for North Georgian Mile in Glossary section: The North Georgian Mile follows the route from Custom House up Gardiner Street to Mounjoy Square and would include the following adjacent streets: Frederick Street, Parnell Square North and West, Granby Row, Dominick Street, Henrietta Street, Eccles Street, Gardiner Street Upper, Belvedere Place, Dorset Street (between Bolton and Upper Gardiner Streets), Beresford Place and Charles Street.

Amend Policy FC45 From: To conserve the unique characteristics of Dublin‟s Historic Villages and promote conservation of their architectural features and streetscapes

To: To conserve the unique characteristics of Dublin‟s Historic Villages and promote conservation of their architectural features and streetscapes by assessment, research, community consultation and appropriate designations and protection policies.

Amend SCO9 From To prepare a number of Schematic Masterplans or Village Improvement Plans (VIPs) for existing and long-established District Centres (Urban Villages) in conjunction with the relevant Area Committees in so far as priorities and resources permit, including the following: Cabra Donnycarney Finglas Glasnevin Harolds Cross Marino Rathgar Terenure Bluebell Crumlin Walkinstown Ringsend

To: To prepare a number of Schematic Masterplans, Village Improvement Plans (VIPs) or Village Design Statements (VDS) for existing and long established District Centres (Urban Villages) in conjunction with the relevant Area Committees in so far as priorities and resources permit, including the following: Cabra Donnycarney Finglas Glasnevin Harolds Cross Marino Rathgar Terenure Bluebell Crumlin Walkinstown Ringsend Sandymount

Section: 7.2.5.5 Enhancing the Public Realm

Summary of Issues The submission agrees with policy FC47 which seeks the repair and retention of traditional shops and pubs fronts and requests that this should be applied to the shop fronts on Upper Baggot Street, Ballsbridge. The RIAI note a lack of clarity in the drafting of FC47 and FC48.

It is suggested that a Public Realm Strategy should be drawn up for the upgrading of the South Georgian Quarter including the reinstatement of granite slabs where possible and the development of a new city park on the canal end of Wilton Terrace. The tour bus parking area should be relocated and Merrion Sq should be relayed as a Georgian Park rather than as a Victorian municipal park as it is as present. Manager's Response In response to the RIAI submission it is recommended that policies FC 47 and FC 48 be revised as a single policy.

The Public Realm Strategy is being prepared at present. The City Council is currently investigating the feasibility of reinstating Wicklow Granite on a Georgian Street as a pilot project. The challenges of availability of appropriate materials and significant cost implications are being interrogated. Manager's Recommendation Omit Policies FC47 and FC48 and replace with a new policy as follows: To seek the repair and retention of shop and pub fronts of architectural interest.

Section: 7.2.5.6 Dublin City Heritage Plan

Summary of Issues One submission stated that copies of the first City Heritage Plan and the Dublin City Industrial Heritage Record mentioned in the Plan could not be located.

It is suggested that there is a need for conservation programmes which rejuvenate and preserve the unique characteristics of Ballybough, Summerhill, Mountjoy Square and immediate surrounding areas.

It is requested that Policy FC56– should also acknowledge our peace-keeping achievements by siting a peace museum at Magazine Fort with bridge across the Liffey to War Memorial Gardens

One submission that that the development of a dedicated Dublin City Museum as in the existing plan should continue to be a policy of the City Council and should be restated.

Another states that historic granite flagstones, kerbs and setts are valuable assets which need more effective protection and sensitive treatment and that the recommendations of Dublin City Council‟s 2009 Survey of Historic Street Surfaces must be fully implemented if the character and quality of the public domain in the centre is to be protected.

It is suggested that the Plan should identify a number of "demonstration or flagship" projects which would stimulate the recognition of the quality of the city's built heritage.

And also that the Plan should include a policy on “branding of the City‟s image” using the built and cultural heritage as the defining qualities.

The Save Moore Street Committee state that the redevelopment of the Carlton Site will cause unprecedented and unneccessary interferance with a monument of National Importance at 14 - 17 Moore St. And that the battlefield site associated with the GPO 1916 Garrison should be identified and preserved in its entirety and should become the focal point of a historical and cultural quarter in the North Inner City. It is further submitted that any development in the area should only proceed within the guidelines of its status as an ACA.

Support is expressed for the Designation of an UNESCO World Heritage status for Georgian Dublin. The RIAI queries the wisdom of investigating Dublin as a whole as potential world Heritage site and suggests that particular distinct elements would be more suitable such as the Georgian squares or the Liffey Quays.

The EPA has requested that Industrial Heritage should be referenced in Policy FC56. Manager's Response Phase 6 of the Dublin City Industrial Heritage Record was completed in 2009. The City Council is investigating all options to make it available to the public in 2011. The City Heritage Plan is available on the web.

A survey of vernacular buildings in Dublin City is to be carried out this year as a Heritage Plan project. There will be particular focus on the historic routeways into the city, and Dublins Historic Urban Villages (FC43).

The OPW has plans to build the Sir Edwin Lutyens bridge spanning the Liffey to connect the War Memorial Gardens to the Phoenix Park, the ambition for which Dublin City Council supports. A Peace Museum at the Magazine Fort is a matter for OPW.

It is agreed that the reinstatement of a policy in respect of a city museum is necessary.

A review of the setted streets of the city is currently underway with a view to detailing a repair specification for intact, authentic setted streetscapes. Part of this project will include recommendations for exceptional examples to be placed on the Record of Protected Structures.

Demonstration of best design practice in new buildings and conservation is already carried out through the range of departments in Dublin City Council. Selected projects include: Stabilisation works to 3 & 14 Henrietta Street, the Saint Luke‟s Graveyard Scheme, the City Walls and Defences Conservation Plan and the Wood Quay Venue which have emerged from the Dublin City Heritage Plan; New design schemes such as the Timber Yard and York Street housing complexes. Sean O‟Casey Community Centre and Donore Avenue Youth and Community Centre all contribute to a high quality urban environment. New spaces such as Father Collins Park add to this legacy.

Publications being produced through the Heritage Plan have the specific aim of raising the awareness of the resident and visiting public to the significance of Dublin‟s archaeological and architectural heritage. A research agenda will be produced as part of the forthcoming Heritage Plan, to guide the Council‟s approach to commemorating historical anniversaries, architectural and archaeological and natural environment publications. An iPhone Application is currently in development to raise awareness of the medieval city walls of Dublin.

The redevelopment of the Carlton site has been given planning permission by An Bord Pleanala. A Commemorative Centre is to be based at the National Monument buildings at 14-17 Moore Street, and shall be under the direction and management of one or more appropriate public bodies (for example the City Council, Office Public Works and or the National Museum). Details of the proposed arrangements shall be subject to the agreement of the planning authority in consultation with the Department of the Environment, Heritage and Local Government.

The DOEHLG is the governing body responsible for undertaking the potential for UNESCO status and has approved The Historic City of Dublin on the Tentative List for Dublin. DOEHLG has not clarified the specific designation as of yet. It is likely that since the designation incorporates the „Literary City‟ it will encompass much of the areas mentioned.

It is agreed that Policy FC56 should be amended to make reference to Industrial Heritage. Manager's Recommendation Insert new policy under 7.2.5.6 as follows: To investigate the feasibility of a dedicated Museum of Dublin with a range of stakeholders including OPW, the National Cultural Institutions, The Heritage Council and the City Council, in recognition of the wide range of cultural artefacts relating to the history and development of the City.

Amend Policy FC56 From: To promote the awareness of Dublin‟s military and maritime heritage.

To: To promote the awareness of Dublin‟s industrial, military, and maritime heritage.

Section: 7.2.5.7 Preservation of Archaeologically Sensitive Locations

Summary of Issues A number of submissions have highlighted that there must be a definite commitment to preserving and enhancing our history with special mention of Mountjoy Square and environs, the battlefield site of the Easter Rising and recent Viking finds.

The Department of the Environment has made a number of comments regarding this section of the Plan with regard to: The separation of policies and objectives and standards; The current status of the Dublin City Heritage Plan,and the lack of references to a number of Ministerial policy documents including the legislation that protects sites and monuments (National Monuments Acts and related legislation, International Conventions etc). There should be reference to the statutory obligations with regard to archaeological sites and monuments, the designated sites in the Record of Monuments and Places as designated by the National Monuments Acts 1930-2004) and the legal requirements that derives from such designations, ministerial policy documents that have been issued to refer to the protection of archaeological heritage (Framework and principles for the protection of archaeological heritage), the Minister‟s 2008 policy document National Policy on town defences and policy or objectives with regard to shipwrecks that lie within its administrative area. The Plan should include a list of monuments in the Ownership or Guardianship of the Minister and in the ownership or guardianship of the Council. Also, terms such as „Zones of Archaeological Interest‟ (section 17.11 p229) and „archaeologically sensitive locations‟ (section 7.2.5.7 p98) do not appear to have any legal or planning validity. Manager's Response There are a number of policies and objectives in the Plan that relate to preserving and enhancing the built heritage. The need for the regeneration and enhancement of the North Georgian Core is highlighted (Policy FC42) and it is proposed to evaluate Mountjoy Square for possible future ACA designation. There are a number of policies and objectives relating to the protection of the archaeology of the city including best practice preservation and the promotion of the international significance of Viking and Medieval Dublin. Amend Policy FC61 to make reference to the research agenda and other initiatives in place which are highly significant in the archaeological work of the City Council.

The observation of the DOEHLG has been carefully considered. A list of the ministerial policy documents will be provided as an Appendix to the Plan and a new policy should be provided to make reference to these documents.

The City Heritage Plan is scheduled for review in 2010 and it is envisaged that it will be launched in 2011. The Council will draw up list of the monuments in its, and the Minister's, ownership or guardianship and will include these as an Appendix to the Heritage Plan. These will include the City Walls, Meath Market, and several graveyards in Council ownership.

Clarity will be given to the descriptive terms such as Zones of Archaeological Interest. Manager's Recommendation Amend Policy FC61 From: To promote the awareness of the international significance of Viking and Medieval Dublin and to investigate key medieval sites and to conserve their character, setting and amenity

To: To promote the awareness of the international significance of Viking and Medieval Dublin and to investigate key medieval sites and to conserve their character, setting and amenity through Irish National Strategic Archaeological Research (INSTAR) Medieval Research Agenda and other initiatives.

Add the following Policy to Section 7.2.5.7: To have regard to the National Monuments Legislation, National Policy documents and Guidelines and Code of Practice that protects sites and monuments (see Appendix 13A).

Add new Appendix, Appendix 13A that lists the national monuments legislation, national policy documents and guidelines that protects sites and monuments.

Amend Objective FCO33 From: To consult the National Monuments Advisory Service in assessing proposals for development which relates to National Monuments.

To: To consult the National Monuments Service Department of the Environment, Heritage and Local Government in assessing proposals for development which relates to monuments.

Amend Bullet point under 7.2.4 The Strategic Approach From: Safeguarding historic open spaces and archaeologically sensitive locations

To: Safeguarding historic open spaces and zones of archaeological interest.

Amend Section Heading 7.2.5.7 From: Preservation of Archaeologically Sensitive Locations

To: Preservation of Zones of Archaeological Interest Insert the following paragraph at beginning of 7.2.5.7 The Dublin City Development Plan Map Zone of Archaeological Interest (shown enclosed by a dot and dash broken line or monuments outside this as a castle symbol respectively) is based on the Record of Monuments and Places Maps 1994. The Zone has been updated to reflect the most recent update at the time of the Development Plan review to the Sites and Monuments Service, DoEHLG, and the Record of Monuments and Places which are protected under Section 12 of the National Monuments (Amendment) Act 1994.

Amend first paragraph, line 1 (page 98) From: Archaeologically sensitive locations in urban areas

To: Zones of Archaeological Interest in urban areas

Section: 7.2.5.8 Industrial Heritage

Summary of Issues It is submitted that the Dublin City Industrial Heritage Record should be available on the web and clarity is requested as to why FCO46 refers to any single building. Manager's Response The information on the DCIHR is currently being manipulated for future inclusion on the Council website. In response to the query as to why a single building is being highlighted within an Objective, this was a specific request under Motion No. 539 of the pre-draft stage of the Development Process. Manager's Recommendation Retain as existing.

Chapter 8 Making Dublin the Heart of the City Region Submission Number(s): 2044, 2168, 2171, 2229, 2235, 2271, 2664, 2769, 2805, 2836, 2837, 2909, 2965, 3101, 3142

Section: 8.0 Making Dublin the Heart of the City Region

Summary of Issues The Dublin Port Company supports the second paragraph of the chapter which recognises the need to support the national role of Dublin Port in accordance with the National Spatial Strategy. Manager's Response Such support is welcome. Manager's Recommendation Retain as existing.

Section: 8.4.2 Branding the City-Region

Summary of Issues It is suggested that there should be a policy and objective on branding the city‟s image based on the use of built and cultural heritage as defining qualities with a small number of prestige projects. It is submitted by Failte Ireland that greater co-operation is needed with existing branding such as „Dublin‟s Doorstep‟ which encourages day trip tourism from Dublin. Manager's Response It is considered that these issues are addressed by Policy HR3 which supports the branding and promotion of Dublin and associated objective HRO1 which seeks to develop a brand identity for Dublin partly based on the city‟s distinctive identity and unique achievements. Heritage based branding and coordination with established parallel branding initiatives may form part of future Dublin City Council branding envisaged under policy HR3 and objective HRO1 and it is considered appropriate to have regard to these matters in this objective. Manager's Recommendation Amend Objective HRO1 From: To develop a brand identity for Dublin based on the city's distinctive identity, unique achievements and competitive advantage as an international city region

To: To develop a brand identity for Dublin based on the city's distinctive identity, built heritage and environment, unique achievements and competitive advantage as an international city region. Section: 8.4.3 Regional Co-ordination for Sustainable Spatial Development

Summary of Issues It is suggested that greater co-ordination between government bodies is required on this issue and that small, focussed groups of staff on secondment could be selected and empowered by various councils to address trans-jurisdictional issues. One submission suggests that Dublin City Council and the Dublin Docklands Development Authority should be amalgamated.

Support is expressed for policy HR4 (collaboration between the four Dublin Authorities) in the submission from the Construction Industry Federation. Manager's Response Section 8.4.3 and Policy HR4 acknowledges the need to co-ordinate and collaborate with adjacent Local Authorities and the Regional Authority. Dublin City Council has collaborated with adjacent authorities to produce several strategies and plans including „The Economic Development Action Plan for the Dublin City Region‟ and „The Greater Dublin Strategic Drainage Study‟. Dublin City Council co-operates with the Dublin Docklands Development Authority and any potential for the two organisations to be amalgamated would be a matter for national government. Manager's Recommendation Retain as existing.

Section: 8.4.4 Reinforcing the Primacy of the City

Summary of Issues Support is expressed for Policy HR5 in one submission. It is suggested that the growth of the city core should take precedence over existing peripheral centres such as Tallaght and Swords and that development outside the M50 should be limited until land inside the M50 is used adequately. Greater emphasis on the city centre as the engine of growth rather than economic corridors is requested in one submission. The regional spatial model of the linear city should be used in preference to the National Spatial Strategy map. Manager's Response The support for policy HR5 is welcome. Section 8.4.4 of the Draft Plan recognises that Dublin City has a dynamic relationship with a number of strong outer centres such as Swords and Tallaght. This dynamic relation needs to be developed and managed in the context of the Regional Planning Guidelines for the Greater Dublin Area as envisaged under policy HR4. The Draft Plan has regard to and will be required to be consistent with the settlement strategy established by the Regional Planning Guidelines and the National Spatial Strategy. The Draft plan envisages economic corridors supporting the primacy of the city centre (Policy HR5) and the role of the city as the primary mixed use employment and retail destination (Policy HR6). Manager's Recommendation Retain as existing. Section: 8.4.5 Regional Economic Development

Summary of Issues It is requested that all references to economic corridors should be omitted from the Draft Plan as it will be used to justify more intense development. The creation of more jobs in the cleaning industries is suggesed in one submission. Manager's Response The three economic corridors are identified in the Economic Development Action Plan for the Dublin City Region (2009) and are transposed into the Draft Plan on a conceptual level. It is considered that the corridors are more appropriately described as „innovation corridors‟ which have no additional implications for land use zonings or standards. The potential creation of more jobs in the cleaning industries is beyond the scope of the plan. Manager's Recommendation Amend the second paragraph of section 8.4.5 (p.105) From: The Dublin city region, with its critical mass, needs to continue to act as the engine of Ireland‟s economy with a network of thriving polycentric clusters and the following transboundary economic corridors: (1) the Southern Economic Corridor (including the Trinity-UCD Innovation Alliance); (2) the Metro North Economic Corridor; and (3) the Naas Road/Rail Economic Corridor  To: The Dublin city region, with its critical mass, needs to continue to act as the engine of Ireland‟s economy with a network of thriving polycentric clusters and the following transboundary innovation corridors: (1) the Southern Innovation Corridor (including the Trinity-UCD Innovation Alliance); (2) the Metro North Innovation Corridor; and (3) the Naas Road/Rail Innovation Corridor.  Amend Policy HR7 (p.106) From: To support the network of economic clusters and transboundary economic corridors in the polycentric city region as identified in the Economic Development Action Plan for the Dublin City Region  To: To support the network of economic clusters and transboundary innovation corridors in the polycentric city region as identified in the Economic Development Action Plan for the Dublin City Region.  Amend all other references from „economic corridor‟ or „economic corridors‟ to „innovation corridor‟ or „innovation corridors‟.

See also Chapter 3.2.2.2, Chapter 4.4.2.1, Chapter 9.4.4 Section: 8.4.6 Regional Co-operation for Environmental Sustainability

Summary of Issues Submissions suggest that the Draft Plan establish targets for the level of carbon savings over the life of the plan and that the City Council should prepare an Energy Masterplan. Manager's Response It is not appropriate for a land use development plan to establish carbon savings targets, however, it is an objective of the Draft Plan (objective HR03) to prepare and implement a Sustainable Energy Action Plan for the Dublin Region and this Action Plan may contain carbon savings targets. The Climate Change Strategy for Dublin City 2008-2012 addresses the issue of carbon savings targets in Dublin City. Manager's Recommendation Retain as existing.

Section: 8.4.8 Providing Leadership in the City Region

Summary of Issues The Dublin Chamber of Commerce suggest that there is a need to recognise „Local Government (Dublin Mayor and Regional Authority) Bill 2010‟ in the Draft Plan. Manager's Response Policy HR11 promotes strong city governance and Dublin City Council shall have regard to any relevant Act which may be published following consideration of the „Local Government (Dublin Mayor and Regional Authority) Bill 2010‟ by the Oireachtas. Manager's Recommendation Retain as existing. Chapter 9 Revitalising the City's Economy Submission Number(s): 2023, 2030, 2035, 2050, 2075, 2114, 2120, 2157, 2164, 2168, 2171, 2204, 2206, 2209, 2227, 2235, 2245, 2256, 2257, 2259, 2291, 2293, 2333, 2603, 2604, 2664, 2753, 2765, 2769, 2805, 2810, 2836, 2844, 2860, 2884, 2904, 2909, 2921, 2932, 2936, 2943, 2944, 2946, 2947, 2957, 2958, 2965, 2967, 2972, 2988, 2993, 3003, 3026, 3077, 3080, 3094, 3097, 3101, 3142, 3145, 3149, 3154, 3158, 3159, 3165, 3166, 3167, 3169, 3171, 3188, 3190, 3211

Section: 9.2 Challenges

Summary of Issues An Taisce recommends that in the light of the current recession we should "plan for a zero growth or contraction of the economy over the period of the Development Plan". According to another submission, the strong economic growh of the past decade, as referred to in the "Achievements" section of Chapter 9 is never going to return. Manager's Response Various economic projections including those from the ESRI set out that significant economic growth can take place in the near future if the right policy decisions are taken now. It would be unacceptable for the City Council, having regard to its responsibility for the well-being of its citizens and its national economic role, to plan for zero or negative economic growth as this could only lead to increasing unemployment, emigration, and disadvantage in the City. Manager's Recommendation Retain as existing.

Section: 9.3 The Strategic Approach

Summary of Issues It is submitted that the Plan fails to deliver well-considered economic strategies. Manager's Response The strategic approach and the various policies and objectives included in the Draft Development Plan form a robust strategy. Manager's Recommendation Retain as existing.

Section: 9.4.1 General

Summary of Issues Dublin City Business Association (DCBA) recommends that the Plan should give greater emphasis to the city centre as the economic engine for the city region and also submitted their report „Defining Dublin‟s Historic Core‟ for consideration. Other submissions state that the theme of the Plan should be to consolidate and enhance the Central Business District. The Construction Industry Federation states that Policies RE3 and RE4 should be implemented in planning decisions. The Council risks losing investment if it adopts too inflexible an approach in terms of mixed use development as there needs to be imaginative and flexible responses to the current economic challenges. According to the Lord Mayors Commission, an innovative approach should be taken in the phasing of development on sites that would allow some development in the short-term while ensuring that the optimum development of the site will be achieved in stages.

It is submitted that there should be policy regarding City Council interaction with NAMA, and DCBA call for more explicit policy on this issue.

With regard to Vision and City Branding, the DCBA suggest that the Plan include a policy on 'branding of the city's image' using the built and cultural heritage as the defining qualities. A small number of flagship projects should be identified in the development plan and their implementation during the life time of the plan should be an objective.

Dublin BID recommends that research should be carried out to asses the city‟s vitality and viability.

Dublin Chamber of Commerce recommends that „the core and over-arching strategy of the next Development Plan must be business focused‟, must address the well- documented competitiveness deficits and specifically improve the business environment so that existing jobs are supported and new ones generated. The Chamber submits that the Plan must be creative and practical in its responses to present economic challenges by fostering higher density commercial development in the Central Business District.

The Lord Mayors Commission on Employment recommends that a policy of shall be included to have consideration to the implementation of the recommendations of the Commission.

It is also requested that a new policy be included after RE5 to set up a task force to report annually on how costs and services that DCC provides to schools and businesses can be kept to a minimum.

An Taisce recommends that “the Development Plan should plan for a contraction in international tourism, in retail, and in the number of journeys taken in the city.”

The Dublin Port Company, the Dublin Chamber of Commerce and others stressed the critical role of the Port in terms of economic development and employment. Manager's Response The economic role of the city centre could be made more explicit in Policy RE2.

The Plan (Policy RE3) recognises the need for Planning to be agile and responsive in the face of challenging and rapidly changing circumstances and this policy is considered sufficient.

Existing Policy regarding NAMA is set out in Policy RE5 and is considered sufficient.

With regard to Vision and Branding, Policy HR3, Objectives HRO1 and HRO2 in Chapter 8 of the Draft Plan specifically deal with branding the City. Further, REO1 supports the implementation of the Economic Development Action Plan for the Dublin City Region, which sets out objectives to develop the Dublin Brand and a Marketing Strategy to raise Dublin‟s International Profile. An amendment of Policy HRO1 is recommended at the appropriate section in Chapter 8. The International City Region Indicators project is also set out in the Action Plan and this is can encompass the Dublin BID proposal.

Revitalising the City‟s Economy is a Core Strategy of the Plan. As regards competitiveness deficits, improving the business environment so that existing jobs are supported and employment generated, and creative and practical in its responses to present economic challenges, a new policy subsection RE2(ii) could be added.

It is considered appropriate to include an objective to have regard to the Lord Mayors Commission on Employment.

Operational matters such as costs and services are not matters for the Development Plan.

Planning for a contraction in economic activity would result in increasing unemployment, emigration and impoverishment. It is not clear why it is desirable to plan for a contraction in the number of journeys by, for example walking or cycling.

Issues in relation to the Port and Docklands are dealt with in Section 4.4.1.2 (page 28) and Managers response is set out there. Manager's Recommendation Amend Policy RE2 From: To promote and enhance the role of Dublin as the national economic engine and driver of economic recovery and growth

To: To promote and enhance the role of Dublin as the national economic engine and driver of economic recovery and growth, with the city centre as its core economic generator.

Insert a new Subsection (ii) to Objective REO2 to read: (i) To request Economic and Employment Impact Statements for appropriate planning applications and to have regard to the economic criteria set out, in planning decision- making (ii) To examine the need and opportunity for new development and financing models that will allow desirable developments to go ahead in the short-term while ensuring that the optimum development of the site will be achieved in stages

Insert a new subsection (ii) to Policy RE2 to read: (i) To promote and enhance the role of Dublin as the national economic engine and driver of economic recovery and growth; with the city centre as its core economic generator. (ii) To promote and enhance the city’s competitiveness and address deficits, to improve the business environment so that existing jobs are supported and employment generated, and be creative and practical in its responses to present economic challenges

Insert a new subsection (ii) to Policy RE4 to read: (i) To take a positive and pro-active, approach when considering the economic impact of major planning applications in order to support economic development, enterprise and employment growth and also to deliver high-quality outcomes (See Chapter 16 for Guiding Principles) (ii) To have consideration to the implementation of the recommendations of the Lord Mayor’s Commission on Employment

Insert a new objective REO4, p. 112: (i) To actively support initiatives and programmes in the Lord Mayor's Job Creation Plan.

Section: 9.4.2 Enterprise

Summary of Issues It is suggested in submissions that the Plan encourage work clusters and flexible affordable work space to develop in proximity to one another. It is further suggested that the Plan should support artists to live and work in the city. The DCBA called for greater policy recognition of the issue of vacant buildings. The Lord Mayors Commission supports promoting temporary uses of vacant property and land to deal with the problems of dereliction, to make areas more attractive and to generate employment.

The Lord Mayors Commission also sets out the role of restaurants and cafes in employment generation, making the city more attractive/vibrant for residents, shoppers, visitors and workers, and on this particularly the regeneration benefits. A Food Tourism Strategy for the city should be developed in consultation with stakeholders such as the Restaurant Association of Ireland and others. It is submitted that the clustering benefits to be seen in areas such as South William Street district, Millennium Mall, Parnell Street, Capel Street, Baggot Street etc should be recognised in policy (similar to proposed policy RD15 p.124) and that the sale of hot food at casual trading stalls should be actively encouraged and promoted, to develop a New York type streetscape where hot food is sold at almost every street corner.

Dublin BID states that there is much to support in the economic chapter and welcomes policy regarding ethnic businesses and markets in the city.

As regards finding alternative uses for the significant vacant commercial space in the city, it is submitted that there is insufficient flexibility in the regulatory and planning system to facilitate some proposed alternative uses and the time it can take to process the change of use is too long or prohibitively expensive to make a short or medium change of use commercially viable.

Other submissions state that employment density is critical and that the mixed-use designation on employment land should be reversed. Manager's Response Existing policies with regard to vacant and temporary uses are considered sufficient.

With regard to the role of cafes, restaurants and outdoor food stalls it is considered that these relate to the category of locally traded services as set out in Section 9.4.2 and Policy RE10 and Objective REO5. The proposals made in submissions are agreed and relevant objectives are proposed.

As regards the barriers to encouraging alternative uses for vacant commercial space, a new subsection (ii) of Objective REO5 could be added stating that a study will be carried out to examine these issues and bring forward recommendations.

There would appear to be a misunderstanding in the submissions relating to mixed- use development. Mixed-use includes a wide range of uses that generate employment (e.g. entertainment, leisure, retail etc as well as offices etc). There is now a consensus that there is a range of services (i.e. mixed use) that have to be available to support major office employments and the mixed use designation is considered vital to maintaining and generating employment in the City. Manager's Recommendation Amend Policy RE10 From: To promote and facilitate the economic and employment generating potential of the locally traded services sector.

To: To promote and facilitate the economic and employment generating and regeneration potential of the locally traded services sector, making the city more attractive/vibrant for residents, shoppers, visitors and workers, and to recognise the clustering benefits of, for example, cafes and restaurants.

Amend Objective REO5 From: To prepare a report and recommendations on how the economic and employment generating capacity of the locally traded services sector could be enhanced

To: (i) To prepare a report and recommendations on how the economic and employment generating capacity of the locally traded services sector (including the feasibility of a Food Tourism Strategy and the potential of street food vending) could be enhanced. (ii) To prepare a report and recommendations on the potential for any barriers to securing alternative uses for vacant commercial space.

Section: 9.4.3 Innovation

Summary of Issues The explicit link between culture and the economy is welcomed by The Irish Theatre Institute and others but there could be greater emphasis on cultural tourism and cultural enterprises.

The Lord Mayors Commission recommends that it should be the policy of the Development Plan to promote the highest quality provision of Broadband (e.g. 100Mbps) in the city and that conditions be attached to appropriate planning permissions requiring infrastructure to be provided. It should be the policy of the City Council to promote the film industry including facilitating filming in public places in order to benefit from employment generation, international profile and increased tourism. The potential of Green/Clean technologies should be recognised.

Designing Dublin state that there needs to be a broad approach to Innovation.

The Lord Mayors Commission also recommends that “The Development Plan should set out in policy how cities are crucibles of Innovation, that Dublin is the only realistic city of sufficient scale to compete with other Innovation cities globally, that the city centre Z5 zoned area/inner city is the crucial metropolitan and national resource for Innovation, and have policy to promote those urban factors of proximity and diversity that are spurs to Innovation."

Submissions from the National Disability Authority and others set out the employment issues of people with disabilities and ask that these are considered in the Development Plan. Manager's Response For the sake of emphasis cultural enterprises and tourism can be added to RE14. The proposal regarding the film industry is agreed, as is the potential of Green/Clean technologies. Broadband improvement is addressed in Chapter 5.2.

The Plan takes a broad approach to Innovation, “in all its dimensions”, “across all fields of activity including enterprise, education, tourism, public policy and civic engagement”. REO6 sets out an Objective in this regard and this is considered sufficient.

With regard to the Lord Mayor's Commission suggestion on Innovation, this is a useful elaboration of existing Plan policy and agreed.

It is a key public policy objective that people with disabilities should have equal access to employment and training and the delivery of this objective is a matter for statutory bodies such as FAS, DETE and the Equality Authority. The Innovation Section introduction sets out how openness and diversity of people are positive economic assets and this includes people with disabilities. Manager's Recommendation Amend Policy RE14: From: To promote and facilitate the development and growth of Dublin‟s existing and emerging creative industries

To: (i) To promote and facilitate the development and growth of Dublin‟s existing and emerging creative industries, including cultural enterprises and tourism, the film industry, Green/Clean technologies and other potential high growth sectors.

Amend Policy RE12 From: To promote and facilitate Dublin as a creative and innovative city that is globally competitive and an internationally linked, attractive and open city

To: (i) To promote and facilitate Dublin as a creative and innovative city that is globally competitive, internationally linked, attractive and open (ii) to recognise that cities are crucibles of innovation and that the city centre Z5 zoned area/inner city is the crucial metropolitan and national resource for innovation, promoting the proximity and diversity of uses that foster innovation

Section: 9.4.4 Clusters and Corridors

Summary of Issues There are a significant number of objections to the policy in relation to Economic Development Corridors on the basis that they might be cited as a basis for commercial development beyond what is envisaged in the Plan, and may have negative effects on residential communities. One submission requests that Ballsbridge should be explicitly included in the southern corridor.

The Dublin City Business Association (DCBA) questions the emphasis on the economic corridors and would like instead to see a greater emphasis on the city centre as the economic engine for the region. They also suggest an emphasis on the Dublin- Belfast economic corridor.

A number of submissions propose an east-west economic corridor along the Liffey. A submission proposes a Digital Hub-Grangegorman economic corridor. DIT welcomes the Draft Plan and sets out the benefits of the Grangegorman Campus.

A submission from the National Paediatric Hospital Development Board, pertaining to the proposed development of the Children's Hospital of Ireland (CHoL) on the Mater Hospital Campus requests the Planning Authority's support for the intensification of medical uses in the district. The project will provide employment for 3000 people. It is proposed that the City Development Plan incorporate a specific Objective recognising the strategic status of the Children's Hospital of Ireland and to support the provision of the appropriate volume of floor space and associated facilities necessary to secure its delivery at the Mater site, having regard to: its national medical function.

Another submission states that Chapelizod has the potential to be a creative cluster. Manager's Response The Economic Development Corridors arise from the Economic Development Action Plan for the Greater Dublin Area and are designed to optimise the employment and other opportunities arising from the considerable public investment that has taken or will take place as well as considerable private investment. The southern corridor arises from the Innovation Alliance between TCD and UCD set out in Government policy most recently in the report of the Innovation Taskforce, this effectively a measure to deliver the optimum benefits and synergies for Dublin and the from the great resource that these Universities are, as well as from the significant public investment in the Strategy for Science, Technology and Innovation Programme.

As regards the DCBAs proposal that the city centre is promoted as the economic engine for the region, this is agreed and amended policy is proposed at Section 9.4.1 RE2

As regards the Belfast economic corridor, this is set out in Fig.16 Dublin City Region Economic Strategy Map (p.109) and is in effect a continuation of the northern (Metro North) economic corridor and no change is recommended.

With regard to the proposals for east-west/Liffey economic corridor and a Digital Hub- Grangegorman corridor, these are effectively within the city centre cluster (Fig.16) and hence do not require that level of designation.

The submission from the National Paediatric Hospital Development Board complies with overall national and city policy and an amended version its proposal recognising the strategic role of other Hospitals in the city is recommended as set out below.

It is not considered necessary to designate Chapelizod as a potential creative cluster. Manager's Recommendation For the purpose of clarity and accuracy, the term economic corridors should be replaced with Innovation Corridors as follows:

Amend Text in Chapters 3 & 9 & All Text References in Plan (see also Recommendation in Section 3.2.2.2) From: Economic Corridors To Innovation Corridors Amend existing Policy RE15 From: To promote and facilitate economic development and clustering taking place along the Southern, Metro North and Naas Road / Rail Economic Corridors within in the Dublin City Region

To: To promote and facilitate economic development and clustering taking place along the Southern, Metro North and Naas Road / Rail Innovation Corridors within in the Dublin City Region and to promote the city centre being the economic engine for the region

Amend the second paragraph of 9.4.4 From The three economic corridors set out in the Economic Development Action Plan for the Dublin Region will provide a focus for regional economic development and clustering.

To The three corridors set out in the Economic Development Action Plan for the Dublin Region will provide a focus for regional innovation and clustering. In this context and in the interests of clarity, the innovation corridors have no additional implications for zoning or standards.

Amend Policy RE16 From: To promote and facilitate the further development of clusters within the city thereby generating competitiveness, productivity and innovation benefits

To: To promote and facilitate the further development of clusters within the city thereby generating competitiveness, productivity and innovation benefits and to promote north-south linkages between Digital Hub- Grangegorman

Amend Policy RE17 From: To encourage the regeneration of the city centre zoned area through the promotion and facilitation of innovation clusters and the intensification of existing clusters such as the Mater Hospital, James‟s Hospital and the Digital Hub

To: (i)To encourage the regeneration of the city centre zoned area through the promotion and facilitation of innovation clusters and the intensification of existing clusters such as the Mater Hospital, James‟s Hospital and the Digital Hub (ii) to recognise the strategic role of the Hospital complexes in the city including the Children's Hospital of Ireland having regard to their national medical function, their role as a major employer in the city, as a generator of significant economic benefits for the economy of Dublin's inner city, and a promoter of the knowledge economy through research and education links with third level colleges in the city Section: 9.4.5 Office / Commercial / Employment Space

Summary of Issues It is submitted that all references to live-work units should be omitted from the Plan given that the concept has failed in both the Docklands and Pelletstown.

Detailed submissions were submitted regarding the need to incentivise the redevelopment of outdated office stock in Dublin 2, Harcourt area etc. The ESB states that the redevelopment of its HQ would double the number of employees, consolidate a major national enterprise in the city centre, and have significant streetscape and energy efficiency/sustainability benefits. It further states that existing Plan policies would hamper the delivery of these benefits. It is also submitted that reference should be made to the need to encourage indigenous HQs as well as FDI ones. The Dublin 2 (CBD) office employment area is critical to economic health of the city and region however, it is suggested that the significant level of outdated stock is a significant threat or risk for the city.

Submissions also state that the Plan must ensure that the status of the city centre as the primary office location is retained. Consolidation and intensification of office employment developments should be encouraged as it is key to the achievement of other Plan policies. It is further requested that a policy be introduced that requires office based uses to be located in the CBD and that proposals outside the CBD be subject to a sequential approach.

The Lord Mayors Commission recommends that "The Development Plan should facilitate the provision of the type of office development to meet the requirements of IDA promoted FDI companies who want to locate their European or EMEA or global HQs in Dublin, and also to meet the requirements of indigenous firms for their HQs."

A number of submissions referred to the „oversupply‟ of office space in the city and that this should be a factor in considering new developments. Manager's Response It is considered that live-work units are a valuable option in delivering employment and residential opportunities and mixed-use areas and that they should remain as policy in the Development Plan.

Section 9.4.5 Offices/Commercial/Employment Space sets out the following: “A choice of good quality and cost competitive office and commercial space is critical in attracting investment, supporting enterprises and generating employment. There is a need to encourage the high quality redevelopment of outdated office stock.”

It is agreed that the office/employment intensity in the Dublin 2 area is critical to the city‟s economic and employment success and that its high quality character and proximity to Government, the Oireachtas, Cultural Institutions, restaurants, shopping, public transport etc is a significant competitive advantage for Dublin vis-avis other cities. It is also agreed that the increasingly obsolete office stock is a significant threat to this competitive advantage and that there is a need to incentivise high quality redevelopments of outdated office stock throughout the city. The proposal re. Indigenous HQs is agreed. The proposal to discourage office employment development outside the CBD and to introduce a sequential test is not desirable. The draft Plan has no CBD designation, the closest is the Z5 city centre zoning (which does not include parts of Dublin 2 office areas). Also it is desirable to provide a range of office types, locations, rents throughout the city to encourage mixed use and regeneration.

The Lord Mayor's recommendation regarding encouraging indigenous; European; European, Middle East and Africa (EMEA); and global HQs to locate in Dublin is agreed adn it is considered appropriate to amend Policy RE20 (H2 Office Space).

As regards the submissions referring to the „oversupply‟ of office space in the city, it has been estimated about 25% of this vacant office space is obsolete and does not meet contemporary requirements. Also, the previously very high office rents were a competitive disadvantage for the City and the recent drop in rental values has significantly boosted the City's ability to attract and retain foreign and indigenous investment. As Dublin competes globally for investment, there is not a set limited demand for office space. Indeed the demand for and take up of office space can increase significantly as the city regains competitiveness and this includes affordable office space. Limiting the supply would increase office rents and tend to reduce employment generation potential. Manager's Recommendation Amend Policy RE20 From: To promote and facilitate the supply of commercial space, where appropriate, e.g. retail and office including larger floorplates and quantums suitable for HQ type uses, as a means of increasing choice and competitiveness.

To: (i) To promote and facilitate the supply of commercial space, where appropriate, e.g. retail and office including larger floorplates and quantums suitable for indigenous and FDI HQ types uses, as a means of increasing choice and competitiveness, and encouraging indigenous; and global HQs to locate in Dublin (ii) to consolidate employment provision in the city by incentivising and facilitating the high quality redevelopment of obsolete office stock in the City

Section: 9.4.6 Economic Area Regeneration

Summary of Issues It is submitted by the DCBA that the Development Plan should focus on efforts to bring derelict sites into development and to maximise opportunities for upper storey use.

The Dublin BID supports the policies on ethnic businesses but requests that REO11 should also include Capel Street.

According to the Lord Mayors Commission, the extent of underutilised/vacant land in the inner city is both a serious problem for the city and also the greatest opportunity to improve the attractiveness, innovation potential, sustainability. It is submitted that the possibility of the regeneration momentum stalling or falling back in the economic downturn is a challenge and it is a key priority for the City Council to encourage continued high quality private and public investment in these areas. Manager's Response It is considered that the policies and objectives in Section 9.4.6 are sufficient to deal with issues of dereliction and upper floor uses.

It is agreed that Policy REO11 be amended to make specific reference to Capel Street as a cluster.

It is also agreed that these issues of regeneration are critical over the period of the Plan and more specific reference should be made to them in policy. Manager's Recommendation Amend Objective REO11 From: To assess the potential of the Parnell Street and other areas for the creation and the promotion of ethnic retail and restaurant clusters

To: To assess the potential of the Parnell Street, Capel Street and other areas for the creation and the promotion of ethnic retail and restaurant clusters

Amend Objective REO10 From: To map and collate approaches to regeneration and in particular the specific employment and enterprise objectives in regeneration plans, to monitor delivery of these outcomes and encourage dissemination and learning

To: (i) To map and collate approaches to regeneration and in particular the specific employment and enterprise objectives in regeneration plans, to monitor delivery of these outcomes and encourage dissemination and learning (ii) To carry out an assessment of the challenges and barriers to Regeneration as well as the opportunities and to bring forward recommendations for action.

Section: 9.4.7 Tourism: Visitors, International Education and Conventions

Summary of Issues The Lord Mayor's Commission submits that Development Plan policy should recognise that student communities are a strategic resource for urban development and in particular for regeneration and that it should be policy to promote Dublin as an International Student City.

It is stated in one submission that international scholarships will be ineffective if there is no intercultural campus to cater for students.

Fáilte Ireland recommends that the City Council retains policy ACT14 (sic) from the current Development Plan. Fáilte Ireland has recently applied GIS analysis to its Tourism Content System. Such analysis could inform the targeted provision of a wide range of future tourist services and facilities. It is suggested that this analysis could be undertaken in partnership with Dublin City Council, and should form an additional objective in section 9.4.7.

The Dublin Port Company opposes REO14 regarding the feasibility of a cruise terminal in the Poolbeg area on the basis that the objective does not serve a useful purpose ,that such a terminal could not be justified on financial grounds and that the cruise liner companies are not in favour.

With regard to the Convention Centre, the Lord Mayors Commission submits that it should an Objective to prepare an Action Plan in consultation with the stakeholders that would optimise the significant and wide-ranging benefits of the Convention Centre Dublin (CCD). Another submission recommended a policy to promote the CCD area as a major business, tourism, hotel, entertainment and leisure destination of international standard, as well as other recommendations for the Spencer Dock area. Manager's Response The statements of the Lord Mayor's Commission regarding international students are useful elaborations of existing policy and agreed. The recent report of the Innovation Taskforce has further highlighted the significant benefits from attracting International Students.

With regard to a specific campus for international students, it is considered that Objective REO13 which seeks to address the challenges experienced by such students can sufficiently address this issue.

It is likely that Fáilte Ireland are referring to Policy ACT 13 in current Plan which states: “It is the policy of Dublin City Council to develop appropriate tourism infrastructure, including signage, information, tourism trails, cafes, toilets, public transport, car and coach parking in the main tourist areas. In particular, it is policy to facilitate and encourage computerised information points for visitors."

It is agreed that this should be re-adopted as policy and also to include a new objective on supporting Fáilte Ireland in its GIS work.

It is considered that the examination of the feasibility of a cruise terminal in the Poolbeg area is reasonable in order to establish the potential or otherwise of this project.

The Convention Centre Dublin is a major national (PPP) project and these proposals are agreed. It is not considered necessary to include the other recommendations for the Spencer Dock Area. Manager's Recommendation Amend Policy RE29 From: To promote Dublin as an International Education Centre, as set out in national policy, and to support and encourage provision of necessary infrastructure such as colleges and high quality custom built and professionally managed student housing

To: To promote Dublin as an International Education Centre/Student City, as set out in national policy, and to support and encourage provision of necessary infrastructure such as colleges (including English Language colleges) and high quality custom built and professionally managed student housing

Amend Policy RE27 From: To promote and enhance Dublin as a world class tourist destination for leisure, business and student visitors

To: To promote and enhance Dublin as a world class tourist destination for leisure, culture, business and students

Add new Policy RE31 to read as follows: To develop appropriate tourism infrastructure, including signage, information, tourism trails, cafes, toilets, public transport, car and coach parking in the main tourist areas, and to facilitate and encourage computerised information points for visitors.

And new Objective REO15 to read as follows: To support Fáilte Ireland in its data analysis of its Tourist Content System in order to inform the targeted provision of a wide range of future tourist services and facilities.

Add additional Objective REO16 to read as follows: To prepare an Action Plan in consultation with the stakeholders that would optimise the benefits Convention Centre Dublin and bring forward enhanced pedestrian linkages to O‟Connell Street etc and also public realm management. (see also para 4.4.5; public realm)

Amend Policy RE28 From: To promote and facilitate the optimum benefits (including the international marketing benefits) to the city of the Convention Centre Dublin, as well as all other major visitor attractions such as IMMA, Collins Barracks, the Phoenix Park and the Guinness Storehouse

To: To promote and facilitate the optimum benefits (including the international marketing benefits) to the city of the Convention Centre Dublin as well as all other major visitor attractions such as IMMA, Collins Barracks, the Phoenix Park, the Guinness Storehouse and the Georgian Squares, and to promote the Convention Centre Dublin area as a major business, tourism, hotel, entertainment and leisure destination of international standard.

Chapter 10 Strengthening the City as the National Retail Destination Submission Number(s): 2044, 2075, 2132, 2199, 2201, 2235, 2265, 2333, 2653, 2664, 2769, 2810, 2827, 2837, 2884, 2909, 2922, 2942, 2966, 2967, 2982, 2986, 3007, 3011, 3101, 3152, 3155, 3159, 3167, 3168, 3202, 3210

Section: 10.1 Achievements

Summary of Issues It is suggested that there is no basis in economic reality for an additional half million to one million square feet of retail in the CBD. It is also requested that the reference to Roches Stores be removed from Section 4.3. Manager's Response The retail capacity for Dublin City is established in the Retail Strategy For The Greater Dublin Area 2008-2016. The Retail Chapter does not refer to Roches Stores. Manager's Recommendation Retain as existing.

Section: 10.2 Challenges

Summary of Issues According to the Dublin City Centre Business Association Ltd. the assertion that that Luas has resulted in significant increases in footfall in Henry Street and Grafton Street is simplistic and flawed as passengers have transferred from Dublin Bus to the Luas.

With reference to Section 10.2; the reference to Cows Lane as an emerging retail area, it is suggested that the City Council should pursue a policy of offering incentives such as reduced rates and charges, particularly for start up businesses. Manager's Response It is considered that the text of this section should be amened to indicate that the introduction of Luas has significantly improved access to the city centre as outlined in the Developing the Retail Core Framework Plan. Temple Bar Cultural Trust / Properties provide support in the Cows Lane area, however, the introduction of financial incentives for retail uses in certain areas is beyond the scope of the Development Plan. Manager's Recommendation Amend the first paragraph of section 10.1 (p.120) From: The introduction of the Luas which directly serves the two principal shopping streets has resulted in significant increases in the number of pedestrians in both the Henry Street and Grafton Street Areas

To: The introduction of the Luas which directly serves the two principal shopping streets has resulted in significantly improved access to the Henry Street and Grafton Street Areas.

Section: 10.4 The Strategic Approach (See Fig. 17 And 18)

Summary of Issues A number of submissions request that the Plan emphasise the importance of the car borne consumer as essential to the City‟s economy and ensure that the policies of the plan facilitate and make the central retail core accessible for all modes of transport including the car. It is contended that anti-car policies have prevented a greater expansion in retail development within the city. Other submissions request a more targeted and explicit car parking policy than is currently stated in Chapter 5.

It is suggested in one submission that a new policy be added (RD11); "To prevent erosion of the commercial strength of the Retail Core Area and to enhance the primacy of the City Centre, to keep all parking and traffic management programmes under close review and to strongly support historic investment in bus, DART and metro public transport modes by 2017.”

The RIAI suggest that the Strategic Approach outlined at Section 10.4 should ensure that the provision of retail is within an overall framework of environmental sustainability and impact on Climate Change regarding waste management, energy use (particularly lighting, ventilation and refrigeration). Manager's Response Chapter 17.40.11 clearly states that public on-street parking is a necessary facility for shopping and business premises and is recognised as essential to the day-to-day functioning of the city. Proactive parking policies set out in the Plan ensure that pricing of on-street spaces is geared to short stay parking. Dublin City Council will continue to discourage commuter car parking and seek to ensure adequate parking provision for short-term shopping, business and leisure purposes. The Draft Plan provides policy guidance on car parking to provide car parking as part of the overall sustainable transport needs of the City. Policy SI12 makes it clear that Dublin City Council will discourage commuter parking but will facilitate parking provision to serve short term uses such as retail. In view of the issues raised, it is proposed to refine guidance in Chapter 17, Section 17.40 to allow a relaxation of maximum parking standards to support the sustainable development of a regeneration area. Manager's Recommendation Retain as existing.

Section: 10.5.1 General Retail

Summary of Issues A number of submissions raise the issue of Adult Entertainment Shops including „Head Shops‟. The Joint Policing Committee has submitted that all possible steps be taken to curb the operation of Head Shops including, if necessary, the designation of the city centre as an Architectural Conservation Area indicating that Head Shops would be a material change of use. Other suggestions request restrictions on the locations of adult entertainment premises including locations in close proximity to a school, within a residential area, in regeneration areas, in areas of high pedestrian foot-fall and streets appealing to family markets. It is submitted that strict planning regulations should be introduced to control the location and growth of this type of business. It is also requested that a new policy be included after RD9 – “To prohibit the further expansion of off licenses or part off licenses except in areas where a compelling case can be made. Any application for an off license should include a map of all the off licenses located within a 1 km radius of proposed development.”

A number of submissions propose that the Plan should recognise the market trade as being intrinsic to the character of Dublin and that it must be structured with an agreed plan between the traders and the authorities. Suggestions in relation to developing markets include; Turning St. Stephen's Green Shopping Centre into a food market similar to the Boqueria market of Barcelona and Holding a weekly market in Smithfield square to animate the space Also developing a strategy to bring food markets back to the city by redeveloping the City‟s historic central markets, which are of very high architectural quality, kick-started through framework plans and rented to local food producers rather than generic retail outlets

In terms of general retail provision it is suggested that the the ground floor spaces of all buildings be turned into consumer space, that shop front design be reviewed and made more interesting in order to create a smarter image for the city and specifically that mono-use shopping centres with privatized arterial space will be discouraged. Manager's Response Policy RD9 seeks to prohibit adult entertainment shops in proximity to residential areas and to seek to prevent an excessive concentration of such uses having regard to the existing proliferation of similar retail outlets in an area and the vitality of a shopping area. Adult entertainment shops are considered to include „head‟ shops. Furthermore, relevant national legislation is pending relating to this issue and the Plan can be varied to accord with the provision of such legislation when enacted.

Standard 17.29 „Off-Licence and Part Off-Licence‟ establishes a comprehensive range of criteria for considering off-licence proposals.

Policy RD6 promotes and facilitates a range of indoor and outdoor markets and objective RDO3 seeks to promote and facilitate the early implementation of the City Markets Project. Furthermore, Policy RD8 seeks to minimise the negative impact of dead frontage arising from high vacancy levels in retail or retail service outlets by the promotion and facilitation of temporary uses which contribute to the vitality of the street.

Policy RD7 requires a high quality of design and finish for new and replacement shopfronts, signage and advertising in accordance with the Dublin City Council‟s Shopfront Design Guidelines.

Policy RD5 seeks to ensure that proposed large commercial developments, where appropriate, would incorporate retail, residential, employment and entertainment/cultural uses within the design. Furthermore, the guiding principles contain guidance in relation to connections and making successful streets in terms of good urban design. Manager's Recommendation Retain as existing. Section: 10.5.2 Primacy of the City Centre & Retail Core Area

Summary of Issues Support is expressed for Policies RD10 and RD11 which promote the City as the National Retail Destination. It is suggested that the Plan recognise that the efficient servicing of the core retail area is critical to its operation and success for instance the Port Company stresses the connection between the Port area and retail goods delivery.

The Civic Trust suggest that the policy wording of RD13 should be strengthened to commit the Council to working with the city's business community to create a high quality and distinctive retail environment in the city which focuses on excellence of design. Another submission contends that the Planning Authority can work in partnership with retailers to deliver additional employment and should be more proactive in identifying suitable sites for retail development. It is further suggested that planning priority should be given to owner-occupied shops, workshops, galleries, restaurants, bars etc. and that the Plan should not promote two city centres.

It is suggestd that a Communications Campaign espousing the positives of the city centre as a retail destination should be implemented, particularly given the new 30km/hr zone operation.

With regard to the retail core, a careful monitoring policy for the secondary retail streets is required, particularly as these streets contribute towards achieving the objective of extending pedestrian loops beyond the main shopping streets.

It is also contended that the designation of Grafton Street and O'Connell Street as Architectural Conservation Areas impedes the objective of developing the central area as the prime retail area.

For the Grafton Street area, objectives should be included to provide for the upgrading of the general environment of Grafton Street, and extension of the pedestrian zone to double its current size and the upgrading and improvement of Johnson's Court as a key link.

The Dublin BID suggest that buskers be treated as casual traders and that permits be issued so as to regulate and monitor the quality of performances. Manager's Response It is implicitly recognised that the efficient servicing of the core retail area and other parts of the city is critical for its operation and success and objective REO14 seeks to examine the feasibility of a cruise terminal in the Poolbeg area and Dublin Port, including a review of the current disembarking point and its connectivity with the city and the development of tour options for visitors within the city and set out recommendations.

The Council does work with the city‟s business community, particularly throught the operation of the Business Improvement Districts (BIDs) initiative. Objective RDO4 seeks to evaluate and give consideration to the further designation of the BIDS scheme in the city. A promotional campaign for the city centre could be considered under the BIDs initiative. Furthermore, section 10.5.6 relates to competitiveness and seeks to ensure that Dublin adapts to developments in retail formats and facilitate competition and innovation in the retail and other services sector.The city does not have two city centres, rather the draft plan recognises that there are two distinct retail cores in the city centre which should be enhanced by better linkages.

Objective RDO1 seeks to implement the environmental and other improvements set out in the Retail Core Framework Plan such as improving facilities for pedestrians, a high quality street environment and better links between the shopping area and new routes, with the refurbishment and extension of the key pedestrian street network including the Grafton Street Pedestrian Spine and adjoining pedestrianised streets such as Johnsons Court. Furthermore, it is recommended that Fig 18 be amended to include Johnsons Court as a Category 2 principal shopping street.

The designated Architectural Conservation Areas in the city centre seek to achieve a balance between facilitating appropriate development whilst protecting the unique character of the area.

The Council is seeking to be proactive in addressing issues relating to the retail core including identifying suitable sites for retail development and upgrading the public realm through the Retail Core Framework Plan.

Giving priority to owner occupiers and the regulation of busking is beyond the scope of the plan. Manager's Recommendation Amend Figure18 to show Johnsons Court (located between the Powerscourt Shopping Centre and Grafton St) as a Category 2 shopping street.

Section: 10.5.3 Character Areas

Summary of Issues In relation to Policy RD15 concerning the promotion of use clusters in the city, it is requested that the Council consider that the development of ethnic shopping and eating areas on Capel Street and Parnell Street only be undertaken in accordance with clear planning and design guidance to ensure the integrity of these streets are not further undermined by poor shopfronts.

Further, it is perceived in another submission that there is a distinct segregation on Dublin's Streets. Shops and restaurants, often run and populated by resident ethnic minorities, sit side by side with cheaper retail, adult shops, head shops and pubs that missed out on the Celtic Tiger and are segregated from the City‟s high street areas such as Grafton and Henry Street.

One submission raises the issue of Stoneybatter being listed as one of the character areas that the Council wishes to reinforce and protect and to states that a streetscape in a village area normally consists of a mix of viable shops and offices. However, it is contended that the viability of these businesses in the area is being negatively affected by convenience stores and clustering. Manager's Response Policy RD7 requires a high quality of design and finish for new and replacement shopfronts, signage and advertising in accordance with the Dublin City Council‟s Shopfront Design Guidelines.

Policy RD15 seeks to promote and facilitate clustering of uses, including complementary uses, that add character and vitality to the city for example cultural/creative/antiques on Francis Street, ethnic restaurants/shops on Parnell Street and Capel Street whilst other provisions of the draft plan seek to provide for the needs of the larger retailers which together give a wide retail offer to the citizens of the city.

Policy RD24 seeks to promote and facilitate the provision of supermarket shopping primarily in District Centres and Neighbourhood Centres which in course should support the viability and vitality of centres such as Stoneybatter. Manager's Recommendation Retain as existing.

Section: 10.5.4 The Wider City

Summary of Issues The Civic Trust requests that Policy RD18 be amended to include provision for improvements to the public realm and guidance on design of shopfronts in district and neighbourhood centres.

The retail strategy should support the future vitality and viability of the main retail centres and aim to facilitate a competitive environment for the retail industry in the future. Policies RD17-18 are welcomed. The Construction Industry Federation suggest that a provision for the creation of District Centres in sustainable sites should be seriously considered and supported by the Council for insertion into the Development Plan alongside Policy RD18 in order to maintain employment opportunities and provision of services for the 'local' economy.

The Chamber of Commerce make the point that promoting and allowing large scale retail developments to proliferate elsewhere in Dublin outside of the Retail Core could have potentially serious adverse affects on the viability of the city centre.

It is requested that Policy RD22 be amended to provide for co-operation with other councils in the GDA in relation to traffic, parking and public transport developments.

It is requested that investment in additional convenience floorspace be encouraged at Key Developing Area and Key District Centres. Specific Map based objectives should be included to encourage the rejuvenation of older centres such as Artane Castle and Park Shopping Centre, Prussia Street. Recognition is also requested for the potential contribution Spencer Dock North can make to the city's modern retail environment as a competitor to modern regional centres.

Another submission contends that the Plan seems to be seeking excessive retail provision in the District Centres which directly conflicts with the objective to protect and reinforce the Retail Core. It is therefore suggested that an objective be included to require the preparation of a Retail Impact Statement for all retail developments proposed for District Centres which must consider their potential impact on the city Retail Core and also on the closest Level 2 Major Town Centre.

A submission refers to the RGP which state that District Centres would normally be 10,000m2 in area in or adjacent to main towns and up to 20,000 m2 within "some" parts of Dublin. It is not therefore correct to say at page 275 of the Draft Plan that:- "Although the level of floorspace existing in each centre does vary considerably, the DoEHLG Retail Planning Guidelines set a guidance size of approximately 20,000 sq.m. in the metropolitan area of the GDA.

It is also submitted that both the Northside Shopping Centre and Ballymun are designated District Centres yet both dramatically exceed the 20,000m2 limit set by the Retail Planning Guidelines. Figure 17 on p.118 which identifies 32 District Centres. This could result in the City's District Centres containing over twice the retail floorspace of the Retail Core (see Appendix A, p.23-24). (Note that Fig.17 does not include Pelletstown and Park West which is taken to be an oversight). -Re-introduce a grading mechanism for District Centres across the City ranging from 20,000m2 for District Level 1 i.e. KDCs, to 10,000m2, to 5,000m2 (neighbourhood centre). Include a restriction on the proportion of comparison retail floorspace that is allowed in District Centres, such that not more than 20% of the net retail floorspace may be used for that purpose. Manager's Response Policy RD7 requires a high quality of design and finish for new and replacement shopfronts, signage and advertising in accordance with the Dublin City Council‟s Shopfront Design Guidelines.

Policy RD26 seeks to promote and facilitate competition and innovation in the retail and other services sector to the benefit of competitiveness and the consumer. There are a sufficient number of district centres designated in the draft plan as these align closely with the settlement strategy.

The retail strategy seeks to strike a balance between providing an appropriate type and scale of retailing in the district and neighbourhoods centres which serve a local function in terms of affordability and accessibility whilst also protecting and reinforcing the prominence of the retail core.

Policy RD18 seeks to maintain and strengthen the existing District and Neighbourhood centres and to re-vitalise, re-invent and prevent the obsolescence of older suburban District and Neighbourhood Centres which relevant district centres being identified on Fig.17.

Policy HR4 seeks to collaborate with adjacent authorities and the regional authority to ensure that a coordinated approach is taken to the planning of the Dublin region including issues such as traffic, parking, and public transport developments.

Policy RD17 seeks to ensure adequate retail provision in the Key Developing Areas such as the Docklands and the Point Village is identified as a district centre. Any significant retail proposal will be subject to a retail impact assessment. The retail strategy including the provision of district and key district centres aligns with the regional settlement strategy and accords with the Retail Strategy For The Greater Dublin Area 2008-2016. The retail proposals at both Ballymun and Northside were partly warranted on the basis of area regeneration.

The retail strategy acknowledges that to date the development plan and retail strategy for the city has set out three separate sub-categories of district centres according to character, size, location, access by public transport, vitality and viability and potential. However, this classification has proven unnecessarily complex and difficult to implement. The current regional retail strategy documents that the subdivision of the district centre level into two further sub-categories to reflect the different function and size of centres was given consideration, but that it was not included in the final strategy as it could over complicate and restrict the development of centres unnecessarily.

The proportion of comparison retailing permitted in district centres will be assessed through the development management process in the context of retail impact assessment, the need to support the prominence of the city centre retail core, and the Retail Strategy for the Greater Dublin Area 2008-2016. Manager's Recommendation Retain as existing.

Section: 10.5.5. Convenience Shopping

Summary of Issues Another submission suggests that a specific policy be included in the Plan to achieve the rebalance of convenience floor space within the inner retail core by encouraging convenience retailing in the south inner retail core of the City centre.

A submission from a nine year old, requests more sweet shops that only sell sweets and that there should be ice cream parlours on every street corner. Manager's Response The strategic approach to retailing in the Draft Plan promotes the provision of specialist shops. Furthermore, Policy RD23 seeks to promote and facilitate the provision of accessible, good quality convenience shopping with strong choice and competition in the inner city and elsewhere partly on the basis of attracting and retaining families with children in the city. Manager's Recommendation Retain as existing.

Section: 10.5.6 Competitiveness and Sustainable Planning

Summary of Issues It is contended by the DCBA that competition in the city centre in retail cannot be created with anglo-saxon large shopping space but by attracting Euro supply chain companies. The CIF state that the Council should facilitate changing retail patterns and needs and move away from single use sites by integrating provision at district level with other services, offices and residential to create vibrant centres serving the built up surrounding housing districts. Manager's Response Section 10.5.6 relates to competitiveness and seeks to ensure that Dublin adapts to developments in retail formats and facilitate competition and innovation in the retail and other services sector. The zoning and other provisions of the draft plan generally support the provision of retailing as part of a range of mixed uses in the city centre, district centres and neighbourhood centres. Manager's Recommendation Retain as existing.

Section: Other Issues

Summary of Issues The assertion that the retail sector has failed to fully capitalise on the city centre's strengths is refuted in one submission. The impact of NAMA on large development sites in the city centre could become problematic in the future with a fear expressed by the DCBA that stagnation and dereliction in the Central Business District could result. Another submission contends that future Schematic Masterplans should not delay/restrict the delivery of trading convenience floorspace or extant planning permissions.

It is submitted that better quality, standardised and regular research is needed to determine Dublin's vitality and viability. Consumer research that will provide definite conclusions and facilitate appropriate adjustments in the City‟s offering and message is requested.

With regard to shopping typologies the Dublin BIDs state that if the policy is to encourage shoppers as well as commuters to use public transport then it is important to understand the tipping point between car usage and public transport and how to best balance the twin objectives of sustainability and economic vibrancy. Manager's Response The draft plan indicates that the south retail core needs some more capacity for larger retail units to allow for innovation and support retailing. Masterplans etc should not delay delivery of retail facilities. The City Council's Office of International Relations and Research will be capable of undertaking more retail research for Dublin City. Manager's Recommendation Retain as existing.

Chapter 11 Providing Quality Homes in a Compact City Submission Number(s): 2026, 2035, 2086, 2109, 2114, 2168, 2199, 2227, 2235, 2253, 2258, 2261, 2290, 2651, 2653, 2655, 2747, 2753, 2794, 2802, 2806, 2810, 2811, 2829, 2837, 2872, 2879, 2909, 2916, 2918, 2932, 2935, 2938, 2943, 2949, 2950, 2964, 2965, 2966, 2972, 3003, 3019, 3071, 3097, 3101, 3124, 3144, 3147, 3149, 3159, 3164

Section: 11.1 Achievements

Summary of Issues It is suggested that Pelletstown should not be listed as an achievement in terms of the creation of new neighbourhoods as community infrastructure has not been provided in the area. Manager's Response A new neighbourhood has been created in Pelletstown which is served by a train station, new village centre with shops and restaurants etc, well designed public open spaces including play facilities and an upgraded linear park along the Royal canal. A Local Area Plan will be prepared for Pelletstown as outlined in the Core Strategy and it is envisaged that further enhancement of community infrastructure will be addressed under this Plan. Manager's Recommendation Retain as existing.

Section: 11.3 The Strategic Approach

Summary of Issues The Irish Wheelchair Association submit that there is a need to commit to a housing strategy developed in partnership with other stakeholders.

The RIAI state that the strategic approach should be to provide both quality homes and quality neighbourhoods which are not separate concepts. Manager's Response The Housing Strategy is part of the Development Plan and is developed in consultation with other stakeholders as part of the wider statutory Development Plan consultation process. The strategic approach envisaged in the Draft Plan is to provide for quality residential accommodation and sustainable mixed use neighbourhoods (in addition to re-balancing regional growth, providing a variety of housing typologies and tenures, and providing housing that is accessible and affordable). It is considered that this strategic approach will allow for the existing suburbs to make an appropriate contribution to meeting the future needs of the City. Manager's Recommendation Retain as existing. Section: 11.4.1 National and Regional Guidelines

Summary of Issues It is submitted that the Plan is based on outdated projections of demography / demand for housing and should recognise the economic downturn, emigration, vacant stock and brownfield capacity etc.

Another submission considers that the Draft Plan must make adequate provision for the housing targets established in the draft Regional Planning Guidelines i.e. 97,000 new units by 2022, that the Council must ensure that a shortage of quality new housing does not occur during the life of the plan and that the Plan assist in guiding population growth by achieving balanced growth across the wider region. The Council must take cognisance of the market and market conditions, include a new catch all policy which indicates that if any particular policy is shown to inhibit growth or be overly restrictive the Council can conduct a review of such policy. Manager's Response There is a statutory obligation on the Council to have regard to the scale of population growth and housing allocation outlined in the Regional Planning Guidelines for the Greater Dublin Area which have been developed taking account of a wide range of issues including the downturn in the economy, development capacity, vacancy rates, balanced regional development and national population projections. There is sufficient zoned land to meet the draft regional housing allocation for Dublin City Council for the period of this Development Plan.

The Draft Plan seeks to achieve an appropriate balance between different interests and in general, seeks to promote sustainable growth subject to appropriate safeguards. The Council may vary the provisions of the plan should it be considered necessary during the lifetime of the plan. Manager's Recommendation Retain as existing.

Section: 11.4.2 Sustainable Residential Areas

Summary of Issues The IWA stress the need for choice of sheltered / supported / transitional accommodation in areas that are safe, close to community and transport facilities and suitable for peoples with disabilities.

Many submissions consider there is a need for a mix of housing types at lower plot ratios, densities and height to retain a family friendly city which is accessible, environmentally friendly, has a variety of tenures and protects residential amenity.

Need to complete North Fringe development as a Strategic Development Zone and that all large developments should provide amenities such as playgrounds, crèches, cultural, sports and educational facilities at an early phase of development.

Other submissions state that subdivided houses can lead to urban decay and damage community fabric and that there is a need to provide minimum standards for sub- divided accommodation. It also suggests that an objective be included which aims to meet the needs of empty nesters, developing infill and vacant sites with higher densities which would also free up larger family homes.

It is suggested that QH3 (variety of housing) be amended to foster transformation in a meaningful, connected and permeable way, and that a new policy is needed to promote the carrying out of urban centre strategies for all neighbourhood and district centres. Need to eliminate sub standard and unauthorized private rented accommodation including pre-1963 accommodation. Manager's Response The Draft Plan promotes the provision of a variety of housing typologies (QH3) with minimum space standards incorporating the concept of flexible and adaptable homes. Draft Plan policy fosters sustainable neighbourhoods containing mixed uses which support the provision of community and transport facilities. Appendix 19 contains Safety Design Guidelines which encourage design for safety and security and avoiding anti-social behaviour.

The Draft Plan promotes the provision of housing at sustainable densities, a mix of housing types and tenures, promotes family accommodation with enhanced development standards, and promotes sustainable building design (QH10), the provision of quality housing for all (QH11), and the use of infill / brownfield sites when possible.

There is a need to balance the requirement to provide for residential amenity and movement in the city. Residential amenities are a primary consideration in the development management process including any new rail proposals.

QH7 is a balanced policy insofar as it allows for the subdivision of larger properties in areas close to transport nodes and Key District Centres subject to the application of the development standards and seeks to avoid subdivision in other areas to protect residential character. The potential redevelopment of existing houses will be subject to the policies and standards of the Plan through the development management process.

The development standards will allow for a mix of housing to be provided on an area basis with some developments benefiting from higher / lower plot ratios, densities etc depending on a number of factors including zoning and site location / characteristics.

Changing the current system relating to implementing the building regulations is beyond the scope of the Plan.

The core strategy indicates that a Local Area Plan will be prepared for the North Fringe Key Developing Area which will guide future development and the role out of facilities in the area. It should be noted that new policy QH8 will apply to any new larger proposals to ensure that suitable physical, social, and community infrastructure is provided in tandem with residential development and substantial infrastructure is available to initial residents. Guidance on permeability and connections in the urban fabric are contained in chapter 16 Guiding Principles. Neighbourhood and district centres are identified on the zoning maps and any plans prepared for these areas will be proposed and prioritised subject to need and resources.

Development proposals relating to existing sub-standard private rented accommodation are subject to all of the standards contained in the Development Plan including the residential standards. Opportunities to promote improvement in the quality and standards of private rented accommodation will be pursued by the Council in the context of emerging relevant legislation including: Housing(Standards for Rented Houses) Regulations 2008; Housing (Standards For Rented Houses) (Amendment) Regulations 2009; and the Housing (Miscellaneous Provisions) Act 2009. Manager's Recommendation Retain as existing.

Section: 11.4.3 Sustainable Building Design

Summary of Issues It is submitted that there is a need that policy supporting material alterations to the external fabric of a building under certain circumstances e.g. improve BER from F to B or higher (RIAI).

Policy QH10 (sustainable energy use) must not be applied prescriptively (CIF). Manager's Response Policy QH10 Sustainable Building Design promotes improved energy performance of all new development including adaptations needed for climate change and would allow for the implementation of passive solar design. Environmental initiatives will be implemented in accordance with established good practice and some may be subsidised financially (e.g. relevant grants from Sustainable Energy Ireland). It is not appropriate to use a sustainable building design policy to eliminate substandard private rented accommodation and whilst the policy promotes good practice such as improving building energy ratings, it would not be appropriate to generally support external alterations in this regard as this needs to be balanced with visual amenity considerations through the development management process. Manager's Recommendation Retain as existing.

Section: 11.4.4 Quality Housing for All

Summary of Issues The IWA submit that quality house design that meets accessible design principles and standards is needed and that 10% of social and affordable housing should be made fully accessible. It is suggested that reference to actions identified in DoEHLG‟s upcoming National Housing Strategy for People with Disabilities be made and that the Housing Adaptation Grant Scheme needs to be funded.

Other submissions suggest that flexibility and adaptability could be made an objective adn that integrated custom built retirement accommodation should be provided for in the Plan.

The RIAI request that QH11 (adaptable housing) should be drafted 'to promote' as opposed 'to ensure' and that policy should seek to promote the reinstatement of suitable subdivided existing housing stock to accommodate families. Manager's Response The Draft Plan is informed by current guidance on a wide range of issues including the needs of people with disabilities. The application of the Housing Adaptation Grant scheme is beyond the scope of the plan. Policy QH11 ensures that new housing will be designed having regard to the Development Plan standards and the Lifetime Homes standards contained in DoEHLG guidance. The proportion of social and affordable housing that is designed in a way that specifically meets the needs of those with disabilities is beyond the scope of the Plan as it a Building Regulation matter and an operational issue arising as part of the design process. Custom built retirement accommodation can be provided under policy QH12 as currently worded. Applicants for planning permission will be expected to demonstrate how their proposals have been designed to be adaptable and flexible under Policy QH11.

It is not considered necessary to introduce a policy for the reinstatement of subdivided units to provide family accommodation given that Policy QH18 seeks to ensure that housing provides for the needs of family accommodation and provides a satisfactory level of residential amenity. Manager's Recommendation Retain as existing.

Section: 11.4.5 Good Property Management

Summary of Issues It is submitted that high density apartments should be family sized with good private amenity space and possibly parking and that there is a need for legislation on apartment living e.g. noise, upkeep of common areas.

Designing Dublin suggest that managed developments be kept to a minimum. Submissions also state that Dublin City Council needs to take estates in charge; that good quality estate management based on principles of mutual respect is needed; that strict laws and enforcement are needed for good property management and to stop properties falling into disrepair and to avoid anti-social behaviour. Manager's Response Policy QH14 promotes efficient and effective property management in the context of evolving national legislation including the Multi-Unit Developments Bill 2009, the Property Services (Regulation) Bill 2009 and the establishment of the National Property Services Regulatory Authority. In addition Development Plan residential standards relating to acoustic privacy A1(5) and management and maintenance B2(4) will also address the issue of noise and upkeep of common areas in apartment complexes. The Council will adhere to relevant Planning and Housing legislation whether it is stated in the text of the plan or not.

Target Floor Areas and other standards for apartment developments seek to ensure that new apartment developments provide suitable accommodation for families including private open space. The Council will take managed residential developments in charge when appropriate under the terms of its „taking in charge‟ policy. Appendix 19 Safety Design Guidelines provide guidance on designing development in a way which avoids anti-social behaviour and promotes safety and security. Manager's Recommendation Retain as existing.

Section: 11.4.6 Apartment Living Summary of Issues The RIAI submit that appropriate target floor areas should be indicated as part of an LAP or as part of an approved masterplan and reiterate previous submission in relation to existing Variation 21. The DDDA welcomes the approach to residential development and supports the need identified to provide functional quality apartment homes as an alternative to suburban low density housing needs (DDDA). Submissions also state that there is a need to improve apartments by increasing standards for private open space particularly in the inner city. Other submissions raise issues of improvements such as sound proofing and screening of plant. Other submissions contend that apartments don‟t foster a community atmosphere and that 3 bedroom apartments are not attractive to the market and will add to vacancy rates. Manager's Response Policies and standards in the Draft Plan to provide accommodation suitable for families in apartment complexes should contribute to more balanced and stable communities living in apartments. It is considered that larger apartments will not lead to higher vacancy rates, better designed larger and more affordable apartments would be attractive to a wider market as is the norm in many European cities.

Noise insulation and plant installation standards is primarily a building control issue, however, Development Plan residential standards relating to acoustic privacy A1(5) will contribute to addressing the issue of noise in apartment complexes and visual amenity is considered as part of the development management process and the screening of roof plant can be required if necessary in this context.

Target Floor Areas and other standards for apartment developments seek to ensure that new apartment developments provide suitable accommodation for families including private open space. If considered necessary in the context of sustainable planning, a Local Area Plan could apply different target floor areas to identified areas / sites to those contained in the Draft Plan. A detailed submission relating to achieving liveable sustainable new apartment homes was already considered under the existing Variation 21 adoption process. Manager's Recommendation Retain as existing.

Section: 11.4.8 Demolition and Re-use of Housing

Summary of Issues It is submitted that no more properties should be built until existing vacant units are occupied and that owners of empty units should be forced to take Council tenants. It is contended that QH20 (discouraging demolition unless increased number of units) should not apply in Z2 conservation areas.

The RIAI state that the Plan Should recognise preference for upgrading the fabric of existing buildings in lieu of demolition. The Dublin Civic Trust suggest that the Plan should include design principles similar to those found in the Lower Rathmines Road Regeneration Study and protect mews laneways to facilitate the residential use of upper floors. Manager's Response The Council is not in a position to require owners of vacant units to take Council tenants and this issue is beyond the scope of the Plan. It is unlikely that significant amounts of new housing will be built until there is a market for such housing which will be created, in part, by the absorption of the existing overhang in the market.

Where necessary, it is envisaged that design principles similar to those found in the Lower Rathmines Road Regeneration Study 2005 can be put into new Local Area Plans to help reintroduce residential uses in historic areas.

It is not considered appropriate to prohibit mews lane development as such development helps to increase the density of development in urban areas subject to the safeguards outlined in standard 17.9.14.

Policy QH20 discourages demolition, therefore, it implicitly recognises the preference for upgrading existing fabric and it is inappropriate to make an exception to the policy for Z2 conservation areas. In addition to complying with development standards for conservation areas (17.10.8.1) Streetscape, environmental and amenity considerations must be satisfied before demolition would be considered and this would apply particularly to Z2 areas due to their conservation status.

The issue of contemporary extensions is addressed by the guidance contained in „Contemporary Extensions‟ section of Appendix 23 „Guidelines for Residential Extensions‟. Manager's Recommendation Retain as existing.

Section: 11.4.9 Regeneration

Summary of Issues One submission states that improvements to existing stock and amenities is more desirable and sustainable than demolition and new housing should be town house style up to 8 storeys in height. Manager's Response Notwithstanding policy QH20 to discourage the demolition of habitable housing, decisions on the appropriate approach to the transformation of key regeneration areas will be taken on a case by case basis. New housing in regeneration areas will be expected to comply with the Standards for Residential Accommodation (Section 17.9of the Draft Plan) which seek to provide a variety of housing types and tenures at sustainable densities. Manager's Recommendation Retain as existing.

Section: 11.4.10 Social and Affordable Housing

Summary of Issues Submissions refer to the need social housing for the homeless; and suggest that unused apartment blocks be co-opted for social housing. Reference is also made to inspections before the sale or transfer of housing, and that voids must be re-occupied quickly. It is submitted that there is frustration among people with disabilities with the standard of Council accommodation provided for them and query the Housing Needs Assessment for the „disabled or handicapped‟.

With reference to anti-social behaviour in local authority estates it is submitted that this needs to be addressed including the development of a strategy to combat anti-social behaviour.

The Dublin Chamber of Commerce suggest that a citywide retrofitting programme should be undertaken of all houses owned and managed by the Council.

The CIF request amendment to Policy QH25; 20% for social and affordable housing is excessive in current circumstances and they request Council to commit to funding all its Part V requirements as part of pre-planning discussions. The CIF further suggest that existing housing stock should be exhausted and that other methods of providing social housing such as the DoEHLG social housing leasing programme should be examined.

Focus Ireland submit that there is a need to examine the growing gap between social housing need and supply and take account of changed funding context. It is contended that the supply of social housing needs to increase significantly to meet housing need and QH25 should be amended to provide for 30% social housing. Another submission suggests artist studios could be provided as part of the 20% social and affordable housing allocation. The reduction in the percentage applied to affordable housing under Part V to the benefit of social housing is not in accordance with the City's objective to create a balanced, liveable city with a mix of tenures, residents etc. Manager's Response The inspection of housing for sale or transfer and the allocation of social housing are an operational matters and outside the scope of the Development Plan. Appendix 19 Safety Design Guidelines provide guidance on designing development in a way which avoids anti-social behaviour and promotes safety and security. The Housing Strategy addresses the housing needs of the homeless.It also identifies methods of providing housing including voluntary and co-operative housing, social housing leasing, and Part V, however, the level of capital funding received by the Council for the provision of housing is a matter for the DoEHLG.

The Council is committed to improving and regenerating identified areas. Subject to funding, the Council supports social housing leasing which may involve vacant apartment blocks. Seeking to minimise void stock turnover times is outside the scope of the Development Plan.

The Construction Industry Federation submission seeks to reduce the requirement for social and affordable housing whereas the submission from Focus Ireland seeks to increase the requirement for social and affordable housing. The requirement outlined in policy QH25 is based upon an estimation of social housing need contained in the housing strategy which indicates that it will continue to be necessary to set aside 20% for social and affordable housing, however, the ratio should be 15:5 in favour of social housing. It is considered that this represents an appropriate balance in terms of the percentage and ratio of social and affordable housing sought. Furthermore, it is considered that seeking circa 80% private, 5% affordable and 15% social housing would not detract from the aim to create a balanced, liveable city with a mixture of tenures and residents. The Construction Industry Federation submission requesting that the „Council commit to funding all its Part V requirements as part of pre-planning discussions‟ is ambiguous, however, it should be noted that the Planning and Development Act 2002 allows for the Part V requirement to be provided in a number of delivered ways including, transfer of land, transfer of units and financial contributions and teh extent of any Part V required from any development is not determined until the planning application is decided.

The retrofitting of Council housing stock and the provision of accommodation for people with disabilities is subject to resources and is a matter for the Housing Department. The Part V legislation makes no specific provision for artists studios to be provided. However, if an artist qualified for social or affordable housing, it may be possible to use the unit in part as an artist studio under Plan standards aimed at facilitating home based economic activity where appropriate.

The assessment of housing need is carried out by local authorities every three years and a new housing need assessment is due to be carried out in 2011 when the number of people identified under the „disabled or handicapped‟ category will be reassessed. Manager's Recommendation Retain as existing.

Section: 11.4.12 Homeless Services

Summary of Issues Submissions state that there is a need to reduce homelessness and it is also submitted that a homeless hostel / institutional mapping exercise should be carried out to allow for a fair distribution of concentration over all areas.

Focus Ireland request that Policy QH28 be amended to include targets and that QH29 be redrafted to avoid pejorative and negative language. Manager's Response The Council seeks to reduce homelessness through its support for the Homeless Action Plan for Dublin (Policy QH28). The Homeless Action Plan includes a target to reduce long term homelessness to zero by the end of 2010. Policy QH29 should be amended to emphasise that it seeks to avoid an undue concentration of such facilities in any one area of the city. The requirements to be submitted with planning applications for such facilities remain outlined at Chapter 11, Section 11.4.12.

The various homeless agencies are best placed to provide mapping of homeless services as part of the development management process as they have ready access to the base information (i.e. the location of all the relevant services). Manager's Recommendation Amend Policy QH29 From: To ensure that all proposals to provide or extend homeless accommodation or support services shall be supported by information demonstrating that the proposal would not result in an undue concentration of such uses nor undermine the existing local economy, resident community or regeneration of an area. All such applications shall include: a map of all homeless service within a 500m radius of the application site (equivalent to a 1km diameter map of facilities around the application site); a statement on the catchment area identifying whether the proposal is to serve local or regional demand; and a statement regarding management of the service/facility

To: To ensure that all proposals to provide or extend homeless accommodation or support services shall be supported by information demonstrating that the proposal would not result in an undue concentration of such uses in an area Section: 11.4.13 Student Accommodation

Summary of Issues A submission from DIT, DCU, and Trinity College submission requests the removal of prohibition on single unit student accommodation for on-campus student residential developments on land owned by 3rd level institutions. Manager's Response The issues raised in this submission have merit. However, it is proposed to alter the detailed standards contained in Appendix 21 „Guidelines for Student Accommodation‟ rather than policy QH30. Manager's Recommendation Retain as existing. Chapter 12 Creating Good Neighbourhoods and Sucessful Communities Submission Number(s): 2021, 2030, 2042, 2086, 2109, 2157, 2168, 2204, 2229, 2258, 2260, 2267, 2298, 2333, 2621, 2653, 2655, 2673, 2724, 2753, 2791, 2801, 2811, 2812, 2831, 2845, 2919, 2941, 2966, 2983, 3003, 3026, 3032, 3039, 3040, 3071, 3094, 3099, 3124, 3142, 3149, 3164, 3165, 3167

Section: 12.1 Achievements

Summary of Issues One submission comments on the perceived difficulties and limitations of some of the city‟s new communities; such as Pelletstown and North Fringe; while the other submission observes that a much greater level of community facilities and infrastructure are still required in these areas. Manager's Response The city's new communities are still developing and as such have not yet reached their full potential in terms of the services, facilities and infrastructure. As outlined in the draft Development Plan's Core Strategy both Pelletstown and North Fringe are to benefit from new Local Area Plans which will -among a range of other issues- strive to create good neighbourhoods which provide for a wide range of community facilities. Manager's Recommendation Retain as existing.

Section: 12.2 Challenges

Summary of Issues These submissions call for consideration to be given to what makes a great community – in particular a high quality living environment- and for Dublin City Council to measure and take cognisance of the community infrastructure requirements for existing and future populations. Manager's Response It is considered that Chapter 12 as a whole addresses the wide range of factors which make neighbourhoods attractive and communities successful. In this regard the importance of residential amenity and high quality urban design is much emphasised by this chapter. In response to the ascertaining of community infrastructure requirements, this chapter also introduces the concept of social audits; a mechanism which is to be applied to the development of large-scale residential and/or mixed-use schemes which must show how the scheme will deliver a key social infrastructure element. Manager's Recommendation Retain as existing. Section: 12.3 The Strategic Approach (See Fig. 20)

Summary of Issues In relation to highlighting the city‟s network of sustainable communities –particularly in Figure 20- this one submission suggests that recognition be given to the strong communities developing in an easterly direction from the city towards the Docklands. Manager's Response Figure 20 is for indicative purposes only to illustrate the connectivity and linkages which exist between city neighbourhoods. Manager's Recommendation Retain as existing.

Section: 12.4.1 A Good Urban Neighbourhood

Summary of Issues Many submissions were keen to stress the importance of consultation between local community groups and Dublin City Council in relation to new developments. As highlighted by the submission from the National Council for the Blind of Ireland, these consultations should include people with disabilities. One submission emphasises the need for consultations between communities and the HSE and the Gardai. Other issues raised by individual submissions include: the importance of protecting residential amenities; the need to achieve a sustainable mix of office, residential and social infrastructure in new developments; the prioritising of local communities over commercial imperatives; and for any new development in existing neighbourhoods to be sensitively stitched in.

An additional submission recommends that Dublin City Council strive to make it‟s existing neighbourhoods successful and to ensure that the spirit of these areas is preserved not just the buildings. One submission suggests that Dublin City Council develop a local market in each of its neighbourhoods. Manager's Response Chapter 12 recognises the importance of consulting with local communities in policy NC3. This policy's reference to “consultative forums” denotes all types of representative forums ranging from residents committees to special interest groups such as people with disabilities. Consultation between communities and the HSE and the Gardai is more relevant to the remit of Dublin City Council's City Development Board and the Joint Policing Committees. The protection of existing residential amenities, mixed-use development, high quality urban design, and excellence in architecture is encouraged throughout the draft plan. In addition, policy NC2 promotes developments which build on local character as expressed in historic buildings. The development of local markets in the city is addressed by policies and objectives in other chapters, namely; GC15, FC24, RD6, and RDO3. Manager's Recommendation Retain as existing. Section: 12.4.3 Neighbourhoods and Supporting Infrastructure

Summary of Issues In relation to the supporting infrastructure needed by communities a few submissions emphasise the need for improved community facilities. It was suggested by one other submission that the provision of these facilities be worked out at pre-planning stage, in consultation with the local community. One submission makes the point that in regard to the recreational needs of communities, alternatives to football pitches should be provided, while one other assert that the membership and usage costs of such facilities should be fair and non-prohibitive. It is also highlighted by one submission that age appropriate sports facilities need to be provided in accessible locations. Manager's Response The draft Development Plan has introduced the requirement for all applications involving large-scale residential and/or mixed-use schemes to be accompanied by an audit of the area's existing facilities. This requirement is addressed by Chapter 4 (SC13), Chapter 12 (Section 12.4.6) and Chapter 17 (17.9.1/C). This audit must show how the development will complement the range of neighbourhood facilities already present in the area and how it will contribute to it's social infrastructural elements generally. While the statutory provisions and timeframes of the development management process do not afford the possibility of direct consultations between applicant and the local community, tools such as; Local Area Plans, Schematic Masterplans, as well as Village Improvement Schemes, provide ample opportunities to compile a social facilities audit through consulting and engaging with the local community.

Policy NC18 addresses the need to provide alternative recreational activities for young people other than football pitches, and policy NC7 addresses the need for all community/recreational facilities to be suitable for all ages and to be accessible in terms of location and cost of use. Manager's Recommendation Retain as existing.

Section: 12.4.4 Schools and Educational Facilities

Summary of Issues A number of submissions state that the lack of schools in certain areas needs to be addressed. One other submission seeks an increase in multi-denominational schools, while one other submission requests Dublin City Council to support the development of a new third and forth level university for the North Fringe/Greater Swords area. The Dublin Docklands Development Authority requests that its Living and Learning Document be considered. Manager's Response Section 12.4.4 states that Dublin City Council will actively assist and liaise with the Department of Education and Science (DES) in relation to the provision of schools with particular regard to forecasting demand and the timely identification of suitable sites and phasing arrangements. Policy NC10 seeks to reserve lands for educational purposes in locations close to the areas of greatest residential expansion. Additionally, in accordance with the DES & DoEHLG‟s Joint Code of Practice on the Provision of Schools and the Planning System (2008) the draft Development Plan reiterates the requirement for residential proposals in excess of 200 dwelling units to be accompanied by an assessment of the capacity of local schools to accommodate the proposed development (Section 17.17).

The religious ethos of schools is not a matter for the Development Plan It is Development Plan policy to facilitate the provision of new third level institutions (NC9). With regard to the DDDA's Living And Learning document it is not appropriate for the Development Plan to refer to it directly, given its focus on service delivery by the DDDA. Manager's Recommendation Retain as existing.

Section: 12.4.5 Sustainable Provision and Optimum Use of Social Infrastructure

Summary of Issues Submissions comment on this topic on the lack of recreational facilities close to residential areas, with one submission placing a particular emphasis on the lack of activities and spaces for teenagers. One submission request that policy NC13 state that Dublin City Council will support and/or expand on the provision of community facilities within neighbourhoods where a need has been identified and that this shall be done in consultation with the local community. Manager's Response The draft Development Plan acknowledges the fact that some areas of the city experience a significant deficiency in terms of recreational and play provision, and that the involvement of the local community and of young people will form an important element in addressing this. Chapter 6, Policy GC34 states that it is Dublin City Council policy “to ensure the availability of a range of recreational facilities to the general population at locations throughout the city. In areas where a proven deficiency exists, Dublin City Council will work with the providers of such facilities, including schools, institutions and private operators, to ensure access to the local population.” In addition, Chapter 12, Section 12.4.1 “A Good Neighbourhood” promotes the involvement of the local community in this regard; policy NC3 states that it is Dublin City Council policy to “recognise the important role that community groups play in the city and to engage with consultative forums which are inclusive of all age groups,” while objective NCO2 seeks “to investigate the opportunities, in consultation with young people, to provide for challenging play opportunities.” Manager's Recommendation Retain as existing.

Section: 12.4.6 Social Audits and the Provision of Social Infrastructure

Summary of Issues One submission suggests that the natural environment be recognised as an essential part of play while one other suggests that children be consulted on a wide range of issues pertaining to their interactions with their local environments. One submission calls for a play space/play map to be incorporated into the Development Plan. With regard to play space design the Dublin Docklands Development Authority asks that the Development Plan consider its Play Space Guidelines document. The submission from the Dublin City Children Services Committee called for the Development Plan to support the vision and aims of Dublin City Council‟s “Children‟s Services Policy Statement (Dec. 2009)” and its commitment to the Government‟s “Agenda for Children‟s Services: Policy Handbook.” Finally, a typing error was highlighted in the first paragraph of this section where reference is made to 200,000m2 where in fact it should read 20,000m2. Manager's Response In terms of the natural environment as being fundamental to children‟s play and the importance of consulting with children, it is considered that NCO2 addresses this when it states that it is an objective “to investigate the opportunities, in consultation with young people, to provide for challenging play opportunities which provide a wide variety of play experiences and where possible allow access to the natural environment.” In addition, Development Standards pertaining to Playgrounds/Play Spaces (Chapter 17, Section 17.16) emphasises the importance of natural play elements. In relation to the inclusion of a play space/play map this work will be carried out as part of Dublin City Council‟s Play Plan and shall be included in that document.

It is considered appropriate that the Draft Plan Development Standards on Playgrounds/Play Spaces make reference to the DDDA‟s Play Space Guidelines.

The Draft Plan recognises the work of the Dublin City Children Services Committee and its linkages with spatial planning, particularly in relation to the physical and natural environments occupied by children. In this regard, it is considered that there is merit in the inclusion of an additional objective in Chapter 12, Section 12.4.6: NCO3 “To support the vision and aims of Dublin City Council‟s Children‟s Services Policy Statement.” Manager's Recommendation Insert new objective at end of Section 12.4, NCO3: To support the vision and aims of Dublin City Council‟s Children‟s Services Policy Statement (Dec. 2009).

Amend Text, Section 12.4.6, Para 1. From: Large-scale residential and/or mixed-use schemes, typically 200 units or 200,000m2

To Large-scale residential and/or mixed-use schemes, typically 200 units or 20,000m2

Amend Policy SC13, Bullet Point 2. From: A Community Infrastructure Statement, demonstrating how the scheme can contribute to the community infrastructure of an area (as set out in Chapter 17 Development Standards).

To: In addition, schemes over 200 Units / 20,000 m2 shall be accompanied by a Community Infrastructure Statement, demonstrating how the scheme can contribute to the community infrastructure of an area (as set out in Chapter 17 Development Standards).

Amend Text, Para 8, Line 4. From: „developers will be required to submit an audit of existing facilities within the area‟

To: „developers will be required to submit a Community Infrastructure Statement comprising an audit of existing facilities within the area‟

Insert New Bullet Point, Section 17.16, at end of para 3:  Further guidance should be sought from the Dublin Dockland's Development Authority Play Space Guidelines document (2007) in relation to its area.

Section: 12.4.7 Social Inclusion and Regeneration

Summary of Issues Concern is raised in one submission that the needs of the disabled have been confined to the latter parts of the draft Development Plan while one other submission contends that the concept of Universal Design has not been embraced. It is also asserted by one submission that the Plan gives little recognition to the 10% of the city‟s population who were born overseas and that there is no reference to Dublin City Council‟s Intercultural Plan. One other submission requests that the Plan place more emphasis on combating inequality and social exclusion, while another asked that better clinics be provided for those with drug addiction issues. In addition, a collective submission from the city‟s religious leaders and faith communities highlights the role that they could possibly play in creating successful communities. A request is also made that Dublin become recognised as a WHO Age Friendly City. The submission from the Dublin City Children‟s Services Committee highlight the importance of taking the Government‟s “life-cycle” approach to the development of sustainable neighbourhoods, an approach which involves taking cognisance of the needs of: children; disabled people; older people; and those of working age. Manager's Response The Draft Development addresses access needs of the disabled throughout numerous policies and objectives (Chapter 5 (SIO46, SIO47), Chapter 7 (FC32), and Chapter 12 (NC7). In addition, such needs are acknowledged by the Guiding Principles: Section 16.1 in terms of landscaping; and by the Development Standards namely; Section 17.16 in terms of the creation of successful play spaces for disabled children, and Section 17.32 in relation to ensuring street furniture does not act as an obstruction to people with disabilities. Appendix 20 “Access For All” outlines criteria which all applications much comply with. It is also considered that the draft Development Plan has fully embraced the concept of Universal Design. Policy NC23 seeks “to promote built environments and outdoor shared spaces which are accessible to all. Such developments must be in accordance with the principles of Universal Design, the City Development Plan‟s Access For All Standards, and the National Disability Authority‟s „Building For Everyone‟ publication.” In addition, Appendix 3, Section 5 of The Dublin City Council Housing Strategy seeks “to ensure that new housing is designed to be adaptable, flexible, and accessible to all by incorporating universal design.”

One of the six themes which the Draft Plan is based on is entitled “Social.” This theme specifically promotes the integration of all ethnic communities. In addition, the Housing Strategy acknowledges the increase in ethnic and cultural diversity among the city‟s resident population, particularly in inner city areas. Objective FC03 supports a range of cultural initiatives and facilitates the provision of a broad range of cultural facilities required by the City‟s diverse ethnic populations, while objective REO11 seeks to assess the potential of Parnell Street and other areas for the creation and the promotion of ethnic retail and restaurant clusters. In relation to the assertion that the draft Development Plan has not referenced Dublin City Council‟s Intercultural Plan this is addressed by Chapter 12‟s policy NC22 which refers to the “implementation of Dublin City Council‟s Towards Integration: A City Framework.”

The provision of clinics for those with drug addiction issues is outside the remit of the Development Plan and is not a function of the City Council. Similarly, the assistance which faith communities can provide in terms of the City Council‟s community development work is outside the remit of the City Council but shall be referred to the Community Development Section. The issue of Dublin becoming recognised as a WHO Age Friendly City is also outside the remit of the Development Plan but shall be referred to the Housing, Social and Community Affairs SPC.

The importance of the Development Plan recognising the Government‟s “life-cycle” approach (as outlined in Towards 2016- Social Partnership Agreement, and The National Action Plan For Social Inclusion 2007-2016) to the development of sustainable communities is acknowledged. Thus, it is considered that there is merit to the inclusion of an additional policy in Chapter 12, Section 12.4.7- NC24. Manager's Recommendation Insert New Policy, NC24 in Section 12.4.7. To promote sustainable neighbourhoods which cater to the needs of persons in all stages of their lifecycle i.e. children, people of working age, elderly, people with disabilities.

Chapter 13 Implementation Submission Number(s): 2802, 2834, 2918, 2935, 2965, 2966, 2972, 2985, 3042, 3142, 3179

Section: 13.1 Collaboration & Engagement Mechanisms

Summary of Issues It is suggested that the City Council must acknowledge that residents and their communities are equal stakeholders in the city and that the Council must tap into the knowledge and resources of local communities.

It is submitted that where Local Area Plans and Masterplans are being prepared, consideration could be given to establishing multi-disciplinary taskforces of individuals from both the private and public sectors at the design stage to encourage collaboration, invent solutions and build entrepreneurship so that projects are designed for and with the residents of the area. Manager's Response The Draft Plan specifically states that the citizens of Dublin are the city's most valuable asset and that the on-going collaboration and support of citizens and communities is essential to the implementation of the Plan. The Plan is considered to sufficiently acknowledge and emphasise the importance of local communities throughout its Chapters.

With regard to multi-disciplinary groups established for LAPs, the City Council considers that the process it has used to date which has involved very extensive consultation with local communities, sectoral groups etc. Is sufficient. Manager's Recommendation Retain as existing.

Section: 13.2 Monitoring

Summary of Issues A number of suggestions for new additions to the monitoring section were received including; to provide fully accountable, transparent and independent monitoring of the Development Plan and the establishment of a CITYSTAT office, under the Lord Mayor, to enable complete measurement of work and outputs by Dublin City Council from 2011 to 2017. New performance monitoring indicators relating to transport specifically in relation to capacity, level of service and robustness are also requested. Manager's Response It is considered that the Draft Plan contains sufficient mechanisms to provide for transparent, independent monitoring of the Plan. A commitment is given to collaboration and engagement with outside bodies, communities and other stakeholders in the Plan's implementation and the use of independently verified indicators and annual reports to the Elected Council provides a transparent and accountable framework within which to implement the Plan.

CitiStat is a small performance-based management group responsible for continually improving the quality of services provided to the citizens of Baltimore and other cities. It is considered that the City Council's Research Office and the City Indicators Project which is now fully operative performs these functions for the City Council.

The performance indicators already set out in the Draft Plan are sufficient to monitor progress on the Plan's implementation. Additional indicator monitoring for the City is carried out as part of the City Indicators Project. Manager's Recommendation Retain as existing.

Section: 13.3 Implementation Mechanisms

Summary of Issues The Implementation Plan is considered by one submission to be inadequate. A clear Phasing Plan, illustrating how the development and the necessary infrastructure set out in the Core Strategy can be sequentially provided, is needed.

It is recommended that a 'Statement of Compliance' is provided to demonstrate how the Core Strategy is consistent with the Draft Dublin Area Regional Planning Guidelines 2010-2022 and the National Spatial Strategy 2002 - 2022. In particular the Development Plan should clearly define its population projections in line with the Draft GDA RPG and provide a strategic approach to zoning. The quantum of zoning should be based on population projections.

It is suggested that elements of the Sustainability Toolkit could be included as part of normal planning applications regardless of whether or not it is in the area of an LAP or Masterplan.

The Plan does not clearly define actions, highlight responsibilities or funding for the delivering initiatives in the Plan, particularly in relation to transportation.

The Plan should identify key delivery mechanisms and flexible solutions that facilitate continued development to the required standards such as planning applications that facilitate phased development and extended planning permission durations (e.g. 10 year permissions). Manager's Response The Core Strategy has been amended to accord with the requirements of the DoEHLG and this is fully set out at Chapter 3.

The Development Plan is a strategic document which sets out a vision for the spatial form and development of the City over the next 6 years. It sets out policies and objectives to guide and achieve this vision. As such it is not an action plan showing actions, costs and responsibilities, nor would this be possible given than many of the policies and objectives are dependent on other agencies and on whether private landowners wish to develop their own property within the lifetime of the Plan.

With regard to phasing of developments, it is appropriate that developments above a certain scale be phased and this is provided for in the Draft Development Plan in a number of sections. It is considered that sufficient provision has been made for phasing of developments.

Dublin City Council may grant permissions for a 10 year period in certain cases, depending on the scale and extent of development. Applicants may seek to extend the duration of planning permission under the provisions of the Planning & Development Act 2000, as amended. Manager's Recommendation Retain as existing.

Section: Other Issues

Summary of Issues One submission suggests that polices and objectives should be indicated in the Implementation section

The establishment of an „Urban Laboratory‟ to make a series of architectural and urban studies and proposals for Dublin City Council is suggested in a submission from the Dublin Institute of Technology. The project would be on-going and would seek to map the whole Dublin City Council area.

Another submission states that Dublin City Council should consider undertaking cost- benefit audits of public projects to inform the development of future projects and to assess what social/economic or other gains a particular project brought to the city e.g. the Spire, Temple Bar etc. In introducing new masterplans, variations or standards it is suggested that the City Council should ensure that they rigorously cost the maintenance and operational implications of their requirements. Manager's Response As the Implementation Chapter focuses on how the Plan is to be delivered it is not considered appropriate that policies and objectives be included. However, the Chapter will be examined so as to highlight the specific actions and initiatives proposed in the final printed document.

While the Urban Laboratory is considered to be an idea worth examining further, it is not considered appropriate that a commitment be given to this proposal at this stage given that procurement issues may arise. However, the potential to develop links with third level institutes in the City in order to develop plans and studies related to the policies and objectives of the Development Plan is considered to be highly valuable but it is considered that the opportunity to develop such links is facilitated by the existing text at Section 13.1, Collaboration and Engagement Mechanisms.

The requirements to carry out cost-benefit analyses of publicly funded projects are set by the Department of Finance and it is not considered appropriate that such matters would be dealt with in the Development Plan but could be brought to the Planning Development & International Affairs SPC. Manager's Recommendation Retain as existing.

Chapter 14 Development Management Submission Number(s): 2227, 2261, 2333, 2603, 2753, 2802, 2837, 2847, 2907, 2914, 2938, 2972, 2974, 2983, 3041, 3101, 3159

Section: 14.2 Compliance with Permissions Granted and Enforcement

Summary of Issues A number of submissions raise the issue of the operation and effectiveness of planning enforcement by Dublin City Council and state that the action taken by the Council in this regard is inadequate and ineffective. The plan must include a statement of intent regarding enforcement action to be taken in the event of breaches of the Plan and commit to taking speedy enforcement action.

It is stated in one submission that under current legislation only local authorities can initiate legal proceedings on enforcement issues and a reversal to the pre-2000 position where action could be taken by private citizens is requested.

A statement of intent should be made regarding enforcement action to be taken in the event of breaches of the Plan.

It is also submitted that in cases where an illegal demolition or breach of planning permission has been highlighted by Dublin City Council will undertake to pursue any legal actions through the Circuit Court at a minimum instead of the District Court. Any developer who has been found guilty of a breach of planning laws is to be precluded from applying for planning permission individually or as part of a company for a period of 5 years.

In addition it is suggested that it should be a requirement of all future developments in Dublin City that the external site works, for example the lighting, footpaths etc. are completed before any of the houses or apartments are occupied.

It is also submitted that Dublin City Council will also insist that developers/constructors meet with residents groups. Manager's Response While the operation of Planning Enforcement is not a matter for the Development Plan, in the interests of clarity and information, the following response is given;

The Planning Enforcement Section of Dublin City Council is extremely proactive and responds to on average 1,200 complaints per annum alleging unauthorised development. All valid complaints are investigated fully and appropriate action up to prosecution under Section 157 and injunction proceedings under Section 160 of the Planning and Development Acts 2000 – 2006 are taken. This results in court appearances each week. In some cases, action is taken by way of negotiation with residents/developers who have carried out unauthorised development. A report on enforcement action is presented on a quarterly basis to each Area Committe to keep Elected Members up to date on progress.

The manner in which to deal with breaches of the Plan are set out in the Planning & Development Acts. As this is provided for in legislation it is not necessary to make a further statement in the Plan itself.

The legislation sets out specific timescales within which action can be taken on foot of an Warning Letter, Enforcement Notice etc. and these cannot be altered in the Development Plan.

Any citizen is entitled to take injunction proceedings under Section 160 of the Planning and Development Act 2000. Further entitlements for citizens would require legislative change.

The Enforcement Section is bound by the provisions of the Planning and Development Acts 2000 – 2006 when taking legal action and cannot choose the level at which prosecutions are taken or injunctions sought. All Section 157 proceedings must be prosecuted in the District Court. Action under Section 160 are heard in the Circuit or High Court depending on the rateable valuation of the property concerned. The manner in which to deal with those found guilty of breaches of previous planning permissions is set out in the Planning & Development Acts. As this is provided for in legislation it is not necessary to make a further statement in the Plan itself.

The completion of site works in advance of occupation is a compliance matter, which can be implemented by the requirement of a Bond in certain conditions (145).

As the Planning Authority is not empowered under planning legislation to compel developers to meet with residents groups, it is not possible to amend the wording in the Plan as requested. Manager's Recommendation Retain as existing.

Section: 14.4 Development Contributions

Summary of Issues A number of submissions raise issues in relation to Development Contributions and Community Gain including requests for a review of the scheme; a general reduction in the contribution rates; reductions for certain types of development; action in relation to collection of levies; greater transparency in the scheme including the involvement of residents in to input into spending; a committment to funding the list of projects in the Scheme and; annual reports to be published.

Other submissions request that a new section be included to state that planning permission will not be granted to development companies of a developer who has not paid outstanding development levies.

Also it is requested that Community Gain should be a condition of any grant of planning permission for development over 2 units. Manager's Response Development Contributions Schemes are dealt with under the statutory procedures set out under Sections 48 and 49 of the Planning Development Act and the operation of such schemes is not appropriate for the Development Plan. Reductions and amendments to the Scheme cannot be done through the Development Plan process as there is a separate statutory procedure provided for in law for the making of the Scheme.

The making of the Development Contributions Scheme is a statutory process involving public display and an opportunity to make submissions before the Council makes the Scheme. An Annual Report is presented to the City Council which lists the amount collected in the previous year and the projects on which the levies were spent. These measures provide transparency in both the making and operation of the Scheme

The appropriate means to collect development contributions are set out in the Planning & Development Acts as are the restrictions on granting of planning permission for failure to comply with conditions of previous permissions.

Under the Planning & Development Act 2000, as amended, financial contributions can only be attached to planning permissions in accordance with Sections 48 and 49 of the legislation. Manager's Recommendation Retain as existing.

Section: 14.5 Bonds

Summary of Issues One submission suggests that greater bonds should be sought for cover unfinished works. Manager's Response The calculation and application of bonds is not a matter to be set out in the Development Plan as it is an operational issue. The application of bonds within the City Council is reviewed on a periodic basis and, in light of current trends and issues in the development of sites, will be subject to review in the near future. Manager's Recommendation Retain as existing.

Section: 14.6 Environmental Impact Assessment

Summary of Issues Submission raise the question as to whether an Environmental Impact Assessment has been carried out on the Draft Development Plan. Manager's Response An EIA of the Draft Development Plan is not required as the EIA/EIS process is designed for capital projects as opposed to policy documents and plans. However, a Strategic Environmental Assessment and an Appropriate Assessment have been carried out and are being reviewed in tandem with the stages of the Draft Plan, as an iterative process. Manager's Recommendation Retain as existing. Section: 14.7 Applications for Planning Permission

Summary of Issues It is submitted that the costs associated with making planning applications, in particular the requirements to provide expert reports, plans and documents is considered prohibitive. It is suggested that much of the detailed technical information could be provided by way of a condition attached to a grant of planning permission.

Another submission requested that all changes to applications, requested or agreed at planning meetings, and/or by requests for further information should be circulated to all those with submissions lodged and they should be consulted fully on any suggested changes. It was also requested that the Development Plan should state that no planning application will be decided by the Planning Officer until such a time as reports are received from other departments.

The RIAI requested that all new planning applications should submit an assessment of its overal sustainability such as the RIAI checklist for sustainability or similar approved methodology. A further submission requested that no permissions should be given for pre-fabricated buildings, especially for young school children, unless they are of a high ecological quality.

It is also suggested that a 'feedback notice' post completion of developments be required wherein the developer/designer would seek feedback from end-users of the development. It is suggested that this would create greater awareness of life-time design and improve the quality of developments. Manager's Response The Planning Authority is empowered to seek technical reports where is considers these necessary to make an informed and balanced decision on a planning application. As each proposal is considered on its own merit the extent of technical information required differs with each site (e.g. location, scale of proposal, impact on the environment, amenities, traffic, proximity to protected structures or archaeological features) and cannot be set out or dealt with by condition on a grant of permission.

Under the provisions of the Planning & Development Acts, third parties are entitled to receive notification of what has been requested from applicants as further information and are notified when such information is submitted to the Planning Authority. Any amendment to this would require legislative change.

The timescales within which a planning decision must issue are set out in planning legislation and it is not possible to amend these through the Development Plan process.

With regard to sustainability checklists, it is considered that there is adequate requirements already contained within the Draft Plan to address this issue. The sustainability requirements of buildings is set out in Chapter 16 and Chapter 17 of the Draft Plan.

The Development Plan and the Building Regulations set out the standards and statutory requirements which developments and buildings are to meet. The management of a non-statutory system of 'feedback forms' would be difficult for the planning authority to administer and control. While the concept of a 'feedback form' to improve the quality of developments is a worthwhile idea, it may be more appropriately referred to the development industry/ professional bodies to develop further as a voluntary system to improve design of development. Manager's Recommendation Retain as existing.

Section: Other Issues

Summary of Issues With regard to levies on derelict sites, submissions suggested that they be; increased to encourage development enforced and collected to provide funds for the Council waived where temporary consent is given to use the site for allotments or patio gardens

In relation to Section 5 Declarations on development and exempted development, it is suggested that a site notice be placed at the location of the application.

It is also suggested that Planning Gain should be rigorously defined in the Plan. Manager's Response Derelict sites are governed through separate legislation and are therefore not a matter to be dealt with by the Development Plan. However, for clarity and information purposes; The derelict site levy amount of 3% of market value is prescribed by legislation (Derelict Sites Act 1990). Any changes to that amount would require further government enactment It is the policy of the City Council to vigorously pursues all levies. Currently there are levies due in respect of 43 sites, 18 of which have been removed from the Derelict Sites Register. All cases are the subject of legal action and at various different stages in the legal process. In 2009 payments totalling €212,981 were received in respect of 13 properties Under current legislation the derelict sites levies will apply until such time as the site in question is rendered non derelict. The waiving of levies in any other instance will require legislative changes

The procedures to be followed for Section 5 Declarations are set out in the Planning & Development Act 2000 and Planning & Development Regulations 2001, as amended and these legislative requirements cannot be altered through the Development Plan process. The requirement for a site notice would require legislative change.

As the term Planning Gain is not used in the Plan, it is not necessary to include a definition. Manager's Recommendation Retain as existing.

Chapter 15 Land Use Zoning Submission Number(s): 1, 2, 2025, 2027, 2031, 2032, 2034, 2046, 2069, 2071, 2073, 2076, 2085, 2090, 2091, 2097, 2098, 2118, 2130, 2136, 2140, 2157, 2158, 2164, 2171, 2191, 2202, 2203, 2204, 2205, 2210, 2212, 2227, 2230, 2231, 2232, 2233, 2234, 2236, 2237, 2240, 2241, 2242, 2243, 2245, 2246, 2247, 2259, 2261, 2268, 2270, 2272, 2278, 2279, 2280, 2281, 2282, 2283, 2284, 2285, 2286, 2287, 2288, 2289, 2290, 2292, 2294, 2333, 2604, 2606, 2607, 2608, 2609, 2610, 2611, 2612, 2613, 2614, 2615, 2616, 2617, 2618, 2619, 2622, 2624, 2625, 2629, 2639, 2642, 2643, 2644, 2653, 2659, 2660, 2661, 2662, 2664, 2665, 2666, 2667, 2668, 2669, 2678, 2741, 2742, 2743, 2748, 2756, 2760, 2761, 2762, 2763, 2764, 2766, 2767, 2769, 2770, 2772, 2776, 2777, 2784, 2790, 2794, 2798, 2802, 2806, 2807, 2809, 2819, 2820, 2821, 2842, 2847, 2860, 2868, 2870, 2873, 2877, 2880, 2882, 2884, 2885, 2886, 2889, 2890, 2891, 2892, 2899, 2901, 2906, 2909, 2913, 2914, 2915, 2920, 2922, 2927, 2928, 2930, 2933, 2938, 2943, 2944, 2945, 2948, 2950, 2954, 2957, 2958, 2960, 2962, 2963, 2964, 2965, 2966, 2979, 2980, 2982, 2986, 2988, 2991, 2992, 2993, 2995, 3008, 3021, 3022, 3026, 3036, 3037, 3038, 3039, 3040, 3047, 3050, 3051, 3053, 3054, 3055, 3056, 3057, 3058, 3059, 3060, 3062, 3063, 3064, 3065, 3070, 3072, 3073, 3076, 3077, 3078, 3080, 3082, 3083, 3084, 3085, 3086, 3087, 3088, 3089, 3091, 3092, 3093, 3094, 3095, 3096, 3097, 3103, 3104, 3105, 3110, 3111, 3112, 3113, 3114, 3115, 3116, 3117, 3118, 3119, 3120, 3121, 3122, 3123, 3125, 3126, 3127, 3128, 3130, 3134, 3136, 3137, 3138, 3139, 3140, 3142, 3144, 3148, 3150, 3153, 3154, 3155, 3156, 3159, 3160, 3162, 3164, 3166, 3167, 3169, 3176, 3178, 3181, 3183, 3187, 3195, 3197, 3198, 3199, 3200, 3201, 3203, 3204, 3205, 3206, 3207, 3208, 3209, 3212

Section: 15.1 Zoning Principles

Summary of Issues In relation to zoning principles, the issues are about the priority for office use in south inner city, the need for more mix-use and regeneration designations, the over prescriptive nature of the Plan, need for coordination between the four Dublin Authorities, whether consistency with the Docklands master plan is warranted, and that the zoning of land into the River Liffey at North Wall Quay is premature. A summary is below.

The Plan should focus on strengthening office space in the core commercial area, that is, Dublin 2 by moving away from having too many land use zonings. The final plan must ensure that the status of the city centre as the primary office location within the administrative area of Dublin is maintained.

Across the City, there should be more mix use and regeneration designations.

The plan is extremely prescriptive. While the policy supports the provision of public services, the land use zonings and development standards do not appear to reflect this support.

For clarity in regional development, Dublin City and the three adjoining Dublin counties should develop similar Land Use Zoning designations. It is submitted that the Draft Plan re-zonings is on the basis of the Docklands Master Plan 2008 and the proposed Section 25 Scheme for Poolbeg and this basis is incorrect. The submission is of the view that the DDDA must comply with the existing City Development Plan. The submission contends that the Master Plan does not comply with the City Development Plan in this regard, and the Draft Poolbeg Scheme has no status whatsoever.

Bullet point 7 in section 15.1 should be reworded to state "to accord with the provisions of the Dublin Docklands Development Authority Act, 1997, to consider the provisions of the DDDA Master plan in the making of the Development Plan", in keeping with the DDDA Act specific requirements.

The land extension into the River Liffey at North Wall Quay (northern camp shire) is premature and without context and should be excluded from all Development Plan mapping.

It is submitted that the statement in bullet point 8 of Section 15.1 that permission will not be granted for a development which materially contravenes the zoning objective is proscribing a statutory right and the Council has unlawfully fettered its discretion to grant permission in material contravention of section 34(6) Manager's Response The role of the City Centre as an employment centre is recognised in chapter 9 – Revitalising the City‟s economy. However, the character of the City Centre, especially Dublin 2, is multi- layered with significant areas of Georgian Conservation areas. There needs to be a balanced approach to the redevelopment of the area between encouraging growth and conserving the heritage of the area which is recognised in the various zones between, Z5 – City Centre, Z6 – Employment Enterprise and Z8 – Georgian Conservation areas. Outside the Z5 City Centre Zone, the main employment zone is Z6 and regeneration areas zoned Z14. There is sufficient employment land, mix use and regeneration areas across the City in a clear hierarchy of Strategic Regeneration Areas and Key District Centres for the sustainable development of the City. The zoning ensures land is available in appropriate locations throughout the City to accommodate expected growth in population during the lifetime of the Plan while the standards guide individual development proposals. In preparing the Draft Plan, there was consultation with the other Dublin Local Authorities and the Regional Planning Guidelines for the Greater Dublin Area ensures consistency between the policies and objectives of the different Development Plans. The 15 zoning categories used by DCC are considered to be appropriate for a capital city.

While the Dublin Docklands Development Authority must consult with Dublin City Council in making the Master Plan, they are not obliged to be consistent with the current Development Plan. Dublin City Council, however, in the making of a Development Plan for that part of their area included in the Dublin Docklands Area must be consistent with the Master Plan. The proposed zonings in the Draft Plan would be consistent with the Master Plan and the wording in bullet point 7 of section 15.1 „ ensure consistency‟ is in accordance with the DDDA Act 1997, section 24. The Poolbeg Planning Scheme is a draft document which has not influenced the zonings in the Draft Plan. The land extension into the River Liffey at North Wall Quay (northern camp shire) is a zoning in the DDDA Master Plan 2008 and has been transposed into the Draft Plan so the zoning would be consistent with the Master Plan, to accord with the DDDA Act 1997. A local authority cannot grant planning permission for a development which materially contravenes its own Development Plan (except, of course, by a particular procedure (under Section 34(6) of the Planning Act, 2000), following a vote of the elected members of the local authority). The development plan must be read subject to the terms of section 34(6) and there is no suggestion that the power under this subsection is being ousted. Manager's Recommendation Retain as existing.

Section: 15.3 Proposed Policy Approach

Summary of Issues The issues are concerned with the relaxation of criteria to zoning objectives and the lack of clarity on the policy approach to former institutional lands.

It is submitted that the Draft Plan has relaxed the land use criteria attached to almost all zoning objectives. The submission contends that the Draft Plan has relaxed the land use criteria in relation to employment land where mixed use is open for consideration in respect of all sites. This represents a threat to employment land. It is recommended that a thorough review of employment land is undertaken to enable the identification of strategic land reserves suitable for Foreign Direct Investment for instance, high density employment activity and mixed use.

It is submitted that in the policy approach to resource lands, that all existing Z12 zonings will be changed to either Z15 or Z10B. However, it is noted that, despite the text, not all Z12 lands within the plan area have been re zoned to Z10B and the Z12 zoning objective is retained at Chapter 15 (Land Use Zoning) of the Draft Dublin City Council Plan. Clarification is sought from the City Council as to whether they intend to retain the Z12 zoning objective or to rezone all lands currently zoned Z12 to Z10B. Manager's Response Employment land is mainly zoned Z6 where the objective remains „To provide for the creation and protection of enterprise and facilitate opportunities for employment creation‟. There is a range of uses open for consideration but they are subsidiary to the main employment generating uses and must be in accordance with the land use objective. The Z6 lands are identified as the main land reserves for employment use and the policy of the City Council is „to promote and facilitate foreign direct investment into the City by working with the IDA and other agencies, and having regard to the needs of international investment.‟ (Policy RE6).

The intention in preparing the Draft Plan was to identify resource lands, either Z12 or Z15 as ones providing a range of community, educational and institutional uses and zone them Z15. While land not involved in such uses should be rezoned to either Z10B if located in the outer city or another appropriate zoning. The published Draft Plan retained both Z10B and Z12 zonings which could be confusing as both zonings are alike. To provide clarity, it is recommended that Zoning Z12 is retained with new wording which promotes these lands as environmental amenity lands and, that zoning Z10B is removed from the Development Plan. The wording of the section 15.10.13 is set out below in the Recommendation. Manager's Recommendation Replace section 15.10.13 with new wording.  Omit all text in Section 15.10.11 – Zone Z10B from the Draft Plan as per 15.10.11 and 15.10.13 below. Section: 15.4 Permissible and Non Permissible Uses

Summary of Issues All reference to Embassy office and Live work units should be omitted from the Plan. Remove all references to embassy residential and embassy office from the Plan and leave only the definition of office use in Appendix 27. There should be clarity about the definition of uses. Medical consultancy definition and standards do not allow for demand for such uses around the Mater. All zoning categories should permit use for food production where food is for local sale and/or consumption to max area of 1ha. Head shops should require specific planning permission for change of use. Sex shops should require specific planning permission. Manager's Response As a general rule uses are listed in the development plan so the development of such uses are regulated and managed through the DM process. To remove uses entirely from the Development Plan would be to ignore their existence and fail to provide planning guidance which would be contrary to the proper planning and sustainable development of the City. There appears to be ambiguity about separating embassy use into embassy residential and embassy office. The main reason for this differentiation is to recognise that the traditional residential embassy with ancillary offices has become primarily a consular office use. Therefore, the embassy office use recognises this change in the nature of embassies. The uses are defined in Appendix 27 of the Plan and there is also a glossary of terms which clarifies definitions. The guidelines on medical and related consultants are set out in section 17.14 and have been expanded to allow for clinics and stand alone medical centres in appropriate locations. Buildings for the health, safety or Welfare of the public are permitted in most zones and includes in its definition clinic or for the provision of any medical or health services.

Domestic food production, such as allotments, is permitted under the definition of open space and open space is a permitted use in all zones.

Head shops and sex shops are included in the definition of a shop which means in effect that shops changing their use to either one do not have to apply for planning permission. Until there is a change to the national planning regulations, Planning Authorities cannot require specific Planning permission for such change of uses. Manager's Recommendation Retain as existing.

Section: 15.7 Relaxation of Zoning Objectives for Protected Structures

Summary of Issues Section 15.7 - Relaxing of zoning standards for protected structures. Not strong enough to protect Protected Structures. Too vague. 'certain cases' lacks definition and will come to mean 'all' Section 15.7 should read "DCC actively encourages uses, which are compatible with the character of protected structures". Request to remove the rest of the paragraph. Manager's Response This standard has been used sparingly and judiciously in limited circumstances and has been a very useful tool and is a long established principle in previous City Development Plans. It is considered that the continuation of this standard is required. Manager's Recommendation Retain as existing.

Section: 15.10.1 Sustainable Residential Neighbourhoods - Zone Z1

Summary of Issues The issues query the compatibility of uses with the zoning objective and whether there is any need for further residential zoning of land.

The submissions queried a number of uses in this zone as being incompatible with the objective to protect residential amenities, in particular any office use. It is requested that the following uses are removed/ omitted from the open for consideration category, that is, 'Embassy office' live-work units, Part off licence, and pigeon lofts.

As the size of a neighbourhood shop is very large and defined as between 1,000sq.m to 2,500sq.m in Appendix 27 (Land use definitions), then it should be removed entirely from the permissible or open for consideration uses in zoning Z1 and replaced with Shop (Local) which would be compatible with the zoning objective.

Insert after education – „Excluding night-time uses‟.

Media recording and general media associated uses are open for consideration in Z1 areas, but the use needs to be more clearly defined precisely.

Zoning for residential purposes should only be to meet needs, given the current climate of over supply, the future needs of the city for residential units needs to be revisited. Manager's Response Some of the listed uses well established uses in residential areas, such as, part off- licenses in the local shop and pigeon lofts. It is considered reasonable for them to remain in the open for consideration category. It should be noted that there are strict criteria for considering applications for Part off licences set out in Section 17. 29 of the standards chapter which ensures the protection of residential amenities.

Live work units should remain in the open for consideration category as the use provides for residential and employment uses at a scale compatible with residential areas and maintains the day to day living environment which is also compatible with residential areas.

Embassy office should remain as open for consideration in Z1 areas.

The size of a neighbourhood shop is in accordance with the Regional Retail Guidelines. It is noted, however, that the size is large and therefore, it should be removed from the permissible category in Z1 zoning as it is suited to Neighbourhood Centres (Z3) and above. Local Shop should be the permissible use in Z1 zoning which is defined as a unit with a size of 500- 1,500 sq.m. of letable space.

In education, the issue of night-time use will be addressed through the DM process when the individual circumstances of each case are assessed.

Media recording and general media associated uses are sectors involved in recording of film, video, music, journalism, etc., often using IT digital processes. The main criteria in assessing such proposals in residential areas are whether such uses would protect residential amenities is now included in the Glossary.

The amount of zoned land for residential purposes is determined by the Greater Dublin Regional Planning Guidelines and the Draft Development Plan is consistent with the housing and population targets set out in the Guidelines.

The DoEHLG advises that LAs should retain 50% 'headroom' of residential zoned lands over and above the 6 year supply. Manager's Recommendation Omit Neighbourhood Shop from the permissible category and insert Local Shop in the permissible category.

Section: 15.10.2 Residential Neighbourhoods (Conservation Areas) - Zone Z2

Summary of Issues The submissions centre on concerns about uses in this zoning, and request that Embassy Office and Live work units should not be either permissible or open for consideration in. It is requested that bed & breakfast, community facility and education uses should be removed from the open for consideration category. Manager's Response It is considered that the primary aim of the Z2 zoning is to protect and improve the amenities of these conservation areas, especially the attractive quality of architectural design and scale, that is the built environment rather than uses. It should not be the intention to deprive these areas of facilities such as community centres or schools, many of which already exist in these areas. In any new developments, particular regard would be paid to the scale and architectural quality so the amenities are maintained. Bed and breakfast replaced guest house as a guest house is a more intensive form of development.

Live-work units are a new use in Z2 but there is specific guidance about appropriate scale, discreet signage and a specific consideration that it must not detract from the physical character and fabric of the streetscape, which is considered reasonable.

Embassy office should should remain in the open for consideration category. Manager's Recommendation Retain as existing.

Section: 15.10.4 District Centres - Zone Z4

Summary of Issues It is submitted that the Draft Plan should provide for more flexibility in the assessment of proposals, which may exceed c, 2,000 sqm of office floor space, dependent on the type of office floors space being provided and how it will integrate with the mix of uses proposed in the overall development of the Z4 lands.

It is requested that there is a relaxation in the floor space limitation for offices in Zone Z4 located in the Inner City by either, the inclusion of an additional footnote which would state as follows: - 'Floor area limitations for office use shall not apply in the case of Inner City Sites‟ or by changing the wording in the listing of office use in the permissible and open for consideration categories use category, as follows: - 'office' (max 600 sqm. / max 2,000 sqm. Excluding Inner City).

List Adult sex shops as not permissible in Z4. Manager's Response The essential purpose of District Centres is to provide a range of higher order facilities to serve an entire district. Such facilities include shops, offices, schools, libraries, restaurants, theatres, health facilities and offices. District centres should be animated areas with both daytime and night-time uses. In all District Centres the office floor area limitation in the „open for consideration‟ category has been increased to 2,000 sqm in the Draft Plan and the centres with development opportunities, identified as Key District Centres, have no limitations on office floor areas.

In such cases it would be more appropriate to change the zoning rather than raise the office floor area limitation across the entire Z4 zoned areas of the city leading to an over supply of floor area.

Adult sex shops are not listed as there is no differentiation between a shop and adult sex shop in the legislation. The policy In the current Development Plan has been incorporated into the Draft Development Plan as RD9 (Retail Chapter). Manager's Recommendation Retain as existing.

Section: 15.10.5 City Centre - Zone Z5

Summary of Issues The issues raised are that helipads should be considered a permissible use and that the entire City Centre Business District should be zoned Z5 apart from the Georgian squares.

It is submitted that Helipads be added as to list of permissible uses.

The current zoning of the CBD in Dublin and in particular the prime Dublin 2 office areas is a mixture of various types of zonings. It is submitted that this entire area apart from the Georgian squares should be zoned Z5. Manager's Response It would be inconsistent with the proper planning or sustainable development of the City Centre to list helipads as a permissible use, as it is already a congested area. Also, there are issues of noise, light intrusion and safety.

The character of the City Centre, especially Dublin 2, is multi- layered with significant areas of Georgian Conservation areas. There needs to be a balanced approach to the redevelopment of the area between encouraging growth and conserving the heritage of the area which is recognised in the various zones between, Z5 – City Centre, Z6 – Employment Enterprise and Z8 – Georgian Conservation areas. Manager's Recommendation Retain as existing.

Section: 15.10.6 Employment/Enterprise Zones - Zone Z6

Summary of Issues The issues are concerned with the range of retail use and to allow office use as permissible in the City Centre. One submission argues in favour of continuing to allow flexibility of uses on Z6 land while another wants maximum ratios of subsidiary uses specified. There is a concern that green clean industries could be general heavy industry, for example the manufacture of wind turbines, which could adversely affect amenities by reason of noise, smells etc., and, therefore, light industry should be specified as the permissible use.

Broaden definition of permissible retail uses.

Office should be included as a use which is permissible in principle under the Z6 zoning objective through the inclusion of "office (Inner City)" with the list of permissible uses while retaining office use as an open for consideration use within the outer city context. It is submitted further that lands within the city centre zoned Z6 must be specifically identified for major intensification of office based employment. ~ Requests that Para 15.10.6 include reference to Site Coverage of 80-100% for Inner City. Manager's Response The primary aim for Z6 lands is to provide employment; although a range of subsidiary uses are permitted which includes a neighbourhood shop which could be to a floor area of 2,500sq.m. which is considered reasonable.

Office is an open for consideration use in recognition that Z6 zones are primarily light industrial/ office based industry / employment zones and that office development would be primarily located in the Key District Centres, City Centre (Z5), Inner Suburban Mix-use areas (Z10A) and Strategic Development and Regeneration Areas (Z14). However, it remains open for consideration which allows an assessment of a specific proposal in the context of its City Centre location.

Site coverage for Z6 zones is addressed in section 17.5 of the Draft Plan.

With regard to the ratio of other uses to the employment based use, the Draft Plan provides clear guidance that such uses must be subsidiary to the main employment generating uses and shall not conflict with the primary zoning objective of Z6 zones or the viability of nearby District Centres, which is considered reasonable.

The concern that green clean industries could fall into the general industry category and cause „bad neighbour‟ problems is a valid planning concern, therefore the permissible use should specify that light industry is intended. (See Glossary also) Manager's Recommendation Amend Permissible Uses

From Permissible Uses ATM, Betting Office, Car park, Childcare facility, Conference centre, Cultural/recreational building and uses, Embassy office, Enterprise centre, Green/Clean industries, Hotel, Industry (light), Live work units, Open space, Park and ride facility, Public service installation, Restaurant, Science and technology-based industry, Shop (neighbourhood), Training centre.

To Permissible Uses ATM, Betting Office, Car park, Childcare facility, Conference centre, Cultural/recreational building and uses, Embassy office, Enterprise centre, Green/Clean light industries, Hotel, Industry (light), Live work units, Open space, Park and ride facility, Public service installation, Restaurant, Science and technology-based industry, Shop (neighbourhood), Training centre.

Section: 15.10.7 Employment (Industry) - Zone Z7

Summary of Issues The main issue is concern about the importance of the port and it is contended that Dublin must keep its port. The following to be included in the draft plan: The industrial zoning Z7 (all which is in the vicinity of the Port) should be amended to include in 'normally permissible' the words 'and port-related use‟. Submits that there is also a scarcity of Z7 in Dublin and that as Ireland moves to a more sustainable economy we are likely to need more Z7, as we will be less reliant on countries like China for our industrial needs.

Welcomes recognition that many of the uses are incompatible with residential. Manager's Response The Development Plan recognises that a large proportion of Z7 lands are occupied by Dublin Port and in the Draft Plan, in zoning objective Z7 „Port-related industries and facilities‟ is listed in the permissible use category already. There is sufficient Z7 lands and Z6 - Employment/Enterprise- lands to provide for sustainable economic development. Manager's Recommendation Retain as existing.

Section: 15.10.8 Georgian Conservation Areas - Zone Z8

Summary of Issues It is submitted that the ratio of residential should be reduced to 20-40% or removed altogether to encourage the reuse and renovation of Georgian buildings as the current ratio acts as a disincentive to practical use.

While the relaxation of the ratio is welcomed for new build and redevelopment of non Georgian buildings, there is a request that the requirement for residential is removed entirely or a more definitive statement is made about this guideline. It is also submitted that the relaxation of the residential ratio will encourage new build on Georgian plots.

The National Maternity Hospital (Holles St.) considers the Z8 zoning needs to be more flexible to include an appropriate balance of mix use and there should be no limit on offices and housing use.

The category of uses permitted in principle should include retail, as there is the potential to create new pedestrian spaces and routes which require active frontages. Therefore, it is requested that 'Restaurant' and 'Shop (Neighbourhood) be included in the permissible uses under the Z8 Zoning Objective, or at least in the open for consideration category to afford the council flexibility to permit retail in appropriate but limited redevelopment schemes. Manager's Response With regard to office use in conservation areas (Z8), the 40% is considered to be the maximum office content that should be permitted in order to promote the reuse of such buildings for residential use and enhance the vitality of these areas in the evening and night time.

The Draft Plan recognises that there are a number of 1960‟s and 1970‟s office blocks which are not Georgian and allows the relaxation of the limit on office use as long as any modern infill development is sensitive to the historic fabric and respects both the surroundings and the skyline. This is a reasonable approach.

The range of permissible uses is consistent with the conservation zoning objective. Restaurant use is open for consideration. Retail is neither permissible nor open for consideration as the provision of shop fronts and signage would be highly intrusive on the architectural character of both Georgian buildings and the character of the areas.

In the case of new build or redevelopment of buildings which are not Georgian, and where the existing and established use is wholly office, the 40% limit on the proportion of office use (excluding retail, bank, building society) need not apply provided the building contributes to the enhancement of the existing architecture and civic design character. Manager's Recommendation Retain as existing.

Section: 15.10.9 Amenity / Open Space Lands / Green Network - Zone Z9

Summary of Issues The issues concern the preserving of open space lands and that advertising should be included as an open for consideration use recognising the commercial nature of large sports grounds (e.g. Lansdowne / Aviva Stadium). Manager's Response The Development Plan recognises the importance of amenity open space, as there is an emphasis on green infrastructure and creation of a green network.

Advertising and advertising signs are not appropriate in Z9 zones which are designated amenity open space lands. Appropriate locations for advertising are commercial areas such as the District Centres and the City Centre. Manager's Recommendation Retain as existing.

Section: 15.10.10 Inner Suburban (Sustainable Mix-Use) - Zone Z10A Summary of Issues The issues raised request the deletion of the requirement for 10% public open space on Z10A lands and that the site coverage is increased to 75%. Manager's Response Public open space is required for development proposals in all land use zones in the City, as part of the policy approach to develop the green network, enhance bio- diversity and provide public open space. Site coverage is addressed in section 17.5 of the Development Plan and ranges from 45% to 90% depending on the zoning. As Z10B is recommended to be deleted, the title of this zone be changed to read Z10. Manager's Recommendation Amend title of zone From Z10A

To Z10

Section: 15.10.11 Outer Suburban (Sustainable Mix-Use) - Zone Z10B

Summary of Issues The issues are concerned about the amount of, and guidelines on the required open space and that future development should be sympathetic to the use history and maintenance of natural vegetation/ trees. Some submissions request that the open space requirement is increased to 50%. Others request that it is less than the required 20% of site area, as it limits layout options and it may not be possible to have publicly accessible open space. There should be a proviso that the requirement for open space need not apply where the footprint of building exceeds 50%, as with Z15. Future development of these sites needs to be highly sympathetic to the previous use of the site. In particular the removal of natural vegetation/ trees should be discouraged. Manager's Response A primary objective of Zone 10B is to ensure the existing environmental amenities are protected in any development, and therefore, there is a requirement for 20% public open space rather than 10% as in most other zones. 50% public open space is considered excessive, especially considering the DoEHLG Guidelines on Sustainable Residential Development in Urban Areas, May 2009, which advise a minimum of 20% on such lands. Given the character of these sites due to the former institutional use, the sites are of a reasonable size to provide the 20 % public open space without compromising layout options. This approach is now incorporated into Z12 zoning objective (see below). Manager's Recommendation Omit Z10B as a zone and incorporate into Z12.

Section: 15.10.13 Institutional Land (Future Development Potential) - Zone Z12 Summary of Issues Submissions request the reinstatement of the Z12 objective from the 2005 Plan, not only because it provides amenity lands but also because it facilitates the future redevelopment of existing institutional land when the land is surplus to requirements; the title should be changed to 'former and existing institutional lands' to reflect this intention.

Other submissions request that the zoning Z12 should be dropped and all lands currently included as Z12 and Z15 in the draft development plan should be included in Z15 and recognised as "Resource Lands". Manager's Response In reviewing the Z12 and Z15 lands, the intention was to emphasis the importance of Z15 lands as an important resource for the City in achieving a compact sustainable City with a full range of community infrastructure, such as, schools, hospitals and open space. Therefore, in the review of all these lands, the criteria applied was that if land was in use as institutional, community, educational, then it either remained Z15 or, if not zoned currently, was rezoned to zone Z15. If, however, it was no longer in institutional, then it was rezoned to Z10B or Z12, or other proposed zoning objective which reflected it current primary use; this rigorous approach is entirely reasonable. Also, the Z10B zoning maintained the objective to protect the open space amenities of these lands with any development and the requirement is 20% public open space. However, the Plan has both Z10B and Z12 zoning for lands which are no longer in institutional use which is causing confusion and affects the objective to emphasis the importance of Z15 lands. It is recommended that the Z12 zoning is retained in section 15.10.13 with additional guidelines and amended wording to incorporate elements of Z10B, as set out below and in the response to the submissions and recommendation in section 15.3. – Policy approach.

It is recommended that zone Z10B should be omitted.

The rationale for addressing Z12 and Z15 zones is explained above and it is considered that rezoning lands to Z15 which are not primarily in some form of community or institutional use would be entirely unreasonable. Manager's Recommendation Omit all text in Section 15.10.11 – Zone Z10B from the Draft Plan.

Insert new text in section 15.10.13 as follows:

15.10.13 Outer City – (Sustainable Mix-Use, Green Network and Environmental Amenity) – Zone Z12

Land Use Zoning Objective Z12:

To ensure the existing environmental amenities are protected in the development of these lands located in suburban areas.

These are lands located outside the city centre in primarily suburban locations. Some of the lands were previously in institutional use which have closed down and/ or moved to other locations. Many of the lands are characterised by an open mature landscape which should be retained in the use and/or future development of these lands. The important element of the Core Strategy is to foster sustainable neighbourhoods which support thriving communities. Accordingly, the main objective on these lands is to achieve a variety of uses – residential, employment, neighbourhood retail and community uses while maintaining any existing open space character. The balance between these uses will differ depending on the character and location of the lands in relation to existing District Centres and public transport. Also, proposals should have regard to the range of supporting community infrastructure in the area (see section 12.4.6).

If there are proposals for development, these lands provide the opportunity to develop sustainable mix use and provide green infrastructure, landscape protection, public open space, and sustainable energy solutions. With any development, the City Council will require the preparation and submission of a Schematic Master plan for the entire site setting out a clear vision.

Where lands zoned Z12 are to be developed, a minimum of 20% of the site, incorporating landscape features and the essential open character of the site, will be required to be retained as accessible public open space, having regard to the policies and objectives set out in chapter 6 to progress the implementation of a green infrastructure network which fosters linkages and permeability throughout the City.

In considering any proposal for development on lands subject to zoning objective Z12, the master plan shall set out a clear vision for the future development of the entire land holding. In particular, the master plan will need to identify the strategy for the provision of the 20% public open space requirements associated with any development, to ensure a co-ordinated approach to the creation of high quality new public open space on these lands linked to the green network.

And, for the avoidance of doubt, as required by part V of the Planning Act 2000, at least 20% social and affordable housing requirement, as set out in the Housing Strategy in this Plan, will apply in the development of these lands for residential and residential with other uses.

Zoning Objective Z12:

Permissible Uses ATM, Bed and breakfast, Buildings for the health, safety and welfare of the public, Caravan park/Camp site (holiday), Childcare facility, Community facility, Conference centre, Cultural/recreational building and uses, Education, Embassy residential, Enterprise centre, Garden centre, Golf course and clubhouse, Guest house, Halting site, Home based economic activity, Hostel, Hotel, Live-work units, Media recording and general media-associated uses, Medical and related consultants, Open space, Place of public worship, Public service installation, Residential institution, Residential, Restaurant, Science and technology-based industry, Training centre.

Open for Consideration Uses Boarding kennel, Car park, Civic and amenity/recycling centre, Funeral home, Industry (light), Municipal Golf Course, Nightclub, Office, Outdoor poster advertising, Part off- licence, Shop (neighbourhood).

Section: 15.10.14 Strategic Development and Regeneration Areas - Zone Z14

Summary of Issues Some submissions request that education and health are added to the land use objective, as follows: "the social, economic and physical development and/or regeneration of an area with mixed use, of which residential, Z6, education and health would be predominant uses"

Others request a new policy „that all new developments on Z14 lands at Poolbeg, take account of and do not undermine the long term operational requirements of existing utilities, including existing power station‟.

Further submissions request that a new sentence to be added to Section 15.10.14 (third paragraph) to the effect that "It should also be noted that a residential element is not specifically required to form part of development proposal on Z14 lands."

That District Centre be permissible in Z14 or at least in Z14 lands that are identified as Developing Areas.

Others request that all uses permissible or open for consideration within the Z3 Neighbourhood Centres are open for consideration within the commercial nodes of Z14 lands. Manager's Response The Z14 regeneration areas are intended for comprehensive development and each area has a number of guiding principles set out in Chapter 16 of the Development Plan. Education and health are considered part of the social development objective which is underlined by paragraph three of section 15.10.14 where developments must include proposals for additional social infrastructure/facilities. For example, specific guiding principles for Grangegorman include education and health.

Planning applications for development are assessed in the context of the location and existing properties. In Poolbeg, the existing utilities would be considered during the planning application process as well as any submissions made during the consultation period.

Residential use is considered an important part of comprehensive development as indicated in the guiding principles for every area, as such, residential is specifically required.

These comprehensive development areas are not intended to detract from hierarchy of retail centres, that is, the City Centre shopping area, District Centres or the designated Key District Centres. Therefore, district shops are permissible in Z4 and Z5 zones or designated KDCs only, which is reasonable approach. The North Fringe and Naas Road are Key District Centres.

The referred section is in Appendix 4, Retail Strategy addressing District Centres – Developing Areas and Figure 17; two of the listed areas (Pelletstown and Cherry orchard/ Park west) are not District Centres or KDCs, where District shops are neither permissible nor open for consideration. Their inclusion, however, in this part of Appendix 4 does not accord with the zoning and should be amended as recommended below.

There is a far wider range of uses both permissible and open for consideration in Z14 than within Z3 Neighbourhood Centres. The only uses in Z3 that are missing from Z14 are Household Fuel Depot, Internet Cafe and Takeaway. Manager's Recommendation Note the second recommendation concerns Appendix 4 and Figure 17 – Retail

Insert Internet Café and Takeaway into the open for consideration category in Z14 zone Amend Text, last paragraph of section on District Centres & Key Developing Areas P. 282 From: The main growth or developing areas for the lifetime of this development plan are set out below and are also identified as Key Developing Areas in the Core Strategy.  North Fringe Pelletstown Cherryorchard / Parkwest Naas Road Docklands

To: The main growth or developing areas for the lifetime of this development plan are identified as Key Developing Areas in the Core Strategy. A number of these include Key District Centres such as North Fringe, Ballymun and the Naas Road and District Centres, such as the Point Village in Docklands.

Section: 15.10.15 Resource Lands (Education, Recreation, Community and Health) - Zone Z15

Summary of Issues The issues are concerned about whether there was evidential research undertaken in reviewing Z15 lands, the undue restrictive nature and intention of the Z15 zone on the landowners property rights, the undue restrictions on other development, while others consider there should be further restrictions, such as, residential use, the apparent bias against particular owners on religious grounds, the ambiguity about development being confined to a change of use, restricting the Planning Authority‟s discretion to grant permission in material contravention of section 34(6), an apparent additional onus to provide social and affordable housing beyond the requirements of part V of the Planning Act 2000, that the schematic master plan is prepared by Dublin City Council Planners, the requirement of 25% public open space which in some submissions is considered too little and should be increased to 50% while others view it as unfair and inconsistent with national guidelines, that Z4 type use should be allowed on Z15 lands adjoining District Centres (Z4), further restriction should be included in Z15 zones in conservation areas, that Z15 lands should be required to retain lands for expansion (unless demonstrated as unnecessary) and this should be a priority in facilitating development on these lands. Some submissions request clarification about the guidelines, such as, that the 25% public open space would not apply to extensions to existing use, that residential development is considered acceptable over the entire site provided that the criteria a) and b) are met in relation to the schematic master plan and the provision of open space, and that the 25% public open space requirement applies only to the portion of the land being redeveloped. The summary is as follows.

It is submitted that most lands in institutional use are now zoned Z15. There is no quantification, or other assessment, in the Development Plan of the need for such extensive lands for such purposes.

It is also submitted that the Z15 zoning is extremely restrictive and the category of zoning as „Resource‟ lands is unclear and not identified in the legislation. The Z15 landowners are confined to continuing their current use so long as the community has a need for the institution. Landowners cannot be compelled to continue with moribund or under-utilised services or to transfer under-utilised lands for expansion of services. It is submitted that among private landowners, the Z15 zoning is applied almost exclusively to religious organisations as the land has been selected in an arbitrary, irrational and fundamentally unfair manner.

It is contested that paragraph 4 of section 15.10.15 “With any development proposal on these lands, consideration for change of use will only be given if the current institutional uses e.g. schools, are no longer needed by the community for the foreseeable future” implies that the zoning designation only contemplates change of use of buildings or land and not any other development. This is a particularly unacceptable and bizarre provision of the zoning.

It is submitted that paragraph 10 of Section 15.10.15, the 20 per cent social and affordable housing requirement applicable to Z15 is an additional scheme of social and affordable housing to any development of the land which is an extra requirement separate from the social and affordable housing requirement under Part V of the Planning Act.

It is requested that the City Council should prepare the schematic master plan and a line should be inserted at the end of Paragraph 7 as follows: „The schematic masterplan to be carried out by DCC at the expense of the client and to be agreed by the relevant local area committee.‟

It is submitted that the proposed minimum of 25% of the site area should be devoted to public open space in the event of development on Z15 lands is punitive as for all other developments there is a minimum of 20 per cent. The requirement for min. 25% public open space is in excess of the recommendation of national planning guidance. Also, it is submitted that the provision of public open space should be increased to 50%.

It is requested that residential is removed from the open for consideration category, on the grounds that commercial residential development is not compatible with the stated objectives of the zoning designation, while another submission requests residential is made a permissible use.

It is submitted that where Z15 lands are located at transitional zones beside Z4, then consideration should be given to permitting shopping and other district centre uses on a portion of the Z15 lands.

It is submitted that Z15 lands in conservation areas require a more restrictive objective and that the objective would serve to maintain such areas in their existing institutional or community use or as open spaces for the community at large exclusively.

Greater clarity as to meaning of provision of 25% of site for accessible public open space is requested – it should be made clear that 25% refers to all lands for which a schematic plan has been prepared and includes lands retained as institutional.

In development of or extensions to existing institutions, such as hospitals, it is requested that the Plan should clarify that the requirements for a master plan and 25% public open space would not apply.

On the one hand, it is submitted that there should be a provision for Z15 lands that the institution should be required to retain land for expansion and that this should have priority in terms of facilitating development on these lands, while another submission requests that the paragraph “With any development proposal on these lands, consideration for change of use will only be given if the current institutional uses e.g. schools, are no longer needed by the community for the foreseeable future” should be omitted, as it could potentially allow for a situation whereby a proposed development that would benefit both the institutional landowners and the local community could be unreasonably obstructed by a minority of the local community or local representatives.

It is requested that the Plan clarifies that residential development on Institutional lands will be acceptable over the entire institutional landholding, provided that the criteria set out under the open for sonsideration paragraphs (a) and (b) are met.

In addition, the Plan must clarify that the 25% open space requirement applies only to that portion of land being redeveloped for „open for consideration uses' and that does not apply to development for „permitted uses‟ under this zoning objective. Manager's Response Background work on the preparation of the Draft Development Plan revealed that there are some 177 identified sites consisting of some 734 hectares zoned Z15. There are a number of community based uses, such as, schools, convents / churches, colleges, hospitals, care homes and universities. In terms of need, the Draft Regional Planning Guidelines (RPG) give population and housing targets that must be facilitated in the Development Plan. On the basis of these targets and trends for an increase in the proportion of older people and children, there will be a continued need for resource lands in the city. In the provision of services, the Draft Regional Planning Guidelines (RPG) advise that such facilities should be easily accessible for both residents, patients, staff and visitors from the surrounding community and not be isolated in terms of location except where particular circumstances require it.

The category 'Resource Lands' is a broad objective which should be clarified by referring to community and institutional uses in its title.

A development plan can include an objective reserving land for a particular class of use. The intention, as set out in paragraph 3 of section 15.10.15, is to emphasise Z15 lands as an important resource to the City in the achievement of a compact sustainable city with a full range of community infrastructure. As such the range of uses on these lands must be tailored to meet the needs of the zoning objective. It is noted that the paragraph may have been misinterpreted and, therefore, it is recommended that Paragraph 3 is reworded to clarify the intention for Z15 lands.

The suggestion, that landowners are confined to continuing their existing use so long as there is a continuing need in the community is not accurate. Clearly, the development plan cannot force any landowner to continue with any use such as school if it closes down. The Z15 zoning, however, restricts the alteration to other uses if there is a community need for the existing use. It is perfectly in accord with proper planning and development that the Development Plan seek to retain these uses as close to the communities they serve rather than relocating to more remote areas. The onus is on the landowner to demonstrate that there is no longer the need for such uses.

In the review of the Z12 and Z15 lands, the only consideration was to identify the primary use of the land, and not the owner. Therefore, the zoning objective reflects the use of the land. In reviewing the zoning objectives Z12 and Z15, the criteria applied was that if land was in use as institutional, community, educational, health, then it either remained Z15 or was rezoned from Z12 to Z15, and if it was no longer in institutional use, then it was rezoned to Z10B or Z12, or to another zoning objective which reflected it current primary use. The fact that the Z15 zoning comprises a more focused approach than the previous Development Plan, does not amount to any more than a fine tuning of a well established and accepted approach to the zoning considerations applicable to possible residential development on lands currently under institutional use.

Paragraph 4 of 15.10.15, is intended to apply to development which includes works and changes of use. It is noted, however, that the sentence appears to have been misinterpreted and therefore, it is recommended that it should be altered for clarity.

Paragraph 10 of 15.10.15 refers only the provisions of Part V as reflected in the Housing Strategy. However, the paragraph should be amended to clarify that Part V relates to residential development or where mixed to the residential portion only.

All masterplans will be prepared through the DM process. The City Council will encourage landowners to consult the local community and area committee in the development of the masterplans prior to making a planning application.

Given the national guidelines (Guidelines for Planning Authorities on Sustainable Residential Communities, 2009), the request for an increase in public open space provision to 50% is considered unreasonable. The national guidelines specify a minimum standard of 20% public open space. As the priority of the core strategy is to re-enforce the importance of green infrastructure and create a compact sustainable City, then it is considered reasonable to require 25% public open space in the Draft Development Plan. It should be noted that this requirement is the same as the current City Development Plan 2005-2011.

The provisions for Z15 lands and the clear principles for redevelopment are reasonable, balanced and based on the planning policies in the Draft Plan. Residential development under the criteria set out in section 15.10.15 would be compatible with these criteria.

The range of uses for Z15 lands is considered reasonable and should not be expanded to permit retail use associated with District Centres.

Where Z15 lands are in a conservation area, the policies in Chapter 7 – Fostering Dublin‟s character and culture - and criteria for conservation areas as set out in Section 17.10.6 apply which gives additional protection to these areas.

It is not intended that the requirements for 25% public open space or the preparation of a schematic master plan would apply to development directly related to extensions to the existing community and institutional use which would enhance the facilities. However, where there are large sites and the proposal is to undertake a substantial redevelopment and changes in the layout of the existing use, then it would be reasonable to require a schematic master plan.

A schematic masterplan must be prepared for the entire landholding setting out a clear vision for its future development, including the strategy for the provision of public open space and it must incorporate landscape features and the essential open character of the site. As such, it will depend on the master plan and the landscape features of the site, as to where the 25% public open space is to be located, that is, whether it is only on the portion being developed or partly on the remaining lands.

All development, except where it is directly related to the existing community and institutional uses, requires the provision of 25% public open space.

In the interests of consistency between Z12 and Z15, it is considered that hte Z15 zoning objective should also include a "Funeral Home" as an open for consideration use. Manager's Recommendation Replace all text at existing Section 15.10.15 with the following:

15.10.15 Community and Institutional Resource Lands (Education, Recreation, Community, Green Infrastructure and Health) - Zone Z15

These are areas which are zoned for educational, recreational community and health uses and for existing uses which are unlikely to change in the future.

The present uses on the land generally include community realted development including schools and colleges, residential healthcare institutions, e.g. hospitals, prisons.

These lands are an important resource for the City in the achievement of a compact sustainable city with a full range of community infrastructure such as, schools, hospitals and open space, essential for the creation of vibrant neighbourhoods and a sustainable well-connected City.

With any development proposal on these lands, consideration should be given to their potential to contribute to the development of a strategic green network.

In the event that it is demonstrated to the planning authority that the lands are not required for current or future community and institutional uses and that the lands zoned Z15 are to be comprehensively redeveloped, then a masterplan in accordance with the requirements set out below will be required (See Masterplan Requirements Below).

A masterplan is not required in the case of minor developments associated with the existing use; where the development proposed relates to extensions to the existing community and institutional use and would enhance the facilities; or in the very limited circumstances as described below.

In very limited circumstances, where it has been demonstrated to the planning authority that, in order to secure, protect and consolidate the institutional, educational, recreational, community, green infrastructure and health uses and retain the facility in the local area, some limited degree of development may be permissible on a once off basis and subject to the primary use of the site being retained for institutional, educational, recreational, community, green infrastructure and health uses.

And, for the avoidance of doubt, at least 20% social and affordable housing requirement, as set out in the Housing Strategy in this Plan, will apply in the development of lands for residential or where mixed the residential portion only‟ subject to the Z15 zoning objective.

Zoning Objective Z15:

Permissible Uses ATM, Buildings for the health, safety and welfare of the public, Childcare facility, Community facility, Cultural/recreational building and uses, Education, Medical and related consultants, Open space, Place of public worship, Public service installation, Residential institution

Open for Consideration Uses Bed and breakfast, Car park ancillary to and subject to the main use remaining as community or institutional, Funeral Home,Guesthouse, Hostel, Hotel, Municipal Golf Course, Residential.

Masterplan Requirements In preparing a masterplan, the following two requirements shall apply: (a) 25% of the site (this open space is in lieu of the requirement for 10-20% public open space provided for in paragraph 17.9.7 above) shall be set aside for accessible public open space and/or community facilities. However, this requirement need not apply if the footprint of the existing buildings exceeds 50% of the total site area of the institutional lands in question;

(b) A Master Plan setting out a clear vision for the entire land holding, including the portion of the site proposed to be set aside for accessible public open space and/or community facilities must be made. In this regard, the Master Plan must incorporate landscape features and retain the essential open character of the site. It must also identify how the requirement for 25% of the site to be set aside for accessible public open space and/or community facilities will be met and it should ensure that the space will be provided in a manner designed to maximise appropriate public use and to protect existing sporting and recreational facilities which are available predominantly for community use. The public open space should contribute to, and create linkages with the strategic green network. Where such facility exists it shall rank for inclusion in the open space requirement.

Section: Other Issues

Summary of Issues It is submitted that there should be a new land use zoning of Major Public Transport Corridors which will allow for greater density of development along these areas, which is welcome as they are destined to become ever more important modes of transport. It would also allow the introduction of a special additional levy on developments along the route which could be used to offset the cost of construction.

It is submitted that the development plan has omitted zoning on infrastructural lands which are indicated on the plans as "white lands". These lands are not designated with any zoning objectives, and are primarily for the provision of road, rail and transport infrastructure. The Plan should take account of the strategic nature of these lands and ascribe a zoning objective to some or all of them. The 19th century rail infrastructure of the city together with the DART and LUAS infrastructure were often facilitated by cuttings below grade. It is suggested that many of these cuttings could where culverted, as is common in Europe, could accommodate additional uses. For example, the rail line from Royal Canal to Phoenix Park could create a new residential Street by connecting old Cabra road and new Cabra road over the rail track. The actual layout of Fatima Mansions is not shown correctly on the maps and there is no outline on the sites which are subject to the zoning change. Manager's Response The potential for an increase in density of development around major transport corridors has been considered and is included in chapter 17 in section 17.5 – Density. In relation to development levies, there is an existing section under the Planning and Development Act 2000 to introduce an additional levy for transport and this has been applied to the Metro North Corridor. Therefore there is no need to introduce a separate zoning. These lands are primarily to show existing road, rail and transport infrastructure. The designation of routes of such infrastructure is determined by and governed through various pieces of legislation and it would be inappropriate to pre- empt such designations in the Development Plan. The base maps are the most up-to-date from the Ordnance Survey which show that layout for Fatima Mansions. The zoning maps illustrate all zonings in the City without differentiation. Manager's Recommendation Retain as existing.

Map: A

Map Reference: A Reference Number: 01 Site Address: TOPAZ - North Road Finglas Submission Number(s): 3140 Summary of Issues Request to rezone North Road, Finglas Service Station from Z6 to Z3. Manager's Response It is not appropriate to rezone this land as the facilities at a petrol station are to provide the sale of fuel with the ancillary, small scale sale of goods which would not be considered to offer, or compete with the range of facilities provided as part of a neighbourhood centre. Recommendation Retain Z6 zoning.

Map Reference: A Reference Number: 02 Site Address: Lidl - Finglas Submission Number(s): 3201 Summary of Issues Request to rezone from Z6 to Z4.

It is requested that the current zoning of the Lidl Finglas Store at the junction of Slaney Road and St. Margaret‟s Road of Z6 should be amended to Z4 Manager's Response The store is located in an operating employment/ enterprise Z6 zone where a neighbourhood shop is open for consideration. The District Centre (Z4), Finglas Village, is at some distance from the store and therefore it would be contrary to the retail hierarchy to rezone the store at this location. Recommendation Retain Z6 zoning Map Reference: A Reference Number: 03 Site Address: No 33-53 North Road Finglas Submission Number(s): 2906, 3072 Summary of Issues Request to rezone from Z9 to Z1.

The submissions concern the land (the lower half of gardens) located between the Finglas River and the rear houses of 33 to 53 North Road. The submissions are requesting that the zoning is changed to Z1, residential which it was previously in the Dublin City Development Plan 1991.

Manager's Response According to the Dublin City Council records the land in question is not owned by the City Council, nor is it the subject of a CPO. The sites are in use as private gardens which are comparatively long. Given that similar lands to the south, fronting on to the Finglas Road slip road have be developed for residential purposes, a Z1 zoning is considered appropriate in this case. Recommendation Amend zoning from Z9 to Z1. Map Reference: A Reference Number: 04 Site Address: Finglas Village Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The submission is made on behalf of the St. Laurence O'Toole Diocesan Trust. The house and associated site area is surplus to church requirements and the submission requests that it is rezoned from Z15 (Resource lands) to zoning objective Z1 (Residential) as it is located in a residential area. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: A Reference Number: 05 Site Address: De la Salle PS - Glasnann Road Finglas Submission Number(s): 3114 Summary of Issues Request to rezone from Z15 to Z12, Z1 or Z10B.

The submission objects to the proposed change from Z12 to Z15 on grounds that the playing fields are no longer used for institutional or recreational purposes, and surrounding area is mainly residential. Manager's Response The Z15 zoning is not a new proposal as the lands are currently zoned Z15 in the existing Development Plan. The former primary school has closed down, however there is a temporary Gaelscoil temporarily occupying the school building which is separated by fencing from the playing field. Given that part of the land remains in educational use it should remain Z15. Any proposed redevelopment would have to meet the criteria for Z15 detailed in section 15.10.15. Recommendation Retain Z15 zoning.

Map Reference: A Reference Number: 06 Site Address: Old Finglas Road - Sisters of Faith (See also B20) Submission Number(s): 2643 Summary of Issues Request to rezone from Z15 to Z10B.

Majority of the site is currently zoned Z15 - Institutional Lands (long-term institutional use) with a number of active uses, such as, schools, playing fields, nursing home, and convent. The rezoning from Z15 to Z10B would provide a planning policy context which is supportive of potential future development on the site in conjunction with the continuation of the institutional uses.

Manager's Response The Sisters of the Holy Faith lands are providing education, health and institutional uses. As the lands are in active institutional use providing services to the community, then it should remain Z15 and any proposed development would have to meet the criteria for Z15 detailed in section 15.10.15.

Recommendation Retain Z15 zoning. Map Reference: A Reference Number: 07 Site Address: Lidl - Glasnevin Submission Number(s): 3201 Summary of Issues Request to rezone from Z6 to Z4.

It is requested that the current zoning of the Lidl Glasnevin Store at Slaney Road of Z6 should be amended to Z4.

Manager's Response The store is located in an operating employment/ enterprise Z6 zone where a neighbourhood shop is open for consideration. The District Centres (Z4), at Finglas Village and Phibsborough are some distance from the store and therefore it would be contrary to the retail hierarchy to rezone the store at this location. Recommendation Retain Z6 zoning.

Map Reference: A Reference Number: 08 Site Address: TOPAZ - Finglas Road Glasnevin (See also E9) Submission Number(s): 3140 Summary of Issues Request to rezone from Z1 to Z3.

Request to rezone Finglas Road, Glasnevin Service Station from Z1 to Z3. Manager's Response It is not appropriate to rezone this land as the facilities at a petrol station are to provide the sale of fuel with the ancillary, small scale sale of goods which would not be considered to offer, or compete with the range of facilities provided as part of a neighbourhood centre. Recommendation Retain Z1 zoning. Map Reference: A Reference Number: 09 Site Address: Bannow Road/Broombridge (See also E3) Submission Number(s): 2231, 2802 Summary of Issues Request to rezone from Z10A back to Z6. Request to retain Z10A.

There are two submissions concerning these sites, one supporting the zoning to Z10A considering its proximity to Broombridge rail station and the under utilisation of an urban site, and the other submission opposing the rezoning considering the downturn in the market. Manager's Response Given its location in an inner suburb, the Z10A is appropriate. The Development Plan is for the period 2011 to 2017 when it is predicted there will be economic growth. Recommendation Retain Z10 zoning.

Map Reference: A Reference Number: 10 Site Address: Dominican Convent - Cabra (See also E2) Submission Number(s): 3119 Summary of Issues Refer to Map E02 Request to rezone from Z15 to Z12 or Z10B.

The submission objects to the extension of the Z15 zoning over the whole site (these are 2 parts of the site zoned Z12 in 2005 - 2011 Plan). Submission proposes the retain the Z12 zoning on these two parts of the site (albeit reduced at Area A on Map because of a recent school extension) or alternatively rezone the lands Z10B Manager's Response Having regard to the proposed draft zoning policy for these lands, it is considered that the parcel of land fronting Ratoath Road be retained as Z15 while the parcel of land fronting Abbey Drive be rezoned for residential purposes as it is surplus to institutional needs, contiguous to Z1 lands, and will not negatively impact on the strategic landbank of Z15 zoned lands. Recommendation Amend zoning of land fronting Abbey Drive from Z15 to Z1. Retain Z15 zoning of land fronting Ratoath Road. Map Reference: A Reference Number: 11 Site Address: St. Helena's Drive Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The house and associated site area is surplus to church requirements and the submission requests that they be rezoned from Z15 to zoning objective Z1 Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning.

Map: B

Map Reference: B Reference Number: 01 Site Address: Sillogue Road Ballymun Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The submission is made on behalf of the St. Laurence O'Toole Diocesan Trust. The house and associated site area is surplus to church requirements and the submission requests that it is rezoned from Z15 (Resource lands) to zoning objective Z1 (Residential) as it is located in a residential area. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: B Reference Number: 02 Site Address: Shangan Road Ballymun Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The submission is made on behalf of the St. Laurence O'Toole Diocesan Trust. The house and associated site area is surplus to church requirements and the submission requests that it is rezoned from Z15 (Resource lands) to zoning objective Z1 (Residential) as it is located in a residential area. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning.

Map Reference: B Reference Number: 03 Site Address: Santry - lands at Submission Number(s): 2234 Summary of Issues Submission supports Z3 zoning. Manager's Response Submission noted & recommend retaining Z3 zoning Recommendation Retain Z3 zoning. Map Reference: B Reference Number: 04 Site Address: Clonshaugh Industrial Estate Submission Number(s): 2917, 2917 Summary of Issues It is requested that a site close to the entrance to Clonshaugh Industrial Estate be identified as a key location for intensification within the Clonshaugh Node.

Manager's Response It is not considered appropriate to identify any particular site in the Clonshaugh Industrial Estate for intensification given the strategic nature of the Development Plan.

Recommendation Retain Z6 zoning. Map Reference: B Reference Number: 05 Site Address: Northside/Clonshaugh - Lands at Submission Number(s): 2118, 2351 Summary of Issues Request to rezone lands north of the river Santry from Z14 to Z4.

Request to rezone lands along Kilmore Road from Z9 to Z4.

Request to amend Key District Centre boundary to include all Z4 lands.

The submission concerns the North Side Shopping Centre which has an approved development. Request the extension of the Z4 zoning and the Key Development Centre (KDC) boundary on Map K to the lands north of the River Santry and changing of the Z9 open space zoning to Z4 District Centre along Kilmore Road. Manager's Response In the Prime Urban Centres (Current Plan), there is a mixture of Z4 (District Centre) and Z14 (comprehensive redevelopment) zonings under the current Plan. In the review of the Development Plan, the adopted approach was to change any Z14 zoning to Z4 in KDC to reflect the range of appropriate uses and confine Z14 zonings to the designated Strategic Development and Redevelopment Areas. In view of this approach and the approved development at the North Side Shopping Centre, the change of the Z14 zoning to Z4 to the site on the north side of the River and extension of the boundary of the KDC to the lands north of the River Santry is considered appropriate. Given the approved development on Kilmore Road and the proposed demolition of the existing apartments, the rezoning from Z9 to Z4 is considered reasonable.

Recommendation Amend zoning of lands north of the river Santry from Z14 to Z4

Amend zoning of lands along Kilmore Road from Z9 to Z4

Amend Key District Centre boundary to include all Z4 lands Map Reference: B Reference Number: 06 Site Address: Priorswood Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The submission is made on behalf of the St. Laurence O'Toole Diocesan Trust. The house and associated site area is surplus to church requirements and the submission requests that it is rezoned from Z15 (Resource lands) to zoning objective Z1 (Residential) as it is located in a residential area. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: B Reference Number: 07 Site Address: Greencastle Road Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The submission is made on behalf of the St. Laurence O'Toole Diocesan Trust. The house and associated site area is surplus to church requirements and the submission requests that it is rezoned from Z15 (Resource lands) to zoning objective Z1 (Residential) as it is located in a residential area. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning.

Map Reference: B Reference Number: 08 Site Address: Chivers Site - Malahide Road Submission Number(s): 3082 Summary of Issues Submission supports the Z6 zoning. Manager's Response Submission noted & recommended that Z6 zoning is retained Recommendation Retain Z6 zoning Map Reference: B Reference Number: 09 Site Address: Tayto Site - Malahide Road Submission Number(s): 3087 Summary of Issues Submission supports the Z6 zoning. Manager's Response Submission noted & recommended that Z6 zoning is retained Recommendation Retain Z6 zoning

Map Reference: B Reference Number: 10 Site Address: St Pauls Ayrfield Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The submission is made on behalf of the St. Laurence O'Toole Diocesan Trust. The car park area located at the Church is surplus to church requirements and the submission requests that it be rezoned from Z15 (Resource lands) to zoning objective Z1 (Residential) as it is located in a residential area. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: B Reference Number: 11 Site Address: St. Joseph's Hospital, Raheny (See also C5) Submission Number(s): 3039 Summary of Issues Request to rezone from Z9 to Z15.

Beaumont Hospital requests a re-zoning of lands from Z9 to Z15 on lands known as St. Joseph's Hospital given that planning permission was granted (5896/07) for a new two- storey 100 bed nursing unit in the south-western side of the site on the portion of land zoned Z9. Manager's Response Request to rezone from Z9 to Z15.

Beaumont Hospital requests a re-zoning of lands from Z9 to Z15 on lands known as St. Joseph's Hospital given that planning permission was granted (5896/07) for a new two- storey 100 bed nursing unit in the south-western side of the site on the portion of land zoned Z9. Recommendation Retain Z9 zoning. Map Reference: B Reference Number: 12 Site Address: Brookwood Artane Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The submission is made on behalf of the St. Laurence O'Toole Diocesan Trust. The car park area located at the Church is surplus to church requirements and the submission requests that it be rezoned from Z15 (Resource lands) to zoning objective Z1 (Residential) as it is located in a residential area. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning.

Map Reference: B Reference Number: 13 Site Address: Sybil Hill Submission Number(s): 2889 Summary of Issues Request to rezone from Z15 to Z1.

The subject site is the former swimming pool site which was owned by owners of St. Paul's College.The order closed the pool in 2006, and sold the site. The proceeds were used to upgrade facilities at the school. The site now lies vacant and is no longer in institutional use. There are two swimming pools in the vicinity and there is an opportunity to re-utilize land which has become redundant by re-zoning the lands to Z1. Manager's Response It is recommended that the site be rezoned to Z1 to consolidate residential uses in the area. Recommendation Amend zoning from Z15 to Z1. Map Reference: B Reference Number: 14 Site Address: 193-195 Howth Road Submission Number(s): 3086 Summary of Issues Request to rezone from Z1 to Z4.

Submission relates to lands at 193-195 Howth Rd, Dublin 3 seeks to rezone site from Z1 to Z4.

Manager's Response It is recommended that the zoning of the site be amended from Z1 to Z4 given that the two existing houses are vacant, planning permission has been granted for a substantial medical surgery on site (ref.4104/09), the site is contiguous to an existing Z4 zone and is close to Killester Dart station.

Recommendation Amend zoning from Z1 to Z4 Map Reference: B Reference Number: 15 Site Address: Donnycarney Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The submission is made on behalf of the St. Laurence O'Toole Diocesan Trust. The house and associated site area is surplus to church requirements and the submission requests that it is rezoned from Z15 (Resource lands) to zoning objective Z1 (Residential) as it is located in a residential area. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: B Reference Number: 16 Site Address: Griffith Avenue, Marino, Dublin 8 Submission Number(s): 3055 Summary of Issues Request to rezone from Z15 to Z12 or Z10B.

The proposed rezoning of the site in the Draft Development Plan to Z15 is not considered appropriate as the subject site is not used for any institutional, educational, health care or other community uses and are in fact surplus to the Congregations requirements at this location. The Masterplan submitted with planning application [3226/09] indicated that the subject lands would accommodate future buildings. Manager's Response Z15 reflects a long term social infrastructure resource for the city and in this instance it has been demonstrated that the lands in question are surplus to the core uses of the educational facility on these lands, therefore a Z12 zoning is considered more appropriate. Recommendation Amend zoning from Z15 to Z12. Map Reference: B Reference Number: 17 Site Address: Hampton Court - Grace Park Road Submission Number(s): 3116 Summary of Issues Request to rezone from Z15 to Z12, Z1 or Z10B.

The submission objects to change from Z12, to Z15 of a portion of their lands and requests that the lands should be zoned back to Z12 or zoned to Z1 or Z10B (outer suburban use). Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning.

Map Reference: B Reference Number: 18 Site Address: Regency Hotel - Swords Road, Whitehall Submission Number(s): 3150 Summary of Issues Request to rezone from Z1 to Z3, Z4 or Z15.

Submission contends that in spite of the commercial use of these lands, the site is zoned for residential purposes in the current Development Plan. It is requested that the new Plan contains a zoning which is based on the existing long time established use of the site as the Regency hotel. Manager's Response The proposed zoning change is contrary to the residential context of the site. Recommendation Retain Z1 zoning. Map Reference: B Reference Number: 19 Site Address: Home Farm Road Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The submission is made on behalf of the St. Laurence O'Toole Diocesan Trust. The house and associated site area is surplus to church requirements and the submission requests that it is rezoned from Z15 (Resource lands) to zoning objective Z1 (Residential) as it is located in a residential area. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: B Reference Number: 20 Site Address: Old Finglas Road - Sisters of Faith (See also A6) Submission Number(s): 2643 Summary of Issues Request to rezone from Z15 to Z10B.

Majority of the site is currently zoned Z15 - Institutional Lands (long-term institutional use) with a number of active uses, such as, schools, playing fields, nursing home, and convent. The rezoning from Z15 to Z10B would provide a planning policy context which is supportive of potential future development on the site in conjunction with the continuation of the institutional uses. Manager's Response The Sisters of the Holy Faith lands are providing education, health and institutional uses. As the lands are in active institutional use providing services to the community, then it should remain Z15 and any proposed development would have to meet the criteria for Z15 detailed in section 15.10.15. Recommendation Retain Z15 zoning.

Map Reference: B Reference Number: 21 Site Address: Hillside Farm - Ballymun Submission Number(s): 3047 Summary of Issues Request to rezone from Z15 to Z12 or Z10B.

The majority of lands at Hampstead are not and never have been used for any institutional, educational, health care or other community uses. The Highfield Hospital Group intend to consolidate and enhance their facilities on the 10 acre Highfield Hospital site to the east of Hillside which will create 200 jobs and help retain the existing 300 jobs at Highfield Hospital. This investment is placed in serious doubt as a result of the proposed rezoning of the farmlands from Z12 to Z15 by undermining the value for loan securing purposes Manager's Response As the lands are proximate to future Metro proposals and in the main a working farm and not institutional use, then the zoning should be changed in that area, while retaining the Z15 zoning at the Hampstead Hospital and Elmhurst Nursing Home sites. Recommendation Amend zoning from Z15 to Z12 except at Hampstead Hospital and Elmhurst Nursing Home sites where the Z15 zoning should be retained. Map Reference: B Reference Number: 22 Site Address: Beaumont Hospital Lands Submission Number(s): 3039 Summary of Issues Request to rezone from Z1 to Z15.

Beaumont Hospital submits that the hospital site is generally zoned Z15, but that some areas within the boundary line are zoned Z1, The hospital requests that all the hospital lands be zoned Z15 as there is no advantage to maintain the small areas of Z1 Manager's Response Agreed as peripheral strip of Z1 zoned land has little residential capacity. Recommendation Amend zoning from Z1 to Z15.

Map Reference: B Reference Number: 23 Site Address: Artane School of Music Submission Number(s): 2756 Summary of Issues Request to rezone from Z15 to Z4.

The submission requests the rezoning of lands at the Artane School of Music from Z15 to Z4, District Centre to allow intensification. Manager's Response It is not considered appropriate to rezone to Z4 having regard to the District Centre in close proximity. Recommendation Retain Z15 Zoning. Map Reference: B Reference Number: 24 Site Address: Butterly Business Park - Artane Submission Number(s): 3203 Summary of Issues Requests addition of specific objective to allow Discount Foodstore.

Butterly Business Park, Kilmore Road, Dublin 5, which is zoned Z6. It is requested that a specific objective be included in the draft development plan that will allow for the development of a Discount Foodstore on the site. Manager's Response The existing Z6 zoning should be retained as it does not prohibit discount foodstores. Recommendation Retain Z6 zoning.

Map Reference: B Reference Number: 25 Site Address: Ardlea Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The submission is made on behalf of the St. Laurence O'Toole Diocesan Trust. The car park area located at the Church is surplus to church requirements and the submission requests that they be rezoned from Z15 (Resource lands) to zoning objective Z1 (Residential) as it is located in a residential area. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: B Reference Number: 26 Site Address: Swords Road - Lands at Submission Number(s): 1 Summary of Issues These lands were inadvertently identified as Z15 institutional lands in the Draft. However in the current Development Plan their zoning is Z12 as they are not in institutional use. The lands do not fit the definition of institutional lands, are not in use for institutional purposes and therefore it is recommended to revert to the current 2005 Development Plan Z12 Zoning. Manager's Response The Whitehall Framework Plan identifies the subject lands for development. In addition, the lands are zoned Z12 under the current Development Plan 2005-2011. Accordingly, it is considered appropriate to amend the zoning from Z15 to Z12 as per the 2005 Development Plan. Recommendation Amend zoning from Z15 to Z12.

Map Reference: B Reference Number: 27 Site Address: Oscar Traynor Road lands Submission Number(s): 2 Summary of Issues These lands were inadvertently identified as Z15 institutional lands in the Draft. However in the current Development Plan their zoning is Z12 as they are not in institutional use. The lands do not fit the definition of institutional lands, are not in use for institutional purposes and therefore it is recommended to revert to the current 2005 Development Plan Z12 Zoning. Manager's Response Amend zoning from Z15 to Z12 as per 2005 Development Plan. Recommendation Amend zoning from Z15 to Z12. Map: C

Map Reference: C Reference Number: 01 Site Address: Donaghmeade Submission Number(s): 3187 Summary of Issues Request to rezone from Z9 to Z1.

The church and surrounding lands are zoned Z9 (Amenity/ Open Space Lands) in the Draft Plan which does not reflect the current use as a church and parochial house. The submission requests that the whole site be zoned to Z1 (Residential) as many other churches within the DCC area. Failing this, at least the parochial house should have the zoning objective Z1. Manager's Response Lands are in institutional use, therefore Z15 considered appropriate. Recommendation Amend zoning from Z9 to Z15.

Map Reference: C Reference Number: 02 Site Address: Grange Park View Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The submission requests that church and surrounding lands be rezoned from Z15 (Resource lands) to zoning objective Z1 (Residential). Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments not directly associated with the Z15 zoning which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are surplus to the institutional requirements of the current occupier. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding. Recommendation Retain Z15 zoning. Map Reference: C Reference Number: 03 Site Address: TOPAZ - Foxhall Raheny Submission Number(s): 3140 Summary of Issues Request to rezone from Z1 to Z3.

Request to rezone Foxhall, Raheny Service Station from Z1 to Z3. Manager's Response It is not appropriate to rezone this land as the facilities at a petrol station are to provide the sale of fuel with the ancillary, small scale sale of goods which would not be considered to offer, or compete with the range of facilities provided as part of a neighbourhood centre. Recommendation Retain Z1 zoning.

Map Reference: C Reference Number: 04 Site Address: Raheny Shopping Centre Submission Number(s): 2280, 2642 Summary of Issues Request to rezone from Z1 to Z4.

Request that the rear of the Raheny Shopping Centre, be rezoned from Z1 to Z4 'Mixed Services'. Submission indicates the front of main part of centre has Z4 zoning and rear part of site is used as part of the shopping centre for some years and has permission for use as a car park and an office / retail development (4792/05). Manager's Response The rear part of the site has a two storey medical centre and retail building granted permission in 2005. The car parking serves the shopping centre and medical centre. It is considered that the proposed rezoning is reasonable given that it would support the existing district centre and the site: is contiguous to existing Z4 zoned lands, is currently in a non-residential use, and is located between a shopping centre and the railway to the north. Recommendation Amend zoning from Z1 to Z4. Map Reference: C Reference Number: 05 Site Address: St. Joseph's Hospital, Raheny (See also B11) Submission Number(s): 3039 Summary of Issues Request to rezone from Z9 to Z15.

Beaumont Hospital requests a re-zoning of lands from Z9 to Z15 on lands known as St. Joseph's Hospital which is a community nursing facility proving care for elderly patients under the hospital's management. Planning permission was granted (5896/07) for a new two-storey 100 bed nursing unit in the south-western side of the site on the portion of land zoned Z9. Manager's Response It is premature to rezone from Z9 to Z15 at this time. The Z9 zoning will not prohibit the construction of the approved development, at which time the zoning can be reviewed. Recommendation Retain Z9 zoning.

Map: D

Map Reference: D Reference Number: 01 Site Address: Ballyfermot - Community Civic Centre Submission Number(s): 3183 Summary of Issues Request to rezone from Z4 to Z9.

In time the LUAS Line will extend to Ballyfermot along Ballyfermot Road resulting in more housing and apartment development and that it is necessary to retain this green area as an open space area for quality of life reasons. Manager's Response This is an existing green area which complements the adjacent community civic centre. Recommendation Amend zoning from Z4 to Z9.

Map Reference: D Reference Number: 02 Site Address: St. John's Monastery - Le Fanu Road - Ballyfermot Submission Number(s): 3115 Summary of Issues Request to rezone from Z15 to Z1 or Z10B.

The submission objects to the Z15 zoning and proposes that either Z1 (residential) or Z10B (Outer suburban mixed use) would be more in keeping with the surrounding residential use. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: D Reference Number: 03 Site Address: Mount La Salle - Ballyfermot Site A Submission Number(s): 3121 Summary of Issues Request to rezone from Z15 to Z12, Z10B or Z1.

The submission requests to retain the current Z12 zoning objective in the development plan. Request rezoning of the area A & B lands at Mount La Salle to either Z1 or Z10B because these lands are not used for any educational or institutional purpose. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning

Map Reference: D Reference Number: 04 Site Address: Bluebell Road/Davitt Road/Grand Canal tow path Submission Number(s): 2944, 3162 Summary of Issues Request to retain existing Z9 zoning.

The submissions would like to see other methods of dealing with anti social behaviour rather than changing Z9 to Z11 on the Bluebell Road and Grand Canal tow path. One of the submissions objects to proposed zoning change from Z9 to Z12 on Bluebell Road and Grand Canal tow path. Manager's Response This submission does not relate to any zoning issue. Recommendation Retain existing zoning along canal. Map Reference: D Reference Number: 05 Site Address: Jamestown Road Submission Number(s): 2130 Summary of Issues Request to rezone from Z6 to Z10A.

The submission requests the rezoning of site which is bounded by Jamestown Road to the north, a number of industrial/light enterprise premises to the south and the Bluebell Industrial Estate to the West. Proposal to rezone site from Z6 to Z10A. Manager's Response A comprehensive approach needs to be taken towards the potential rezoning and redevelopment of this site as it forms part of the strategic Z6 employment landbank. Recommendation Retain Z6 zoning.

Map Reference: D Reference Number: 06 Site Address: ESB - Kylemore Road Submission Number(s): 2667, 3207 Summary of Issues ESB Supports the retention of Z6 Manager's Response Submission noted & recommend that Z6 zoning is retained Recommendation Retain Z6 zoning. Map Reference: D Reference Number: 07 Site Address: Cherry Orchard Submission Number(s): 2629 Summary of Issues Request to rezone from Z12 to Z9.

Public Park from Z12 to Z9. Cherry Orchard Park is located in the heart of the area and is accessible by all estates and therefore should be re-developed and improved as an open park with full amenities for local people. Manager's Response The Z12 zoning allows for these lands to be developed whilst maintaining environmental amenities including 20% public open space. Recommendation Retain Z12 zoning.

Map Reference: D Reference Number: 08 Site Address: Elmdale Crescent - Open Spaces Submission Number(s): 2629 Summary of Issues Request to rezone from Z1 to Z9.

The residents are requesting the re-zoning of the open green spaces in Elmdale Crescent from Z1 to Z9 as the space is the only green open area in entire Elmdale estate. Manager's Response The space adjacent to the entrance to the Elmdale estate was zoned Z1 in the 2005 Development Plan and the larger more central space was changed from Z9 to Z1 under variation no.7 of the 2005 Development Plan. Subsequently planning permission was granted to Habitat for Humanity to construct 16 houses on the central space under plan ref. 6331/06. Recommendation Retain Z1 zoning. Map Reference: D Reference Number: 09 Site Address: Cherry Orchard Lands. Submission Number(s): 2629 Summary of Issues Request to rezone from Z14 to Z4.

Z14 to Z4, full shopping facilities - Cherry Orchard has no shopping facilities with the exception of one small shop. It is proposed that therefore full amenities be provided for under this plan to be located on the site including shops and schools Manager's Response It is not appropriate to rezone to Z4. Z14 allows for the provision of the uses requested. Recommendation Retain Z14 zoning.

Map Reference: D Reference Number: 10 Site Address: Chapelizod Village Submission Number(s): 3094 Summary of Issues COVA, supports the zoning of Chapelizod Village. Manager's Response Submission noted & recommended that zoning is retained Recommendation Retain zoning in Chapelizod village.

Map: E

Map Reference: E Reference Number: 01 Site Address: Navan Road Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The submission is made on behalf of the St. Laurence O'Toole Diocesan Trust. The house and associated site area is surplus to church requirements and the submission requests that it is rezoned from Z15 (Resource lands) to zoning objective Z1 (Residential) as it is located in a residential area. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: E Reference Number: 02 Site Address: Dominican Convent - Cabra Submission Number(s): 3119 Summary of Issues Refer to Map A10 Request to rezone from Z15 to Z12 or Z10B.

The submission objects to the extension of the Z15 zoning over the whole site (these are 2 parts of the site zoned Z12 in 2005 - 2011 Plan). Submission proposes the retain the Z12 zoning on these two parts of the site (albeit reduced at Area A on Map because of a recent school extension) or alternatively rezone the lands Z10B Manager's Response Having regard to the proposed draft zoning policy for these lands, it is considered that the parcel of land fronting Ratoath Road be retained as Z15 while the parcel of land fronting Abbey Drive be rezoned for residential purposes as it is surplus to institutional needs, contiguous to Z1 lands, and will not negatively impact on the strategic landbank of Z15 zoned lands. Recommendation Amend zoning of land fronting Abbey Drive from Z15 to Z1. Retain Z15 zoning of land fronting Ratoath Road. Map Reference: E Reference Number: 03 Site Address: Bannow Road/Broombridge (See also A9) Submission Number(s): 2231 Summary of Issues Request to rezone from Z10A back to Z6. Request to retain Z10A.

There are two submissions concerning these sites, one supporting the zoning to Z10A considering its proximity to Broombridge rail station and the under utilisation of an urban site, and the other submission opposing the rezoning considering the downturn in the market. Manager's Response The Z10A Zoning (Inner Suburban Mixed Use) as extended to this site is considered appropriate with regard to the strategic location of the site within the canal ring. The Z10A Zoning as proposed under the draft plan permits a wider range and extent of uses than permitted under Z6, which is appropriate in the context of the existing and proposed public transport accessibility of the site in close proximity to Boombridge Station / Liffey Junction served by existing mainline suburban rail and proposals for Luas Line BX. Recommendation Retain Z10 Zoning

Map Reference: E Reference Number: 04 Site Address: Carnlough Road - Cabra Submission Number(s): 2873 Summary of Issues Request to rezone from Z1 to Z3.

Requests the rezoning of lands at Carnlough Road, Cabra from Z1 to Z3 to reflect permitted retail and community uses. Manager's Response The subject site is bounded by residential zoning Z1. It is considered that it would be pre- mature to zone the site as Z3 for neighbourhood uses, pending implementation of the permitted planning application. The Z1 Zoning reflects the current use of the site and is considered appropriate. Recommendation Retain Z1 Zoning Map Reference: E Reference Number: 05 Site Address: Rear of 57 Prussia Street Submission Number(s): 3200 Summary of Issues Request to rezone from Z6 to Z4.

Submission requests that the site at Units 1 to 4 to the rear of 57 Prussia Street, and opposite Park Shopping Centre, be rezoned from Z6 to Z4. Manager's Response It is considered appropriate that the subject site be re-zoned to Z4 (mixed-services facilities) on the basis that Z4 lands immediately adjoin the site to the north and additional Z4 lands are located on the opposite roadside. The re-zoning would represent a consolidation of Z4 Lands and is considered appropriate. Recommendation Amend Zoning from Z6 to Z4.

Map Reference: E Reference Number: 06 Site Address: Motorvalu - Prussia Street Submission Number(s): 3078, 3199 Summary of Issues Request to rezone from Z1 to Z10A.

Given the site's proximity to Grangegorman, precedents for Z10A in the area, the evolution of zoning in the area since 1999 and the site's inner suburban context, it is contended that the site's current Z1 zoning objective does not reflect the site's inner suburban context, the site's development potential, or its long-established commercial use. Manager's Response It is not considered appropriate to re-zone the subject site for Z10 inner suburban mixed- uses that could accommodate office and retail uses, as well as residential, given the surrounding residential context of the site. Recommendation Retain Z1 Zoning Map Reference: E Reference Number: 07 Site Address: Grangegorman Submission Number(s): 2157, 2606, 2860, 2964, 2980 Summary of Issues It is submitted that the existing Z12 zoning will not allow for the range of activities and uses appropriate for the development of the Granegorman campus. Z14 zoning is requested to be consistent with other strategic development and regeneration areas in the city. The Grangegorman project proposes significant mix-use development with additional physical and social infrastructure/facilities which will add significantly to the local, citywide and national social infrastructure.

Three submissions support the Z12 zoning. The submission notes, however, that it has effectively been re-zoned by the inclusion of the following clause at 15.10.13: "In the Development Plan all references to Z1OB zoning will apply to Z12 zoning". This change was not agreed by the City Council when adopting the Draft Plan. Manager's Response It is considered appropriate that the lands at Grangegorman be designated Zoning Objective Z14 to facilitate the comprehensive and integrated development of strategic lands critical to the regeneration of the inner city, possibly by way of a Strategic Development Zone (SDZ).

Zoning Objective Z14 seeks the social, economic and physical development and / or rejuvenation of an area and relates to Strategic Development and Regeneration Areas (SDRAs). Grangegorman is identified as a SDRA in Sections 15.10.4 and 16.3 of the Draft Plan. Accordingly, the Z14 Zoning would render it consistent with the overall zoning approach for SDRAs. Recommendation Amend Zoning from Z12 to Z14 Map Reference: E Reference Number: 08 Site Address: Mt Bernard Park, Phibsborough Submission Number(s): 2954, 3036 Summary of Issues Request to rezone from Z1 to Z9.

From Z1 to Z9 - To facilitate connectivity between the proposed Royal Canal linear park and Mount Bernard Park and allow the residents of the area access to the canal. Manager's Response The Phibsborough / Mountjoy Local Area Plan (LAP) seeks the enhancement and expansion of the Mount Bernard Park and acknowledges the importance of the disused Iarnrod Eireann Lands for the extension of the park as a valuable amenity resource for the local community. In this regard, it is considered appropriate that these lands be Zoned Z9 to reflect and support the proposals of the LAP.

It is relevant to note that the Z9 Zoning for Amenity / Open Space Lands / Green Network does not preclude public service installations, in the event that Iarnrod Eireann as a statutory undertaker and public transport provider, may need to utilise the lands for the purposes of support infrastructure. Recommendation Amend Zoning from Z1 to Z9

Map Reference: E Reference Number: 09 Site Address: TOPAZ - Finglas Road Glasnevin (See also A8) Submission Number(s): 3140 Summary of Issues Request to rezone from Z1 to Z3.

Request to rezone Finglas Road, Glasnevin Service Station from Z1 to Z3. Manager's Response It is not considered appropriate to re-zone the subject site Z3 for the purposes of neighbourhood uses given the context of surrounding residential lands and the proximity to Glasnevin Cemetery which is of national historical significance.

In addition, the development standards for petrol stations restrict the sale of ancillary goods to the small-scale sale of goods as secondary to the primary sale of fuel to reduce the potential conflict between pedestrians and vehicles and also to protect local amenities and established neighbourhood centres. Recommendation Retain Z1 Zoning Map Reference: E Reference Number: 10 Site Address: Smurfit Printworks - Botanic Ave Submission Number(s): 3083 Summary of Issues Supports Z10A Zoning. Manager's Response Support for zoning is noted. Recommendation Retain Z10 Zoning

Map Reference: E Reference Number: 11 Site Address: Hendron Place Submission Number(s): 2202, 2261, 2742, 2806, 2821, 3040 Summary of Issues Request to rezone from Z10A to either Z2 and/or Z3

Opposition expressed to the proposed rezoning of the Hendron Site to Z10A in light of a recent decision by An Bord Pleanála on this site, the small site size, and proximity to Z2 and to protected structures. Manager's Response Z2 refers to existing residential areas. Z3 refers to neighbourhood uses. This is an underutilised industrial complex where a Z10A zoning objective reflects existing uses and is considered more appropriate in order to facilitate sustainable mixed use development. Recommendation Retain Z10 Zoning. Map Reference: E Reference Number: 12 Site Address: Summer Street North Submission Number(s): 2046 Summary of Issues Request to rezone from Z1 to Z9.

Small area to the rear of Sean O'Casey Avenue is now a community garden and should be rezoned from Z1 to Z9 Manager's Response The current residential zoning of the land does not impact on the use of the land as a community garden. Recommendation Retain Z1 zoning.

Map Reference: E Reference Number: 13 Site Address: Drumcondra Road Lower Nos 33,35,37 Submission Number(s): 2236 Summary of Issues Request to rezone from Z2 to Z4.

The permitted uses within the current zoning are too restrictive to allow for a reasonably economic use of the site given its prominence on a main thoroughfare and proximity to public transport. Requests the rezoning to Z4 "To provide for and improve mixed service facilities" in line with adjacent sites on the opposite side of the road. Manager's Response The residential use of the buildings is not considered appropriate having regard to the lack of amenity deriving from the location on a main route into the city. The location no longer constitutes a residential enclave. Z4 zoning is contiguous and would reflect the appropriate zoning having regard to the reality on the ground.

Recommendation Amend zoning from Z2 to Z4. Map Reference: E Reference Number: 14 Site Address: 'Tolka Park', Richmond Road, Drumcondra, Submission Number(s): 2890 Summary of Issues Request to rezone from Z9 to Z1.

Shelbourne FC will be relocating to Dalymount Park, the Richmond Area Action Plan identifies Tolka Park as a site suitable for potential redevelopment, residential development would integrate well with the adjoining uses. Manager's Response It is considered premature to rezone these lands until long term alternative accommodation and facilities have been identified to facilitate the relocation of Shelbourne Football Club from Tolka Park. Recommendation Retain Z9 Zoning. Map Reference: E Reference Number: 15 Site Address: Fairview Strand Submission Number(s): 2073, 2268 Summary of Issues Request to rezone from Z1 to Z4.

Submission requests a zoning change at Fairview Strand between Windsor Avenue and Phibsborough Avenue from Z1 to Z4, as the area is in commercial use, is located within Fairview Village and as the majority of the block is not in residential use. Manager's Response Further to site assessment, it is apparent that there are a number of commercial and local services such as medical practices, dentist solicitor offices in the majority of properties with frontage onto Fairview Strand. There are also commercial uses to the rear of these properties. On the basis of current uses, it is considered appropriate to re-zone a portion of the site for neighbourhood uses (Z3). Z4 Zoning for mixed-uses and services is not appropriate given the character of the terrace of buildings and the need to protect the scale and intensity of uses, as well as the protection of residential amenity of properties in the immediate vicinity. Recommendation Amend Zoning From Z1 to Z3

Zoning change for the southern portion of the site only, so that it corresponds to plot depths and similar in depth to the adjoining Z4 Zoning. The Z3 Zoning does not extend to the rear so as to incorporate residential properties 50-51 along Windsor Avenue, and it should not extend westwards beyond 39 Fairview Strand Road. Map Reference: E Reference Number: 16 Site Address: West Wood Club Submission Number(s): 2140 Summary of Issues Request to rezone from Z9 to Z4.

The submission requests a change of zoning from Z9 to Z4 at the West Wood Club, Clontarf as it is in commercial use. Alternatively a change in permissible or open for considerations uses under the Z9 zoning is requested. Manager's Response It is not considered appropriate to re-zone the subject open space lands for the purposes of mixed-use services and facilities on the basis that these lands form part of a larger strategic open space and associated recreational amenities (Fairview Park), the retention of which is important to meet the recreational needs of the city. It is would not be appropriate to re-zone lands on an incremental basis that would result in a loss of this strategic asset. Recommendation Retain Z9 Zoning

Map Reference: E Reference Number: 17 Site Address: Alfie Byrne Rd. (See also F1) Submission Number(s): 2741, 2790, 2950, 3148 Summary of Issues The submissions support the Z9 zoning and request an amenity action plan. Manager's Response The support for Z9 Zoning is noted.

In terms of the requests for an amenity action plan, this matter will be referred to the Arts, Culture, Leisure and Youth Affairs SPC Recommendation Retain Z9 Zoning Map Reference: E Reference Number: 18 Site Address: North Williams Street Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The submission is made on behalf of the St. Laurence O'Toole Diocesan Trust. The house and associated site area is surplus to church requirements and the submission requests that it is rezoned from Z15 (Resource lands) to zoning objective Z1 (Residential) as it is located in a residential area. Manager's Response Agreed. Lands are not key to overall Z15 zoning objective. Recommendation Amend Zoning from Z15 to Z1

Map Reference: E Reference Number: 19 Site Address: ESB East Wall Road Submission Number(s): 2665, 3205 Summary of Issues ESB support the retention of Z6. Manager's Response The support for Z6 Zoning is noted. Recommendation Retain Z6 Zoning Map Reference: E Reference Number: 20 Site Address: Docklands (See also F18) Submission Number(s): 2664, 2769, 2807, 3096, 3096 Summary of Issues Request to rezone from Z14 to Z7.

The port company considers that these lands should be retained for existing and future rail use and the zoning altered to Z7. It is contended by the Port Company that DCC do not have to replicate the master plan of DDDA (refer to Docklands Development Authority Act 1997 Section 24 (2)(a) Manager's Response It is not considered appropriate to rezone these lands Z7 for industrial uses on the basis that these lands form part of a comprehensive regeneration area and are identified as a Strategic Development and Regeneration Area (Docklands) in Section 15.10.4 and 16.3 of the Draft Plan. An alternative zoning would enable piecemeal development which may prevent comprehensive and integrated redevelopment of the lands.

In addition, the subject lands are designated Zoning Objective Z14 in the Docklands Masterplan 2008. Under the 1997 Dublin Docklands Development Act, the Dublin City Development Plan must have regard and ensure consistency with the Docklands Masterplan. Accordingly, there is no discretion is this regard and the lands should remain as Z14. Recommendation Retain Z14 Zoning Map Reference: E Reference Number: 21 Site Address: North Wall Quay Submission Number(s): 3084, 3166, 3167 Summary of Issues Request to rezone from Z14 to Z9.

The Z14 zoning of the campshires is at odds with the objectives of the North Lotts Planning Scheme 2002 and the City Development Plan's own designation of the campshires as a Conservation Area. The land extension into the Liffey as illustrated is premature and without context. Manager's Response The campshire lands are designated Zoning Objective Z14 in the Docklands Masterplan 2008. Under the 1997 Dublin Docklands Development Act, the Dublin City Development Plan must have regard to and ensure consistency with the Docklands Masterplan. Accordingly, there is no discretion is this regard and the lands must remain as Zoning Objective Z14. Recommendation Retain Z14 Zoning

Map Reference: E Reference Number: 22 Site Address: 88-90 Townsend Street Submission Number(s): 2097 Summary of Issues Request to rezone from Z1 to Z4.

The submission requests rezoning from the current Z1 to Z4 as the property has not been in residential use for over 20 years. The property has been in use as office / training / retail. Planning application granted under 5161/08 further strengthens the case for rezoning. Manager's Response The Z1 Zoning of the subject site reflects the zoning objectives in the Docklands Masterplan 2008. Under the 1997 Dublin Docklands Development Act, the Dublin City Development Plan must have regard and ensure consistency with the Docklands Masterplan. Accordingly, there is no discretion in this regard and the lands should remain as Z1. Recommendation Retain Z1 Zoning Map Reference: E Reference Number: 23 Site Address: No. 91 – 92 Townsend Street Submission Number(s): 2098 Summary of Issues Request to rezone from Z3 to Z4.

The submission requests rezoning from the current Z3 to Z4 in order to develop this pivotal corner site. Planning application granted under 5161/08 further strengthens the case for rezoning. Manager's Response The subject lands are designated Zoning Objective Z3 in the Docklands Masterplan 2008. Under the 1997 Dublin Docklands Development Act, the Dublin City Development Plan must have regard and ensure consistency with the Docklands Masterplan. Accordingly, there is no discretion is this regard and the lands should remain as Z3. Recommendation Retain Z3 Zoning

Map Reference: E Reference Number: 24 Site Address: Sir John Rogerson's Quay Submission Number(s): 3092 Summary of Issues Supports the zoning of the subject lands as Z14. Manager's Response Support for Z14 Zoning noted. Recommendation Retain Z14 Zoning Map Reference: E Reference Number: 25 Site Address: No 15 Barrow Street Submission Number(s): 3089 Summary of Issues Request to rezone from Z1 to Z4.

Submission relates to Lands at 15, Barrow St., Dublin 2 owned by Dublin Sanitary Disposals Ltd. Seeks to rezone site from Z1 to Z4. The subject lands have accommodated an established non-conforming "light industrial" use for over 60 years. Manager's Response The subject lands are designated Zoning Objective Z1 in the Docklands Masterplan 2008. Under the 1997 Dublin Docklands Development Act, the Dublin City Development Plan must have regard and ensure consistency with the Docklands Masterplan. Accordingly, there is no discretion is this regard and the lands should remain as Z1. Recommendation Retain Z1 Zoning

Map Reference: E Reference Number: 26 Site Address: ESB - South Lotts Road Submission Number(s): 3073, 3204 Summary of Issues Request to rezone from Z1 to Z10A. Request to rezone from Z9 to alternative zoning (laneway).

The site has an established office use which is ancillary to the utility/light industrial use and it may be necessary to expand the uses on the site. The Z1 zoning is inconsistent with the current uses on site and may prejudice the enhancement of the ESB operations. Further requests that the Z9 zoning of the laneway along the northern boundary of the ESB landholding is a current anomaly as this is a vehicular access route to multiple users. Manager's Response The subject lands are designated Zoning Objective Z1 in the Docklands Masterplan 2008. Under the 1997 Dublin Docklands Development Act, the Dublin City Development Plan must have regard and ensure consistency with the Docklands Masterplan. Accordingly, there is no discretion is this regard and the lands should remain as Z1. Recommendation Retain Z1 Zoning Objective Map Reference: E Reference Number: 27 Site Address: Site - Fronting Sandwith Street and Boyne Street Submission Number(s): 3059, 3134 Summary of Issues Request to rezone from Z4 to Z5.

Request the site is rezoned from Z4 to Z5 and that a specific objective be attached to the site which requires the preparation of a Framework Plan to appropriately address the significant regeneration opportunities presented by the subject site. Manager's Response The subject lands are designated Zoning Objective Z4 in the Docklands Masterplan 2008. Under the 1997 Dublin Docklands Development Act, the Dublin City Development Plan must have regard and ensure consistency with the Docklands Masterplan. Accordingly, there is no discretion is this regard and the lands should remain as Z4. Recommendation Retain Z4 Zoning

Map Reference: E Reference Number: 28 Site Address: Davenport Hotel at the corner of Merrion Street Lower and Fenian Street Submission Number(s): 3060 Summary of Issues Request to rezone from Z8 to Z5.

The submission requests that the Davenport Hotel at the corner of Merrion Street Lower and Fenian Street be rezoned from Z8 to Z5 as the current zoning is unduly restrictive and unnecessary given that the Hotel is located on the RPS and is located in a Conservation Area. Manager's Response The subject site is on the cusp of the Z8 / Z5 Zonings that apply to the city centre with Z8 lands adjoining the site to the south and Z5 lands to the east. It is considered that the re- zoning of the site to Z5 would not detract from the integrity of the architectural and civic design character of the Georgian Conservation Area as a coherent streetscape, given that the subject building, the Davenport Hotel, is listed for protection on the Record of Protected Structures. Recommendation Amend Zoning From Z8 to Z5 Map Reference: E Reference Number: 29 Site Address: Mont Clare Hotel - Merrion Street Lower Submission Number(s): 3063 Summary of Issues Supports Z5 zoning. Manager's Response Support for Z5 Zoning is noted. Recommendation Retain Z5 Zoning

Map Reference: E Reference Number: 30 Site Address: ESB Headquarters - Fitzwilliam Street Lower Submission Number(s): 2993 Summary of Issues Request to rezone from Z8 to Z6.

The submission, on behalf of ESB Headquarters request an extension of the proposed Z6 zoning to all constituent parts of the site which accommodate the core mono-purpose office footprint; it is consistent with numerous precedents throughout the city centre where Z6 land zoning and office based employment buildings are sited alongside Z8 land use zonings. Manager's Response It is acknowledged that this location is central to the corporate identity of ESB, and employs c.1100 people. Moreover, ESB is at the forefront of innovation in sustainable energy, and as such accords fully with the Development Plan core strategy for economic renewal. However, it is also recognised that the ESB headquarters lies within the internationally significant Georgian Quarter of the city, mostly zoned Z8.

It is noted however, that St James East to the rear of the site is largely zoned Z6 employment, and that the core buildings to the rear of the original Georgian House footprint are modern mono-purpose offices not suited to modern office use.

It is considered that this modern office area can be zoned for Z6 employment, with the frontage remaining Z8, in order to allow the twin objectives of modern employment headquarters and the protection of the Georgian streetscape to be achieved. Recommendation a) Extend the Z6 zoning to the rear of the ESB site and retain the Z8 zoning to the frontage to Fitzwilliam Street Upper, Mount Street upper and Baggot Street Lower. Map Reference: E Reference Number: 31 Site Address: 74/75 Lower Baggot Street Submission Number(s): 3051 Summary of Issues Request to rezone from Z6 to Z5.

The site is located within the central business district in close proximity to the emerging public transport hub at St. Stephen's Green and as such identify fully with the wider city centre area. The application of the Z5 zoning objective to this area would be entirely consistent with the City Council's stated policy of intensifying and consolidating the city centre. Manager's Response The subject site is located within an urban block that is zoned for employment purposes (Z6) and with residential zoning in the vicinity. The re-zoning of the city to city-centre uses (Z5) would facilitate piecemeal development and would be contrary to the objective in the plan to consolidate the city centre zoning (Z5). Recommendation Retain Z6 Zoning

Map Reference: E Reference Number: 32 Site Address: Lands at Mespil Hotel, 50-60 Mespil Road, Dublin 4. Submission Number(s): 2991 Summary of Issues Request to rezone from Z1 to Z6.

Z6 zoning for the Mespil hotel is appropriate having regard to the strategic location of the site in respect of the transportation infrastructure, the extension of the existing Z6 zoning located in the general area, the current use on-site, and future potential redevelopment of the site. Manager's Response It is considered appropriate to re-zone the subject site which is currently in hotel use from Z1 residential uses to Z6 for employment uses, in the interests of the consolidation of the employment zone at this location in the south inner city. In this regard, it is relevant to note that the subject site adjoins lands zoned for employment (Z6). The site also benefits from a high level of public transport accessibility. Recommendation Amend Zoning from Z1 to Z6 Map Reference: E Reference Number: 33 Site Address: 39 Mespil Court Submission Number(s): 3050 Summary of Issues Request to rezone from Z6 to Z10A.

The site is centrally located within convenient walking distance of high quality public transport infrastructure, the existing Z6 zoning does not promote mixed uses in urban locations close to public transport, an the site is currently under-utilised and has the potential to be redeveloped for higher density mixed use developmentthereby consolidating the urban area. Manager's Response It is not considered appropriate to re-zone the subject site for the purposes of Inner Suburban Mixed-Uses (office, retail and residential) on the basis that it forms part of an overall employment zone (Z6), the partial re-zoning of which would facilitate piecemeal development and may preclude more comprehensive redevelopment and the most efficient use of scarce urban land. Recommendation Retain Z6 Zoning

Map Reference: E Reference Number: 34 Site Address: Burlington Hotel Submission Number(s): 2995 Summary of Issues Request to rezone from Z1 to Z6.

Rezoning will facilitate economic development and employment creation as part of a mixed use development, be consistent with land ownership, and will redress an zoning anomaly wherein the current land use of the site is commercial rather than residential. Manager's Response The subject site is located within a primarily residential area and in close proximity to residential conservation areas. It does not form part of an overall employment zone and the re-zoning of which would not contribute to consolidation of existing employment uses. Accordingly, it is not considered appropriate to re-zone for employment purposes (Z6). Recommendation Retain Z1 Zoning Map Reference: E Reference Number: 35 Site Address: Gardner House/Lad Lane Submission Number(s): 3169 Summary of Issues Request to rezone from Z1 to Z6.

Element of the site at Gardner House/Lad Lane Dublin 2 illustrated in this submission currently zoned as Z1 should be rezoned with the remainder of the site and surrounding uses as Z6. Manager's Response The subject site zoned as residential forms part of a larger urban block which is zoned for employment purposes (Z6). Accordingly, it is considered appropriate that the site be re- zoned to Z6 for the purposes of consolidation employment uses with regard to established employment uses in the immediate vicinity. Recommendation Amend Zoning From Z1 to Z6

Map Reference: E Reference Number: 36 Site Address: Lad Lane/Wilton Place Submission Number(s): 2992 Summary of Issues Request to rezone from Z1 to Z6.

Rezoning approriate having regard to: the character and setting of the neighbouring buildings; policy to promote the city centre as the primary office location; and the proximity of the site to public transport corridors. Manager's Response The subject site is currently zoned for residential purposes and immediately adjoins lands zoned as Z1 & Z8. It is considered that re-zoning of the site for employment purposes may detract from the architectural and civic design character and streetscape coherence of the Georgian Conservation Area. Accordingly, it is not considered appropriate to re-zone to Z6. Recommendation Retain Z1 Zoning Map Reference: E Reference Number: 37 Site Address: Garda Station - Harcourt Terrace Submission Number(s): 3195 Summary of Issues Request to rezone from Z2 to Z6.

Site at Nos. 11A (Garda Station) and 12-16 Harcourt Terrace, Dublin 2. Request to rezone a portion of the subject lands from Z2 to Z6 and the existing Z6 zoning on the remaining lands is supported. Manager's Response The subject site contains buildings which date from circa 1940s and forms part of a residential conservation area (Z2) with many of the properties on the opposite terrace listed for protection on the Record of Protected Structures.

The buildings are located in a residential street with impressive Regency style residential houses facing the site and late 19 century redbrick houses to the north. The historic heritage of the streetscape would be the main reason for the Z2 Residential Conservation Area zoning.

It is not considered appropriate to re-zone part of the subject site for employment purposes on the basis that employment uses could undermine the streetscape character and special amenity value of the Harcourt Street / Adelaide Road / Charlemont Place Conservation Area. Recommendation Retain Z2 Zoning Map Reference: E Reference Number: 38 Site Address: Adelaide Road - 7-18, 66-70, 1-11 & 22 Harcourt Tce Submission Number(s): 3093 Summary of Issues Request to rezone from Z2 to Z8.

Proposed rezoning would permit uses which would enhance the viability of the restoration of existing protected structures without having a negative impact on the civic architectural quality or protected structure status. Manager's Response The two sides of the street are quite different with Regency buildings on the western side and redbrick late C19th dwellings on the eastern side. The street has the Grand Canal to the south. Two of the buildings have memorial tourism plaques. There are 6 mews to the rear of 6-7. The Regency properties, which are listed buildings, on the western side of the street are in good order and in a mix of uses. The late C19th houses on the eastern side are mainly in residential use. The properties, 21- 22, on the corner with Adelaide Road appear to be vacant.

It would appear that from a review of the definition of Z2 and Z8 objectives and their explanation in the Draft Plan that a Z8 zoning would be a more suitable zoning for the western side of the street, as there is a mixture of uses. A Z8 zoning will allow the protection of the architectural character while allowing for limited other uses. „Nos. 21and 22 are not Georgian and are in a mainly residential terrace and should remain Z2. Recommendation Amend Zoning From Z2 to Z8 on western side of the street.

Retain Z2 Zoning on the eastern side of the street. Map Reference: E Reference Number: 39 Site Address: Adelaide Road/Earlsfort Terrace Submission Number(s): 2031 Summary of Issues Request to rezone from Z2 to Z8.

At present there are office uses on the terrace and the derelict house at the end of the terrace has not developed despite having a residnetila planning permission. This location and building is more suitbale for office uses. Manager's Response Out of the 12 protected buildings on this terrace (Nos. 7 – 18 Adelaide Road), 6 no. buildings are entirely in residential use, 4 no. buildings are in commercial use while 2 no. buildings are in both commercial and residential use. Similarly, the terrace of protected structures opposite (22-24 and 66 – 70 Adelaide Rd) is in commercial and residential use. It would appear that from a review of the definition of Z2 and Z8 objectives and their explanation in both the current and Draft Plans that a Z8 zoning would be a more suitable zoning in this instance. The transitional nature of this street – uses predominantly office / commercial (modern office blocks and Z6 zoning adjoin these terraces). A Z8 zoning will allow the protection of the architectural character while allowing for limited office use. Recommendation Amend Zoning From Z2 to Z8 Map Reference: E Reference Number: 40 Site Address: 17-19 Lower Hatch St and 15 - 18 Earlsfort Tce. Submission Number(s): 3065 Summary of Issues Request to rezone from Z8 to Z5 or Z6.

Rezone in order to facilitate the appropriate redevelopment of the site. Alternatively it is requested that the Z8 zoning objective of the site is reduced to more accurately reflect the part of the site which is considered may be worthy of this conservation objective. Manager's Response It is considered appropriate to reduce the Z8 Zoning on the subject site so that it gives a more accurate representation of the Georgian Buildings which it seeks to protect and reflects also the existing permission for redevelopment of the lands to the rear. The site is also located within the city-centre office quarter highly accessible by public transport. On this basis, it is considered appropriate to reduce the extent of Z8 Zoning. Recommendation Amend Zoning From Z8 to Z6

Z6 to reflect extent of existing of permission to the rear of building.

Map Reference: E Reference Number: 41 Site Address: Earl Court/Davitt House Submission Number(s): 3051 Summary of Issues Request to rezone from Z6 to Z5.

The site is located within the central business district in close proximity to the emerging public transport hub at St. Stephen's Green and as such identify fully with the wider city centre area. The application of the Z5 zoning objective to this area would be entirely consistent with the City Council's stated policy of intensifying and consolidating the city centre. Manager's Response The subject site is located within an urban block that is zoned for employment purposes (Z6) and adjoins Z8 Georgian Conservation Area. The re-zoning of the city to city-centre uses (Z5) would facilitate piecemeal development and which may detract from the special character of the conservation area and would also be contrary to which seeks the consolidation of the city centre zoning (Z5). Recommendation Retain Z6 Zoning Map Reference: E Reference Number: 42 Site Address: Seagrave, No. 19/20 Earlsfort Terrace Submission Number(s): 3051 Summary of Issues Request to rezone from Z6 to Z5.

The site is located within the central business district in close proximity to the emerging public transport hub at St. Stephen's Green and as such identify fully with the wider city centre area. The application of the Z5 zoning objective to this area would be entirely consistent with the City Council's stated policy of intensifying and consolidating the city centre. Manager's Response The subject site is located within an urban block that is zoned for employment purposes (Z6) and adjoins Z8 Georgian Conservation Area. The re-zoning of the city to city-centre uses (Z5) would facilitate piecemeal development and which may detract from the special character of the conservation area and would also be contrary to which seeks the consolidation of the city centre zoning (Z5). Recommendation Retain Z6 Zoning

Map Reference: E Reference Number: 43 Site Address: St. Stephen's Green House, Earlsfort Terrace Submission Number(s): 3051 Summary of Issues Request to rezone from Z6 to Z5.

The site is located within the central business district in close proximity to the emerging public transport hub at St. Stephen's Green and as such identify fully with the wider city centre area. The application of the Z5 zoning objective to this area would be entirely consistent with the City Council's stated policy of intensifying and consolidating the city centre. Manager's Response The subject site is located within an urban block that is zoned for employment purposes (Z6) and adjoins Z8 Georgian Conservation Area. The re-zoning of the city to city-centre uses (Z5) would facilitate piecemeal development and which may detract from the special character of the conservation area and would also be contrary to which seeks the consolidation of the city centre zoning (Z5). Recommendation Retain Z6 Zoning Map Reference: E Reference Number: 44 Site Address: 56/60 St. Stephen's Green Submission Number(s): 3051 Summary of Issues Request to rezone from Z8 to Z5 or Z6.

The site is located within the central business district in close proximity to the emerging public transport hub at St. Stephen's Green and as such identify fully with the wider city centre area. The application of the Z5 zoning objective to this area would be entirely consistent with the City Council's stated policy of intensifying and consolidating the city centre. Manager's Response The subject site forms part of an urban set-piece that is zoned Z8 Georgian Conservation Area and is part of the Georgian Streetscape and Squares along St. Stephen's Green. The re-zoning of the site to city centre uses (Z5) would undermine the architectural and civic design character and coherence of these important streets and is not considered appropriate. Recommendation Retain Z8 Zoning

Map Reference: E Reference Number: 45 Site Address: Hainault House, 67-69 St. Stephen's Green Submission Number(s): 3051 Summary of Issues Request to rezone from Z8 to Z5 or Z6.

No 80 Harcourt Street and Hainault House are modern purpose build offices. The site is located within the central business district in close proximity to the emerging public transport hub at St. Stephen's Green and as such identify fully with the wider city centre area. The application of the Z5 zoning objective to this area would be entirely consistent with the City Council's stated policy of intensifying and consolidating the city centre. Manager's Response The subject site forms part of an urban set-piece that is zoned Z8 Georgian Conservation Area and is part of the Georgian Streetscape and Squares along St. Stephen's Green. The re-zoning of the site to city centre uses (Z5) would undermine the architectural and civic design character and coherence of these important streets and is not considered appropriate. Recommendation Retain Z8 Zoning Map Reference: E Reference Number: 46 Site Address: Osborne House Submission Number(s): 3051 Summary of Issues Request to rezone from Z6 to Z5.

The site is located within the central business district in close proximity to the emerging public transport hub at St. Stephen's Green and as such identify fully with the wider city centre area. The application of the Z5 zoning objective to this area would be entirely consistent with the City Council's stated policy of intensifying and consolidating the city centre. Manager's Response The subject site is located within an urban block that is zoned for employment purposes (Z6) and adjoins Z8 Georgian Conservation Area. The re-zoning of the city to city-centre uses (Z5) would facilitate piecemeal development and which may detract from the special character of the conservation area and would also be contrary to which seeks the consolidation of the city centre zoning (Z5). Recommendation Retain Z6 Zoning

Map Reference: E Reference Number: 47 Site Address: No's 21-23 Grafton Street Submission Number(s): 3136 Summary of Issues Requests site specific objective relating to the strategic importance of the site to deliver large scale, modern retail floorspace. Manager's Response The comments regarding the importance of the subject site for the delivery of modern retail formats in the city-centre retail are noted. It is not considered necessary to include a site-specific objective given the city-centre zoning objective (Z5) which facilitates a robust mix of uses and the Retail Strategy for the City in this Draft Plan (Appendix 4) which sets out provisions for the city-centre retail core. Recommendation Retain Z5 Zoning Map Reference: E Reference Number: 48 Site Address: Russell Court at St. Stephen's Green South / Harcourt Street Submission Number(s): 2957 Summary of Issues Supports Z8 Zoning. Manager's Response Support for zoning noted Recommendation Retain Z8 Zoning

Map Reference: E Reference Number: 49 Site Address: No. 80 Harcourt Street Submission Number(s): 3051 Summary of Issues Request to rezone from Z8 to Z5 or Z6.

No 80 Harcourt Street are modern purpose build offices. The site is located within the central business district in close proximity to the emerging public transport hub at St. Stephen's Green and as such identify fully with the wider city centre area. The application of the Z5 zoning objective to this area would be entirely consistent with the City Council's stated policy of intensifying and consolidating the city centre. Manager's Response The subject site forms part of an urban set-piece that is zoned Z8 Georgian Conservation Area and is part of the Georgian Streetscape and Squares along St. Stephen's Green & Harcourt Street / Iveagh Gardens. The re-zoning of the site to city centre uses (Z5) would undermine the architectural and civic design character and coherence of these important streets and is not considered appropriate. Recommendation Retain Z8 Zoning Map Reference: E Reference Number: 50 Site Address: Harcourt Centre, Harcourt St, D2. Submission Number(s): 2071, 2988 Summary of Issues Request to rezone from Z4 to Z6. he submission requests the rezoning of the Harcourt Centre from Z4 to Z6 reflecting both the established pattern of office based employment at this centre, and of comparable sites (such as Park Place, Earlsfort Centre), therefore further enabling the Harcourt Cluster to continue to strengthen its central role and function within the CBD. Manager's Response It is considered appropriate to amend the zoning of the subject site from mixed-use services and facilities (Z4) to employment purposes (Z6) to reflect the established pattern of office development on the site and to support the Harcourt Street Area as an important employment zone or cluster within the city and in close to proximity to quality public transport (Luas). Recommendation Amend Zoning from Z4 to Z6 Map Reference: E Reference Number: 51 Site Address: Synge Street - No.17 Submission Number(s): 2885, 3054 Summary of Issues Request to rezone from Z15 to Z10A.

The residence will be vacated shortly and will no longer be in use by the Congregation of the Christian Brothers. This property is surplus to the Congregation's requirements at this location and it is the intention to find an appropriate new use to be located in this protected structure. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: E Reference Number: 52 Site Address: Harrington Street Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The submission is made on behalf of the St. Laurence O'Toole Diocesan Trust. The house and associated site area is surplus to church requirements and the submission requests that it is rezoned from Z15 (Resource lands) to zoning objective Z1 (Residential) as it is located in a residential area. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: E Reference Number: 53 Site Address: Mill Street Newmarket Dublin 8 Submission Number(s): 3137 Summary of Issues Request to rezone from Z6 to Z10A.

The site is located south of Newmarket Square and the submission requests rezoning of the property from Z6 to Z10A. Manager's Response The subject site is located immediately south of Newmarket Square which is re-zoned for mixed-use purposes by way of variation to reflect the provisions of the Liberties Local Area Plan (LAP). The subject site also forms part of the former Newmarket Framework Development Area (FDA) as designated under the 2005-2011 Development Plan. Accordingly, it is considered appropriate to amend the zoning to Z10A to facilitate inner city mixed-use development, including industrial and enterprise uses in any redevelopment, to facilitate the regeneration of the area with active and vibrant uses, which would also facilitate employment uses. Recommendation Amend Zoning From Z6 to Z10 Map Reference: E Reference Number: 54 Site Address: Warrenmount Convent, Blackpitts, Dublin 8. Submission Number(s): 3037 Summary of Issues Request to rezone from Z15 to Z12.

A new modern convent has been built and the older convent has been partly vacated and consequently may not be used solely for institutional use. The school lands were ceded by Presentation Sisters to the schools and the Convent lands have no relation to the school lands. Parts of the site no longer in institutional use could possibly be developed for future uses. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: E Reference Number: 55 Site Address: Donore Avenue Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The submission is made on behalf of the St. Laurence O'Toole Diocesan Trust. The house and associated site area is surplus to church requirements and the submission requests that it is rezoned from Z15 (Resource lands) to zoning objective Z1 (Residential) as it is located in a residential area. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: E Reference Number: 56 Site Address: Coombe Hospital Submission Number(s): 3088 Summary of Issues Request to rezone from Z15 to Z14.

Submission relates to The Coombe Women and Infants University Hospital, Cork St., D8. The submission seeks that this site be rezoned from Z15 to Z14 as this hospital is in the process of relocating to Tallaght Hospital, the site abuts St. Teresa's Gardens lands and thus would lend itself to the similar Z14 zoning and inclusion within SDRA 12 and the rezoning would ensure the effective redevelopment of a strategic, high-profile site Manager's Response The proposed Z14 zoning for urban regeneration would complement the Z14 zoning for the adjacent sites (Theresa‟s Gardens, Bailey Gibson and Player Willis) and provides the opportunity to create a quality mixed use district to revitalise the Dolphins Barn end of Cork St. in accordance with the principles set out in SDRA 12 (Chapter 16.3) including community facilities and a new public park. Recommendation 1. Amend from Z15 to Z14 2. Amend 16.3 (SDRA 12) 1st line from: St. Theresa‟s Gardens – (inclusive of former Player Willis and Bailey Gibson sites) to: St. Theresa‟s Gardens - (Inclusive of former Player Willis, former Bailey Gibson sites and „Coombe‟ Hospital) Map Reference: E Reference Number: 57 Site Address: Reuben Street Submission Number(s): 3022 Summary of Issues Request to rezone from Z1 to alternative zoning.

Site next to FKL Building on Reuben Street be changed from residential zoning to zoning that permits the development of an iconic building for an architectural practice. Manager's Response The submission is not accompanied by a map reference to a particular site. Further it site investigation, it is apparent that the surrounding properties in the immediate vicinity of the FKL Building consist primarily of terraced two-storey redbrick residential dwellings. It is not considered appropriate to amend the zoning to facilitate office use, on the basis that an alternative zoning could potentially detract from the character and residential amenity of the surrounding properties. Recommendation Retain Z1 Zoning

Map Reference: E Reference Number: 58 Site Address: South View Terrace Submission Number(s): 2608 Summary of Issues Request to rezone from Z1 to Z2.

These unique Tudor Style houses are an integral part of Rialto Cottages and Rialto developed in the 19th century by Guinness Brewery. Should be zoned Z2 Manager's Response The subject properties are unique Tudor Style houses and are an integral part of Rialto Cottages and Rialto developed in the 19th century by Guinness Brewery. In addition, the properties have frontage onto South Circular Road and contribute to the special character of the area. It is considered appropriate to amend the zoning from residential (Z1) to residential conservation Area (Z2). Recommendation Amend Zoning From Z1 to Z2 Map Reference: E Reference Number: 59 Site Address: South Circular Road - Dolphins Barn Submission Number(s): 2608 Summary of Issues Request to rezone from Z1 to Z2.

Many of the houses in this part of South Circular Road are the same red brick Victorian Houses as the rest of South Circular Road which are zoned Z2, therefore requests rezoning to Z2 to be in keeping with integrity of the rest of the road. Manager's Response The submission proposes an extensive number of properties along a number of streets for designation as residential conservation area, whilst many of the surrounding streets in the vicinity are zoned residential (Z1). It is considered that the most appropriate mechanism is to investigate if the subject properties and surrounding streets would merit designation as an Architectural Conservation Area (ACA). It would be pre-mature to amend the zoning pending even a preliminary assessment for ACA. Recommendation Retain Z1 Zoning

Map Reference: E Reference Number: 60 Site Address: Rialto Motors Submission Number(s): 2880, 3058 Summary of Issues Request to rezone from Z6 to Z10A.

Rezoning to Z10A would allow for more intensive form of inner suburban uses which would capitalise on the good public transport linkages in this area.and have regard to strategic location of site. Manager's Response The subject site forms part of a larger employment lands (Z6), the partial re-zoning of which would facilitate piecemeal development and could restrict the comprehensive redevelopment of the overall lands. RE-zoning would represent incremental zoning of a strategic employment site. Accordingly, it is not considered appropriate to re-zone the subject site for inner suburban mixed-uses (Z10). Recommendation Retain Z6 Zoning Map Reference: E Reference Number: 61 Site Address: Rialto Bridge Submission Number(s): 2608 Summary of Issues Requests the designation of the bridge as Z2 zoning. Manager's Response It is not considered appropriate to designate a bridge structure as a part of a residential conservation area. The subject bridge is not located within a conservation area not does it immediately adjoin such an area. Inclusion of the structure on the Record of Protected Structures would be a more appropriate mechanism, if appropriate further to assessment. Recommendation Retain as existing

Map Reference: E Reference Number: 62 Site Address: Lissadel Green Submission Number(s): 2085 Summary of Issues Request to rezone from Z6 to Z1.

Houses on Lissadel Green should not be zoned Z6. There were shops there previously but these have been demolished and houses are now in their place Manager's Response The properties referred to as zoned Z6 for employment purposes, are actually zoned Z3 for neighbourhood uses under the 2005-2011 Plan and are proposed as such under this Draft Plan. It appears there has been a misinterpretation of the Zoning Objectives.

Neighbourhood uses provide for local facilities within a residential area, may include an element of housing and would not be injurious to the residential amenity of adjoining properties. Accordingly, it is recommended to retain Z3 Zoning. Recommendation Retain Z3 Zoning Map Reference: E Reference Number: 63 Site Address: Mourne Road Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

It is submitted that the house and the associate lands are surplus to church requirements and should be rezoned to Z1. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning.

Map Reference: E Reference Number: 64 Site Address: TOPAZ - Kilmainham Submission Number(s): 3140 Summary of Issues Request to rezone Kilmainham, Service Station from Z9 to Z3. Manager's Response It is not considered appropriate to re-zone the subject site Z3 for the purposes of neighbourhood uses given the context of surrounding open space lands and that the site forms part of the Camac River Valley. Re-zoning of the site would also be contrary to the development plan objective to deliver a strategic green network and the OPW Guidelines on Flood Management. Recommendation Retain Z9 Zoning. Map Reference: E Reference Number: 65 Site Address: Chapelizod - Lands at Submission Number(s): 2292 Summary of Issues Request to rezone from Z9 to Z1.

Rezoning request in relation to site in Chapelizod from Z9 to Z1. Manager's Response The site is on part of the banks of the River Liffey and is part of the natural landscaping to the River. The site would be in the flood plain of the River Liffey. Due to its location, and size the zoning should remain the same. Recommendation Retain Z9 Zoning.

Map Reference: E Reference Number: 66 Site Address: 176-179 James’s Street Submission Number(s): 2927 Summary of Issues Request to rezone from Z1 to Z10A.

Rezoning would secure the synergies of the James's St. area, which arise from the clustering of medical related services which is unique in the context of the city. Manager's Response It is not considered appropriate to re-zone the subject site and the lands in the surrounding area are zoned entirely residential. It is recommended to retain this residential zoning in the interest of protecting residential amenity of existing residents in the area. Recommendation Retain Z1 Map Reference: E Reference Number: 67 Site Address: Grand Canal Harbour Submission Number(s): 2877, 2877 Summary of Issues Supports Z5 zoning.

Submission supports the overall provisions of the City Plan, particularly with respect to the proposed rezoning of the site at Grand Canal Harbour from Z I0 to Z5. Manager's Response The support for Z5 Zoning is noted. Recommendation Retain Z5 Zoning

Map Reference: E Reference Number: 68 Site Address: St. James Street Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z5.

The submission points out that it seems odd that the church and surrounding lands are zoned Z15 (Resource lands) instead of Z5 (City Centre) as the adjoining Guinness Brewery lands. At the very least, the parochial house, which has access from Grand Canal Place, should have zoning objective Z5. Manager's Response Agreed. It is considered appropriate to rezone to Z5 to consolidate Z5 zoning. Recommendation Amend Zoning from Z15 to Z5. Map Reference: E Reference Number: 69 Site Address: Law Society of Ireland Site at No.32-No.40 Benburb Street Submission Number(s): 2920 Summary of Issues The Law Society of Ireland supports existing zoning Z5. Manager's Response The support for Z5 Zoning is noted. Recommendation Retain Z5 Zoning

Map Reference: E Reference Number: 70 Site Address: Arbour Hill - 49A-51 - Site at Submission Number(s): 2915 Summary of Issues Supports zoning as Z1. Manager's Response The support for Z1 Zoning is noted. Recommendation Retain Z1 Zoning Map Reference: E Reference Number: 71 Site Address: Rathmines Road Lower (See also H5) Submission Number(s): 2943 Summary of Issues Request to rezone from Z2 to Z8.

The submission requests that the terrace be zoned from Z2 to Z8

(Refer to Reference H5) Manager's Response This area is currently zoned Z2 conservation area and all the houses, plus Rathmines Church, are on the Record of Protected Structures.

The Z8 zoning objective is inappropriate of this location as its purpose is to protect the architectural design and set-piece character of the main Georgian Streets and Squares in the city centre. Because of their city centre location the Z8 zoning allows up to 40% offices. This is considered inappropriate for this particular terrace of properties, which is the subject of a Design Framework to encourage residential conservation areas.

(Note: Refer also to H5 - Same Site) Recommendation Retain Z2 Zoning Map: F

Map Reference: F Reference Number: 01 Site Address: Alfie Byrne Rd. (See also E17) Submission Number(s): 2741, 2790, 2950, 2950, 3148 Summary of Issues Submissions support Z9 zoning and request an amenity action plan. Manager's Response The support for Z9 Zoning is noted.

In terms of the requests for an amenity action plan, this matter will be referred to the Arts, Culture, Leisure and Youth Affairs SPC Recommendation Retain Z9 Zoning

Map Reference: F Reference Number: 02 Site Address: 318 Clontarf Road Submission Number(s): 2776, 2886 Summary of Issues Request to rezone from Z1 to Z3.

The site is now completely in use as a restaurant business with no residential element at the site. The restaurant forms part of an existing local neighbourhood centre which is zoned Z3. Manager's Response The subject site is relatively small in extent with adjoining residential uses (Z1). Re-zoning of the site would represent piecemeal re-zoning of residential uses and would not serve to consolidate the existing neighbourhood centre in the vicinity, which is located further east at some distance away. Accordingly, it is not considered appropriate to re-zone to Z3. Recommendation Retain Z1 Zoning Map Reference: F Reference Number: 03 Site Address: ESB - Poolbeg/North Wall Submission Number(s): 2669, 2669, 3209 Summary of Issues ESB supports retention of Z7. Manager's Response The support for Z7 Zoning is noted. Recommendation Retain Z7 Zoning.

Map Reference: F Reference Number: 04 Site Address: ESB Poolbeg power station Submission Number(s): 2669 Summary of Issues ESB supports retention of Z7.

There should be a new policy that development on Z14 lands on Poolbeg does not undermine the long term operational requirement of existing utilities including the existing power stations. Manager's Response The support for the Z7 Zoning is noted.

Chapter 5.2 addresses the stated concerns regarding the protection of the power stations as strategic infrastructure (Refer to Chapter 5.2, Proposed Text Amendment for Section 5.2.4.14). Recommendation Retain Z7 Zoning Map Reference: F Reference Number: 05 Site Address: Docklands - Railhead/South Port Submission Number(s): 2664 Summary of Issues Request to rezone from Z14 to Z7. Request to rezone from Z9 to Z12.

The Dublin Port Company consider that South Port zoned Z14 is highly unsuitable for residential and office development given the disamenity of 24 hr port use and associated shipping container and cargo movements. The area on the North of the Poolbeg Peninsula could be developed for use by cruise ships and should be re-zoned to Z7. Request to re- Zone the Poolbeg 'pipes field to Z12. Manager's Response It is not considered appropriate to rezone these lands Z7 for industrial uses on the basis that these lands form part of a comprehensive regeneration area and are identified as a Strategic Development and Regeneration Area (Docklands) in Section 15.10.4 and 16.3 of the Draft Plan. An alternative zoning would enable piecemeal development which may prevent comprehensive and integrated redevelopment of the lands.

In addition, the subject lands are designated Zoning Objective Z14 in the Docklands Masterplan 2008. Under the 1997 Dublin Docklands Development Act, the Dublin City Development Plan must have regard and ensure consistency with the Docklands Masterplan. Accordingly, there is no discretion is this regard and the lands should remain as Z14.

Refer to Site E20 Recommendation Retain Z14 Zoning

Map Reference: F Reference Number: 06 Site Address: ESB Synergen power plant Submission Number(s): 2669 Summary of Issues ESB supports retention of Z7. Manager's Response The support for Z7 Zoning is noted. Recommendation Retain Z7 Zoning Map Reference: F Reference Number: 07 Site Address: Pigeon House Road Submission Number(s): 3096 Summary of Issues Request to rezone from Z7 to Z7A. Request to rezone from Z14 to Z7. Request to rezone from Z14 to Z9.

Change from existing Z7A to Z7 to reflect the industrial zoning of the area and consistency with surrounding zoning. Z7A zoning should exclude incineration. Change from Z7 to ZI4 as no Poolbeg plan exists and the sewage plant and working port are essential infrastructure. The area lying to the west of lrishtown Nature Park should be zoned Z9. With the rest of the F6 Docklands Masterplan vision area having Z7 zoning to reflect its existing use. Manager's Response This Z7 Zoning is part of a larger Z7 area, which provides key infrastructure for the city region. Under the Waste Management (amended) Act, 2001, a development plan is required to include the objectives of the Waste Management Plan for its Area. In this regard, the Z7 Zoning reflects the higher level national legislation to a greater extent than the Docklands Masterplan. Accordingly, in this specific instance, it is considered appropriate that the provisions of the draft plan take precedence over the Masterplan.

In respect of all other sites referenced, it is considered appropriate to retain the Z14 Zoning for comprehensive redevelopment, to ensure consistency with the Docklands Masterplan, in accordance with the provisions of the 1997 DDDA Act. Recommendation Retain Z7 & Z14 Zoning

Map Reference: F Reference Number: 08 Site Address: Whitebank Road, Southbank Quay - Site at Submission Number(s): 2069, 2069 Summary of Issues Supports Z14 zoning. Manager's Response The support for Z14 Zoning is noted Recommendation Retain Z14 Zoning Map Reference: F Reference Number: 09 Site Address: Fabriza Developments - Poolbeg Submission Number(s): 3091 Summary of Issues Request to rezone from Z9 to Z14. Request to rezone from Z14 to Z9.

Submission supports the zoning of the majority of the lands as Z14, however, the strip of land immediately adjoining Sandymount Strand should also be zoned Z14 instead of Z9 as open space and amenity can be provided within a future redevelopment of the Z14 lands..

Rezoned to Z9 as recreational space to compensate for the loss of public space and to provide a buffer between the beach and other zoned lands etc. Manager's Response The Z9 Zoning as currently pertaining to a strip of land within the overall Z14 Lands, serves an important function as an amenity strip along Sandymount Strand enabling connectivity with Irishtown Nature Park. It is not considered appropriate to re-zone this strip of land to Z14.

Similarly, it is not appropriate to re-zone the overall site for open space uses, the basis that it has been identified as a Strategic Development and Regeneration Area (SDRA) in the Draft Plan and is also designated as Z14 in the Docklands Masterplan 2008. Under the 1997 Dublin Docklands Development Act, the Dublin City Development Plan must have regard and ensure consistency with the Docklands Masterplan. Accordingly, there is no discretion is this regard and the lands should remain as Z14. Recommendation Retain Z9 & Z14 Zonings

(As shown in Draft Plan) Map Reference: F Reference Number: 10 Site Address: Glass Bottle Site in Irishtown Submission Number(s): 2624, 3070 Summary of Issues Request to rezone from Z14 to Z9. Request to rezone from Z14 to Z7.

From Z14 to public golf course

From Z14 to Z7 Irish Glass Bottle site should be zoned back to Z7.

From Z14 to Z9 Irish Glass Bottle site should be zoned Z9 having regard to need for site remediation works and the potential harm to human health. Manager's Response It is not considered appropriate to re-zone the subject site to alternative land-use zonings, whether Z9 for open space uses or Z7 for industrial uses, on the basis that it has been identified as a Strategic Development and Regeneration Area (SDRA) in the Draft Plan and is also designated as Z14 in the Docklands Masterplan 2008. Under the 1997 Dublin Docklands Development Act, the Dublin City Development Plan must have regard and ensure consistency with the Docklands Masterplan. Accordingly, there is no discretion is this regard and the lands must remain as Z14. Recommendation Retain Z14 Zoning Map Reference: F Reference Number: 11 Site Address: Coast Line (See also H29) Submission Number(s): 3144 Summary of Issues Request to rezone coastline to Z11.

Surprise expressed that there is no Z11 zoning bordering Sandymount and Merrion Strands. The entire 'pipes field ', between Bissets Engineering works and lrishtown Nature Park should be zoned either Z11, Z9 or Zl2. Manager's Response Zoning Objective Z9 for open space applies to the vast majority of the coastline in the Sandymount Area and is considered sufficient to afford protection to the amenity of the coastline. In this regard, the coastline has an important role in the strategic green network for the city and is shown as a strategic green route (See Figure 10). Furthermore, the Natura 2000 Sites are shown on Map J of the Draft Plan and any possible protection of these sites by way of a new zoning would be superseded by the EU Directive as applies to these sites. In any case, the tidal zone above the high water mark lies outside the jurisdiction of Dublin City Council. Accordingly, it is not considered appropriate to introduce a new zoning for the coastline.

In terms of the 'Pipes Field', these lands form part of a Strategic Development and Regeneration Area (SDRA) zoned for comprehensive redevelopment. The lands are also zoned Z14 under the Docklands Masterplan 2008. Under the 1997 Dublin Docklands Development Act, the Dublin City Development Plan must have regard and ensure consistency with the Docklands Masterplan. Accordingly, there is no discretion is this regard and the lands should remain as Z14. Recommendation Retain as existing. Map Reference: F Reference Number: 12 Site Address: Merrion - Sisters of Charity (See also H26) Submission Number(s): 3127 Summary of Issues Request to rezone from Z15 to Z12.

The entire property is likely to become surplus to the Sisters' needs, as they consolidate their administrative requirements on an alternative site in their ownership and the residential needs are similarly consolidated or moved into the wider community. The lands are embedded in the mature residential suburb.

Refer also to reference H26 (same site). Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: F Reference Number: 13 Site Address: Sandymount Avenue Submission Number(s): 2877, 2877, 2928 Summary of Issues Request to rezone from Z15 to Z12 or Z10B.

The subject lands do not provide for an institutional use and there is an existing permission on the subject site (DCC Reg Ref: 2771108; ABP Ref: PL29S.23 191 I ) which provides for the development of a mixed use office and medical related use scheme. Manager's Response The lands on Sandymount Avenue are vacant and not in institutional use and are vacant. There is a current grant of planning permission for office and medical related uses, which would be non conforming uses under Z15 zoning. Given that there is an existing grant of planning permission, it is reasonable that the lands are zoned Z12. Recommendation Change the proposed zoning from Z15 to Z12

Map Reference: F Reference Number: 14 Site Address: 40/56 Serpentine Avenue Submission Number(s): 2091 Summary of Issues Request to rezone from Z3 to Z10A.

The proposed zoning of the lands to objective 'Z10A' would permit a wider range and extent of mixed-uses and would facilitate the timely delivery of a regenerating and revitalising scheme on the subject lands which is close to employment cetres and transport facilities. Manager's Response Z3 Neighbourhood Zoning provides for local facilities such as small convenience stores and services and can form a focal point for the surrounding residential community. Neighbourhood centres provide an essential and sustainable amenity for residential areas. Accordingly, it is not considered appropriate to re-zone the subject lands to Z10 for mixed use development. Recommendation Retain Z3 Zoning Map Reference: F Reference Number: 15 Site Address: Marian College - Lansdowne Road Submission Number(s): 3120 Summary of Issues Request to rezone from Z15 to Z12 and Z1 or Z10B for Swimming Pool.

The Marist Brothers object to change from Z12 to Z15 on grounds that it will adversely impact on capacity to support educational / institutional uses on site. As such, Marian College propose Z12 over entire site, or rezone swimming pool area as Z12, or rezone site to Z1 or Z10B. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning.

Map Reference: F Reference Number: 16 Site Address: No 79 Lansdowne Road Submission Number(s): 3126 Summary of Issues Request to rezone Z9 to Z1.

An appropriate use of the site would be for a small residential building and accordingly it is requested the subject site be re-zoned to Z1. Manager's Response The subject site forms part of the Dodder River Amenity. Re-zoning of the site to Z1 for residential purposes would not be considered appropriate with regard to protection of the river valley amenity, the over-arching objective to deliver a strategic green network and the OPW Guidelines on Flood Risk Management. Recommendation Retain Z9 Zoning Map Reference: F Reference Number: 17 Site Address: No 1 Fitzwilliams Street - Ringsend Submission Number(s): 3103 Summary of Issues Request to rezone from Z1 to Z4.

The site is to the south west of the Library and the older building of Ringsend which are zoned Z4. The block frames the redeveloped library square and is a natural extension of Ringsend Village It is requested that the Z4 zoning of the village be extended to include the subject lands and other sites around the around the newly developed square, which would fully integrate the lands into Ringsend Village. Manager's Response The subject site is located within an existing focal point in Ringsend Village, including a parade of shops and adjoining the public library with its surrounding civic space. It is considered appropriate to re-zone the subject site from residential to mixed-use services and facilities in the interests of consolidating Ringsend Village. Recommendation Amend Zoning From Z1 to Z4 to encompass entirety of perimeter block extending to the north west to existing Z4 zoning. Map Reference: F Reference Number: 18 Site Address: Rail head East Wall Road (See also E20) Submission Number(s): 2664 Summary of Issues Request to rezone from Z14 to Z7.

The port company considers that these lands should be retained for existing and future rail use and the zoning altered to Z7. Manager's Response It is not considered appropriate to rezone these lands Z7 for industrial uses on the basis that these lands form part of a comprehensive regeneration area and are identified as a Strategic Development and Regeneration Area (Docklands) in Section 15.10.4 and 16.3 of the Draft Plan. An alternative zoning would enable piecemeal development which may prevent comprehensive and integrated redevelopment of the lands.

In addition, the subject lands are designated Zoning Objective Z14 in the Docklands Masterplan 2008. Under the 1997 Dublin Docklands Development Act, the Dublin City Development Plan must have regard and ensure consistency with the Docklands Masterplan. Accordingly, there is no discretion is this regard and the lands should remain as Z14. Recommendation Retain Z14 Zoning Map: G

Map Reference: G Reference Number: 01 Site Address: TOPAZ - Kylemore Road Submission Number(s): 3140 Summary of Issues Request to rezone Westway, Kylemore Road Service Station from Z6 to Z3. Manager's Response It is not considered appropriate to re-zone the subject site for the purposes of neighbourhood uses (Z3) given the site forms part of a larger strategic employment landbank (Z6) and re-zoning would facilitate piecemeal development and may preclude comprehensive redevelopment of the strategic lands to cater for the employment needs of the city. Recommendation Retain Z6 Zoning.

Map Reference: G Reference Number: 02 Site Address: Bluebell Ave. Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The submission is made on behalf of the St. Laurence O'Toole Diocesan Trust. The car park area located at the Church is surplus to church requirements and the submission requests that they be rezoned from Z15 (Resource lands) to zoning objective Z1 (Residential) as it is located in a residential area. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: G Reference Number: 03 Site Address: Lands South of Naas Road Submission Number(s): 2842, 3053 Summary of Issues Request to rezone from Z9 to Z14.

The subject site accommodates residential development in the land use strategy of the Naas Road Lands Strategic Plan. In this regard, it is considered that the site should be zoned Objective Z14 in order to accommodate residential development. Manager's Response A portion of the subject site is indicated for development in the adopted Naas Road Local Plan. Specifically, the land-use strategy shows a strip of land along the northern boundary of the site appropriate for residential purposes in principle, which would provide frontage development and passive surveillance of the adjoining open space. Recommendation Amend Zoning From Z9 to Z14 for a portion of the site only along the northern boundary.

The Z14 Zoning to correspond in extent to the lands shown for residential purposes on this site in the Naas Road Local Plan.

Map Reference: G Reference Number: 04 Site Address: Carriglea Industrial Estate Submission Number(s): 2678 Summary of Issues Supports zoning of Z14. Manager's Response Support for Z14 Zoning is noted. Recommendation Retain Z14 Zoning Map Reference: G Reference Number: 05 Site Address: Longmile Road Submission Number(s): 2842, 3053 Summary of Issues Request to rezone from Z15 to Z10B.

Given that the subject site is no longer in use by the Congregation of the Christian Brothers and that they do not intend to use the building and associated land for their services, it is requested that the site is zoned objective Z10B. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: G Reference Number: 06 Site Address: Longmile Road - Sisters of Charity Submission Number(s): 3127 Summary of Issues Request to rezone from Z15 to Z12 and Z4.

There are underutilised parcels of land around the school buildings which would allow for consolidation of the area and be ideal for expansion of adjacent retail facilities in a mixed development. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning.

Map Reference: G Reference Number: 07 Site Address: St. Mary's Cross Kildare Road Crumlin Submission Number(s): 2901 Summary of Issues Request to rezone from Z1 to Z9.

This is the site of a stone Celtic Cross erected by the Historical Society in 2002 to commemorate the site of an original medieval Cross. In considering the location of this site on open space and it's historical importance at a prominent location at the North entrance to the Village a more appropriate zoning objective would be Z9 Manager's Response The subject site is small in extent and relates essentially to the site of a modern commemorative structure. The site is too small to contribute in any meaningful way to the city's Z9 Zoning for open space. Accordingly, it is not considered appropriate to re-zone for open space purposes. Recommendation Retain Z1 Zoning Map Reference: G Reference Number: 08 Site Address: St. Mary's Church, Crumlin Submission Number(s): 2901 Summary of Issues Request to rezone from Z1 to Z9.

As this church is a listed building, and is situated inside a Conservation Area, a more appropriate zoning objective would be Z9 to provide an appropriate space around this building and provide a context for the heritage of this area. Manager's Response It is not considered appropriate to re-zone the site of the church grounds as open space for the purposes of providing a visual context for the church, given that the church is listed on the Record of Protected Structures (RPS) and its protected structure status affords sufficient protection in this regard. Recommendation Retain Z1 Zoning.

Map Reference: G Reference Number: 09 Site Address: Bunting Road - Old St Marys Submission Number(s): 2901 Summary of Issues Request to rezone from Z1 to Z9.

Along Bunting Road where there is a small open space opposite the Old Saint Mary's Church with a statue of Oisin and an area landscaped and maintained by Dublin City Council which is zoned as Z1; this should rezoned to Z9. Manager's Response It is not considered appropriate or necessary to re-zone the subject lands from residential use to open space, on the basis that there are extensive areas of open space zoned lands in the immediate vicinity and that there is sufficient existing open space in the area. Recommendation Retain Z1 Zoning. Map Reference: G Reference Number: 10 Site Address: Sommerville Avenue, Looceville House and Glebe House Submission Number(s): 2901 Summary of Issues Request to rezone from Z1 to Z2.

This area contributes to the character of the Village, therefore it would be more appropriate to extend the conservation area specific objective to include these important buildings. Manager's Response It is considered that the issues raised in the submission relating to the merit of particular buildings for inclusion in the Record of Protected Structures (RPS) and the special character of the area, would be more appropriately addressed by way of assessment of the area for designation of an Architectural Conservation Area (ACA). This is a more appropriate mechanism than re-zoning to residential conservation.

It is noted that a number of submissions have requested the designation of Crumlin Village as an ACA and this will be given consideration over the lifetime of the Plan. Recommendation Retain Z1 Zoning

Map Reference: G Reference Number: 11 Site Address: Saint Agnes Church, Crumlin Submission Number(s): 2901 Summary of Issues Request to rezone from Z1 to Z9.

This zoning objective is not appropriate for this location, as the building here is the focal point for this part of Crumlin Village and as such requires a more robust protection of it's context, suggested by a zoning objective Z9. Manager's Response The purpose of the open space zoning is to preserve, provide and improve recreational amenity and open space and green networks. This zoning would not accurately reflect the existing use of the site which is a church. In addition, a place of workship is not listed under the permissible uses or uses open for consideration under Z9 Open Space. Accordingly, it is not considered appropriate to re-zone the subject site from Z1 to Z9. Recommendation Retain Z1 Zoning Map Reference: G Reference Number: 12 Site Address: Armagh Road - Sisters of Charity Submission Number(s): 3127 Summary of Issues Request to rezone from Z15 to Z12.

Proposed rezoning facilitates appropriate alternative development in the event that the institutional use becomes redundant or the lands are underutilised. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning.

Map Reference: G Reference Number: 13 Site Address: Captains Road/Armagh Road, Dublin 12 Submission Number(s): 3056 Summary of Issues Request to rezone from Z15 to Z12 or Z10A.

The submission requests that the lands at Captains Road/ Armagh Road, Dublin 12 be rezoned from Z15 to Z12 or Z10A as they are no longer in institutional use. Manager's Response Agreed. Lands are no longer key to strategic requirements for Z15 zoning. Balance of lands to remain as Z15. Recommendation Amend zoning from Z15 to Z12. Map Reference: G Reference Number: 14 Site Address: Windmill Road - No.2 Submission Number(s): 2034 Summary of Issues Request to rezone from Z1 to Z3.

The site is bounded by Z3 zoned lands and has a commercial use on the ground floor since the 1930‟s. Properties in the immediate vicinity have a more of a mixed commercial character rather than a residential character. Manager's Response The subject site immediately adjoins lands zoned for neighbourhood uses and it is considered appropriate to re-zone for such uses (Z3) on the basis that it would represent consolidation of an existing neighbourhood centre as a focal point for the surrounding residential community. Recommendation Amend Zoning from Z1 to Z3

Map Reference: G Reference Number: 15 Site Address: 103/105 Crumlin Road Submission Number(s): 2191 Summary of Issues Request to rezone from Z9 to Z1.

Rezone properties at 103/105 Crumlin Road and the rear of 103 Crumlin Road from Z9 to Z1 to reflect the fact that the site has been in residential use for over 100 years. Manager's Response The Z9 Zoning on the subject site is an anomaly given that a residential building occupies the site, which forms part of a larger open space area. It is considered appropriate to amend the zoning for that portion of the open space lands which corresponds to the site as submitted, in order to reflect current uses of the site. Recommendation Amend Zoning From Z9 to Z1 Map Reference: G Reference Number: 16 Site Address: Clogher Road Submission Number(s): 3187 Summary of Issues Request to rezone from Z15 to Z1.

The submission is made on behalf of the St. Laurence O'Toole Diocesan Trust.The car park area located at the Church is surplus to church requirements and the submission requests that they be rezoned from Z15 (Resource lands) to zoning objective Z1 (Residential) as it is located in a residential area. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning.

Map Reference: G Reference Number: 17 Site Address: Terenure College and Templeogue Road Submission Number(s): 3057 Summary of Issues Request to rezone from Z9 to Z15.

The submission objects to the Z9 zoning for playing pitches at Terenure College and Templeogue Road and requests the retention of Z15 on the entire lands in addition to the retention of policies in relation to residential use in Z15. Manager's Response The lands are in use as playing pitches. The rezoning to Z9 would reflect the current active uses to the northern portion of the site which are not considered key to overall strategic Z15 lands. Recommendation Retain Z9 zoning.

Map: H

Map Reference: H Reference Number: Site Address: 19th Century Pembroke Estate Submission Number(s): 2076 Summary of Issues Request to rezone from Z1 to Z8 or ACA.

Submission requests a zoning change of the 19th Century Pembroke Estate from Z1 to make it either a Architectural Conservation Area or Zone Z8. Manager's Response The Pembroke Estate is a large area of the south city with many diverse character areas, much of which is already zoned Z2 (Residential Conservation Areas) with a strong representation on the Record of Protected Structures. The Z8 zoning relates to the set- piece Georgian Squares and is entirely inappropriate for a large area of mainly Victorian buildings.

The merits of parts of the Pembroke Estate as an Architectural Conservation Area will be reviewed on a prioritised basis. Recommendation Retain Z1 zonings in Pembroke Estate (other than those zoned Z2, etc. Already) Map Reference: H Reference Number: 01 Site Address: Harolds Cross - Sisters of Charity Submission Number(s): 3127 Summary of Issues Request to rezone from Z15 to Z12.

The entire property should be zoned Z12. The zoning would facilitate continued development of the hospice and any other required institutional uses on the retained portion of the Sisters' lands. It would facilitate appropriate development of the surplus lands. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning.

Map Reference: H Reference Number: 02 Site Address: ESB - Parnell Ave. - Harolds Cross Submission Number(s): 2666 Summary of Issues ESB support retention of Z1. Manager's Response Support for zoning is noted. Recommendation Retain Z1 Zoning Map Reference: H Reference Number: 03 Site Address: St. Clare's - Harolds Cross Submission Number(s): 3104 Summary of Issues Request to rezone from Z15 to either Z10A or Z10B or Z12.

The previous use, as a convent, has ceased on the site and the buildings are vacant and unsuitable for modern use in their current form. The zoning should be changed in order to attract other uses and the required investment to upgrade the buildings including protected structures at a reasonable cost. There is an abundance of „Z15‟ zoned lands and other amenity lands in the vicinity. Manager's Response The lands are no longer in institutional use and are not key to Z15 requirements, therefore rezoning to Z12 considered appropriate.

Recommendation Amend zoning from Z15 to Z12.

Map Reference: H Reference Number: 04 Site Address: Cathal Brugha Barracks Submission Number(s): 2943, 2948 Summary of Issues Request to rezone from Z15 to Z9.

To retain the long term future of these green spaces Manager's Response Cathal Brugha Barracks is in active military use and the site is largely blanked out on the zoning maps. The future of the barracks is a matter for the Department of Defence, but it was indicated during the preparation of the Rathmines Local Action Plan that it would be kept under review.

The overall site is zoned Z15, which provides for 25% accessible open space in any redevelopment. Given this, together with the fact that the existing playing field may not be in the optimum location in any redevelopment it is considered inappropriate and unnecessary to rezone a small part of this barracks. Recommendation Retain Z15 zoning. Map Reference: H Reference Number: 05 Site Address: Rathmines Road Lower (See also E71) Submission Number(s): 2943 Summary of Issues Request to rezone from Z2 to Z8. Manager's Response This area is currently zoned Z2 conservation area and all the houses, plus Rathmines Church, are on the Record of Protected Structures.

The Z8 zoning objective is inappropriate of this location as its purpose is to protect the architectural design and set-piece character of the main Georgian Streets and Squares in the city centre. Because of their city centre location the Z8 zoning allows up to 40% offices. This is considered inappropriate for this particular terrace of properties, which is the subject of a Design Framework to encourage residential conservation areas. Recommendation Retain Z2 Residential Conservation Area zoning. Map Reference: H Reference Number: 06 Site Address: St. Louis High School Submission Number(s): 2027, 2032, 2136, 2205, 2210, 2212, 2232, 2241, 2247, 2270, 2284, 2288, 2611, 2743, 2762, 2763, 2777, 2820, 2891, 2945, 3111, 3111, 3112, 3122, 3212 Summary of Issues Request to rezone from Z15 to Z10B. Request to rezone from Z15 to Z9.

Part of site should be rezoned to 10B having regard to: contribute to the viability of the convent and school, accommodate a finer grain development, utilise highly accessible suburban location which is surplus to the requirements; provide additional facilities for the school and community; the zoning and use of adjacent lands.

From Z15 to Z9 To retain the long term future of these green spaces Manager's Response In the review of zonings Z12 and Z15 lands, the criteria applied was that if land was in use as institutional, community, educational, health, then it remained. It is quite reasonable given the current use of the land that it remain as Z15. The Z15 zoning will ensure the amenities of the lands will be protected in any proposals for future development as set out in 15.10.15.

With regard to the submissions seeking the rezoning of part of the site for Z9 purposes, it should be noted that the existing Z15 zoning provides for 25% open space in any case. Given this together with the fact that the existing open space may not be in the optimum location for any future layout, it is considered inappropriate to introduce any further zonings. Recommendation Retain Z15 Zoning

Map Reference: H Reference Number: 07 Site Address: ESB - Gulistan Terrace - Rathmines Submission Number(s): 2668, 3208 Summary of Issues ESB Support retention of Z4. Manager's Response The support for the zoning is noted. Recommendation Retain Z4 Zoning. Map Reference: H Reference Number: 08 Site Address: 56 - 58 Rathmines Road Upper Submission Number(s): 2943 Summary of Issues Request to rezone from Z2 to Z8. Manager's Response These two Georgian style terraces are on the east side of Rathmines Road Upper, surrounded by lower scale buildings. They are zoned Z2 Conservation Area and are on the Record of Protected Structures.

The Z8 zoning objective is inappropriate of this location as its purpose is to protect the architectural design and set-piece character of the main Georgian Streets and Squares in the city centre. Because of their city centre location the Z8 zoning is to 40% offices; this is considered inappropriate for this particular terrace of properties, which is the subject of a Design Framework to encourage residential conservation areas. Recommendation Retain Z2 Residential Conservation Area zoning.

Map Reference: H Reference Number: 09 Site Address: Teacher Training College Submission Number(s): 2943, 2948 Summary of Issues Request to rezone from Z15 to Z9.

To retain the long term future of these green spaces Manager's Response Z15 Institutional Lands are characterised by trees and open space which provide a setting and context for the existing buildings on the site. This open character is adequately safeguarded by the Z15 zoning objectives which require 25% accessible open space as part of a Masterplan for any redevelopment. Given this requirement, together with the fact that the proposed Z9 areas may prejudice the proper design and layout of any proposed re-development, it is considered inappropriate and unnecessary to rezone small parts of the overall site for Z9 purposes. Recommendation Retain the Z15 zoning. Map Reference: H Reference Number: 10 Site Address: 44 -54 Rathmines Road Upper Submission Number(s): 2943 Summary of Issues Request to rezone from Z2 to Z8. Manager's Response These two Georgian style terraces are on the east side of Rathmines Road Upper, surrounded by lower scale buildings. They are zoned Z2 Conservation Area and are on the Record of Protected Structures.

The Z8 zoning objective is inappropriate of this location as its purpose is to protect the architectural design and set-piece character of the main Georgian Streets and Squares in the city centre. Because of their city centre location the Z8 zoning is to 40% offices; this is considered inappropriate for this particular terrace of properties, which is the subject of a Design Framework to encourage residential conservation areas. Recommendation Retain Z2 Residential Conservation Area zoning.

Map Reference: H Reference Number: 11 Site Address: No 2 Killeen Road, Ranelagh Submission Number(s): 2639 Summary of Issues Request to rezone from Z2 to Z1.

Requests a zoning change from Z2 to Z1 as Z1 is considered more appropriate. Manager's Response No.2 is part of a coherent streetscape of two storey, redbrick houses, which warrants a consistent zoning. As the rest of the street on both sides is in a Z2 conservation area, this should be retained for No.2. Recommendation Retain Z2 zoning. Map Reference: H Reference Number: 12 Site Address: Nos. 122, 124, 126 and 128 Ranelagh Road, D.6. Submission Number(s): 3064 Summary of Issues Support for Z2 zoning. Manager's Response Noted -refers to a group of protected structures in Ranelagh Village, in a predominantly Z4 zoned area. Recommendation Retain Z2 Zoning

Map Reference: H Reference Number: 13 Site Address: Cherryfield Submission Number(s): 2025, 2162, 2678, 2909 Summary of Issues Request to rezone from Z1 to Z2.

Identical houses on opposite sides of Cherryfield Avenue & Hollybank Avenue Lower are zoned differently, either Z1 (Residential) or Z2 (Residential Conservation Area). Submission requests that these identical houses are all zoned Z2. Manager's Response Hollybank Ave has a coherent streetscape of red brick, bay-windowed terraced houses and merits Z2 Conservation Zoning on both sides

Cherryfield Ave consists of a bay-windowed terrace on both sides of the street, with an unusual white concrete façade in a rusticated pattern which does merits further analysis. Recommendation a) Amend Z2 zoning to include both sides of Hollybank Ave Lower. b) Review Cherryfield Avenue as part of a ACA appraisal. Map Reference: H Reference Number: 14 Site Address: Milltown Park Ranelagh Submission Number(s): 3123 Summary of Issues Request to rezone from Z15 to Z10B.

The submission on behalf of the Jesuits, request to rezone part of the site from Z15 to Z10B. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: H Reference Number: 15 Site Address: Scully's Field Submission Number(s): 2237, 2246, 2279, 2281, 2282, 2772, 2933, 3110, 3156 Summary of Issues Support Z9 zoning. Request to rezone from Z9 to Z1.

Seven submissions support the retention of the Z9 zoning (open space) for the lands known as Scully‟s field as: the area is a vital flood plain to reduce flooding risk, it is a unique amenity on banks of the River Dodder, it is a Conservation Area and an important habitat for wildlife, biodiversity, flora and fauna. The site specific objective to build a public park at Scully‟s Field should be retained. It is an asset on the Dodder linear walk and cycleway.

The owner seeks rezoning of the northern part of the site from Z9 to Z1, together with site specific objective to facilitate an alternative access and delivery of a linear public park. The provision of public open space is unlikely to happen without a driver such as the provision of residential use. The northern section of the site falls outside the floodplain of the River Dodder. Manager's Response Scully‟s Field is a 2Ha approximately wooded/overgrown area located on the north side of the Dodder between Milltown Road and Clonskeagh Road, and south of Ramleh Park (see also H16 – O‟Shea‟s Pub site). The site is privately owned, but there is a right of way along the riverbank. Part of the site, parallel to the river is a Conservation Area. The Office of Public Works flood map records indicate the northern part of the site has not been flooded in recent times, and this is the area which the owner proposes for Z1 housing with the remainder along the river zoned Z9 open space, together with a site specific objective requiring the “delivery” of the linear park in tandem with residential development.

The proposal has considerable merit in that it would help deliver the policies and objectives in the plan, (such as GCO33) to provide a green corridor along the Dodder. However, the Housing Strategy (Appendix 3) indicates that there is more than sufficient zoned housing land available (503Ha) to meet the needs of the city over the next Plan period, while allowing for 50% headroom, as advised in Department of Environment Heritage and Local Government guidance. It is also noted that the existing narrow right of way, while not ideal, does provide for a continuous river walking in the vicinity. In all the circumstances, it is considered the Z9 zoning objective should remain. Recommendation Retain Z9 zoning as existing over whole site. Map Reference: H Reference Number: 16 Site Address: O'Shea's Pub Submission Number(s): 2203, 2246, 2283, 2285, 2286, 2287, 2760, 2933, 3110, 3178, 3197 Summary of Issues Request to rezone from Z6 to Z3 and Z9. Supports Z6 zoning.

Twelve submissions are against the proposed rezoning of the public house and area around O‟Shea‟s Pub from Z3 and Z9 to Z6 (employment/ enterprise) given that the area is a vital flood plain required to reduce flooding risk and Environmental Report (Feb 2010) advises against the rezoning, it would destroy visual amenity of the area from Clonskeagh Bridge; it will damage biodiversity, flora and fauna; and any redevelopment would cause traffic congestion.

The owner of O‟Shea‟s pub welcomes the proposed change in zoning to Z6 as it would allow for refurbishment and the provision of office and retail uses. A site specific objective requiring agreement with Dublin City Council on the provision of Affordable Housing and enhancement of the riverside walk is welcome. Manager's Response The site, beside Clonskeagh Bridge, accommodates the public house (zoned Z3 in the 2005 – 2011 Plan) and a carpark owned by Dublin City Council (zoned Z9 in the 2005 – 2011 Plan). The Office of Public Works flood map records indicate that the site is prone to flooding, and would therefore be subject to rigorous assessment criteria in the recent Department of Environment / Office of Public Works Guidelines on Flood Risk Management which indicate that land areas vulnerable to flooding should not be zoned for development if there is sufficient land zoned for that purpose in the vicinity.

While the rationale for Z6 employment lands is noted, it is considered there is sufficient employment lands in the locality, including the Richview Business Park, (referred to in submission 3197). Similarly, the proposal to promote affordable housing on part of the site is not necessary given the availability of residentially zoned land in areas not at risk for flooding. Having regard to other policies and objectives in the Plan in relation to the Dodder Valley linear park, and the Department of Environment Heritage and Local Government /Office of Public Works guidelines on flooding, it is considered the zoning should revert to Z3 and Z9 as in the 2005 – 2011 Plan. Recommendation Amend the Z6 zoning to Z3 and Z9 as in the current 2005 – 2011 Plan. Map Reference: H Reference Number: 17 Site Address: Donnybrook - Sisters of Charity Submission Number(s): 3127 Summary of Issues Request to rezone from Z15 to Z12.

The proposed rezoning facilitates appropriate alternative development in the event that the institutional use becomes redundant or the lands are underutilised. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning.

Map Reference: H Reference Number: 18 Site Address: Muckross Park Donnybrook Submission Number(s): 3118 Summary of Issues Request to rezone from Z15 to Z12 or Z10B.

The Dominican Sisters object to the proposed change from the existing Z12/Z15 split zoning to Z15 over the whole site, on grounds that former school part is no longer occupied for any institutional purposes. Dominican Sisters propose that either Z12 or Z10B be applied to the northern part of the site. Manager's Response Revert to original Z12/Z15 split zoning on grounds that former school part is no longer occupied for any institutional purposes. Recommendation Amend zoning from Z15 to Z12 to the northern part of the site. Map Reference: H Reference Number: 19 Site Address: Avila Centre - Donnybrook Submission Number(s): 3117 Summary of Issues Request to rezone from Z15 to Z1.

The submission objects to continuation of Z15 zoning on 'Old Avila' site, on grounds that it has ceased use for institutional purposes, and should be zoned Z1 in keeping with adjacent apartment scheme. Manager's Response The lands originally formed part of a larger landholding of Z15 lands. Disposal of a portion of the landholding for residential development (now Bloomfield Park) was permitted on the basis of an overall vision to rationalise occupation on the remaining site. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding further.

The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 Zoning. Map Reference: H Reference Number: 20 Site Address: Donnybrook (Area beside Garda station) Submission Number(s): 2090, 2884 Summary of Issues Request to rezone from Z4 to Z9.

Rezoning of the area beside the Garda station in Donnybrook from Z4 to Z9 as this is the only open civic space area in the village. This should also be declared the villages Civil & Focal Point and have a monument. Manager's Response This carpark is in a central village location and performs a valuable function. The existing Z4 zoning would not preclude a well designed civic space, possibly in collaboration with adjacent sites. Recommendation Retain the existing Z4 zoning. Map Reference: H Reference Number: 21 Site Address: Leinster Rugby Grounds - Donnybrook Submission Number(s): 3076, 3198 Summary of Issues Request to rezone from Z9 to Z10B.

Rezone in order to facilitate a range of uses including potentially introducing student residence halls to support viability of sporting facilities. Request a Specific Local Objective requiring the continuation of the sporting uses of the site. Manager's Response The site, like the Lansdowne (Aviva Stadium) site is zoned Z9 in the Draft Plan and previous Development Plans. However, the current 2005 Development Plan and Draft Plan recognises that some private sports facilities require resources to ensure the long term retention of the facility in the city, and provides in exceptional circumstances for some limited residential development to secure the retention of the primary recreational use.

This dispensation has been availed of at Donnybrook under ref 5890/03 which provided for apartments, a new stand and a pedestrian/cycle path along the Dodder. The new stand has been built. It is considered that the Z9 with the “exceptional” provision is more appropriate for this site than a Z10 mixed use zoning. However, it is recommended that the land use zoning objective be amended slightly to include “student halls of residence “ in addition to residential in exceptional cases. Recommendation a) Retain Z9 zoning for whole site. b) Insert “which may include student halls of residence” to “In highly exceptional circumstances, where it is considered to be required to secure, protect and consolidate the sporting and amenity nature of the lands and retain the facility in the area, some limited degree of residential development may be permitted……” Map Reference: H Reference Number: 22 Site Address: Anglesea Road - Licences Vintners Association Submission Number(s): 2625 Summary of Issues Request to rezone from Z9 to Z1.

Lands at Anglesea Road, Ballsbridge in the ownership of the Licensed Vintners Association. Request the eastern section of the site be rezoned from Z9 to an appropriate zoning to allow residential development on the site. Manager's Response This site lies between Z2 properties on Anglesea Road and the River Dodder, is zoned Z9 with a Conservation Area designation along the Dodder. The site is indicated in an area prone to flooding on the Office of Public Works flood maps.

In the circumstances it is considered that the site contributes to the open space resource of the city and should be retained. Recommendation Retain Z9 zoning.

Map Reference: H Reference Number: 23 Site Address: Land north of RTE Submission Number(s): 3128 Summary of Issues Request to rezone from Z2 to Z15.

The site area at the Northern End of the RTE Campus, surrounding Mount Errol is a potentially viable location for a two-stream National School. It is therefore requested that Dublin City Council consider the possibility of rezoning this portion of the RTE Site as Z15 in its entirety. Manager's Response Given that the area in question, just to the south of Donnybrook Church, is within a Z2 Residential Conservation Area, that includes a protected structure, and that the Z2 zoning provides for education as an open for consideration use, as does the proposed Z12 zoning objective on the RTÉ lands (see H25) it is considered unnecessary and inappropriate to rezone the sites for Z15. Recommendation Retain Z2 zoning and amend the Z15 to Z12 (as per H24 recommendation). Map Reference: H Reference Number: 24 Site Address: RTE - Lands at Submission Number(s): 2604, 2607, 2979, 3128, 3181 Summary of Issues Request to rezone from Z15 to Z10B. Request to retain Z15 zoning.

The RTE campus as a hub of economic activity for both creative and "knowledge" based business has potential to promote economic development and employment in accordance with the Core Strategy. The rezoning would: facilitate the development of a digital broadcasting infrastructure; help drive appropriate mixed-use redevelopment of the remainder of this "brownfield" site which includes the creation of economic, media, software and cultural business clusters and the making available of suitable office, technical and commercial space for both the creative industries and the related "knowledge" based businesses in addition to the provision of some residential space. Also, RTE request a site specific objective relating to media and related creative industries.

Three submissions are against any rezoning and support the retention of the Z15 zoning for the RTE site given that: the current campus design is appropriate; the site signifies a transition from outer to inner city; the digital communication industry has less space requirements; the development of multi-storey buildings on this site will be visually obtrusive and detract from residential amenities; and would be contrary to policy to concentrate office use in the city centre. The "economic corridor" between TCD and UCD would lead to a much more intensive form of development on these lands. The Z15 zoning would require the retention of 25% open space within the site and the protection of its present open character.

A submission suggests that the site area at the Northern End of the RTE Campus, surrounding Mount Errol is a potentially viable location for a two-stream National School. It is therefore requested that this portion of the RTE Site be rezoned as Z15 in its entirety. Manager's Response This draft Development Plan provides for a shift in emphasis with regard to „institutional‟ zoned lands, such that Z15 becomes more a long term resource for the city, providing community, educational, green infrastructure, and institutional uses. Z12 zoned lands, on the other hand, relate to lands where the institutional use has ceased or is no longer appropriate.

In the case of this site it is noted that some 1900 are employed there, with potential employment for 4,000 in media, broadcasting and associated activity, according to RTÉ. As such it is considered more appropriate to zone the site Z12, (as now proposed), where the objective is to provide a variety of uses, the range of which depends on the character and location of the lands and proximity to district centres/public transport.

With regard to the concern about economic corridors, (more appropriately termed innovations corridors), the Draft Plan explicitly states that such corridors do not have any zoning or height repercussions (para 3.2.2.2 etc.)

The concerns about impact on the Seaview Terrace Conservation Area is addressed by the policies on transitional zoning (15.9) and the standards on shadowing etc. Similarly the Protected Structures on site are protected under the Planning Acts, and the significance of any 1960‟s buildings can be assessed at planning application stage.

The Z12 zoning provides for 20% publicly accessible open space in any redevelopment.

Given the importance of the campus for the media and broadcasting, and as part of the smart economy which Dublin City Council is promoting, it is considered appropriate to include a specific objective to facilitate such uses on the site, as offered by RTÉ. Recommendation Amend zoning from Z15 to Z12, with a site specific objective “to facilitate the development of the RTÉ campus as a hub of media and related creative industries which support the smart economy within a quality physical environment.”

Map Reference: H Reference Number: 25 Site Address: Park Ave Sandymount - Bethany House Submission Number(s): 2644 Summary of Issues Request to rezone from Z15 to Z1.

The proposed Z1 zoning would be supportive of a proposed development of sheltered housing, as well as private residential development which is required to facilitate funding for the charity's continuing work. The rezoning of the site is not like commercially driven projects as the rezoning of the site will have a tangible public benefit in terms of the quality of the residential accommodation for residents of the facility. Manager's Response The request for the rezoning from Z15 to Z1 of this part of the property is to facilitate the replacement of 38 single storey sub-standard sheltered accommodation residential units owned and run by the Society of St. Vincent's de Paul at Bethany House. The request to rezone to Z1 is reasonable give the purpose is to improve accommodation for vulnerable members of the community. Recommendation Change the zoning from Z15 to Z1 residential. Map Reference: H Reference Number: 26 Site Address: Gilford Road, Park Avenue - Sisters of Charity (See also F12) Submission Number(s): 3127 Summary of Issues Request to rezone from Z15 to Z12.

The entire property is likely to become surplus to the Sisters' needs, as they consolidate their administrative requirements on an alternative site in their ownership and the residential needs are similarly consolidated or moved into the wider community. The lands are embedded in the mature residential suburb. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning.

Map Reference: H Reference Number: 27 Site Address: TOPAZ - Merrion Road Submission Number(s): 3140 Summary of Issues Request to rezone service station, Merrion Road from Z1 to Z3 Manager's Response The petrol station is opposite St Vincent's Hospital in the middle of a residential area. The site is too small to make a viable shopping parade given proximity of other retail areas in vicinity. Recommendation Retain Z1 zoning. Map Reference: H Reference Number: 28 Site Address: Gowan Motors - Merrion Road Submission Number(s): 2272 Summary of Issues Request to rezone from Z15 to Z1.

Either rezone to Z1 or make residential a permissible use under Z15 Manager's Response While the garage adjoins the large St Vincent's Hospital site (also Z15), it is also surrounded by a residential Conservation Area (Z2) on two sides on Herbert Avenue. As the site is not critical to the functioning of the main Z15 hospital site, a Z1 residential zoning is considered appropriate. Recommendation Amend the zoning from Z15 to Z1 residential. Map Reference: H Reference Number: 29 Site Address: Coast Line (See also F11) Submission Number(s): 3144 Summary of Issues Request to rezone coastline to Z11.

There should at least be a strip of Z11 zoning above the high-water mark. The entire 'pipes field ' and adjacent Green Corridor should be zoned either Z11, Z9 or Zl2. Manager's Response Zoning Objective Z9 for open space applies to the vast majority of the coastline in the Sandymount Area and is considered sufficient to afford protection to the amenity of the coastline. In this regard, the coastline has an important role in the strategic green network for the city and is shown as a strategic green route (See Figure 10). Furthermore, the Natura 2000 Sites are shown on Map J of the Draft Plan and any possible protection of these sites by way of a new zoning would be superseded by the EU Directive as applies to these sites. In any case, the tidal zone above the high water mark lies outside the jurisdiction of Dublin City Council. Accordingly, it is not considered appropriate to introduce a new zoning for the coastline.

In terms of the 'Pipes Field', these lands form part of a Strategic Development and Regeneration Area (SDRA) zoned for comprehensive redevelopment. The lands are also zoned Z14 under the Docklands Masterplan 2008. Under the 1997 Dublin Docklands Development Act, the Dublin City Development Plan must have regard and ensure consistency with the Docklands Masterplan. Accordingly, there is no discretion is this regard and the lands should remain as Z14. Recommendation Retain as existing. Map Reference: H Reference Number: 30 Site Address: Merrion Road - 288 Submission Number(s): 2764, 2766, 2767 Summary of Issues Request to rezone from Z9 to alternative zoning.

Shelter Cycling has operated a glass recycling project for non profit on the site for 40 years.The yard is currently zoned Z9 which puts the future of Shelter Referral in jeopardy. The zoning should be changed in order to reflect the historical and the current use of the site. Manager's Response The submission relates to a narrow piece of land between the DART Line and Merrion Road, south of Merrion Gates. The strip to the north of the site is Z9, while the land to the south is zoned Z6, enterprise and employment.

Z9 provides for public service installations as a permissible use; which includes use as a bring centre and green waste composting centres. It is considered the existing use falls within the ambit of this definition. Recommendation Retain Z9 Zoning Map Reference: H Reference Number: 31 Site Address: Merrion Road - Sisters of Charity Submission Number(s): 3127 Summary of Issues Request to rezone Z15 to Z12.

The proposed rezoning recognises the existing uses of the properties, facilitates the continued operation of existing uses and their expansion where proposed, whilst facilitating alternative development in the event that the institutional use becomes redundant or the lands are underutilised. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning.

Map Reference: H Reference Number: 32 Site Address: Orwell Park - 52-54 Submission Number(s): 2868 Summary of Issues Request to rezone from Z12 to Z1.

Change zoning from existing Z12 to Z1 to reflect current use of site for housing & recognise that lands no longer form part of the adjacent institutional lands. Manager's Response The three residential units have been built and are now separate from the adjacent Z10 lands. Recommendation Amend zoning from Z12 to Z1. Map Reference: H Reference Number: 33 Site Address: Highfield Road Submission Number(s): 3008 Summary of Issues Request to rezone from Z1 to Z9 or Z15.

The historic use of the site has been horticultural production and that the sustainability of the community would benefit from retention of this use. The site could become a 'green engine' for community based programmes. Manager's Response The site is tightly contained by residential properties on three sides and St Luke‟s Hospital to the west side and has an awkward access. A Z9 zoning (recreational and open space) in this location is inappropriate to this location on access, amenity and lack of passive surveillance grounds. For similar reasons the site is not appropriate for institutional or community purposes. Recommendation Retain Z1 Residential zoning. Map Reference: H Reference Number: 34 Site Address: 75 Orwell Road, Rathgar, Dublin 6 Submission Number(s): 3062 Summary of Issues Request to rezone from Z15 to Z10B.

This submission seeks the rezoning of the southern portion of the lands from Z15 zoning to Z10B. It is contended that the retention of the Z15 zoning on this site is not appropriate as planning permission has beeen granted on this site and the Redemptorist Congregation have adopted a strategy to develop the lands to the southern portion of the site to facilitate the consolidation of the institutional use on the northern part of the site. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain Z15 zoning. Map Reference: H Reference Number: 35 Site Address: Terenure Road West Submission Number(s): 2230 Summary of Issues Request to rezone from Z15 to Z1.

Planning permission was granted for a residential scheme under ref (3455/08). The lands are not in the ownership or use of an educational or an institutional organisation/community infrastructure of any kind. The rezoning of these lands to Z1 would therefore not cause any conflict with the City Council's stance that there are sufficient residential lands zoned as it forms part of the southside institutional lands which benefit from planning permission for residential development. Manager's Response The purpose of the Z15 zoning objective as set out in Section 15.10.15 is to emphasise that these lands are an important resource in the achievement of a compact sustainable city with a full range of community infrastructure. The Z15 zoning does not preclude the provision of other minor developments which are deemed to be „open for consideration‟. Comprehensive residential development can be considered once it is demonstrated by submission of a schematic masterplan that the lands are not required for existing or future community and institutional purposes. Minor developments are not subject to the requirement to prepare such a masterplan. Having regard to this, it is not considered appropriate to reduce the strategic Z15 landholding.

Recommendation Retain as Z15 zoning. Map Reference: H Reference Number: 36 Site Address: Harolds Cross Submission Number(s): 2278, 2798 Summary of Issues Request to rezone from Z10A to Z1.

The south east side of a site at the north- west corner of Mount Tallant Avenue and Harolds Cross Road should be changed from Z10A to Z9. The zoning of the site must reflect the set back imposed by condition under a grant of Planning Permission. The majority of the area is zoned Z1. Manager's Response Site fronting Harold‟s Cross Road is part of the former “St Pancras “Works site, which has an unimplemented planning permission for a c.150 residential units. It would be premature to reconfigure the existing Z1/Z10 zoning of the overall site until a permission has been implemented. Recommendation Retain the Z10 zoning.

Map Reference: H Reference Number: 37 Site Address: Site north of 289 Harold's Cross Road Submission Number(s): 2278 Summary of Issues Request to rezone from Z3 to Z1.

Rezone property immediately to the north of no.289 Harold's Cross Road from Z3 to Z1. Manager's Response Vacant and boarded up two storey former showroom set back from main building line. There are three commercial units to Northside and one (Designlight – see H39) to south. Site is within a local parade, offering services to community and should remain Z3 (neighbourhood facilities). Recommendation Retain Z3 zoning. Map Reference: H Reference Number: 38 Site Address: 289 Harolds Cross Submission Number(s): 2278 Summary of Issues Request to rezone from Z3 to Z2.

Rezone no.289 Harold's cross Road 'DesignLight' from Z3 to Z2. Part 3A of submission & photos of sites located towards end of submission. Manager's Response „Designlight‟ is a two storey corner premises and is part of a Z3 neighbourhood cluster of services. Commercial / retail uses are not permissible in the Z2 conservation area (See H38). Recommendation Retain Z3 zoning.

Map Reference: H Reference Number: 39 Site Address: West Corner Mount Tallant Avenue Submission Number(s): 2278, 2798 Summary of Issues Request to rezone from Z10A to Z6.

Brighton Square Association consider that Z6 employment is more appropriate than Z10A mixed use. Manager's Response The Z10 zoning promotes for a mix of uses in any future redevelopment of the site and does not inhibit the continuation of existing longstanding use. Z6 zoning is considered inappropriate in an area closely surrounded by existing and proposed residential uses. Recommendation Retain Z10 zoning. Chapter 16 Guiding Principles Submission Number(s): 2030, 2044, 2055, 2168, 2184, 2199, 2211, 2212, 2248, 2278, 2298, 2333, 2605, 2606, 2653, 2671, 2676, 2694, 2784, 2794, 2802, 2822, 2860, 2870, 2878, 2905, 2913, 2920, 2932, 2935, 2941, 2943, 2960, 2964, 2966, 3003, 3009, 3026, 3070, 3071, 3083, 3090, 3101, 3124, 3144, 3147, 3151, 3158, 3159, 3165, 3166, 3167, 3168, 3169, 3171, 3173

Section: 16.1 The Public Realm, Urban Form and Architecture

Summary of Issues The submissions received in relation to „The Public Realm, Urban Form and Architecture‟ raise a broad range of issues. Some raise very specific issues, for example proposals to improve a particular street, while other raise issues such as maintenance of public lighting or restriction on use of a particular brick to the façade of buildings, etc. Some of the issues raised are dealt with in earlier chapters of this report. Manager's Response In general the submissions have raised site specific queries or matters beyond the remit or control of the Development Plan. The Guiding Principles are set out in order to guide the design and development of future proposals and cannot address pre- existing situations. Manager's Recommendation Retain as existing.

Section: 16.2.4 Sustainable Buildings

Summary of Issues This submission received from the Royal Institute of Architects of Ireland (RIAI) makes direct reference to Green Infrastructure Guiding Principles. A summary of the relevant issues is as follows: Appropriate design standards in relation to building & site geometry. Encourage design which can be adapted in relation to climate change. Encourage design which considers orientation and Passive solar gain. Encourage design which maximizes Thermal Mass opportunities. Encourage buildings to be naturally lit and ventilated where possible. Ability for cross ventilation to be encouraged. Encourage design which maximize the floor to ceiling heights and avoids deep plan building which rely on artificial lighting. Encourage construction methods and materials which require less energy to produce and install Encourage buildings which are designed to be flexible and designed for future systems to be fitted (for example: openable windows; structures services to be designed to allow PV panels to be retro fitted etc). Barriers to Sustainable design to be avoided such as: Ensuring control standard will not adversely affect attempts at passive design or inclusion of renewable energy installations. Ensuring sustainable design does not fail because of misguided aesthetic or visual reasons i.e. it may not necessarily reflect the existing character, appearance or materials employed in the surrounding area. Resilience: Require south facing roof structures of new build residences to have the structural capacity, and be wired for, future PV panels (when they become economically feasible which is likely to happen at some point) Manager's Response The draft plan contains a substantial number of policies, objectives and standards along with supporting text to encourage sustainable building design namely, Objectives GC03, Policy QH10 in Section 11.4.3, Guiding Principles for Sustainable Buildings in Section 16.2.4 (all development proposals incorporate a building design to utilise sustainable energy technologies and innovative design solutions) and Development Standards for Sustainable Site and Building Design in Section 17.1.4. These components of the plan address the issue of green roofs, SUDS, passive solar gain, use of green materials, use of natural ventilation, energy efficient window glazing units, air tightness of buildings, use of thermal mass and insulation, renewable technologies, water conservation measures etc. It is considered that the relevant issues have been addressed in the draft development plan. Manager's Recommendation Retain as existing.

Section: 16.2.5 Green Roofs

Summary of Issues The Society of Chartered Surveyors expresses the view that development schemes should also include green walls as well as green roofs.

Manager's Response Section 16.4.5 requires that all development proposals to incorporate a building design to utilise sustainable energy technologies such as living walls. A „living wall‟ is another term for a „green wall‟ Manager's Recommendation Retain as existing.

Section: 16.3 Principles for Strategic Development and Regeneration Areas

Summary of Issues The submissions highlighted a number of areas that would benefit from additional or amended SRDA principles or designation to guide future development such as the designation of the City Markets or amendment of the SDRA 7 and SDRA 8. Some submissions object to the designation of areas including SDRA 6, while others welcomed the designation and the guiding principles included, such as at O‟Devaney Gardens. A number of submissions highlighted inconsistencies in SDRA 6 for the Docklands area and suggest further development principles be included. Manager's Response The issues raised in the submissions are noted. Strategic Development and Regeneration areas relate primarily to former strategic Z14 sites and the former strategic Z13 sites which are now combined. All of the sites identified can deliver significant quantums of mixed uses to create synergies to regenerate their respective areas.

The Guiding Principles for SDRA6 refer to the area to the north of the Liffey only. Further guiding principles should be added to guide each area zoned Z14 as set out at section 15.10.14, that is SDRA 6 Docklands, comprising Spencer Dock, Poolbeg and Grand Canal Harbour. Manager's Recommendation Replace existing SDRA 6 in its entirety with the following wording at Section 16.3, Page 185

SDRA 6 Docklands (Spencer Dock, Poolbeg, Grand Canal Dock)

The Docklands Strategic Development and Regeneration Area comprises the three major areas of Spencer Dock North, Poolbeg, and Grand Canal Dock as set out in the DDDA Masterplan 2008. Future development shall be informed by the following development principles set out for each area.

Spencer Dock North 1. To develop a new urban neighbourhood based on sustainable densities and with a strong sense of place, a „bridge‟ between the established communities of East Wall and North Wall/Sheriff Street. 2. To facilitate the provision of a socially cohesive community through the provision in an integrated manner of a wide range of housing types and tenures. 3. To create a high quality physical environment through the development of a coherent spatial structure based on a hierarchy of linked streets and spaces. 4. To open up the Royal Canal as a central component of this spatial structure, as a linear park - a „green lung‟, a vital connector to the River and a generator of a network of linked public spaces. 5. To improve accessibility from this new neighbourhood and the adjoining neighbourhoods to the city centre and the I.F.S.C. through the development of an integrated public transportation system. 6. To create a permeable quarter by removing existing physical barriers between these lands and the adjoining neighbourhoods of East Wall and North Wall/Sheriff Street and developing of a network of pedestrian and cycle linkages. 7. To explore alternative and innovative ways of creating a new public dynamic and energy within the linear park and forging a physical synergy between the park and future developments on the adjoining lands to the east.

Poolbeg 1. To ensure that new development facilitates the implementation of a global landscape plan for the Poolbeg Peninsula developed in the context of the unique landscape qualities of the peninsula, river and bay area. 2. To ensure that significant dimensions of the landscape framework are implemented as part of any future development in utilities. 3. To support a „differentiated character‟ approach within an overall landscape framework that will allow for the consolidation of specific activities. 4. An urban scale and form of development with mixed use and defined areas of „predominant character‟. 5. To allow for utilities operation and expansion within an overall environmental improvement strategy and landscape plan. 6. To promote and protect the ecology of the area, while providing for recreational open space with public access within a consolidation framework for public utilities, including the re-use of historic structures. 7. To improve accessibility through the development of a movement framework with a strong emphasis on public transport, pedestrian/cycle networks and incorporating innovative approaches geared to developing sustainable modes of commuter movement and car parking. 8. To initiate a phased development of both commercial development and public realm – landscape/road infrastructure. To ensure that key elements of the landscape framework are of the highest quality design and are implemented early in the overall phasing plan to set future precedent for area character. 9. To ensure phased implementation of major redevelopment sites can be linked to the implementation of significant public realm packages of the landscape framework plan identified outside of the commercial sites in question. 10. To ensure that all development is compatible with the nature conservation designations of the south bay. 11. To ensure that the unique landscape qualities of the Poolbeg Peninsula, rivers and bay area are recognised in any development proposals for the Poolbeg area and that the existing open character and nature of the views from Irishtown Nature Park are retained as far as practicable.

Grand Canal Dock 1. To facilitate sustainable urban densities in this important character area. 2. To sensitively regenerate key brownfield sites cognisant of their context, while optimising their potential to contribute to the city in economic and employment terms. 3. To forge spatial connections with the wider Docklands Area, the city centre and the surrounding neighbourhoods. 4. To recognise Grand Canal Dock Dart Station as a major provider of public transport accessibility in the area. 5. To recognise the emerging role of Grand Canal Dock as a cultural destination in the city.

Section: 16.4 Principles for Building Height in a Sustainable City

Summary of Issues The submissions raised a number of issues and were broad in scope. Some objected to the designation of certain areas for taller buildings and the associated guiding principles for areas including Georges Quay, Pelletstown, Clonshaugh Industrial Estate, Phibsborough etc. Others suggested additional areas to be included, for example Liberty Hall. Some of the submissions recommended minor changes to the text for General Principles or for particular areas such as Heuston or Clonshaugh.

Manager's Response Section 16.4 was included in the Draft Plan to provide principles for building height for each of the identified areas for taller buildings and also to inform Local Area Plans, or Strategic Masterplans. It is clearly set out that the principles should be read in conjunction with the standards for building heights and the development principles set out elsewhere in the Plan, in addition to various land use plans and designations. The issues raised in the submissions are generally minor in nature and would represent a duplication of policy guidance and development standards contained elsewhere in the Plan including Chapter 4, Shaping the City and Chapter 17 Development Standards. In this respect it is not considered necessary to amend Section 16.4. Manager's Recommendation Retain as existing.

Chapter 17 Development Standards Submission Number(s): 2001, 2004, 2010, 2015, 2041, 2043, 2048, 2070, 2082, 2083, 2086, 2095, 2108, 2109, 2131, 2136, 2137, 2156, 2157, 2159, 2170, 2171, 2175, 2188, 2194, 2195, 2198, 2199, 2205, 2210, 2227, 2232, 2235, 2240, 2241, 2242, 2243, 2245, 2247, 2249, 2251, 2253, 2259, 2261, 2270, 2273, 2276, 2277, 2278, 2284, 2288, 2289, 2290, 2291, 2295, 2298, 2302, 2303, 2312, 2327, 2328, 2329, 2330, 2331, 2332, 2333, 2334, 2335, 2336, 2337, 2338, 2339, 2340, 2341, 2342, 2343, 2344, 2345, 2346, 2347, 2348, 2349, 2350, 2351, 2352, 2353, 2354, 2355, 2356, 2357, 2358, 2359, 2360, 2361, 2362, 2363, 2364, 2365, 2366, 2367, 2368, 2369, 2370, 2371, 2372, 2373, 2374, 2375, 2376, 2377, 2378, 2379, 2380, 2381, 2382, 2383, 2384, 2385, 2386, 2387, 2388, 2389, 2390, 2391, 2392, 2393, 2394, 2395, 2396, 2397, 2398, 2399, 2400, 2401, 2402, 2403, 2404, 2405, 2406, 2407, 2408, 2409, 2410, 2411, 2412, 2413, 2414, 2415, 2416, 2417, 2418, 2419, 2420, 2421, 2422, 2423, 2424, 2425, 2426, 2427, 2428, 2429, 2430, 2431, 2432, 2433, 2434, 2435, 2436, 2437, 2438, 2439, 2440, 2441, 2442, 2443, 2444, 2445, 2446, 2447, 2448, 2449, 2450, 2451, 2452, 2453, 2454, 2455, 2456, 2457, 2458, 2459, 2460, 2461, 2462, 2463, 2464, 2465, 2466, 2467, 2468, 2469, 2470, 2471, 2472, 2473, 2474, 2475, 2476, 2477, 2478, 2479, 2480, 2481, 2482, 2483, 2484, 2485, 2486, 2487, 2488, 2489, 2490, 2491, 2492, 2493, 2494, 2495, 2496, 2497, 2498, 2499, 2500, 2501, 2502, 2503, 2504, 2505, 2506, 2507, 2508, 2509, 2510, 2511, 2512, 2513, 2514, 2515, 2516, 2517, 2518, 2519, 2520, 2521, 2522, 2523, 2524, 2525, 2526, 2527, 2528, 2529, 2530, 2531, 2532, 2533, 2534, 2535, 2536, 2537, 2538, 2539, 2540, 2541, 2542, 2543, 2544, 2545, 2546, 2547, 2548, 2549, 2550, 2551, 2552, 2553, 2554, 2555, 2556, 2557, 2558, 2559, 2560, 2561, 2562, 2563, 2564, 2565, 2566, 2567, 2568, 2569, 2570, 2571, 2572, 2573, 2574, 2575, 2576, 2577, 2578, 2579, 2580, 2581, 2582, 2583, 2584, 2585, 2586, 2587, 2588, 2589, 2590, 2591, 2592, 2593, 2594, 2595, 2596, 2597, 2598, 2599, 2600, 2601, 2602, 2603, 2604, 2605, 2606, 2608, 2609, 2610, 2611, 2612, 2613, 2614, 2615, 2616, 2617, 2618, 2619, 2622, 2629, 2641, 2649, 2650, 2653, 2655, 2656, 2660, 2661, 2662, 2664, 2671, 2674, 2677, 2724, 2743, 2744, 2746, 2747, 2749, 2752, 2757, 2759, 2762, 2763, 2768, 2769, 2777, 2783, 2789, 2792, 2793, 2794, 2798, 2799, 2802, 2804, 2806, 2807, 2810, 2811, 2812, 2816, 2818, 2819, 2820, 2821, 2836, 2845, 2847, 2854, 2860, 2870, 2872, 2875, 2877, 2878, 2879, 2883, 2884, 2891, 2892, 2899, 2903, 2907, 2909, 2912, 2913, 2914, 2917, 2918, 2922, 2929, 2930, 2931, 2932, 2935, 2938, 2940, 2943, 2945, 2946, 2947, 2949, 2950, 2951, 2953, 2954, 2957, 2958, 2959, 2960, 2961, 2963, 2964, 2965, 2966, 2971, 2973, 2974, 2980, 2981, 2982, 2987, 2988, 2989, 2992, 2993, 2994, 2995, 2996, 3003, 3010, 3016, 3019, 3020, 3021, 3026, 3030, 3032, 3033, 3034, 3036, 3038, 3040, 3041, 3043, 3046, 3049, 3052, 3065, 3066, 3070, 3071, 3077, 3080, 3083, 3084, 3087, 3091, 3092, 3094, 3095, 3096, 3097, 3098, 3101, 3102, 3106, 3108, 3109, 3111, 3112, 3113, 3122, 3124, 3125, 3135, 3138, 3139, 3140, 3142, 3144, 3146, 3147, 3153, 3154, 3157, 3158, 3159, 3160, 3161, 3162, 3163, 3164, 3165, 3166, 3167, 3169, 3170, 3171, 3173, 3175, 3182, 3184, 3188, 3189, 3190, 3191, 3192, 3193, 3196, 3201, 3211

Section: 17.1 Design, Layout, Mix of Uses and Sustainable Design Summary of Issues It is submitted that clear design guidance should be developed in this section for the roofscapes of the city. This should include advice on the integration of plant and modern service requirements (Dublin Civic Trust). Further it is suggested that the new plan should include specific standards aimed at protecting the streetscape and local character. Manager's Response Section 16.1.9 „Architectural Design‟ provides guidance on setbacks and clutter at roof level. Furthermore, Appendix 23 „Guidelines for Residential Extensions‟ provides guidance on roof design. Section 16.1.3.provides guidance on „Making Successful Streets‟ considering the character of the streetscape. Also, Paragraph 17.11 states that roof forms should harmonise with and not clash with the city's traditional roof forms. Manager's Recommendation Retain as existing.

Section: 17.1.4 Sustainable Site and Building Design

Summary of Issues To reduce the energy demand of all developments, several design considerations were suggested including: passive solar design, use of green building materials, use of energy efficient systems, Improving building envelope air tightness, use of thermal mass and insulation, use of renewable energy, use of green/ living roofs and walls, water conservation measures, district heating and waste recycling.

Submissions suggest that a number of points be added relating to sustainable site and building design and energy efficiency including SUDS, water fixtures, waste management, flood risk impact assessment, sustainability statements, and wastewater treatment capacity.

Further suggestions include a study the potential for generating renewable energy using photovoltaic panels on rooftops etc. and the installation of solar panels on residential buildings should be permitted development. One submission considers that the energy efficiency section is incomplete.

It is submitted that consideration of the use of energy in developments should be incorporated at an early stage in the design process including BER requirements; that policies aimed at reducing "embodied CO2" emissions in developments be included and; that paving front gardens for car parking creates drainage issues. Manager's Response Section 17.1.4 „Sustainable Site and Building Design‟ seeks the use of green buildings materials with low embodied energy, the use of recycled materials, district heating schemes, combined heat and power, . Section 16.2 „Green Infrastructure Guiding Principles‟ has requirements relating to permeable paving, rainwater harvesting, Sustainable Urban Drainage Systems, The Planning and Development Regulations 2008 provide for exemptions in respect of renewable technologies including solar panels. Chapter 5.2 „Water, Drainage, Waste, Energy, and Telecommunications Infrastructure‟ includes policies relating to waste management, water supply, wastewater, flood management, sustainable urban drainage systems, energy supply, energy efficiency, district heating and combined heat and power systems. The use of efficient water fixtures and Building Energy Ratings are a matter for the Building Regulations. Appendix 14 provides guidance on waste storage facilities. The sustainability of a proposed development will be considered as part of the development management process. Taking the above into account, it is considered that that it is appropriate to retain the existing policies, objectives, guiding principles and standards, bearing in mind that the Development Plan is a strategic document. Manager's Recommendation Retain as existing.

Insert further cross-references as appropriate.

Section: 17.2.3 Public Open Space - All Development

Summary of Issues Two submissions consider that the requirement to provide 10% open space provision for inner city Z6 lands should be removed and the 10% requirement should only apply to outer city Z6 sites.

It is further submitted that public open space provision should include a minimum percentage towards allotments, community gardens or urban agriculture where practical; that the Plan make provision for substantial quantities of public and private open space to make new accommodation desirable as a place to live for all residents and particularly for families and the elderly. It is also suggested that more squares and communal spaces should be created to encourage people to gather together and chat which is the essence of community spirit. Manager's Response Section 17.2.3 „Public Open Space – All Development‟ and the open space requirements contained in the section 17.9 „Standards for Residential Accommodation‟ ensure that public, communal and private open space is provided where appropriate. There is a requirement for all development to provide 10% public open space on Z6 lands to develop the green network, enhance biodiversity, and enhance public open space throughout the city, although it is considered appropriate that in regard to the recreational needs of families reference be made in this standard to playgrounds/play spaces as a type of public space.

The 17.2.3 standard provides safeguards where a site is too small or of an inappropriate shape to provide public open space or where there is evidence that there is sufficient existing public open space in area.

Policy GC15 supports the provision of community gardens/allotments/ local markets/pocket parks, where feasible and in particular as temporary uses on vacant, under-utilised or derelict sites in the city and objective GCO16 supports on a phased basis, the development of allotments on appropriate sites in the city. Manager's Recommendation Amend Text, Section 17.2.3 Public Open Space - All Development, P.200, 3rd paragraph, 2nd line:

From: provide local parks, provide outdoor civic spaces/plazas

To: provide local parks, provide playgrounds/play spaces, provide outdoor civic spaces/plazas

Section: 17.3 Density Standards

Summary of Issues The majority of the submissions in relation to this issue state that the Density Standards set out in the Plan are excessive and should be reduced to conform to the Department of Environment, Heritage and Local Government‟s “Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas”, which seek a minimum of 50 dwellings per hectare. There is concern that any increase in density will necessitate an increase in general height and will impact on the character of existing areas.

Some submissions consider that the Density Standards set out are too low, particularly for the city centre. They state that the Development Plan should be targeting increased densities for the recovery and future success of the City. A submission received from the National Transport Authority strongly emphasises that it will be necessary to retain the Draft Development Plan‟s density standards as a minimum, in order to support and not compromise the planned investment in transport infrastructure under the Transport 21 investment programme. The submission further highlights that the Government‟s policy document „Smarter Travel, A Sustainable Transport Future‟ states that there is a “requirement that development in urban rail corridors be high density and appropriate for public transport use”. Manager's Response Land is a finite resource. It is important to ensure its efficient use by facilitating increased sustainable density. The approach taken in the Draft Development Plan is to set out indicative, net and minimum densities of 100 uph in the inner city, 50 uph in the outer city and 75 uph within major public transport catchments (excluding Luas), Key Districts Centres and Developing Areas.

The Draft Plan makes it clear that while sustainable densities are the goal of the Plan, in all cases final densities will be dependent on the scheme design, location and context. There are numerous caveats in the Plan to ensure high quality standards of development in the attainment of sustainable densities, whilst the policies and objectives set out in the conservation chapter further safeguard the special character and fabric of the city, particularly conservation areas. In all cases, appropriate density levels are ultimately determined both by the design of the building and as a result of meeting the requirements of various issues such as sunlight, daylight, access and privacy.

The standards set out are based on the Department of Environment, Heritage and Local Government‟s “Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas” which highlight that, “The State has committed very substantial investment in public transport under the Transport 21 capital programme. To maximise the return on this investment, it is important that land use planning underpins the efficiency of public transport services by sustainable settlement patterns – including higher densities – on lands within existing or planned transport corridors”. The Department Guidelines are national standards and state that, “In general, minimum net densities of 50 dwellings per hectare, subject to appropriate design and amenity standards, should be applied within public transport corridors, with the highest densities being located at rail stations / bus stops, and decreasing with distance away from such nodes”. When the Department refers to minimum standards this is the lowest desirable density and not a maximum density. The Department Guidelines clearly emphasise that subject to appropriate safeguards, “there should, in principle, be no upper limit on the number of dwellings that may be provided within any town or city centre site”.

The Density Standards set out in the Draft Development Plan have been refined from this clear national guidance to reflect the fact that Dublin is the capital city of the state, with the greatest investment in public transport and that a 50 uph (minimum) (20 per acre) is a comparatively low density. In particular, the Minimum Density Standard of 75 uph within Public Transport Corridors excludes light rail, ie Luas. Significant areas of the existing and proposed light rail network in the city will not be supported by appropriate density standards as required by Departmental and Regional Guidance. For the purpose of comparison, existing mainline rail has a current passenger capacity in the region of 8.5-10,000 per hour. Luas carries circa 4-5,000 passengers per direction per hour. It is expected that following network upgrade, that this capacity will increase to circa 8-10,000 passengers per hour, i.e. the same as mainline rail today. Having regard to the issues raised by the National Transport Authority, It is therefore considered essential that Luas be included in the category of Public Transport Catchments where minimum densities of 75 uph is generally promoted in order to safeguard investment set out in the Transport 21 programme.

A reduction in density standards in the context of Dublin as a capital city would curtail the opportunities for developing sustainable mixed use development which serves the common good by supporting an intensity of amenities and good public transport, and would be inconsistent with the recommendations of the “Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas”.

Manager's Recommendation Amend Density Standards on Page 201, Section 17.3 From: Increased densities will be required at public transport nodes and corridors and within public transport catchments. Distances of 1 kilometre from existing or proposed mainline, DART and Metro Stations define public transport catchments. Minimum densities of 75 units per hectare will be promoted within catchments. The capacity of public transport will be taken into consideration in determining appropriate densities in all cases, in addition to the policies for conservation areas.

To: Increased densities will be required at public transport nodes and corridors and within public transport catchments. Distances of 1 kilometre from existing or proposed Dart or Metro Stations, or 800 metres from Luas Stations define public transport catchments. Minimum densities of 75 units per hectare will be promoted within catchments. The capacity of public transport will be taken into consideration in determining appropriate densities in all cases, in addition to the policies for conservation areas.

Section: 17.4 Plot Ratio

Summary of Issues The submissions on this issue request amendment to the Plot Ratios set out in Section 17.4 of the Draft Plan for the various land use zonings. The key concern raised in the majority of these submissions is that the Plot Ratios set out are too high and should be decreased for each of the land use zones. A number of other submissions call for Plot Ratios to be increased. Manager's Response The submissions received which propose a decrease in the Plot Ratios set out in the Plan are noted. The Plot Ratios proposed in the submissions are generally considered to be too low for the promotion of sustainable patterns of development in a complex urban environment, having regard to the need to make the best use of available land and the need to safeguard investment in infrastructure.

Plot Ratio is a tool to help control the bulk and mass of a building and to guide the form of a development. The Plot Ratios set out are indicative and are one of many standards used to assess the suitability of a design or development on a particular site. Other standards include site coverage, density, public and private open space, car parking, overlooking, overshadowing etc. Plot Ratio cannot determine final built form in isolation to other development standards or considerations. Section 17.4 of the Draft Plan clearly explains the concept and application of Plot Ratio and the appropriate Plot Ratios in various zoning objectives. It is not considered appropriate to amend the Plot Ratios as requested. Manager's Recommendation Retain as existing.

Section: 17.5 Site Coverage

Summary of Issues The submissions on this issue request amendment to the Site Coverage standards set out in Section 17.5 of the Draft Plan for the various land use zonings. The key concern raised in the majority of these submissions is that the Site Coverage standards set out are too high and should be decreased for each of the various land use zones. A number of other submissions call for Site Coverage standards to be increased. Manager's Response The submissions received which propose a decrease/increase in the Site Coverage standards set out in the Plan are noted. The Site Coverage standards proposed in the submissions are generally considered to be too low for the promotion of sustainable patterns of development in a complex urban environment, having regard to the need to make the best use of available land and the need to safeguard investment in infrastructure.

Site Coverage is simply a tool to guide against overdevelopment in urbanised locations where standards such as open space and parking are not the primary determinant of site coverage. The Site Coverage standards set out are indicative and are one of many standards used to assess the suitability of a design or development on a particular site. Other standards include plot ratio, density, public and private open space, car parking, overlooking, overshadowing etc. Site Coverage cannot determine final built form in isolation to other development standards or considerations. Section 17.5 of the Draft Plan clearly explains the concept and application of Site Coverage and the appropriate Site Coverage standards in various zoning objectives. The special circumstances where higher Plot Ratios are warranted also apply to Site Coverage. It is not considered appropriate to amend the Site Coverage standards as requested. Manager's Recommendation Retain as existing. Section: 17.6 Building Height in a Sustainable City (See Fig. 21)

Summary of Issues Please also refer to Chapter 4, Section 4.4.4.1, Approach to Taller Buildings.

The Department of Environment Heritage and Local Government welcome the guidance provided in relation to the location and design of taller buildings but request the Plan to be amended to be clear on the purpose of the guidance and on the meaning of the terms used. In particular, it should be clarified whether it is policy to promote taller buildings in certain locations or to specify locations in which taller buildings may be delivered as part of delivering higher densities.

The Department also highlights that it is policy (SC15) of Dublin City Council to protect and enhance the intrinsic quality of Dublin as predominantly low to medium rise city, and to provide for taller buildings in the designated limited locations (see Fig. 21), but states that it is unclear whether this policy is to be read with regard to the definitions of low rise and mid rise elsewhere in the Plan. The definition of low rise in section 17.6.2 would encompass the vast majority of buildings in the city today so there may be need to clarify the terms used in Policy SC15 and elsewhere.

A large proportion of the overall submissions received relate to taller buildings or „high rise‟. The majority of submissions strongly oppose taller buildings in general. Many of these submissions request amendments to the definition of High Buildings set out in the Draft Plan to reduce the number of storeys permissible in each category of Low Rise, Mid Rise and High Rise. Other submissions relate to „Areas Identified as Appropriate for High Buildings‟ (Figure 21) and request the majority of areas in the city to be re-categorised as Low Rise with High Rise only allowable in areas such as Docklands and Heuston. Many of the submissions make reference to Clonshaugh Industrial Estate requesting that it be removed from the category where taller buildings are permitted. Further submissions state that for all proposed buildings that are one or more storeys higher than adjoining buildings, an agreed urban design statement with agreed standards should be mandatory, and that height be determined with reference to protected structures in ACAs.

Submissions were also received in general support for the height standards set out in Chapter 17. The Dublin Docklands Development Authority welcomes the designation of the Docklands as an area for taller buildings in the Draft Plan. They also note that not all areas of the Docklands may be suitable for taller buildings.

Some of the submissions received request an increase in the number of storeys permissible in each category of Low Rise, Mid Rise and High Rise. In particular major emphasis is placed on the economic importance of height in the central business district or city centre area and other key development areas. A selection of the key concerns raised in these submissions are set out in the paragraphs below.

The ESB indicate that they wish to remain at their current HQ site at 28 Lower Fitzwilliam Street, D2. It is suggested that it is essential that the Plan include a height range of up to 8 storeys for commercial use if the final adopted policies in support of major employment and economic growth in the city centre are to be realised. The Royal College of Surgeons In Ireland have stated that the building height strategy for the inner city is overly restrictive in its current format and will limit investment in the city centre as well as compromise the RCSI to maintain and further develop their functions in the city centre.

A submission made on behalf of St. James‟s Hospital state that new patient services and facilities will necessitate an increase in height of new buildings compared with the existing. Specifically, the proposed private hospital and centre of excellence are identified as being nine storey buildings, while the Radiation Oncology Centre is identified as a six storey building. The submission goes on to specifically state that the proposed height controls contained in the Draft Plan will prohibit the sustainable development of a modern hospital campus in the city. The HSE has also made a submission expressing reservations in relation to the height limitations in the Draft Plan. They state that this could limit development for hospitals to between 6 and 8 floors and at present there are a number of development, either on site or in planning which will exceed this.

A number of site specific height requests were received. All request height to be increased on particular sites for various reasons including location on a transport corridor, potential for a landmark building, strategic site location, increasing intensity of use, site zoning, etc. Other submissions request the inclusion of further areas of the city that are seen as suitable for taller buildings.

One submission requests the removal of the 2nd last paragraph of Section 17.6.2 of the Draft Plan which dictates that the provisions of the Liberties Local Area Plan be incorporated into the Dublin City Development Plan and supersede and relevant section of the Plan, stating that this is clearly contrary to the Planning and Development Act. Manager's Response Section 17.6 „Building Height in a Sustainable City‟ acknowledges the intrinsic quality of Dublin as a predominantly low rise city. Height is specifically limited to the identified areas in order to preserve this low rise character. The majority of the city is zoned Z1 or Z2 whereby existing character and context is maintained by policies and standards in the Plan. It is emphasised that proposals more than two storeys above surrounding must have a contextual urban statement.

In view of the issues raised in the submissions relating to height in the inner and outer city, it is considered necessary to further refine height policy for the Low Rise category. It is recommended that the inner city category be revised to 8 res/8 office; that the outer city category be revised to 6 res/6 office and that the Rail Hubs be revised to 6 res/8 office. For clarity, the Low Rise category will relate to the prevailing local context. The Low Rise category does not mean that low rise is interpreted as up to 8 storeys across the city. Additional text should be added to Section 17.6.2 to clarify this key point. In addition there are numerous policies and standards designed to safeguard character, context and amenity for all proposed development below 8 storeys. The changes in the low rise category are necessary to ensure Dublin retains a competitive advantage, with particular reference to the city centre, Key Developing Areas and Key District Centres.

Many submissions were received that oppose the areas identified for height and the categories for Low Rise, Mid Rise and High Rise set out. The incorporation of the suggestions raised in these submissions would severely limit the areas where taller building could be considered as part of sustainable mixed development, i.e. to Docklands and Heuston only. This would have severe repercussions for the city in relation to economic renewal and competitiveness. Any such restriction would be unreasonable and would be a deterrent to property investment and urban regeneration. This could clearly lead to a diversion of commercial development outside the country. Such restrictions would also conflict with the key strategies in the Plan to provide quality, mixed use development with a variety of tenure and types which promote the creation of vibrant new neighbourhoods. A recent example of this approach can be seen at Herberton (Fatima).

In accordance with the recommendations of the Department of Environment Heritage and Local Government, it is proposed to amend the third paragraph of 17.6.1 to replace the existing wording to clarify that the Development Plan is not promoting height but restricting it to areas where it may occur.

For avoidance of doubt, the height policy is to specify limited locations in which taller buildings can be considered for identity or economic reasons. Height and density are not linked in the Plan. Policy SC15 will be amended to omit reference to a „low to medium rise city‟ and refer only to a „low rise city‟. Supporting text will be added to the fourth paragraph of 17.6.1 to provide a greater linkage to the qualitative and quantitative standards against which all proposed taller buildings will be assessed outside the identified areas.

As per Motion 1400 of the previous Manager‟s Report, it is considered that the preparation of an Urban Design Statement to analyse the impacts of a proposal more than one storey higher that the prevailing height in the vicinity is unduly onerous, particularly where there are numerous safeguards set out in the Development Standards section to assess such proposals and safeguard the character and context of existing areas, including in ACAs and conservation areas. The current standard requires the preparation of an Urban Design Statement for proposals more than two storeys higher than the prevailing height in the vicinity.

One submission requests the removal of the concluding paragraph of Section 17.6.2 of the Draft Plan which dictates that the provisions of the Liberties Local Area Plan be incorporated into the Dublin City Development Plan and supersede and relevant section of the Plan, stating that this is clearly contrary to the Planning and Development Act. The comments are noted. This provision was introduced by way of Council Motion. Manager's Recommendation Amend the third paragraph of 17.6.1 From: While promoting height in the identified areas, Dublin City Council will continue to adopt a co-ordinated policy approach.

To: While facilitating height in the identified areas, Dublin City Council will continue to adopt a co-ordinated policy approach.

Amend text to the fourth paragraph of 17.6.1: From: Outside the identified mid to high rise areas, all proposed buildings will be assessed against the qualitative and quantitative standards set out in the Development Plan, including those standards addressing local character, streetscape, open space, daylight and the amenity of existing and future residents

To: Outside the identified mid to high rise areas, all proposed buildings will be assessed against the qualitative and quantitative standards set out in the Development Plan, including those standards addressing local character, streetscape, open space, daylight and the amenity of existing and future residents, set out in Chapter 17, from Section 17.1 to 17.41.6 where relevant.

Insert text to Section 17.6.2 to Low Rise Category: From: Low-Rise

To: Low-Rise relates to the prevailing local context.

Amend text in Section 17.6.2, Low Rise Category in the Inner and Outer City: From: Inner City – Up to 8 res/6 office – Below 25m Rail Hubs - Up to 6 res/6 office - Below 19/25m Outer City – Up to 6 res/4 office – Below 19m

To: Inner City – Up to 8 res/8 office – 25m/33m Rail Hubs - Up to 6 res/8 office - 19m/33m Outer City – Up to 6 res/6 office – 19m/25m

Amend Policy SC15; From: To protect and enhance the intrinsic quality of Dublin as a predominantly low to medium rise city and to provide for taller buildings in the designated limited locations (See Fig. 21).

To: To protect and enhance the intrinsic quality fo Dublin as a predominantly low rise city and to provide for taller buildings in the designated limited locations (See Fig. 21)

Section: 17.7 Access for All

Summary of Issues Concern was expressed in a number of submissions regarding lighting, ramps, steps, artworks, cyclists in certain areas. It is submitted that stepped entrances are becoming increasingly uncommon features in new developments which may conflict with traditional townhouse design. Manager's Response Section 17.7 „Access for All‟ indicates that Dublin City Council will have regard to the National Disability Authority‟s Building For Everyone Planning Guidance (Booklet 9, 2009), the UK Lifetime Homes Standards, and will seek to encourage the implementation of best practice standards with regard to access in relation to both indoor and outdoor environments. Lighting, ramps, steps, artwork and signage in the existing built environment are beyond the scope of the Plan. Cycling in unauthorised areas is an enforcement matter for An Garda Siochana. Building regulations are a separate code and are beyond the scope of the Plan, however, innovative design which facilities access to residential buildings will be promoted through the development management process. Manager's Recommendation Retain as existing. Section: 17.9 Standards for Residential Development

Summary of Issues It is submitted that all apartments should be built to sufficient standards to provide sufficient residential amenity including opens space, storage, light etc. Concern was expressed in submissions regarding the overall size and quality of apartments which have been constructed in recent years. It is perceived that appears that apartments are being built to the minimum standards which negatively impacts on ventilation, sunlight and energy efficiency and that environmental standards for noise, light pollution, streetscape quality are needed. It is further submitted that a Party Wall Act should be introduced. People with mobility issues are confined to ground floor units.

It is submitted that the City Council must address 'quality of life issues' and that there is a need to address the issue of poor quality housing in the inner city in order to retain families and create a vital and vibrant city. Submissions also state that there is a need for a variety of housing types in the inner city and that the Draft Plan should include a positive policy dealing with all the residential typologies and seek to protect existing residential amenities.

Two submissions state that a balance of owner occupation to rental occupation contributes to harmony and cohesiveness. Manager's Response The enhanced standards in the draft plan aim to provide high quality apartments including open space, storage, daylight, sunlight and energy efficiency. Producing legislation in relation to party walls is beyond the scope of the plan. Setting the balance of owner occupier / rental properties in an area is beyond the scope of the plan. The draft plan encourages the provision of a variety of housing typologies (policy QH3) and seeks to protect existing residential amenities (standard 17.9.8) and to value the character of existing buildings and streetscape where appropriate (17.10.8.1). Some people do want to live in the city and want to live in high quality apartments which is what the standards for residential accommodation aim to achieve. The building regulations are a separate code and are beyond the scope of the development plan, however, it should be noted that the draft standards contains provisions relating to improving acoustic privacy (A1/5). Many modern apartments buildings contain one or more lifts which together with universal design features should enable people with mobility issues to live or access upper floors. The draft plan provides a coherent spatial framework for the delivery of sustainable development to ensure an improved quality of life for its citizens as outlined in the context for the Development Plan. Manager's Recommendation Retain as existing.

Section: 17.9.1 Residential Quality Standards

Summary of Issues Submissions suggest that dwelling units must include larger size apartments with good private amenity space in the form of roof gardens or internal balconies; that detailed conditions should be placed on developers to ensure higher-quality homes including screening, storage areas on balconies, and communal satellite dishes and broadband facilities etc.

The RIAI submit that, in relation to all dwellings, Dublin City Council should have regard to the principles and standards outlines in DoEHLG guidance. Further, it is submitted that the plan needs to reflect the importance of household gardens to the wellbeing of their users. Manager's Response Guaranteeing construction quality is beyond the scope of the Development Plan but is covered by alternative mechanisms such as the Homebond scheme and the certificate of compliance scheme. Standard B1/3 aims to ensure that new residential developments are designed to be safe and secure. Standard B2/1 „Communal Open Space‟ facilitates the provision of roof gardens. Standard A2/3 provides for minimum storage requirements for apartments. Standard B2/4 provides that windows should be designed to enable cleaning from the inside where possible and the provision of maintenance facilities. The screening of utilities will be considered as a visual amenity issue as part of the development management process. It is considered that the suggestion to provide for communal satellite dish and broadband facilities merits the inclusion of a relevant standard.

The draft plan does recognise the importance of private open space and requires the provision of such space in new residential development and standard 17.9.8 seeks to ensure that extensions and alterations to dwellings have no unacceptable effect on the amenities of adjacent property.

The draft plan aims to provide high quality apartments at sustainable densities which are suitable for families and provide with good amenity spaces and parking where appropriate. Policy QH1 in Chapter 11 states that is policy to have regard to the DoEHLG Guidelines on „Quality Housing for Sustainable Communities – Best Practice Guidelines for Delivering Homes Sustaining Communities‟ (2007); „Delivering Homes Sustaining Communities – Statement on Housing Policy‟ (2007), „Sustainable Urban Housing: Design Standards for New Apartments‟ (2007) and „Sustainable Residential Development in Urban Areas‟ and the accompanying Urban Design Manual: A Best Practice Guide (2009). Manager's Recommendation Amend standard to include a new sentence at the end of second paragraph of B2/4 „Management and Maintenance‟ (p.216) From: Service ducts serving two or more apartments should be accessible from common areas for maintenance purposes

To: Service ducts serving two or more apartments should be accessible from common areas for maintenance purposes. The provision of facilities to provide for communal satellite and broadband services should be provided.

Section: A1 The Unit - All Residential Development

Summary of Issues Submissions requested that consideration be given to; the potential of deck access to reduce maintenance costs and facilitate more dual access apartments etc.; south facing apartments may not be compatible with low carbon development and north light can be good quality if properly designed; a relaxation of standards for effective treatment of street corners or 5% of development proposals. It is submitted that the plan makes no provision for studio apartments or for accommodation for single persons. The RIAI make a number of suggested word additions/changes to allow residential floor space standards to be established at local plan level. Manager's Response The Council has regard to the DoEHLG „Sustainable Urban Housing: Design Standards for New Apartments‟ (2007). The Draft Plan contains acoustic privacy standards for residential development (A1/5) however noise regulations are part of the building regulations which are beyond the scope of the plan. It is envisaged that proposals to extend bedsit / flats would comply with the general residential standards of the plan, however, there is a safeguard in section 17.9 indicating that standards may be relaxed in relation to the refurbishment of existing buildings subject to the provision of good quality accommodation.

There is concern that extensive deck access detracts from the residential amenity of apartments along the deck due to the proximity of apartment windows to the deck which may significantly diminish privacy, daylight / sunlight, and create more noise etc for occupants. The draft plan allows for a limited length of deck access and states that the key performance criterion is the quality of residential amenity.

The draft plan envisages that a single person would occupy a one bedroom apartment and seeks to achieve target average floor areas in order to provide high quality homes which are flexible and spacious to allow for changing circumstances and encourage living at sustainable densities.

The standards in the draft plan such as the requirement to provide internal floor to ceiling heights of 2.7m will be balanced with other provisions of the plan including those aimed at protecting streetscape character etc a s part of the development management process. The intention is to limit the amount of single aspect apartments and make them high quality units when they are constructed. Good design can achieve the standards on most sites whilst simultaneously addressing the issue of solar gain. However, the standard 17.9.7 does allow for the standards to be relaxed in order to ensure infill and vacant inner city sites can be developed.

The target average floor area is a universal standard for the whole of the city in order to enhance the quality of apartment homes. Planning legislation is clear that a Local Area Plan must be consistent with the provisions of the Development Plan. Therefore, it would be inappropriate to put different residential standards in a Local Plans etc. Manager's Recommendation Retain as existing.

Section: A2 The Unit - Apartments only

Summary of Issues The RIAI submit that the specified mix of residential units should be established by Local Area Plans etc. Other submissions state that there is a need to improve apartment standards by increasing the amount of private space provided, ability to dry clothes; that the minimum floor to ceiling height of 2.7m adds unnecessary building and operating costs to apartments. A further submission suggests that the minimum 3 bedroom requirement may be too low for a site on Mount Tallant Avenue. Manager's Response The draft plan contains a standard for drying clothes (A2/4), and a standard for private / communal open space and balcony sizes (A2/2). The draft plan contains a standard for the mix of residential units including a requirement for 15% or more three bedroom units which is universal and not site specific. If considered necessary, a higher proportion of family units could be sought on individual sites through the development management process. Well designed and appropriately defined ceilings ensure quality residential amenity. The 2.7 minimum floor to ceiling height in apartments is in tended to increase the sense of space in apartments, provide well proportioned rooms, promote the penetration of daylight into the depths of the apartment, contribute to flexibility of use, and achieve quality interior spaces.

Planning legislation is clear that a Local Area Plan must be consistent with the provisions of the Development Plan Therefore, it would be inappropriate to put conflicting residential standards in a Local Area Plans etc. Manager's Recommendation Retain as existing.

Section: A3 The Unit - Houses only

Summary of Issues Submissions suggest that separation distances and other residential standards including open space provision should be established for houses and apartments based on the appropriate density of the development and also, that the balcony standards for apartments should be applied to houses and mews. Manager's Response Standard A3/1 „Private and Communal Open Space‟ and standards 17.9.14 „Mews Dwellings‟ refer to achieving traditional 22m rear separation distances, however, both standards allow for separation distances to be relaxed subject to safeguards protecting residential amenity etc. The A3/1 standard refers to first floor windows as it is envisaged that ground floor windows will not result in significant overlooking. The draft plan does not contain minimum separate distances for apartments and it is envisaged that this issue will be addressed through the development management process with a balance being achieved between creating sustainable densities and creating a satisfactory standard of residential amenity for future occupants.

The approach taken in the draft plan is to provide standards for different typologies where possible and to seek a variety of house types which achieve an overall sustainable density of development. The reduced private open space standard for apartments applies to the Docklands, Key Development Centres, Ballymun as well as the inner city to foster sustainable densities. Whilst there is a reduced private open space requirement for houses in the inner city, a balance has to be struck between encouraging the provision of houses in the city and creating houses which are suitable for families with children. In general, houses and apartments have a fundamentally different private open space characteristics and it would not be appropriate to apply balcony standards to houses.

In the context of the issues raised above, it is considered that the text of the draft plan should be amended to refer to private open space standard for Key District Centres rather than Key Development Centres. Manager's Recommendation Amend the second table in standard A2/2 „Private & Communal Open Space (p.212) From: Inner City / Docklands / Key Development Centres / Ballymun

To: Inner City / Docklands / Key District Centres / Ballymun

Section: B2 The Scheme - Apartments only

Summary of Issues It is submitted that poor management companies are a significant problem and that developers should be required to submit a Maintenance Audit with planning applications. With regard to design, suggestions made on design features include: windows that can be cleaned from the inside, low maintenance materials on facades, slow growing planting etc. and that the Council should organise a competition / study on low maintenance, high density housing schemes. Manager's Response There is a policy relating to property management in the Chapter 11, however, issues relating to payments and fees for management companies are beyond the scope of the plan. A maintenance strategy should be prepared under Standard B2/4 „Management and Maintenance‟ to ensure buildings and the landscape are properly maintained over the life of the building, including building maintenance systems and strategies should be incorporated into the design of the building envelope, roof and facades to allow for safe cleaning and maintenance of the building fabric. This standard also seeks the use of windows that are designed to enable cleaning from the inside and durable materials etc. Objective SCO15 seeks to develop a set of assessment criteria for the improvement of architectural quality and which will give guidance for development and provide a means of guiding and assessing design quality. Density and maintenance issues would be relevant to the development of such criteria. Manager's Recommendation Retain as existing.

Section: 17.9.4 Back to Back Dwellings

Summary of Issues It is submitted that a relaxation of this standard could be applied if courtyard/patio type houses similar to the high density houses in Amsterdam were proposed. Manager's Response In general back to back dwellings will not be permitted due to their single aspect. Manager's Recommendation Retain as existing. Section: 17.9.5 Backland Development

Summary of Issues A submission requests the removal of the entire paragraph which relates to backland development. It is also submitted that there needs to be strong prohibition of backland development in the case of protected structures. Manager's Response The removal of this paragraph would result in a policy vacuum in relation to backland development.

Dublin City Council recognises that backland development can conflict with the established pattern and character of an area. Accordingly, applications for backland development will be considered in accordance with this standard which states that such development must not be piecemeal, or result in loss of privacy etc. to existing properties.

If the site is of appropriate size a well designed comprehensive backland development can contribute to meeting the housing needs of the city. Manager's Recommendation Retain as existing.

Section: 17.9.6 Corner / Side Garden Sites

Summary of Issues Concern is expressed that Section 17.9.6 of the draft Plan slightly relaxes the building line provision for corner sites and that the current Plan's restriction to maintain the building line should be observed and maintained.

One submission requests that in Z2 Conservation areas the protection of the established character and historic fabric should take precedence. Manager's Response There is no objection to the re-insertion of 15.9.12 (third bullet point) of the 2005 Development Plan regarding building lines into the Draft Plan. It was excluded previously as it was considered that the issue was adequately dealt with in the previous bullet point.

It is considered that the issue of protection of the established character and the requirement of development proposals to harmonise with adjoining buildings is adequately dealt with in section 17.9.6 of the draft plan. Manager's Recommendation Insert new bullet point to the final paragraph of section 17.9.6 after the first bullet point:

The maintenance of the front and side building lines where appropriate. Section: 17.9.7 Infill Housing

Summary of Issues A submission states that the regulations regarding infill housing developments should be categorical (e.g. remove the generally from „generally not be accepted‟) and that the character of Z2 areas must take precedence over any such development. Manager's Response Section 17.9.7 is considered appropriate due to the diverse and wide range of site typologies within the City. It is not considered appropriate to develop a development standard for every type of site. Section 17.9.7 allows for development proposals on a variety of different site typologies.

It is considered that the issue of protection of the character of Z2 zoned areas is adequately dealt with in section 17.9.6 of the draft plan. Manager's Recommendation Retain as existing.

Section: 17.9.8 Extensions and Alterations to Dwellings

Summary of Issues One submission received requests that there should be more balance between household needs and the look of a building. Manager's Response Applications for planning permission to extend dwellings are dealt with on their merits and will generally be granted provided that the proposed works have no adverse impact on the character and scale of the dwelling and provided that the proposal has no unacceptable effect on the amenities enjoyed by the occupants of adjoining buildings. (See also Appendix 23) Manager's Recommendation Retain as existing.

Section: 17.9.11 Basements

Summary of Issues The introduction of a new section on basements is welcomed.

It is requested that an additional statement be included, stating that basements intended for underground parking, in all areas having a high water table, such as Sandymount, will not be permitted because of underground tidal influences and streams/ rivers. It is also requested that the raising of site ground levels in these areas will not be permitted (alterations in ground levels have resulted in flooding).

Further suggestions include; the exclusion of the development of basements in protected structures and that in residential conservation areas basements should not be allowed where their construction results in the removal of mature trees and landscaping. Concern was expressed that the city is built upon a myriad of underground rivers and streams and that large scale underground development will act as a dam and have a catastrophic effect upon adjoining areas.

Manager's Response Section 17.9.11 provides detailed guidance for basement proposals which adequately deals with the issues raised in the submissions. In particular it is stated that the impact on the water table and/or any underground streams and sewers and the impact of any proposal on future planting and mature development of vegetation and trees on the site will be taken into consideration in considering applications for basement developments. It is also the policy of Dublin City Council to discourage any or any significant underground or basement development below ground level of, or adjacent to, residential properties in Conservation Areas or properties which are listed on the Record of Protected Structures. Manager's Recommendation Retain as existing.

Section: 17.9.14 Mews Dwellings

Summary of Issues It is submitted that the potential relaxation of this standard may will give rise to developments which will be seriously short of required minimum standards. It is further submitted that the regulations regarding mews developments should be categorical (e.g. remove the generally from „generally not be accepted‟) and that the character of Z2 areas must take precedence over any such development.

Other submissions request that any future development of residential mews sites must permit only 1 unit per original house and that the text be amended to state that in Z2 Conservation Areas all such developments must harmonise in style and material and to include the requirement that the provision of rear access to the main frontage premises should be encouraged for maintenance purposes. Manager's Response Section 17.9.14 was transposed from the 2005 Development Plan. The 15m2 of private open space standard may be relaxed for proposals located in the suburbs provided any residential buildings comply with minimum private open space standards and the proposed mews dwelling has a rear garden with a minimum length of 7.5metres for its entire width.

It is considered inappropriate to amend the wording of this development standard to remove the word “generally” as applications are dealt with on their merits and a “one size fits all” approach does not apply to all sites. The safeguards in-built into Section 17.9.14, which define exceptional circumstances, are considered adequate to protect mews lanes, adjoining buildings and the character of an area.

It is considered inappropriate to restrict the future development of residential mews sites to accommodate one unit per original house. Given the diverse and wide range of site typologies within the City such a standard would be contrary to proper planning and sustainable development. Therefore it is considered that no change is required.

It is stated in section 17.9.14 that new buildings should complement the character of both the mews lane and building with regard to scale, massing, height, building depth, roof treatment and materials. This is considered sufficient to deal with the issue raised.

Allowing provision of rear access to the main frontage premises would be in conflict with the private open space standard requirement for a mews dwelling which requires a minimum length of 7.5metres for the entire width of the site. Manager's Recommendation Retain as existing.

Section: 17.10.1 Works to Protected Structures

Summary of Issues It is submitted that Section 15.7 - Relaxing of zoning standards for protected structures is not strong enough to protect Protected Structures and that the phrase 'certain cases' lacks definition and will come to mean 'all'.

Submissions contend that the standards are designed to facilitate ongoing alterations and modification to protected structures to meet current requirements and that this policy can only over time lead to the destruction of Protected Structures.

Further it is considered that roof lights and solar panels are unsightly on Protected Structures and that Section 5 Declaration applications should be considered in this context.

In relation to advertising, An Taisce suggest that hoardings satellite dishes etc should not be erected to the front of a Protected Structure.

As an incentive to owners to restore townhouses, while adhering to professionally considered advice, it is suggested that Dublin City Council should waive development levies for Protected Structures provided that owners conduct professionally verifiable works to a best standard of practice. Manager's Response This standard has been used sparingly and judiciously in limited circumstances and has been a very useful tool in prevous develoment plans. It is considered that the continuation of this standard is required.

Good conservation is management of change. In considering proposals for works to protected structures and their attendant grounds attention will be paid to preserving architectural features of special interest and to the scale, proportions, design and materials of such works in relation to the existing. All works should be carried out to the highest possible standard, under proper supervision and by specialist labour where appropriate. A detailed conservation method statement is required in any case which sets out the significance of the building, detailed survey and full assessment of the proposed works and their impact on the building. In addition to the Development Plan objectives the Council will refer to the DoEHLG guidelines for architectural heritage protection.

In relation to solar thermal and solar power installations, the installation of such units on a protected structure or a proposed protected structure is exempted development if those works would not materially affect the character of the structure. Roof lights on a Protected Structure normally require planning permission.

It is inappropriate to have a blanket ban on certain necessary works or additions to protected structures. In all cases planning permission is required. The works will be monitored for best conservation practice and in many cases the proposed works or additions can be undertaken without damaging the character of protected structures.

Dublin City Council operates a National Conservation Grants Scheme which provides assistance for appropriate conservation works to eligible structures. A new Development Contribution Scheme came into effect in January 2010 and will run to 2016. It is not possible to make any changes to the requirements under this scheme at this time. Manager's Recommendation Retain as existing.

Section: 17.10.2 Development within the Curtilage of a Protected Structure

Summary of Issues It is submitted that the last paragraph of page 225 should be amended to read “In order to protect and encourage mature landscaping within the city and suburbs it is the policy of the city council that the removal of the rear gardens to facilitate constructions of underground accommodation will not be permitted.” Manager's Response It is inappropriate to have a blanket ban on this type of development. The development standards, including the new standards on basements (section 17.9.11) of the development plan, provides the necessary safeguards in respect of the curtilage of protected structures. Manager's Recommendation Retain as existing.

Section: 17.10.3 Demolition of Protected Structures

Summary of Issues It is submitted that Section 17.10.3 Demolition of Protected Structures should be removed. Manager's Response This is a valid and necessary statement under Planning legislation taken from Part IV Section 57 (10 b) of the Planning and Development Act 2000. Manager's Recommendation Retain as existing.

Section: 17.10.6 Parking in the Curtilage of Protected Structures and in Conservation Areas

Summary of Issues A residents association submission states is agreement with the approach outlined under Section 17.10.6 - Parking in the curtilage of protected structures and in conservation areas. Manager's Response This support is welcomed. Manager's Recommendation Retain as existing.

Section: 17.10.8.1 Development in Conservation Areas

Summary of Issues Submissions request that in architectural areas, such as Charleville Road and Ballsbridge, the maximum height of any new residential buildings be determined with reference to that of the listed buildings in the vicinity and the streetscape and that historic areas of city and skyline should be protected from excessive height/density/scale. It is submitted that the permitted increase of residential buildings to 6 storey in suburban areas should not apply in Architectural Conservations Areas.

The RIAI states that the recommendations under Section 17.10.8.1 with regards to new build are unnecessarily restrictive and further, that the guidance should make reference to quality of design and quality of materials on new build. It also suggests that reference should be made to the removal of render as being deleterious.

Submissions also request that Dublin's Architectural Conservation Area's should have a complete ban on external advertisement banners and this policy must be enforced.

One submission makes specific reference to Section 17.10.8.1 stating that the standard requiring only brass or stone nameplates is excessive and that other contemporary materials can be successfully used. Manager's Response Section 17.1.1 of the Plan details how proposed development are required to be of a high standard of design and compatible to their setting. Section 17.10.8.1 further considers new development in these areas and states that all new buildings should complement and enhance the character and setting of conservation areas. Further Policy FC37 states “to protect the special character of the City‟s conservation areas through the application of the policies, standards and guiding principles on building heights” The standards section of the development plan sets out Assessment criteria for high buildings (s. 17.6.3) in which all proposals must have regard to a number of criteria including the protection of the built and natural heritage of the city and protecting important view, landmarks, prospects, roofscapes and vistas. Each ACA is accompanied by a guidance document that sets out development management guidance in respect of new development proposals. The overarching policy of ACAs is to protect and conserve the character and setting of the area. The impact of height, scale and orientation of any new development on the surrounding area is considered in all ACA areas.

New alterations and extensions should complement existing buildings/structures in terms of design, external finishes, colour, texture, windows/doors/roof/chimney/design and other details. It is considered that these measures are necessary to protect these areas.

There is currently very restrictive policy with regard to advertising in ACAs with regard to material type and advertisement size. Every effort is made to ensure the implementation of this policy. It is considered that the requirement for only brass or stone nameplates in conservation areas is muchly restrictive and it is agreed that other suitable quality materials may be used. Manager's Recommendation Amend Section 4th paragraph of 17.10.8.1 From: In conservation areas, no advertising material other than brass or stone name-plate type signs will be permitted.

To: In conservation areas, no advertising material other than brass, stone name-plate or other suitable quality material will be permitted.

Section: 17.13 Institutions / Hostels & Social Support Services

Summary of Issues Two submissions received refer directly to the issue of institutions / social support services and facilities in the city centre. The Dublin Chamber of Commerce requests that the plan seek to remove undesirable activities (such as head shops, certain social services etc.) from the CBD in order to encourage rejuvenation of areas, to encourage families to live in the city centre and to allow visitors to feel secure.

The second submission expresses concern regarding the granting of planning permission for hostel-type accommodation in an inner city area leading to an over concentration of such uses in the area. Manager's Response The City Council recognises that there is a need for the provision of homeless accommodation and support services and fully supports and facilities the provision of same. However, an over-concentration of such facilities can potentially undermine the sustainability and regeneration of areas. To avoid such an over-concentration the City Council seeks an appropriate balance in the future provision of new development and/or expansion of these uses in electoral wards. To this end Policy QH29 has been devised and incorporated into the draft plan which seeks to ensure a balance provision of these necessary services in the city. This policy is supported by standard set out Section 17.13 of the draft plan places an onus on applicants to indicate that any proposal for homeless accommodation or support services will not result in an undue concentration of such uses. It is considered that the draft development adequately addresses concerns raised in the submissions received. Manager's Recommendation Retain as existing.

Section: 17.14 Medical and Related Consultants and Medical Practices

Summary of Issues Two submissions were made in relation to medical consultancies. One states that there is a specific demand for medical consultancies in the vicinity of the Mater Hospital and that this demand presents an opportunity to restore some of Georgian buildings in the area, but that the definition and standards for medical consultancies do not allow for same. On the other hand, another submission states that applications for medical consultancies should be accompanied by map of all existing consultancies within a 1km radius, to safeguard against an oversupply of medical practices within an area. Manager's Response Section 17.14 of the Draft Plan sets out standards for medical and related consultants, and addresses issues pertaining to the small-scale practices and also the larger-scale multi-consultancy facilities. For the smaller-scale consultancies, the standards generally permit the conversion of part of a dwelling, whilst medical centres or clinics are generally directed to district and neighbourhood centres given the potential adverse impacts that these larger scale facilities can have on the residential amenity of an area. Nonetheless, in exceptional circumstances where the property is sufficiency large or there is a proven lack of facilities in the locality, medical centres may be considered on their merits elsewhere, with regard to residential amenity.

It is considered that this approach facilitates an appropriate balance between the need for medical consultancies and the protection of residential amenity. It would also facilitate the use of historic properties for such purposes, where appropriate to the character of the building and residential amenity.

Furthermore, Phibsborough is designated as a Key District Centre with a number of significant redevelopment sites zoned for mixed-use (Z10/Z4), all of which would accommodate medical clinics and are in the vicinity of the Mater Hospital. Manager's Recommendation Retain as existing.

Section: 17.17 Schools

Summary of Issues It is suggested that the criteria for assessing an application for a school should be amended to refer to external hard and soft play areas and include a reference to 'access to natural elements.'

It is further submitted that, in keeping with Dublin City Council‟s stated proposal (17.17 page 232) regarding school sites, building on playing fields, recreational areas and open spaces associated with or beside schools should not be permitted except for the educational facilities to be used by the schools and that this would especially refer to schools zoned Z15. Manager's Response The list of criteria contained within Section 17.17 for determining an application for a school is taken from the DoEHLG & DES Joint Code of Practice on Planning and the Provision of Schools (2008). It is therefore beyond the remit of the Development Plan to make any revisions.

Section 17.17 of the Development Plan stipulates that no substantial residential development should proceed without an assessment of existing schools capacity or the provision of new school facilities in tandem with the development. Z15 Resource Lands (Education, Recreation, Community and Health) are areas which are reserved for future educational, recreational, community and health uses and for existing uses which are unlikely to change in the future. As per the zoning requirement with any development proposal on these, consideration for change of use will only be given if the current institutional uses e.g. schools, are no longer required. (Note recommended changes to Z15 lands in Chapter 15).

It is considored that the draft plan addresses the issues raised in the submission comprehensively in Chapters 12 and 15. Manager's Recommendation Retain as existing.

Section: 17.19 Childcare Facilities - See also Appendix 18

Summary of Issues Dublin City Childcare Committee‟s submission proposed a number of specific amendments. It requests an amendment to the first line of this appendix to include a reference to the Dublin City Childcare Committee‟s strategic objectives. It also considers the second and third paragraphs in this Appendix needlessly repetitive. In addition, it requests that the phrase “city childcare committees” be changed to read “city childcare committee” and that where the phrase “child care” occurs in this Appendix it is changed to read “childcare.” Finally, there is a request that where the appendix refers to childcare facilities provided in Business/ Technology Parks/Places of Employment it states that such provision have regard to the Dublin City Childcare Committee audit and needs analysis.

One other submission states that the provision of 1 childcare facility/75 units is no longer appropriate. Another submission states that the childcare facility requirement takes no account of economic viability and that the strategy to locate childcare facilities adjacent to residential areas rather than places of work, schools, neighbourhood or urban centres, tends to render them unsuitable for working parents as this leads to complicated commuting arrangements.

One submission also requested that where an applicant believes that the provision of one childcare facility/75 units would result in significant over provision in an area, that they be permitted to submit an analysis in their planning application to this effect.

Another submission asked that the Draft Development Plan permit a “change of use” from a childcare facility to another use. Manager's Response Upon review of the draft Development Plan it is considered that the existing first line of Appendix 18 which states that Dublin City Council will have regard to the Dublin City Childcare Committee is sufficient. However, the repetition at the start of the third paragraph is acknowledged and thus it is proposed to delete the first line of this paragraph. The typing errors are acknowledged and the proposed changes shall be incorporated into the final draft.

In addition, it is considered that there is merit in making reference to the Dublin City Childcare Committee‟s audit and needs analysis in the section dealing with “Business/Technology Parks, Industrial Estates.”

The guidance for all new developments to provide 1 childcare facility/75 units has been set out by the DoEHLG. It is therefore beyond the remit of Dublin City Council to amend this direction. However, as highlighted in the DoEHLG‟s document, and in the draft Development Plan‟s Appendix 18, this is a guideline standard and will depend on the particular circumstances of each individual site Upon review of the draft Development Plan it is considered that Appendix 18 does in fact recommend and contain guidance in relation to the provision of childcare facilities adjacent to places of work, schools, neighbourhood and urban centres.

Applications for change of use are dealt with through the DM process. Manager's Recommendation Omit text. Appendix 18, p.323, paragraph 3: “The threshold for…..profile of areas.”

Amend text. Appendix 18, p.324, Business/Technology Parks, Industrial Estates, Employment Areas, Office Blocks, line 1: end of the first line:

From: areas of employment and within office blocks.

To: "areas of employment and within office blocks, with such provision being established having regard to the Dublin City Childcare Committee audit and needs analysis.”

Section: 17.22 Dublin Port

Summary of Issues The key issues raised in the majority of submissions relate to the approach to Dublin Port in the Plan. Concern was expressed regarding suggestions that the port will be relocated with many submissions opposed. Some submissions express support for the relocation of the port.

Please refer to Section 4.4.1.2 „Approach to the Docklands and the Port‟ for Manager's Response and Recommendation. Manager's Response Please refer to Section 4.4.1.2 „Approach to the Docklands and the Port‟ for Manager's Response and Recommendation. Manager's Recommendation Please refer to Section 4.4.1.2 „Approach to the Docklands and the Port‟ for Manager's Response and Recommendation.

Section: 17.25 Retail

Summary of Issues Dublin Civic Trust submits that the standards for retail development should be expanded to restrict floodlighting of shopfronts and the use of loudspeakers onto the public pavement, both of which constitute a form of nuisance and degrade the quality of the public realm.

A separate submission states that the upgrading of shopfronts on O'Connell Street, as the premier street in Ireland, should be a priority in the new plan. It states that while the fabric of the street has undergone a huge improvement, the shopfronts remain low-grade.

A Discount Foodstore operator (Lidl) requests that the definition of the typical area of a Discount Foodstore of up to 1,500 square metres be changed to reflect the Discount Convenience figure of 1,700 square metres. However it is asked that these areas should be seen as indicative sizes and not be viewed as a cap on the size of Discount Foodstores.

It also requests that the role of discount foodstores in enhancing competition, affordability and choice and providing essential amenity for city residents as outlined in Variation 21 of the current development plan be included in the Draft Plan. Manager's Response Shopfronts (Section 17.25.2)

In response to the concerns regarding lighting of shopfronts, Appendix 25 on Outdoor Advertising sets out detailed standards which are applicable to all proposals for shopfronts. The issue of noise nuisance from loudspeakers is addressed by the requirement for a grant of licence by the planning authority.

Section 17.25.2 of the Draft Plan makes specific reference to the O‟Connell Street Area Shopfront Design Guide 2001 and advises architects and designers to consult same when preparing proposals for new shopfronts. Furthermore, O‟Connell Street Architectural Conservation Area (ACA) & Area of Special Planning Control, include provisions to ensure upgrade streetscape fabric for new proposals and to protect the special character of area. It not considered necessary to include any additional measures or reference in the Plan.

Discount Convenience (Section 17.25)

The Retail Strategy, Appendix 4 & Standards for Retail Development both refer to Discount Convenience Stores in the context of proposals exceeding a gross floor area 1,700 sq.m and outside a designated neighbourhood, district or town centre, should undergo key retail tests such as justifying need, retail, sequential test and of an appropriate scale. This approach in terms of scale accords with the policy set out in the Retail Strategy for the Greater Dublin Area 2008-2016 (RSGDA)

The Retail Planning Guidelines for Planning Authorities, (2000) define a Discount Food store as a single-level, self-service store normally of between 100-1500 square metres of gross floorspace selling a limited range of goods at competitive prices, often with adjacent parking. (see Appendix 27 – Land Use Definitions).

In the absence of a revised of definition in the RSGDA, it is recommended to retain the definition as derived from the National Ministerial Guidelines. This figure is not set out as a cap or a restrictive floorspace, but indicative of an average floorspace. Similarly, the RSGDA nor Draft Plan Standards do not limit restrict the floorspace area to 1,700 sq.m, rather they state that above this level and outside key centres (neighbourhoods and districts), that it is necessary to undertake retail impact assessments.

With reference to the provisions of Variation 21, the Retail Strategy of the Draft Plan (Appendix 4) acknowledges the important role of discount stores in the convenience market and the need to locate such stores in highly accessible locations including comprehensive regeneration areas and city centre locations. The reference to comprehensive regeneration areas is not included in the standards section, an omission by error. It is recommended to include same in Section 17.25.5. In the context of the development plan zoning, this would apply to lands designated as Zoning Objective Z14 – Strategic Redevelopment & Regeneration Areas (SDRAs). Manager's Recommendation Insert New Text as Last Bullet Point at End of Section 17.25.3 P. All proposals for shopfronts shall have regard to the guidelines illuminated signs as set out in Appendix 25 of this Plan.

Amend Text in Para 17.25. 5 Page 236 From: This form of retailing forms an important part of the convenience market and should be located in highly accessible locations such as neighbourhood or district centres.

To: This form of retailing forms an important part of the convenience market and should be located in highly accessible locations such as neighbourhood or district centres, or SDRA (See Section 16.3).

Section: 17.26 Take-aways

Summary of Issues The Restaurants Association of Ireland do not oppose the restriction of number / frequency of 'food to go' outlets in a specific area. Manager's Response Dublin City Council acknowledges the submission received and its support for the proposed criteria set out in relation to Takeaways. Manager's Recommendation Retain as existing.

Section: 17.29 Off-Licence and Part Off-Licence

Summary of Issues Two submissions were received which support this development standard. Manager's Response Dublin City Council acknowledges the submission received and its support for the proposed criteria set out in relation to Off-licences. Manager's Recommendation Retain as existing.

Section: 17.30 Restaurants

Summary of Issues A number of submissions oppose the suggestion of restricting the number / frequency of restaurants in a specific area. The inclusion of a differentiation between 'licensed' and 'unlicensed' restaurant is also sought.

The Lord Mayor's Commission on Employment requests that section 17.30 should be reworded to reflect the benefits of restaurant/cafe uses and the clustering benefits. It is also requested that the sale of hot food at casual trading stalls should be actively encouraged and promoted as in New York. Manager's Response Dublin City Council recognises the need and role of restaurants throughout the city. However, the adverse impact of an over concentration of restaurants and the need to maintain an appropriate mix of uses in particular areas of the city such as the City Centre Retail Core Area is also recognised. The criteria for controlling the provision of restaurants are set out in Section 17.30. In particular it is stated that Dublin City Council will have regard to the need to safeguard the vitality and viability of shopping areas in the city and to maintain a suitable mix of retail uses. It is considered appropriate to take account of the number/frequency of restaurants and other retail services in the City Centre Retail Core Area particularly in category 1 & 2 streets when assessing proposals for restaurants.

It is considered that the fourth bullet point of Section 17.30 should be amended accordingly Manager's Recommendation Amend the wording of the fourth bullet point of section 17.30 From: The number/frequency of restaurants and other retail services in the area

To: The number/frequency of restaurants and other retail services in the area (where a proposal relates to a category 1 or 2 shopping street as defined in Fig 18 and Appendix 4).

Section: 17.32 Street Furniture

Summary of Issues One submission raised concerns regarding street furniture such as eating/drinking areas, signboards etc. outside premises which cause a hazard for passers-by with impaired vision.

One submission called for the Council‟s policy in relation to the use of „A‟ board advertising to be reviewed to allow businesses who do not have the advantage of passing foot trade to advertise. Manager's Response Dublin City Council recognises the impact of street furniture which can often lead to problems of visual clutter and to obstruction of public footpaths for pedestrians, in particular with disabilities and the visually impaired. The criteria for assessing such proposals are set out in Section 17.32. In particular it is stated that in considering applications for street furniture, the planning authority will have regard to a number of factors including the impact of the proposal on access and visibility. This is considered sufficient to deal with the issue raised. Manager's Recommendation Retain as existing.

Section: 17.34 Nightclubs / Licensed Premises

Summary of Issues It is submitted that noise pollution from nightclubs, pubs etc in the vicinity of residences are creating problems for residents in some central areas 6 nights a week, and sometimes up to 02:30hrs. In this regard it is suggested that the plan should contain much higher standards for protection from noise (also enforcement and inspection of entertainment venues should take place on a regular basis). Manager's Response The issue of noise emanating from such premises are acknowledged as an issue in Section 17.30 where it states that noise issues need to be addressed in the submission of a planning application. Noise insulation and reduction measures will also be required to be submitted with a planning application. The issue of enforcement and inspection of entertainment venues is outside the scope of the development plan. Manager's Recommendation Retain as existing.

Section: 17.36 Contaminated Land

Summary of Issues The submission from EPA recommends that decontamination activities should ensure that there is no off-site migration of contaminants via run-off, soils or groundwater. Manager's Response It is considered that there is merit in inserting text into the draft plan to take account of the EPA's recommendation. Manager's Recommendation Insert the following text under Section 17.36 Contaminated Land as the fourth bullet point: Decontamination activities should ensure that there is no off-site migration of contaminants via run-off, soils or groundwater.

Section: 17.38 Noise

Summary of Issues A submission requests the strengthening of enforcement on noise issues and the strengthening of resources of the Environmental Health Department Noise Section and the enforcement of hours of work for construction sites and events. The submission also submits that dedicated staff needs to be appointed to the Dublin Docklands Development Authority Area due to the extent of activity. Manager's Response The City Council‟s Environment and Engineering Department are responsible for the implementation and operation of such issues including enforcement. Manager's Recommendation Retain as existing.

Section: 17.39 Petrol Stations

Summary of Issues Topaz Ltd request the removal of the restriction on the sale of alcohol and hot food for consumption off the premises having regard to the neighbourhood function of each service station.

The submission from the EPA suggests best practice for underground storage tanks (USTs). Manager's Response The essential purpose of petrol stations is to provide facilities for the sale of fuels for vehicles. The sale of goods from a petrol station is only permitted as an ancillary small scale facility and does not perform a neighbourhood centre function.

It is considored that the draft plan deals with the relevant land-use planning, design and amenity issues of petrol stations in sufficient detail. Manager's Recommendation Retain as existing.

Section: 17.40 Car Parking Standards

Summary of Issues A number of submissions relate to specific areas and issues; A request for an explanation of the rationale for pay and display on Temple Road, Rathgar That the parking designation on Charleville Road, Dublin 6 remain as is That Grangegorman is located in car parking zone 1 which does not provide sufficient car parking having regard to the Draft Masterplan which proposes 1,150 spaces. That car parking standards in the Draft Plan be amended to provide for a higher level of car parking provision for commercial office users in the Sir John Rogersons Quay area. The submission cites the Dublin Docklands Development Authority‟s Grand Canal Dock Planning Scheme which identifies a car parking standard for commercial offices on lands further than 400m from the Grand Canal Docks Stations which is stated to include the subject lands, of one car parking space per 200 metres of gross floor area. The Development Plan standard is one per 400sqm. That the Smurfit Printworks site be changed from Parking Area 2 to Parking Area 3

In relation to broader policy, it is submitted that the allocation of one car parking space per apartment is not working and that at least two spaces are required in addition to radically increased shared/visitor parking.

Tesco Ireland request that a minimum retail parking standard of 1:14 should be incorporated in the Plan in recognition of the requirement for the private car to access weekly shopping facilities. The existing standards are 1 per 400sqm in parking zone 1, 1 per 100sqm in zone 3 and 1 per 30sqm in zone 3.

It is requested that car parking for colleges of further education be increased to provide for the provision of a limited number of car parking spaces in future development such as those proposed in the Royal College of Surgeons in Ireland campus located to the west side of St. Stephen‟s Green.

A further submission objects to Section 17.40.11 which states there will be a presumption against the removal of on-street spaces to facilitate the provision of vehicular entrances where residents in the wider area are largely reliant on existing on- street spaces. Manager's Response Temple Road is located in the catchment of Luas and is designated as Pay and Display to discourage all day commuter car parking as this would impact on residents and the residential character and amenity of the area. The request to retain the existing parking designation on Charleville Road is noted.

The proposed Grangegorman campus is located in Area 1 which is the most accessible area of the city. Parking is restricted in this zone due to the close proximity to public transport. Furthermore the campus will be directly served by a future Luas Line, further increasing accessibility. It is not considered appropriate to amend the car parking zone for this area which is within walking distance of the city core.

Sir John Rogersons Quay is located within parking zone 1 which is considered to be an accessible area of the city. Given the proximity to public transport and the increased emphasis on mobility management and travel planning in the Draft Plan, the car parking standards and parking zone designation are considered appropriate and necessary to support sustainable transportation policies in order to promote modal change to more sustainable travel options. It should be noted that the Draft Development Plan now provides at Section 17.40 that where a potential development site falls on the boundary of two or more parking zones, it is at the discretion of the Planning Authority to decide the appropriate level of car parking having regard to the location of the site and its accessibility to existing and proposed public transport facilities.

No justification has been given to change the Smurfit Printworks site from Parking Area 2 to Parking Area 3. It is not considered appropriate to change the parking designation of this site to Area 3.

The standard for one car parking space per apartment in Areas 1 and 2 is to provide car storage to support family friendly living policies. It is not intended to increase car use within the city. The provision of an increased car parking allocation would be contrary to other Development Plan policies to take a proactive approach to promoting modal change to sustainable transport options, influencing individual travel behaviour and supporting effective traffic management to manage and reduce congestion in line with national and regional guidance.

It is considered that the existing retail parking standards as set out in the Draft Plan are appropriate as they have been fully tested and found to be acceptable over the life of the 2005 Development Plan. The provision of increased car parking allocations for Retail Use would be contrary to the general thrust of the core strategy.

Given the nature of use proposed as a college of further education, the car parking standards and parking zone designation are considered appropriate and necessary to support sustainable transportation policies in order to promote modal change to more sustainable travel options taking account of, the location of the development in the city centre in close proximity to significant existing and future public transport connections such as Luas and Dart Underground and to the abundance of on and off-street car parking in the immediate vicinity of the site, such as the Royal College of Surgeons and St. Stephen‟s Green Car Parks.

It should be noted that site specific car parking requirements and needs and decisions applications for vehicular entrances on are ultimately assessed through the development management process which takes account of such factors as proposed uses, hours of operation, dual usage, mobility management and travel planning, and any site specific exceptional factors which may be relevant. To alter citywide car parking standards and parking zones to facilitate increased car parking provision in individual sites or areas as suggested is clearly contrary to the proper planning and development. Manager's Recommendation Retain as existing.

Please also refer to Section 5.1.4.7 of the Manager‟s Report which also refers to car parking.

Section: 17.40.6 Motorcycle Parking

Summary of Issues Submissions call for Motorcycle parking allocations to be increased in the context of the policy to reduce CO2 emissions and congestion. It is stated that the 4% motorbike parking allocation is inadequate and that there is a need for increased safe parking areas for motorbikes in the city. Manager's Response The Draft Plan provides guidance on Motorcycle Parking allocations and standards for new build developments for the first time. The standards set out are considered adequate. No reference is made to on-street motorcycle parking facilities. It is considered that that the inclusion of additional supporting text is warranted in this respect. Manager's Recommendation Add additional objective after SIO31; To give consideration to the provision of on-street motorcycle parking at various locations throughout the city where considered appropriate.

Section: 17.41 Cycle Parking

Summary of Issues The submissions on this issue request the reduction of cycle parking standards for third level institutions, with particular reference to the future Grangegorman Campus, from 1 per 3 students to 10% per full time student. Manager's Response The standard for cycle parking for educational buildings including third level institutions is 1 per 3 students, in line with the overall Development Plan vision to promote modal change to cycling and to make Dublin a city where people have the opportunity and confidence to choose to cycle in the city. The existing cycle parking standards are considered both necessary and reasonable. It is not considered that any amendment to the existing standard for educational buildings is warranted on foot of the issues raised. Manager's Recommendation Retain as existing.

Please also refer to Section 5.1.4.4 of the Manager‟s Report.

Section: 17.41.1 Multi-Storey Car Parks and Cycle Facilities

Summary of Issues Submissions request that cycle facilities also include off street parking and charging for electric bicycles and scooters. It is also suggested that privately run parking facilities should be encouraged in the vicinity of suburban train and Luas stations. Manager's Response Detailed proposals for off street charging and other facilities for the cyclist are to be dealt with through Dublin City Council‟s proposed Cycle Parking Strategy which will provide guidance on the nature, quantum and location of cycling parking facilities at public transport stops and interchanges and other key destinations and attractions. Manager's Recommendation Retain as existing.

Please also refer to Section 5.1.4.4 of the Manager‟s Report.

Section: 17.41.6 Financial Contributions

Summary of Issues It is submitted that the existing financial levy of €400 which is imposed in lieu of providing cycle parking facilities on site is insufficient and also that any levy should only apply in exceptional circumstance where facilities cannot be provided on site. Manager's Response Objective SIO10 details that the City Council will prepare a Cycle Parking Strategy and the issue of financial levies would be more appropriately dealt with there. Manager's Recommendation Retain as existing.

Section: Other Issues

Summary of Issues Two submissions consider that the Plan is extremely prescriptive with contradictory policies. It is submitted that Standards should avoid ambiguity so as to give certainty for all involved in the planning process. An Taisce consider that maximum standards should be set where applicable and standards should aim to ensure development of the highest quality.

It is further requested that a working group of planners and Councillors visit developments with a view to amending standards and that the Council should consult with all groups to establish what kind of housing they want built. Manager's Response City Council staff do visit projects and on an occasional basis with Councillors. The creation of a working group of planners and councillors to undertake site visits is not a matter for the Development Plan. The City Council consults tenants about the type of housing they prefer.

There are submissions indicating that the Draft Plan is too prescriptive and too flexible. The draft plan seeks to create a balance between providing a degree of certainty and a degree of flexibility in order to allow for a variety of solutions or unforeseen circumstances. Manager's Recommendation Retain as existing.

Appendix 2 National, Regional, and Local Guidance Submission Number(s): 2167, 2978

Section: Transport 21

Summary of Issues Iarnrod Eireann submit that bullet point 7 should refer to „DART Underground‟ Manager's Response It is considered that there is merit in the inclusion of text referring to DART Underground. Manager's Recommendation Amend the seventh bullet point under Transport 21 heading (p.253) From: To construct the Suburban Rail Interconnector providing a tunnelled link between Heuston Station and the Docklands, via St. Stephen‟s Green and linking with the Northern line

To: To construct the DART Underground providing a tunnelled link between Heuston Station and the Docklands, via St. Stephen‟s Green and linking with the Northern line Appendix 3 The Dublin City Council Housing Strategy 2011 - 2017 Submission Number(s): 2653, 2802, 2837, 2892, 2965, 3142, 3159

Section: Appendix 3 The Dublin City Council Housing Strategy 2011 - 2017

Summary of Issues A commitment to the homeless strategy is welcomed in one submission. Two submissions state that there is a reference to a capacity to provide 67,000 units which is unwarranted. It is suggested that the Council should prepare a regeneration strategy for vacant poor quality stock with weak locational attributes. Another submission states that there is a need to introduce stricter anti-social behaviour policy for all council tenants which will have legal standing.

The RIAI request that exemption from the need to provide social and affordable housing should be extended to all wards where there is a predominance of social housing etc.

*Note – Issues in connection with Part V and Social and Affordable Housing are addressed in of Chapter 11 under section 11.4. Manager's Response Housing Management Services deal with anti-social behaviour on an operational level and the Safety Design Guidelines in Appendix 19 of the Draft Plan provide guidance on designing development to minimise issues relating to anti-social behaviour and promotes safety and security. The reference to 67,000 is a capacity figure which caters for the DoEHLG's 50% headroom requirement. The Regional Planning Guidelines housing figures takes account of vacancy rates and envisage lower housing output in the short term partly on the basis of reducing the existing overhang in the market. The Housing Department manage the process of allocating new social and affordable to different areas of the city and it is policy to avoid over-concentrations of social housing in any one area. Manager's Recommendation Retain as existing. Appendix 4 Retail Strategy Submission Number(s): 2114, 2144, 2884, 3096, 3159

Section: Retail Hierarchy

Summary of Issues The National Transport Authority (NTA) comments on the function and locations of district centres and district centre accessibility. It states that given the large number of district centres identified in the Draft Plan, further elaboration is required, setting out the basis of their functions, scale and locations, in particular, those designated below Key District Centre Level. It also states that the relationship between all District Centres and the City Retail Strategy needs further clarification with regard to scale and catchments.

The NTA also states that the importance of accessibility by public transport, walking and cycling needs to influence the scale and location of the higher order centres outside of the City Centre and that as the locations of each of the 8 Key District Centres demonstrate different levels of public transport accessibility, with reference to Ballymun and Northside, the relationship between accessibility and scale needs to be more clearly defined in the Draft Plan. Manager's Response The NTA refers to the 33 District Centres, inclusive of the 8 Key District Centres, and 10 additional designated under the Regional Retail Strategy. The Retail Strategy as illustrated in Chapter 10, Figure 17 shows 8 Key District Centres and 25 District Centres (33). The 10 Areas referred to as additional to the Dublin City Retail Strategy, are in fact, shown on the Retail Strategy Map, Figure 17.

The City Retail Strategy aligns closely with the Settlement Strategy as set out in the Core Strategy. The Key District Centres (KDCs) relate to the higher order district centres, a number of which are within the Key Developing Areas (KDAs) along rail- based public transport corridors serving emerging local residential communities. The Retail Strategy sets out the rationale for the two-tier designation of Key District Centres and District Centres, and gives further justification for the designation of district centres in general, the new Key District centre at Naas Road, district centres in developing areas and older established areas.

Each of the KDCs are served by existing or planned high quality public transport, with the exception of Northside and Finglas, which serve important regeneration and social functions in terms of revitalisation of older centres, as per the guidance in the Retail Strategy for the GDA.

As such, it is considered that the stated concerns of the NTA are in fact addressed in the Draft Plan.

Notwithstanding the above, it is noted that there is a discrepancy in the list of KDAs as set out in the paragraph section on District Centres and Key Developing Areas. It is recommended to change text in the interest of clarity and consistency with the core strategy.

Manager's Recommendation Amend Text, last paragraph of section on District Centres & Key Developing Areas P. 282 From: The main growth or developing areas for the lifetime of this development plan are set out below and are also identified as Key Developing Areas in the Core Strategy.  North Fringe Pelletstown Cherryorchard / Parkwest Naas Road Docklands

To: The main growth or developing areas for the lifetime of this development plan are identified as Key Developing Areas in the Core Strategy. A number of these include Key District Centres such as North Fringe, Ballymun and the Naas Road and District Centres, such as the Point Village in Docklands.

Section: Guidance on the Scale and Location of Retail Development

Summary of Issues City Centre – Level 1 Two submissions relate to the City Centre Retail Core: one of which requests that Westmoreland Street be made more pedestrian and business friendly, whilst the other suggests the use of dedicated retail maps situated on main shopping thoroughfares to highlight the names and locations of retail units on secondary retail streets.

District Centres – Level 3 A residents association submits that a proliferation of Key District Centres may undermine the city centre and that the proximity of district centres to neighbourhood centres may divert customers from the latter. Specific reference is made to the proposed District Centre at Poolbeg and concern regarding potential negative impacts on Sandymount Village. Manager's Response The City Centre Retail Core Framework Plan as incorporated into the Retail Strategy in Appendix 4 of the Draft Plan, addresses the issue of creating quality pedestrian movement and encouraging retail frontages along Westmoreland Street. In this regard, specific reference is made to Westmoreland Street in the context of strengthening North-South Links of the Retail Core. There is merit in the proposal for appropriate signage to promote the retail core, although not in terms of specific commercial outlets and the potential for same could be explored as part of the City Wayfinding Scheme.

Poolbeg is designated as a District Centre in the Docklands Masterplan 2008. It is a statutory requirement that Dublin City Council has regard to and secures consistency with the Docklands Masterplan and accordingly has no discretion on this matter. Nonetheless, it accords with the two key principles of sustainability and choice as set out in Retail Strategy for the Greater Dublin Area. These principles acknowledge the importance of locally accessible shopping at district and neighbourhood level for social inclusion, sustainability and affordability reasons. Manager's Recommendation Insert New Objective After RD04, P. 124 To give consideration to appropriate signage of the City Centre Retail Core as a destination for retail, cultural and leisure attractions as part of the City Council‟s Pedestrian Wayfinding System.

Section: Assessing New Retail Development

Summary of Issues The RIAI submit that the section on design guidance for new retail development should relate to the section on Sustainable Buildings (16.2.4) and include requirements such that all new supermarkets to be naturally lit where practicable and be powered by tri-generation CHP Units, on the basis that supermarkets have amongst the highest energy use per square metre due to artificial lighting and refrigeration.

It also submits that there should be plot ratio and density guidelines regarding this form of development to maximise site potential in keeping with good urban design. Manager's Response In accordance with principle that all new retail developments should contribute to a good urban environment with the creation of new streets, active frontages and as part of a mixed-use development with a requirement that retail development must conform to the highest urban design standards as set out throughout the plan and be complementary to the streetscape, it is relevant that the general plot ratios and density standards as set out in Sections 17.3 & 17.4 apply also to retail development.

Sections 16.2.4 and 17.1.4 of the draft Plan set out a number of sustainability requirements for all development proposals. However, the concerns regarding the potentially high-energy use of retail developments given the nature of usage and building form are noted and it is considered appropriate to include a reference to same and the general sustainability requirements. Manager's Recommendation Insert New Text at End of Para 1 on Design Section, Page 287: Given the potentially high-energy use of retail developments / supermarkets, all proposals should seek to incorporate a building design to utilise sustainable energy technologies and should meet the requirements for sustainable site and building design as set out in Section 17.1.4. Appendix 5 Travel Plans Submission Number(s): 2054, 2209

Section: Travel Plans

Summary of Issues The National Roads Authority supports the inclusion of Appendix 5. It is also requests that Dublin City Council ensure the implementation of Travel Plans. Manager's Response The support of the NTA is welcome. Dublin City Council has established a Mobility Management Section with responsibility for the management and monitoring of all existing and future Travel Plans submitted as part of the planning process. This has been indicated in the Draft Plan. Manager's Recommendation Retain as existing. Appendix 6 Transport Assessment Submission Number(s): 2209, 2333

Section: Transport Assessment

Summary of Issues The National Roads Authority supports the inclusion of Appendix 6. A further submission requests that Dublin City Council reduce the threshold requirements for the submission of a Transport Assessment. Manager's Response The support of the NTA is welcome. The thresholds for the submission of Transport Assessments are guidelines only and do not preclude the submission of Transport Assessments for developments below the threshold where the Planning Authority is of the opinion that a Traffic Assessment is required. This is clearly set out in the last sentence of Appendix 6. Manager's Recommendation Retain as existing. Appendix 7 Strategic Cycle Network Submission Number(s): 2972

Section: Strategic Cycle Network

Summary of Issues It is requested that a map of the strategic cycle network be provided in the Development Plan. Manager's Response Appendix 7 sets out an indicative list of cycle routes that will be developed, improved or constructed in the future, both within the lifetime of the Plan and beyond. Given the detail and complexity of the many routes involved it is not feasible to provide an accurate and adequately scaled city wide map of sufficient legibility to form part of the Development Plan. Figure 6 of the Draft Plan shows the proposed strategic cycle network for the city. It is therefore proposed to add text to direct interested parties to an electronic version of the city wide cycle maps available at www.dublincitycycling.ie or www.nationaltransport.ie. Manager's Recommendation Insert the following text at end of paragraph one of Appendix 7, Strategic Cycle Network; Mapping of cycle routes is available at www.dublincitycycling.ie or www.nationaltransport.ie Appendix 8 Roads Standards for Various Classes of Development Submission Number(s): 3159

Section: Roads Standards for Various Classes of Development

Summary of Issues It is submitted that alternative approaches to road and footpath arrangements in residential areas should be considered along the lines of „living streets‟ or „homezone‟. Manager's Response Objectives SIO45 and SIO76 seek to promote shared surfaces and homezones. These are residential streets in which the road space is shared between drivers and other road users with the wider needs and safety of residents, including people who walk and cycle, prioritised over car drivers. The detailed design of such areas is not a matter for the Development Plan. Manager's Recommendation Retain as existing. Appendix 11 Proposed Architectural Conservation Areas Submission Number(s): 2308, 2884, 3159, 3172

Section: Proposed Architectural Conservation Areas

Summary of Issues With regard to specific ACAs it is submitted that ACA No. 9 should be extended to include all of Belmont Avenue and Belmont Park. No. 1 Belmont Avenue is not on the list despite it being the oldest listed property in the ACA.

Elmwood Avenue Upper and Elmpark Avenue ACA, This is a typographical error and the text should refer to the Luas line and not the rail line.

In reference to the removal of buildings from the RPS being of local rather than regional significance, one submission requests clarity on criteria for these classifications. And, how they relate to the relevant legislation. Manager's Response It is noted that there is an error. The map is incorrectly drawn and will be amended to include Belmont House (No. 1 Belmont Avenue) and Belmont Park. Error on Page 305 to be amended.

In accordance with the NIAH Handbook 2003 structures of regional importance are defined as those structures and sites which make a significant contribution to the architectural heritage within their region or area. They also stand in comparison with similar structures or sites in other regions or areas in Ireland. Structures of local importance are structures or sites which make some contribution to the architectural heritage but may not merit placing on the RPS.

The Local Authority can decide whether it is more appropriate to protect the structure by inclusion in the RPS or within an ACA. Protection by inclusion within an ACA may be more appropriate where a group of structures is of value because of its contribution to the streetscape or other area and where the interiors and curtilages do not merit the level of protection afforded by the RPS (Section 2.5.3 DOEHLG Architectural Heritage Protection Guidelines for Planning Authorities, 2005). Dublin City Council follows the NIAH evaluation system and in this way it is considered that the groups of structures in the areas set out in Appendix 11 are considered to be of local importance and are more suitably designated as ACAs. Manager's Recommendation Amend boundary on map to correct version.

Amend sentence on page 305 From: Halfway down the road it becomes Elmwood Avenue Upper as it turns southwards and runs alongside the disused Harcourt Street railway line.

To: Halfway down the road it becomes Elmwood Avenue Upper as it turns southwards and runs alongside the Luas line. Appendix 12 Stone Setts to be Retained, Restored or Introduced Submission Number(s): 2030, 2066, 2077, 2078, 2080, 2081, 2087, 2088, 2089, 2094, 2096, 2099, 2102, 2103, 2105, 2112, 2117, 2121, 2125, 2126, 2127, 2128, 2129, 2134, 2138, 2139, 2141, 2142, 2143, 2144, 2145, 2146, 2147, 2148, 2149, 2150, 2151, 2160, 2161, 2163, 2165, 2166, 2183, 2186, 2187, 2190, 2226, 2266, 2296, 2723, 2754, 2755, 2758, 2778, 2785, 3012, 3013, 3014, 3159

Section: Stone Setts to be Retained, Restored or Introduced

Summary of Issues A number of submissions were received in relation to Appendix 12. In particular their is a request for the removal of Castleforbes Road in order to facilitate an upgrade for the road. It is further stated that some of the works on this list are complete and that the Appendix should be laid out in a way which shows which works are actually complete, in progress, and remain to be commenced. Manager's Response An objective survey of the setted streetscapes in Dublin is currently underway which will assess architectural and cultural values, intactness and condition. It is intended that exceptional streets will be added onto the Record of Protected Structures. An up- to-date setts Appendix will not be available until this review project is completed later this summer. The future status of Castleforbes Street will be determined along with all other setted streetscapes, based on the contribution to the industrial, architectural, and material history of the city. Appendices will be reviewed during the lifetime of the plan and updated accordingly. Manager's Recommendation Retain as existing. Appendix 13 Paved Areas and Streets with Grainte Kerbing Submission Number(s): 3159

Section: Paved Areas

Summary of Issues The RIAI submit that Appendix 13A and 13B should include Mountjoy Square, which has granite kerbing and that Mullinahack Street is more commonly called Oliver Bond Street. Manager's Response A review of the setted streetscapes in currently underway and this list will be updated accordingly. Manager's Recommendation Retain as existing. Appendix 14 Guidelines for Waste Storage Submission Number(s): 3159

Section: Guidelines for Waste Storage

Summary of Issues It is suggested that the scale and location of an apartment development (e.g. infill on a tight urban site) may not mean that all of the guidelines set out in this Appendix will be appropriate. Manager's Response The guidelines set out in Appendix 14 apply to all apartment developments generally. It is however accepted that in certain circumstances due to site constraints, elements such as bin sizes and bin locations may need to be amended accordingly. This will be dealt with at the planning application stage with consultation with the Waste Management Section of Dublin City Council. Therefore an amendment is not neccessary. Manager's Recommendation Retain as existing. Appendix 15 Flood Defence Infrastructure Submission Number(s): 3035, 3177

Section: Flood Defence Infrastructure

Summary of Issues One submission contends that proposals for the Dodder from Ringsend to Bushy Park (contained in Appendix 15) were implemented without due regard to the existing amenity and habitat.

Chapelizod Residents Association submit that the measures in Appendix 15 are too weak and not fit for purpose to prevent possible fluvial flooding in Chapelizod. Manager's Response The flood defence infrastructure listed in Appendix 15 is existing infrastructure. These defences play an important role in flood risk management. The purpose of the appendix is to highlight that these features are in fact vital pieces of flood defence infrastructure and not merely walls/embankments etc. which can be removed/altered.

Refer to Section 5.2.4.7 on Flood Mangement. Manager's Recommendation Insert reference to OPW Flood Hazard Maps.

Refer also to Section 5.2.4.7 on Flood Management. Appendix 16 Guidelines on Telecommunications Antennae Submission Number(s): 2101

Section: Guidelines on Telecommunications Antennae

Summary of Issues One submission requests that the emissions certification for non ionising radiation should be improved for masts by independent testing and testing for cumulative effects. Manager's Response Appendix 16 states that as part of their planning application, operators should furnish a statement of compliance with the International Radiation Protection Association Guidelines. Manager's Recommendation Retain as existing. Appendix 17 Seveso 2 Sites Submission Number(s): 3124

Section: Seveso 2 Sites

Summary of Issues The Dublin Docklands Development Authority advise that on Map B of the Docklands Master Plan 2008, two Seveso II establishments are marked for the ESB Poolbeg Power Station while only one is shown on Map F of the Draft Plan. Manager's Response The two marks on the Docklands Plan refer to one site/ establishment which is the ESB Poolbeg Power Station which is one site and is listed in Appendix 17. Manager's Recommendation Retain as existing. Appendix 19 Safety and Security Design Guidelines Submission Number(s): 2168, 2271, 2774

Section: Safety and Security Design Guidelines

Summary of Issues Submissions state that there is a need to tackle crime and maintain accurate statistics and greater enforcement of litter fines, drugs laws, and policing of boardwalk is required. An Garda Siochana submit that „crime prevention through environmental design‟ concepts be incorporated into the guidelines. Manager's Response Tackling crime and maintaining relevant statistics is a matter for An Garda Siochana and is beyond the scope of the Plan. Much of the design guidance in Appendix 19 reflects the guidance in An Garda Siochana‟s „crime prevention through environmental design‟ concept. The last bullet point in Appendix 19 recommends consulting with the An Garda Siochana Crime Prevention Design Advisor and to have regard to the Guidelines on Joint Policing Committees. Regard can be had to the „crime prevention through environmental design‟ concept through this consultation process. Manager's Recommendation Retain as existing. Appendix 20 Access for All Submission Number(s): 2298

Section: Access for All

Summary of Issues The NCBI request detailed technical guidance on the provision of accessibility friendly facilities. In addition the NCBI request that following the bullet point about „dished or level crossings‟ reference should be made to tactile paving and audible signals and reference be made to diagrams/signs etc being made available in accessible formats for people with impaired vision. Manager's Response The „Access for All‟ Appendix provides some guidance on access. For more detailed and comprehensive guidance, Section 17.7 of the draft plan states that the Council will have regard to the National Disability Authority‟s Building For Everyone Planning Guidance and the UK Lifetime Homes Standards.

In relation to the request to refer to „tactile paving and audible signals‟ and visually accessible signage in Appendix 20, it is considered appropriate to include additional text. Manager's Recommendation Amend the second bullet point in appendix 20 (p.328) From: Dished or level crossings at all traffic junctions

To: Dished or level crossings at all traffic junctions and the use of tactile paving and audible signals where appropriate

Insert new bullet point at end of existing list in Appendix 20 (p.328) to read : Where appropriate, sign posting, illustrations and diagrams to inform the public should be made available in accessible formats for people with impaired vision. Appendix 21 Guidelines for Student Accommodation Submission Number(s): 2606, 2663, 2860, 3031

Section: Guidelines for Student Accommodation

Summary of Issues Submissions were received from Trinity College Dublin (TCD), Dublin Institute of Technology (DIT) and The Grangegorman Development Agency which raises concern regarding the exclusion of single occupancy units and states that it is essential to offer a range of accommodation that includes single units so that the city and college can accommodate the requirements of all prospective students. The submission request for the deletion of prohibition on single units and suggest a limit of circa 15% of units for non-shared accommodation and that there be a guideline size that such units not exceed 25 sq.m per bedspace. Manager's Response Dublin City council has regard for the guidelines issued by the Department of Education and Science in relation to 3rd level accommodation. It is considered that shared accommodation is the most appropriate form of accommodation for third level students. However, Dublin City Council recognises that there are certain limited circumstances where postgraduate, mature and married students etc may find that individual accommodation would be more appropriate. It is considered reasonable to remove the restriction on self-contained units and to allow 15% of units in a new development to comprise of single/double occupancy units with a minimum floor area of 25m2 and a maximum floor area of 35m2 for on-site campus student resident developments. Manager's Recommendation Omit the third bullet point on page 329 in its entirety and insert a new bullet point under the first bullet point on page 329 as follows: Each on-site campus student accommodation development shall contain a maximum of 15% single/double occupancy units with a minimum gross floor area of 25m2 and a maximum gross floor area of 35m2. Appendix 22 Guidance on Aparthotels Submission Number(s): 2960

Section: Guidance on Aparthotels

Summary of Issues One submission relates to this issue, it submits that greater clarity is required on Guidelines for Aparthotels. Manager's Response It is considered that the guidance on Aparthotels deal adequately with the issues which are prevalent with regard to such developments and sets out criteria which will be required to be fulfilled assessed in any planning application for an aparthotel. Manager's Recommendation Retain as existing. Appendix 23 Guidelines for Residental Extensions Submission Number(s): 2199, 2847, 2960, 3159

Section: Guidelines for Residental Extensions

Summary of Issues It is submitted that Appendix 23 seems only to apply to traditional suburban housing styles.

The RIAI requests that reference to national guidelines such as the passive House Retrofit Guidelines should be included in Appendix 23.

It submitted that the standard for small dormer style roof windows is misguided in that one large dormer is more energy efficient than two or three small dormer windows and that the installation of solar panels should be permitted development where they do not project from the existing envelope of the building. Manager's Response The illustrations and guidance contained in Appendix 23 are included for the first time in the Development Plan as guidance for applicants. These guidelines refer not only to suburban housing but also terraced houses and those with additions such as roof extensions and porches. It is stated in the introductory paragraph that “Given the wide variety of house types and styles within Dublin City it is not possible to deal with every type of possible extension. These guidelines set out a number of general principles that should be addressed in all cases.”

Dublin City Council encourages and supports a sustainable approach to new build, alterations and extensions. There is no objection to making reference to guidelines or publications which provide useful information regarding extending/renovating a dwelling.

Figure 8 is used for illustration purposes only and shows a sympathetic dormer style window in comparison to a larger one which does not reflect the proportion or character of the dwelling. The general principles given in this section relate to the appearance of such an addition and its impact on the character of the building and surrounding area rather than specifically energy efficiency criteria.

The Planning and Development Regulations 2007 set out planning exemptions for micro-renewable energies including solar panels. Accordingly it is not necessary to have a development standard for solar panels within the Development Plan. Manager's Recommendation Insert new text to Appendix 23 on page 337 directly after the paragraph which deals with Green Roofs as follows:

Useful Websites and Documents Sustainable Energy Authority of Ireland www.seai.ie

Department of Environment, Heritage and Local Government www.environ.ie. Appendix 25 Outdoor Advertising Strategy Submission Number(s): 2049, 2209, 2794, 2814, 2974, 3019, 3101, 3124, 3159

Section: Outdoor Advertising Structures

Summary of Issues General The Outdoor Media Association, which represents five members of the industry, expresses concern that the draft plan does not appear to take account of the commercial benefit of advertising to businesses operating in the city.

Zones of Advertising Control Zone 3: A residents association requests that the Phibsborough Road (Broadstone to Hart‟s Corner) be removed from Zone 3 (Figure 22), pending the implementation of a public realm improvement programme for Phibsborough. Another residents‟ association submission states that outdoor advertising panels would contribute further to the declining physical appearance of Phibsborough.

Zone 4: Dublin Docklands Development Authority (DDDA) expresses concern that the prohibition of all outdoor advertisements in Zone 4, which includes the Campshires in the Docklands Area, may conflict with policies in the Docklands Masterplan. The DDDA requests that this prohibition be made discretionary subject to examination of individual proposals against Masterplan policies on a case by case basis, stating also that the DDDA may advertise festivals and events in the area of the Campshires. A further submission requests that water-based commercial operations be allowed to advertise their presence in close proximity to their vessels in Zone 4.

48 Sheet & 96 Sheet Advertising The Outdoor Media Association considers that the Outdoor Advertising Strategy is quite harsh in that the effective ban on future development of 48 Sheet or 96 Sheet advertising will lead to serious difficulties for many established companies in the industry with reference to the need for reasonable means for the industry to replace and / or develop advertising locations appropriately. The submission requests that the section on restriction of such structures be reworded as follows - ‟96 Sheet or 48 Sheet advertising will not normally be permitted‟ – in order to cater for possible screening opportunities. It submits that the screening of derelict sites or buildings would be best achieved by the 48 / 96 Sheets rather than the smaller panel size preferred by the City Council (8 m2) and so seeks an exemption on 48 & 96 Sheets for the purposes of screening.

The Association recognises that the strategy seeks to consolidate the outdoor advertising inventory in the city, but requests more detail on the approach for a phased removal of existing 48 and 96 sheet panels. It also queries whether the requirement for the removal of existing advertising panels, is compliant with competition law, on the basis that it will restrict the ability of new entrants to the market as they will not have access to a pool of existing advertising panels to trade for new structures. The submission refers to the requirement to decommission at least one other display panel and extinguish the licence for that panel, so that other operators do not use the site – but states that all a media owner can do in terms of decommissioning is to terminate and vacate a site, but does not have the power to restrict another operator from using same at a later stage. It requests that this be clarified in the final Plan.

Traffic Safety The National Roads Authority (NRA) states that a proliferation of roadside advertising signage, especially outside the 50km / hour speed limit areas, can reduce the effectiveness of essential traffic signage such as direction signs, create visual clutter and reduce visibility at junctions / interchanges and bends. It also states that adverting signs placed in locations where they compete with or mimic road traffic signs and signals or are refectories can confuse drivers and should not be permitted. It also refers to the fact that poorly erected or maintained signs can present a safety hazard. The submission requests that the appendix be amended to address the concerns of the above issues. Meanwhile, the Outdoor Media Association submits that references to outdoor advertising with regard to traffic hazards is extremely damaging to the outdoor advertising industry and should be deleted.

Other Advertising Structures One submission expresses concern regarding an apparent lack of regulation on advert newspaper boxes, citing examples where a number of such units remain despite long- closure of the original newsagent. It submits that if there is no regulation of these structures, the city foregoes revenue and ultimately inadvertently delivers ownership of the public domain or public property to such operators.

Illuminated Signs The RIAI submit that low-energy options should form part of the requirements for proposals for illuminated signs to reduce energy use.

Implementation of the Outdoor Advertising Strategy The Outdoor Media Association contends that the grant of three-year permissions for advertising displays will militate against long-term investment and funding of high- quality product and that planning permission should be of sufficient duration to ensure adequate funding of public realm enhancements and an appropriate standard of advertising displays. Manager's Response General The Development Plan must strike an appropriate balance between potentially conflicting issues, such as economic or commercial interests and the amenity of the city. The provisions of the outdoor advertising strategy must have regard also to the mandatory development plan objectives such as to preserve the character of landscape and the amenities of a place.

Zones of Advertising Control Zone 3 of the Advertising Strategy takes cognisance of the 3 Architectural Conservation Areas (ACAs) indicated in the Phibsborough LAP and Appendix 11 of the Draft Plan. Furthermore, it is important to emphasise that public realm improvements can be achieved through a managed programme of on-street outdoor advertising as explained in paragraph 1 of the Strategy. In this way, outdoor advertising could potentially augment the Public Realm Improvement for Phibsborough. Zone 4 restricts all outdoor advertising in areas such as waterways and canals, including along the Campshires in the Docklands Area. This restriction is considered appropriate given the high amenity value and important contribution of these areas to the city‟s public realm network, as well as the designation of these areas as conservation areas. This signage policy is a strategy for the long-term protection of the waterways and is not intended as an instrument to restrict advertising of temporary events, as raised by the DDDA.

48 Sheet & 96 Sheet Advertising It is not considered appropriate to relax the general restrictions or to render an exemption of 48 /96 Sheet Panels for temporary uses. It is accepted that larger advertising structures may prove more effective in certain instances for screening purposes as a temporary measure. The section on advertising for screening purposes does not preclude larger scale structures where appropriate.

The Strategy sets out the mechanism to secure the phased removal of inappropriate existing or unauthorised panels, whereby any applications for new advertising structures will necessitate the removal of existing panels. There is no rationale for further detail on the phased basis, the relationship with the development management process is very clear. This approach is considered appropriate with regard to development plan objectives to protect the character or amenities of a place, and is in accordance with the proper planning and sustainable development of an area.

The concerns of the industry with regard to responsibility for subsequent operators are noted and it is considered appropriate to clarify this matter.

Traffic Safety The Outdoor Advertising Strategy addresses traffic safety as a factor for consideration in respect of all applications for new advertising structures. It states that „Advertising panels will not be permitted where they interfere with the safety of pedestrians, the accessibility of public footpath or roadway, the safety and free-flow of traffic or if they obscure road signs‟. Traffic safety is also addressed in the section implementation of the strategy as follows: „Any advertising structures which would impact injuriously on amenity, built environment or road safety, will be restricted‟. Nonetheless, it is possible to include a further criteria for assessment, that all proposals where relevant would meet the safety requirements of the NRA.

Other Advertising Structures All new advert or newspaper boxes within the public domain require a licence under Section 254 of the Planning & Development Act, 2000, whilst proposals for such structures on private lands must form part of a planning application. Standards for shopfronts as set out Section 17.24 of the Plan, require that all new shopfronts incorporate a hatch or slot of sufficient scale to accept newspaper deliveries, thereby obviating the need for such structures in new proposals. These measures are considered appropriate for the purposes of regulation and to safeguard proliferation of such structures in the public domain.

Illuminated Signs There is merit in the above proposal and it accords with the approach in the plan to reduce energy use and also energy efficiency standards. Accordingly, it is considered appropriate to include reference to consideration of the potential for low-energy options as a guideline for illuminated signs.

Implementation of the Outdoor Advertising Strategy The Draft Plan qualifies the use of three-year temporary permissions to limited instances to enable the planning authority to review the position in the light of changing circumstances at the end of the three-year period. This is considered a reasonable and appropriate mechanism to assess potentially unforseen implications of advertising structures and to ensure protection of the character of the city and the amenities of a particular area. Manager's Recommendation Insert New Text, Para 3, Last Bullet Point on Page 343: Proposals must meet the safety requirements of the National Roads Authority (NRA), where appropriate.

Amend Text Para 8, Page 343 From: Any upgrading of existing outdoor advertising (e. Trivision, scrolling, electronic) will only be permitted if it is acceptable in amenity / safety terms and an agreement is made to decommission at least one other display panel in the City and to extinguish the licence for that panel, so that other operators do not use the site.

To: Any upgrading of existing outdoor advertising (e. Trivision, scrolling, electronic) will only be permitted if it is acceptable in amenity / safety terms and an agreement is made to decommission at least one other display panel in the City and to extinguish the licence for that panel. The purpose of this measure is to ensure that other operators do not use the site.

Insert Text at End of First Bullet in Section on Illuminated Signs, Page 344 „as well as the potential for low-energy options‟. Appendix 26 Sustainability Indicators Submission Number(s): 2168, 2229, 2295, 2603, 2829, 2907, 2909, 2960, 2967, 3149

Section: Sustainability Indicators

Summary of Issues The submissions received raise a number of concerns with the Sustainability Indicators set out in the Draft Plan. A number of improvements are suggested such as setting baselines before the Plan is adopted, benchmarking Dublin with other cities, setting targets in relation to enforcement, etc. It is suggest that the Strategic Policy Committees could play a role in monitoring the implementation of the Plan in each of their areas of responsibility. Manager's Response The indicators were chosen to be specific to Dublin City and cross cutting across a number of areas. A baseline will be set within six months with a monitoring report produced every year. These indicators reflect the vision and key components of the core strategy and are broader than the range of purely environmental indicators under the SEA and AA. The set consists of 18 cross-cutting indicators. These indicators represent an initial working set and may be subject to review and refinement as a result of feedback from engagement with the city‟s stakeholders which will include relevant SPC‟s where appropriate. Manager's Recommendation Retain as existing. Appendix 27 Land Use Definitions Submission Number(s): 2657

Section: Land Use Definitions

Summary of Issues It is requested that sports stadia be added to list of landuse types considered under cultural/ recreational buildings. Manager's Response The types of sports included in the definition of Cultural/ Recreational Buildings are indoor sports facilities, such as, squash courts, basketball arena. The difference between the sports facilities in this definition is whether they are outdoor or indoor sporting activities. Sports Stadia are in general for outdoor sports, such as, football, rugby, hurling and hockey and, therefore, are not included in this definition. Outdoor sports are usually located on Z9 zoned lands – open space - as are sports stadia, such as, Croke Park and Lansdowne Road Aviva Stadium. Manager's Recommendation Retain as existing.

Glossary of Terms and Phrases Submission Number(s): 2603, 2899, 2932, 2943, 2972, 3096

Section: Glossary of Terms and Phrases

Summary of Issues Two submissions relate to the definition and extent of the Inner City. It is noted that the Grand Canal is on south side of city, while the Royal Canal is an north side and that the written description does not follow the Inner City boundary shown on Map K. The Sandymount and Merrion Residents Association expresses concern that the definition of the Inner City, by following electoral boundaries, has no regard to the historical evolution of villages e.g. Claremont Road would be inner city, whilst Sandymount Village would be inner suburbs, yet both are part of Sandymount Village.

The glossary of terms should be at the front of the Plan, and the word „walkability‟ should be in glossary as it is not in the dictionary.

Some definitions are missing specifically; Media recording and general media; associated uses; green/clean industries; shop(neighbourhood); definition of 'creative industries, could be expanded.

It is submitted that a definition of the North Georgian Mile is required. Manager's Response The reference in the glossary definition to the Royal Canal being to the south of the city and the Grand Canal to the north is an error in the text to be corrected. Similarly, the reference to the inner city boundary following the SCR for most of its length, rather than the Grand Canal (reflecting District Electoral Divisions) is a mistake in the text, recommended for correction. The boundary is shown correctly on Map K. The definition of the Inner City in the Draft Plan is on foot of motions (1043 et al) on the proposed Draft Plan, which sought greater clarity with regard to the terms used. The boundary of the Inner City follows the established DED boundaries which are generally closest to the Canals for the sake of consistency and because the DEDs are used for census and other research purposes such as the Housing Strategy.

The definition will not disrupt the coherence of urban villages. In this regard it is noted that both Claremont Road and Sandymount Avenue lie outside the Inner City (i.e. outside the DEDs of Pembroke East A, the southern extent of which h is delineated by Lansdowne Road, the River Dodder, Londonbridge Road, Church Avenue and Beach Road.) The restriction of the Inner City definition to the area entirely between the canals would result in significant areas of the new Docklands including the Conference Centre and Barrow Street being outside the Inner City.

The glossary is at the back in accordance with standard practice, and is referred to in the contents page. Moreover, a glossary at the front would dilute the focus of the Vision and Core Strategy in the first part of the Plan. 'Walkability' appears in Chapter 16 in relation to the Guiding Principles for public realm, urban form and architecture e.g.“How a street or space is connected to the local network of routes and destinations is critical to its success. The planning of new public routes and spaces should also promote permeability and walkability”. For the avoidance of ambiguity it is recommended that it is included in the glossary.

It is agreed that definitions of the phrases identified as missing should be inserted in the glossary apart from 'Shop (neighbourhood)' which is defined in Appendix 27 - Land Use Definitions, and it is not necessary to replicate in glossary. It is noted that shop (neighbourhood) is a permissible use under Zoning Objective Z1 (residential). This should be amended to include shop/local, to accord with the Retail Strategy hierarchy (Appendix 4) and the definition of local shop in Appendix 27 i.e.: Shop: Local: A local shop relates to a small convenience store, newsagent or other tertiary services such as butcher, green grocer, hairdresser and other similar basic retail services.

It is agreed that a definition should be provided in the Plan. Manager's Recommendation Amend the definition of Inner City in Chapter 18 Glossary of Terms From: Inner City (see also City Centre): The Inner City follows electoral division boundaries and is bounded by: on the northside the North Circular Road, Phibsborough Road, the Grand Canal, Drumcondra Road, Clonliffe Road and East Wall Road, and on the southside by: the South Circular Road, Royal Canal, Northumberland Road, Bath Avenue, Beach Road and the Poolbeg Peninsula.

To: Inner City (see also City Centre): The Inner City follows electoral division boundaries and is bounded by: on the northside the North Circular Road, Phibsborough Road, the Royal Canal, Drumcondra Road, Clonliffe Road and East Wall Road, and on the southside by: the South Circular Road, Suir Road, Grand Canal from Dolphin Road to Warrington Place, Northumberland Road, Landsdowne Road, River Dodder, Londonbridge Road, Church Venue and Beach Road. (see Map K)

Insert new text in glossary as follows; Walkability: the extent to which a place is attractive for people to walk to,from, and within. A mix of uses, well connected streets, good architecture, and a safe, quality, public domain are all conducive to 'walkability'.

Insert the following definition for North Georgian Mile in Glossary section: The North Georgian Mile follows the route from Custom House up Gardiner Street to Mounjoy Square and would include the following adjacent streets: North Great Georges Street, Gardiner Place, Upper Gardiner St, Temple St/Hardwicke St, St. George‟s Church and Eccles St. Record of Protected Structures Submission Number(s): 2002, 2022, 2084, 2111, 2116, 2213, 2238, 2262, 2603, 2628, 2751, 2773, 2806, 2821, 2835, 2843, 2845, 2884, 2885, 2887, 2888, 2894, 2895, 2896, 2900, 2901, 2923, 2924, 2925, 2970, 2984, 3040, 3063, 3064, 3141, 3154

Section: Record of Protected Structures

Summary of Issues A significant number of submissions were received with regard to the Record of Protected Structures (RPS) and are outlined below. Manager's Response Responses to submissions on the RPS are dealt with under the following headings:

Buildings proposed to be added from the RPS as part of the Draft Development Plan Buildings proposed to be deleted from the RPS as part of the Draft Development Plan Submissions requesting buildings to be added to the RPS Submissions requesting buildings to be deleted from the RPS Submissions regarding errata and requesting clarification on entry to the RPS

Manager's Recommendation See recommendations under each of the headings below.

Section: Buildings Proposed to be Added to the RPS as part of the Draft Plan

Summary of Issues Approximately 30 Buildings are proposed to be added to the RPS in the Draft Development Plan. One submission was made on these proposed additions, relating to No. 18 Nassau Street.

It is submitted that the proposal to add No. 18 Nassau Street to the RPS is unjustified on the basis that the structure has been significantly altered internally, with little architectural interest remaining and that the structure‟s principal interest lies in its contribution to the streetscape. Accordingly, it is submitted that the building is not of any special significance by reference to the categories of interest as set out in Section 54 of Planning and Development Act 2000. Manager's Response No. 18 Nassau Street is located in the middle of a terrace and the buildings on either side are listed for protection on the existing RPS (Nos. 17 & 19). The upper floors of the terrace appear to be in residential use. The ground floor shop unit of No. 18 has been modernised, but the upper floor levels retain their original proportions and fabric.

The three buildings of this terrace are the only remnant of the 19th century streetscape in the vicinity, being surrounded to the east and west by modern office buildings. The terrace buildings retain their historic character and the upper floors are prominent from the grounds of Trinity College. It is considered appropriate to add the No. 18 Nassau Street to the RPS on the basis of its architectural, historic and streetscape value. Manager's Recommendation Retain No.18 Nassau Street as a proposed addition to the RPS.

Section: Buildings Proposed to be Deleted from the RPS as part of the Draft Plan

Summary of Issues No submissions were made in relation to buildings proposed to be deleted from the RPS. Manager's Response Not applicable. Manager's Recommendation Retain as existing.

Section: Submissions Requesting Buildings be Added to the RPS

Summary of Issues A significant number of submissions requesting the addition of buildings to the RPS were received from special interest groups, resident associations and individuals. These buildings will be assessed under a separate process. However, in the interest of transparency, the following is a summary list of the buildings those buildings requested to be added:

Phoenix Park Cricket Club House Stephen Court, 18 -21 St. Stephen's Green D.2 St. Agnes Terrace (1904) and St. Agnes‟ Presbytery, Crumlin, the 18th Century two storey building lying to the south of St. Agnes‟ Church.  Number of buildings in Crumlin - One house (c. 18th century) no name. Site of archaeological interest in rear garden. Terrace of six red brick houses. Single storey former Post Office Building (19th Century), Site of former garden of possible 18th century „charter school‟, „Innismore House‟ (rear of former Post office building. Was possibly Crumlin‟s 18th century „charter school‟) Note no. 3 and 4 should be listed together. The Shaw Arms Pub – Crumlin‟s oldest pub (early 19th century) a local landmark for centuries. All structures including walls, bridges lock chambers and any works pertaining to the construction of the Royal Canal Fourth corner of the crossroads of Doyles Corner should be included in the RPS in order to preserve the character of the entire crossroads since the three ornate Victorian structuers at the other corners are already protected (the former AIB, Doyles and McGeogh's public houses). Poolbeg Chimney Stacks The entire curtilage wall of the Railway Estate, Inchicore The 1889 former Great Southern and Western Dispensary, Reading rooms and Dining hall of the Railway Estate, Inchicore Former St. Agnes Presbytery, Crumlin. The 18th Century two storey building lying to the south of St. Agnes Church United States of America Embassy Building, Eglin Road Merrion Hall, Strand Road Lisney Building, 24 St Stephen‟s Green Hendron‟s building, Upper Dominick Street The lift bridge located on Sherriff Street Lower over the Royal Canal Bord Failte Headquarters, Baggot Street Bridge, Dublin 2 French-Mullen House, Charlemont Street, Dublin 2, The Walker House at No.1, St. Mary's Lane, Dublin 4 Comprehensive list of structures in Chapelizod put forward by COVA The locks, stone steps and walls bounding towpaths Manager's Response Submissions on conservation issues in relation to policies and objectives will be considered at this stage as part of the Manager‟s Report. However, site specific issues – additions or deletions in relation to the RPS merit detailed analysis and assessment and will be considered as part of a separate process. The strict statutory timeframe does not afford the opportunity to undertake the same indepth analysis as part of the review of the submissions. These submissions will be evaluated under Section 54 and 55 of the Planning and Development Acts 2002 to 2006. Accordingly, these submissions are not being considered as representations on the Draft Plan and will be added to the requests for additions or deletions to the Record of Protected Structures. Manager's Recommendation Retain as existing.

Section: Submissions Requesting Buildings be Deleted from the RPS

Summary of Issues A relatively small number of submissions relate to requests for buildings to be deleted from the RPS. These representations will be considered under a separate process, but in the interest of transparency, a summary list is set out below:

Garden Hall House and Hospital, St. James‟s Hospital AIB site Merrion Road should not be considered for addition 202 Clonliffe Road Mont Clare Hotel, Dublin 2. Nos. 122, 124, 126 and 128 Ranelagh Road, D.6. Manager's Response Submissions on conservation issues in relation to policies and objectives will be considered at this stage as part of the Manager‟s Report. However, site specific issues – additions or deletions in relation to the RPS merit detailed analysis and assessment and will be considered as part of a separate process. The strict statutory timeframe does not afford the opportunity to undertake the same indepth analysis as part of the review of the submissions. These submissions will be evaluated under Section 54 and 55 of the Planning and Development Acts 2002 to 2006. Accordingly, these submissions are not being considered as representations on the Draft Plan and will be added to the requests for additions or deletions to the Record of Protected Structures. Manager's Recommendation Retain as existing.

Section: Submissions Regarding Errata and Requesting Clarification on Entry to the RPS

Summary of Issues A number of submissions refer to errors in the RPS, whilst others seek clarification on the protected status of specific buildings. It is also suggested that the format of the RPS contain column headings as per the RPS which accompanies the current Development Plan. These issues are set out in summary format below:

Entry 477 in the RPS refers to 12A Ballymun Road. It is claimed that there is no number 12A Ballymun Road and the property referred to is in fact 12 Ballymun Road. No. 32 Lower Pembroke Street is a commercial premises rather than a „house‟ as listed  Ref No 5259: Milltown Rd should read Dublin 6, Greenfields not Greenmount, Dublin 5 Ref 5260: Milltown Road should read Dublin 6 not Dublin 5 Ref 5261: Milltown Road should read Dublin 6 not Dublin 5 No. 30 Chapelizod Road is incorrect. It should be No. 30 Main St/Martin's Row (Ref 1360) Units 4, 5 ,6 Greenmount Industrial estate, Harolds Cross - an asterisk showing a protected structure has been incorrected placed on the DP map. No. 17 Synge Street (former residence) is a protected structure – indicated with a red asterix on the map of the dev plan) but it does not seem to be listed in the RPS. The description of the protected elements in the Volkswagen premises on the Naas Road (Record no. 5799) should be changed: from: - „Volkswagen premises, front range of buildings only‟ to : - „Volkswagen premises – Naas Road façade and Tower element‟. A number of errors regarding Chapelizod from COVA. 1857, 23, City Quay, business premises, has been gone since at least 2002-2003. The DDDA sugests that Dublin City Council refer to the Docklands Masterplan Chapter 4 Table 5 of the Environmental Report which lists protected structures removed a number of years prior to the Docklands Masterplan 2003. It is suggested that the City Council consider this and update the Draft Dublin City Maps and RPS accordingly. No.30 Main St./Martin's Row, Chapelizod. Currently incorrectly listed as No.30 Chapelizod Road, Dublin 20. All houses listed on Appian Way should be listed as Dublin 6 not Dublin 4 Nos. 38, 39 & 40 Parnell Square West and Nos. 21, 22, 23 & 24 Dominick Street Lower: submission relates to the extent of protection and requests the delisting of ancillary structures, factory, sheds and offices to the rear of the original buildings at Nos. 38, 39 & 40 Parnell Square West and Nos. 21, 22, 23 & 24 Dominick Street Lower. Manager's Response The submitted errors have been checked and verified and it is considered that amendments to the RPS should be made in respect of these errors. A number of addresses are incorrect and need to be amended.

Regarding, Units 4, 5, 6 Greenmount Industrial Estate, the original Conservation Report has been consulted and the asterik is in the correct position.

Listing 1857, 23 City Quay, no longer exists and should be removed from the Record.

No. 17 Synge Street is not on the Record of Protected Structures and has been incorrectly indicated on the map. The map will be amended to remove the asterick.

No. 32 Lower Pembroke Street description should remain as proposed as the original building may have been a house in earlier times.

A submission requested that the description of the Volkswagen premises on Naas Road be changed to the front façade and tower element only, however, the structures have been assessed and it is considered that the description of 'front range of buildings only' should remain.

The Dublin Docklands Development Authority Masterplan has been consulted in relation to the structures within its administration and a number of changes in this regard are required. The Hailing Station, Britain Quay and Campion's Public House are already removed from the Record. A number of the structures on their list are proposed to be deleted. The other structures are listed in error and should be delisted.

There are a number of errors in relation to the listings of Protected Structures in Chapelizod. Listing 4850 34 Main Street, Chapelizod Dublin 20 is the same listing as 5052 34 Martin's Row, Chapelizod, Dublin 20. Both refer to the 18th Century house in front of the Church of Ireland Church. Listing 4850 should be removed.

Listing 1345 30 Chapelizod Road, Dublin is incorrect and should be relisted as 30 Main St, Chapelizod, Dublin 20.

The Bandroom is incorrectly listed under 4845 and its proper address is Maiden Row, Chapelizod, Dublin 20. This change should be made.

The description under 5797 9 Mullingar Terrace, Chapelizod Road, Dublin 20 should be amended to include the ancillary buildings to the rear.

The description under 5053 35 Martin's Row, Chapelizod, Dublin 20, St. Laurences Church, including tower should also include its graveyard.

Listing 4845 Maiden Row/48 Main Street, Chapelizod, Dublin 20 Bandroom/St. Vincent De Paul Room is wrong and should be 48 Main St (Maiden's Row). Reference to the bandroom should be removed at this address.

Nos. 38, 39 & 40 Parnell Square West and Nos. 21, 22, 23 & 24 Dominick Street Lower: This submission raises issues which relate to the extent of the curtilage of protected structures. It is considered that the most appropriate mechanism to access the curtilage and to clarify the protected status extent of these structures is by way of a Section 57 Declaration. Manager's Recommendation Column headings to be inserted as provided in existing RPS.

Change the following address descriptions: From: 12a Ballymun Road, Dublin 9 To: 12 Ballymun Road, Dublin 9

From: Milltown Road, Dublin 5 To: Miltown Road, Dublin 6

From: Milltown Road, Greenmount, Dublin 5 To: Milltown Road, Greenfields, Dublin 6

From: 30 Chapelizod Road, Dublin 20 To: 30 Main St, Chapelizod, Dublin 20

Change the following descriptions: From: 9 Mullingar Terrace, Chapelizod, Dublin 20 Mullingar House: licensed premises To: 9 Mullingar Terrace, Chapelizod, Dublin 20 Mullingar House: licensed premises including buildings to the rear

From: 35 Martin's Row, Chapelizod, Dublin 20 St. Laurences Church, including tower To: 35 Martin's Row, Chapelizod, Dublin 20, St. Laurences Church, including tower and graveyard.

From: Maiden Row/48 Main Street, Chapelizod, Dublin 20 Bandroom/St. Vincent De Paul Rooms To: 48 Main St (Maiden's Row), Chapelizod Dublin 20

Remove the following listings  34 Main Street, Chapelizod Dublin 20 Pumping Station, Forbes St Crane, Sir John Rogerson‟s Quay Former Marine School-side Pavillion, Sir John Rogerson‟s Quay

Add the following listings

Maiden Row, Chapelizod, Dublin 20 Bandroom/St. Vincent De Paul Room. Process Issues Submission Number(s): 2277, 2622, 2647, 3016, 3034, 3101, 3144, 3173

Section: Process Issues

Summary of Issues A number of submissions relate to procedural issues in terms of the plan-making process.

An Taisce raises concerns regarding legal procedures and contends that statutory requirements have not been met with particular regard to the requirement to undertake a review of the existing plan; the maps for public display of re-zoning proposals; and the tracking of changes between the existing and Draft Plan. Specifically, it states that the maps do not indicate the sites that are being proposed for re-zoning; that the draft plan was not published in a manner clearly showing the changes from the current plan as requested by a council motion which renders it a statutory requirement; and that the first step in the plan process should have been to undertake a comprehensive review of the 2005-2011 Dublin City Development Plan. On the basis of the latter issue, it submits that the plan does not meet the statutory requirements of the Planning and Development Act, 2000. It also submits that the plan should be a concise document without the use of extraneous material.

One submission contends that there should be one single development plan for Dublin and its suburbs, instead of one for each of the 4 Dublin Local Authorities and the Dublin Docklands Authority and suggests that there should be statement to this effect in the Dublin City Development Plan.

A single submission calls for legal clarity and confirmation regarding Dublin City Council‟s role as the planning authority for the Docklands Area and requests confirmation that applicants cannot seek modifications from the respective authorities in relation to the one application.

An inner city residents association requests that a statutory strategic masterplan / framework plan for the city be prepared for the next 50-Year Period, rather than the short-term timeframes of Local Area Plans (LAPs) and the City Development Plans. It submits that the city needs such a masterplan and that the process should be more democratic.

A further submission states that the plan should highlight the current key deficiencies and how it proposes to deal with them, including a timeframe for implementing each section of the plan and a review mechanism, as part of Plan. Manager's Response The Draft Plan has been prepared in full accordance with the statutory provisions of the Planning & Development Act 2000-2006. The public display material during the draft consultation period included copies of the draft plan written statement and maps, alongside the current development plan for ease of reference. There is no statutory requirement to indicate proposed re-zonings or illustrate text changes. As the entire document is a draft it is not considered appropriate to highlight changes/proposals. The tracking document was circulated for the benefit of the Members to each Member of the City Council at the stage of the Proposed Draft and Draft Plan and was available to the public throughout the public display. A comprehensive review of the 2005-2011 Plan was undertaken by way of the statutory 2-Year Review and Background Papers submitted to the Economic Development, Planning & European Affairs SPC in October 2008. There is no legal justification to the legal concerns raised by An Taisce.

Under the Planning and Development Acts 2000-2006, each planning authority is obliged to prepare a development plan for its functional area, whilst it is the remit of the Dublin Docklands Development Authority (DDDA) to prepare a Masterplan for its Area as set out under the DDDA Act, 1997. There is merit in the proposal for a single plan for the region, and in effect, this function is fulfilled by the Regional Planning Guidelines (RPGs).

The Dublin Docklands Development Authority Act, 1997 sets out the respective statutory functions of the Docklands Authority and Dublin City Council. This Act defines the Docklands Area, requires the Authority to prepare a Masterplan and advises that a development plan for any part that is within the DDDA Area should be consistent with the Master Plan. The Development Plan has regard to the Docklands Masterplan with specific reference to consistency in Zoning Provisions and Section 25 Planning Schemes. It is not considered necessary or appropriate that the plan set out the statutory provisions governing the DDDA & Dublin City Council.

The proposal for a 50 Year Masterplan for the City would not meet with the requirements of planning legislation, which requires the making of a development plan every six years. The legislation also sets out specific requirements in relation to the consultation process for the various stages of the development plan process, ensuring the that members of the public have an opportunity to make submissions and observations at the pre-draft stage, draft stage and on material amendments (Sections 11 & 12 of the P&D Act, 2000, as amended.)

In response to concerns regarding implementation, the Draft Plan identifies the key achievements, challenges and the strategic approach for each of the nine priorities of the Plan. Chapter 13, Implementation sets out clearly the mechanisms to guide implementation and progress the implementation of the Plan, including monitoring and the two-year review of the Plan and SEA / AA, Sustainability Indicators and Toolkits. It specifically states that „Dublin City Council will collaborate with the relevant agencies and authorities to expedite the implementation of the plan and will retain a Development Plan Team to oversee and oversee and progress the implementation programme arising from the Plan‟. Manager's Recommendation Retain as existing. Consultation Issues Submission Number(s): 2168, 2204, 2229, 2264, 2757, 2802, 2875, 2892, 2932, 2940, 2973, 3019, 3034, 3074, 3142, 3146, 3185, 3190, 3202

Section: Consultation Issues

Summary of Issues A number of submissions refer to issues that relate to consultation issues on the plan.

Some submissions express concerns regarding the excessive use of terminology and that the current version could only be comprehensible to experts. There are requests for the plan to re-written in plain English so that ordinary citizens can understand and express their views on the document. A further submission states that the language is too aspirational and not citizen friendly. A few submissions also consider the maps as ambiguous and that they should be more legible and all include all relevant detail.

In relation to consultation procedures, one submission requests that significant weight be attached to submissions made by any residents groups, on the basis that such submissions by people who actually live within the city boundaries. On a related issue, there is a request that before any plans come into effect, that a residents group be set- up by local residents to address any queries. One submission states that all consultation on the plan should be open to people and groups of all abilities. Manager's Response The Development Plan must cater for a wide ranging audience including potential applicants, developers, architects, urban designers, investors, as well as residents and citizens who live in and use the city. The Plan must also address strategic issues, as well as development management standards and land-use zoning provisions, whilst fulfilling statutory requirements as set out in the Planning & Development Acts 2000-2006, including the obligation to prepare a Retail Strategy and Housing Strategy. In addition, it must have regard to technical guidance set out in Ministerial Guidelines and policy documents at national and regional level, such the National Spatial Strategy (NSS) and Regional Planning Guidelines (RPGs). For all these reasons, the development plan must include an element of technical language. In this regard, efforts have been made to strike a balance between making the plan accessible and fulfilling statutory requirements. Importantly, the Draft Plan, includes for the first time, a glossary of terms to assist all in the understanding the Plan.

The Figures in the written statement of the plan are conceptual only, the purposes of which is to illustrate strategic policy issues diagrammatically. It is not considered necessary or appropriate for such illustrations to include a greater level of detail.

All submissions have been read in full and given consideration in the preparation of the manager‟s report on submissions. The City Council acknowledges the importance of resident groups through community networking organisations such as the Dublin City Community Forum and the Area Offices. Equally, the City Council would welcome the active involvement of any resident group or individuals in the preparation of local level plans, as with practice on statutory LAPs and non-statutory Framework Plans. The FSD Approach emphasises the importance of collaborative city governance and active involvement of citizens and this is apparent throughout the Plan (Section 1.3 Implementation, Section 2.3 Sustainable Dublin, Section 3.1 Vision, Section 13.1 Collaboration & Engagement Mechanisms).

It is the intention that further consideration be given to effective collaboration and engagement with citizens during the life of the plan as stated in Chapter 13. Manager's Recommendation Retain as existing. Miscellaneous Issues Submission Number(s): 2020, 2802, 2852, 2909, 2974, 3001, 3148

Section: Miscellaneous Issues

Summary of Issues A small number of miscellaneous issues were raised in the submissions, relating to matters beyond the scope of a development plan and unrelated to the topics of the plan chapters. These issues include requests for the following: a parcel lands to be purchased and ceded to a local community; disclosure of discussions regarding the purchase of a specific land bank; a schedule of lands in the City Council ownership to be made publicly available; and additional resources for the Environmental Health Unit, as well as criticism of enforcement procedures in relation to a specific case. Manager's Response The development plan process is not the appropriate mechanism to address any of the above issues. Manager's Recommendation These matters are outside the scope of the Development Plan.

Part 4:

Summary of Submissions in Relation to Draft Environmental Report and Appropriate Assessment and Manager’s Response and Recommendations

Strategic Environmental Assessment Submission Number(s): 2840, 2847, 2912, 2914, 2946, 2959, 2965, 3035, 3067, 3101, 3142, 3170, 3177

Section: Strategic Environmental Assessment

Summary of Issues The Department of Environment, Heritage and Local Government raised the following issues: Recommended that the Wildlife Acts of 1976 and 2000 and the European Communities (Natural Habitats) Regulations, 1997 (SI No. 94 of 1997) and its amendments (SI No. 233 of 1998 and SI. 378 of 2005) should be added to Table 1 in Section 1 of the Environmental Report Noted that Table 8 of Section 4 on pages 70 – 75 is missing „water‟ from the list of Environmental Receptors (also noted that water is included in later tables) Noted that the SEA and AA has only assessed the impact of policies and not of objectives. It is unclear if an assessment of objectives would be included by assessing only the policies. The NPWS has indicated that parts of this route, particularly on the south side of Dublin Bay, are likely to have a significant effect on Natura 2000 sites. It is not accepted that Policy GC1 would be a proposed mitigation for the development Recommended that S2S is treated in a similar manner as Dun Laoghaire Rathdown County Council and to ensure that the assessments do not conflict each other, and also that cumulative effects are assessed Noted that the SEA acknowledges that the Eastern Bypass (Policy SI17) could result in potential significant adverse effects that the indicative route shown is only part of the route which will emerge above ground in the Dun Laoghaire Rathdown County Council area. Recommended that Dublin City Council liaise with Dun Laoghaire Rathdown County Council to ensure that the cumulative impact is assessed and that both plans area compatible with each other with respect to SEA and AA The Environmental Report refers to bringing water from the Shannon to address the drinking water supply issues and states the issue needs to be addressed in the SEA The development of a wastewater treatment plant (WWTP) and outer orbital sewer. The WWTP will be in North County Dublin and will discharge to the sea, affecting both Natura 2000 sites and pNHAs along the north County Dublin coastline

The submission received from the Environmental Protection Agency may be summarised as follows:

The primary purpose of the submission is to promote the full integration of the key findings (mitigation measures and recommendations) set out in the SEA ER are fully integrated in the Final Plan The plan is very positive in terms of environmental polices and objectives and has a proactive approach towards delivering sustainability and ensuring improved quality of life. The approach, which is based on principles of sustainability, the Framework for Sustainable Dublin and thematic integration is commended. Recognition of the need to have a balanced approach between the provision of open spaces for citizens and the protection of open spaces, landscapes and biodiversity is also welcomed Notes the 'Greening of the City' policies and objectives along with the over-arching principles of protecting and enhancing open space and welcomes the need to have a balanced approach between the provision of open space needs of citizens and the protection of open spaces, landscapes and biodiversity areas. Recommends that the Greening the City Initiatives should be linked with Quality of Life, Bio-diversity & Landscape Indicators as a mechanism for determining the level of achievement of the ambitious policies and objectives set out in the plan The section on 'Overarching Strategic Issues Affecting Dublin City's Environment is key to providing a focus to the Environmental Assessment & Appropriate Assessment associated with mitigation measures and recommendations arising from the assessments. Considers that there would be merits in including a link between the 12 Strategic Issues highlighted and the Mitigation Measures & Recommendations in Section 8 Mitigation of the SEA ER & Section 5 - Stage Two Mitigatory Policies and Section 6 Stage Two Mitigation Measures of the AA. The delivery of sustainable development and improved quality of life will be dependant on the full implementation of the challenging policies and objectives within the Plan and that the 'Monitoring Programme' set within the SEA Environmental Report has the potential, if applied in a proactive manner and if integrated within mid- term review of the Plan, to provide valuable feedback on the performance of the plan in terms of environmental policies and objectives. Reference also to the requirement to screen any amendments for the purposes of SEA & AA and the need for a SEA Statement Part 1 of the submission focuses on the integration of SEA findings and related environmental considerations into the Plan and also on the content of the ER. This section also welcomes a number of initiatives undertaken by Dublin City Council. Part 11 on suggestions for inclusion into the Policies and Objectives of the Plan The Environmental Report sets out the indicator for Cultural Heritage as 'Percentage of Protected Structures 'at risk'; It is recommended that this aspect of the SEA and the Draft Plan be updated to reflect the significant positive effects on the cultural heritage of the city

The Department of Communications, Energy Resources has no comment to make at this time in relation to the Appropriate Assessment of the Draft Development Plan.

Submission from the Green Party contends that the manner in which the Draft Plan was amended to widen the number of high-rise locations is considered contrary to proper process and illegal. It submits that the members of the Council amended the Manager's Draft and inserted new provisions for building height, including allowing increased building height within 1km of DART, DART Underground and metro stations and that on this basis the Draft Plan does not comply with the requirement of the SEA Directive. It contends that the only option is therefore to withdraw these provisions.

A number of individual submissions also contend that the environmental assessment of the draft plan is unacceptable and/or illegal and/or invalid as it related not to the actual draft plan put on public display but to an earlier version of the plan.

A view expressed in a small number of submissions is that the potential effects of flood defence infrastructure on existing riverbanks and habitats is not addressed adequately in the SEA. It is suggested that there is scope for mitigation e.g. using soft defences.

One submission seeks the designation of the Liffey Valley from Islandbridge to the City boundary. Manager's Response In response to the assessment of policies and objectives as raised by the DoEHLG on assessment of polices, the objectives contained in the Draft Plan essentially represent the means of achieving policies at a specific level. In this regard, objectives consist of a series of subsidiary action items that flow from a group of policies, or indeed in some instance a singular policy. However, it is accepted that there are a few cases where an objective or a small number of objectives which require to be screened independently to establish their potential to impact upon the environment.

In this regard an exercise was undertaken to ensure that objectives contained in the Development Plan are grouped to the relevant policy or set of policies which they represent a means of achieving at a specific level. It was found that the following objectives are not aligned to any specific policy.

SCO13 To compile an audit of private areas, adjacent to public thoroughfares, onto which members of the public are invited by the owner (i.e. private landings) that the Council deem to be in need of enhancement SIO32 To develop lorry parks and bus parks in suitable locations in co-operation with private enterprise, so as to eliminate the hazards of unsuitable lorry and bus parking in residential and other areas GCO39 To seek to provide public access to Fitzwilliam Square Park, and pending the full acquisition of the park for the city, to seek to have it opened on a number of designated open days‟. Also to seek to provide public access to the park at Wilton Terrace GCO42 To facilitate use of Lansdowne Valley – from Inchicore to Drimnagh Castle – in accordance with the provisions set out in the Drimnagh Integrated Area Plan (June 2009).

Accordingly, an environmental assessment was carried out on them in accordance with SEA methodology – See Matrix entitled Assessment of Standalone Objectives. The Environmental Report will be updated accordingly.

It is considered appropriate to include a number of additional indicators into the Environmental Report to reflect the significant positive impacts of existing efforts by Dublin City Council on the heritage of the city.

Regarding compatibility of development plans with adjoining local authority is Dublin City Council liaise with Dun Laoghaire Rathdown (DLR) County Council to ensure that both Development Plans are compatible with each other in respect to the Eastern Bypass and the Sutton to Sandycove Coastal Greenway (S2S). It is relevant to note that the DLR Plan had been adopted by the time the DoEHLG Letter was received by DCC). The text of the DLRC Plan is noted and a new Objective (for the S2S) and a new Policy (for the Eastern Bypass) has been devised and tested for significant environmental impacts. The Environmental Report (ER) will be updated and amended accordingly.

In relation to the drinking water supply issues, Dublin City Council acting on behalf of the local authorities in the Dublin Region is currently studying a number of options for developing a new long term water supply for the city and region. The current study is entitled Water Supply Project – Dublin Region (Draft Plan).This draft study has been subject to SEA and AA Assessment . It is neither a policy nor an objective of the Draft Dublin City Development Plan to abstract water from the River Shannon.

The development of a wastewater treatment plant (WWTP) and outer orbital sewer will be comprehensively dealt with in the ER. The submission received from the EPA is very detailed and comprehensive. It makes references to the ER of the SEA, the AA and the Draft Plan and makes comments on and /or suggestions for amendments to same. It is considered that the majority of issues raised by the EPA have been comprehensively and adequately dealt with in the draft plan, the Environmental Report and/or the Appropriate Assessment.

Furthermore, other less strategic issues are more appropriately dealt with in specific plans and programmes of Dublin City Council and no amendments are therefore required to the Environmental Report, the Draft Plan or the Appropriate Assessment.

It is considered that there is merit in incorporating a number of suggested amendments by the EPA to the Environmental Report and various chapters of the Draft Plan. Please note that the Manager‟s Report on Chapter 5 also deals with many of the issues raised by the EPA.

In relation to those submissions stating that the SEA is illegal with no consideration of the amendments to the plan made by Council at meetings on the 2nd and 3rd December, namely the new provisions regarding height in the city. In this regard, it should be noted that Dublin City Council carried out the SEA in accordance with provisions of the SEA Directive (Directive 2001/42/EC) and Regulations (S.I. 436 of 2004) and has been informed by the guidance set out in Implementation of SEA Directive (2001/42/EC): Assessment of the Effects of Certain Plans and Programmes on the Environment, Guidelines for Regional and Planning Authorities, 2004. The substantive amendments made at the December Council Meeting in relation to height was the inclusion of revised provisions for building height in the city, including a refinement of locations appropriate for buildings up to 8 sotreys in height (within 1KM of DART, DART underground and Metro stations); a revised policy to promote and enhance Dublin as a low rise city, as opposed to a low to medium rise city; and the incorporation a further details on the low rise category.

In the revised Plan, it was re-affirmed that the city should remain low-rise with height in limited areas and with the elimination of taller buildings in some areas, suchas Clonshaugh. As such, the governing policy remains unchanged and reduces the impact of height even further. In any event, proposals for height in the Draft Plan have been reduced with an overall neutral impact in terms of the environment.

The Environmental Report accompanying the Draft Dublin City Development Plan 2011 - 2017 was finalised post December 3rd 2009. In this regard, the environmental impact of Dublin City Council‟s proposed approach to taller buildings is set out in the Assessment Matrix contained in Appendix A of the Environmental Report, December 2009. The relevant policies for height have been tested against those Environmental Protection Objectives in Section 6 of the Environmental Report. The evaluation from a strategic environmental point of view is detailed in Section 7 of the Environmental Report.

In response to that request for an SAAO from city boundary to Islandbridge, it should be noted that recommendation for same has been made in Chapter 6. Recommendation in Chapter 6. Manager's Recommendation The recommendation for this section proposes for changes to the Environmental Report and to various chapters of the Draft Development Plan Recommended Changes to the Draft Development Plan: (i) Amend Policy GC5 From: To focus on key avenues in the city area between the canals for „greening‟ by way of higher standards of planting and amenity along key routes (see Chapter 17 Development Standards)

To: To ensure high standards of amenity and landscape incorporating principles of ecological planting in design on key avenues in the city area between the canals. (see Chapter 17 Development Standards)

(ii) Amend Objective GCO12 From: To replace all trees removed with an appropriate species, where the removal of street or roadside trees is necessary

To: To replace all trees removed with an appropriate species, where the removal of street or roadside trees is necessary. The planting of native or naturalised species is encouraged

(iii) Amend Policy GC6 From: To protect and improve the natural character of watercourses and to promote access, walkways and other compatible recreational uses along them

To: To protect and improve the natural character of watercourses and to promote access, walkways and other compatible recreational uses along them that do not negatively impact on biodiversity

(iv) Amend Policy GC22 From: To seek the continued improvement of water quality, bathing facilities and other recreational opportunities in the coastal, estuarine and surface waters in the city and to protect the ecology and wildlife of Dublin Bay

To: To seek the continued improvement of water quality, bathing facilities and other recreational opportunities in the coastal, estuarine and surface waters in the city and to protect the ecology, biodiversity, landscape and wildlife of Dublin Bay

(v) Amend Policy FC33 From: To protect the special interest and character of protected structures while complying with the requirements of fire safety

To: To protect the special interest and character of protected structures while complying with the requirements of fire safety and energy efficiency improvements (vi) Amend Policy FC56 From: To promote the awareness of Dublin‟s military and maritime heritage

To: To promote the awareness of Dublin‟s industrial, military and maritime heritage

(vii) Amend Policy QH10 From: To promote more sustainable development through energy end use efficiency, increasing the use of renewable energy, and improved energy performance of all new development throughout the City by requiring planning applications to be supported by information indicating how the proposal has been designed in accordance with Guiding Principles and Development Standards set out in the Development Plan

To: To promote more sustainable development through energy and water use efficiency, increasing the use of renewable energy, and improved energy performance of all new development throughout the City by requiring planning applications to be supported by information indicating how the proposal has been designed in accordance with Guiding Principles and Development Standards set out in the Development Plan

(viii) Amend Policy QH17 From: To ensure apartment developments on City Council sites are models of international best practice and deliver the highest quality energy efficient apartment homes with all the necessary support infrastructure such as public parks and suitable shops contributing to the creation of attractive, sustainable, mixed-use and mixed income neighbourhoods

To: To ensure apartment developments on City Council sites are models of international best practice and deliver the highest quality energy and water efficient apartment homes with all the necessary support infrastructure such as public parks and suitable shops contributing to the creation of attractive, sustainable, mixed-use and mixed income neighbourhoods

(ix) Amend Section 16.2.2 first bullet point page 179 From: The potential for the integration of existing natural features of merit, such as watercourses, mature planting and topography. This approach ensures the landscape character of the area is maintained whilst also assisting biodiversity maintenance and more natural forms of surface water drainage. In effect the layout will be informed by the inherent natural characteristics of the site. The connectivity of proposed open spaces to adjoining existing open space or natural assets should also be considered

To: The potential for the integration of existing natural features of merit, such as watercourses, mature planting and topography. This approach ensures the landscape character of the area is maintained whilst also assisting biodiversity maintenance and, where possible, enhancement and more natural forms of surface water drainage. In effect the layout will be informed by the inherent natural characteristics of the site. The connectivity of proposed open spaces to adjoining existing open space or natural assets should also be considered (x) Insert the following sentence to the end of the first paragraph under 17.36 page 240 “Decontamination activities should insure that there is no off-site migration of contaminants via run-off, soils or groundwater”

2. Recommended Changes to the Environmental Report:

NOTE: It should be noted that the detail of these changes will be set out with any changes to the Draft Development Plan by way of an Addendum to the Environmental Report (ER). The Addendum will accompany the second public display of the Draft Plan.

1. Refer to Wildlife Acts of 1976 and 2000 and the European Communities (Natural Habitats) Regulations, 1997 (SI No. 94 of 1997) and its amendments (SI No. 233 of 1998 and SI. 378 of 2005) the Environmental Report.

2. The ER will be updated to incorporate the new Policy devised in respect of the Eastern Bypass.

3. The ER will be updated to incorporate that new Objective devised in respect of the Sutton to Sandycove Coastal Greenway (S2S)

4. Incorporate further mapping into the ER

5. Include a description of the interrelationships between the environmental topics

6. Link the 12 strategic issues highlighted in section 3 and the mitigation measures of the ER

7. Highlight the potential environmental impacts of the draft plan in the ER

8. Refer to additional plans, directives mentioned in the submission

9. Address data gaps where relevant

10. Update population data when available

11. Reference to the National Soils database in Section 3.6.2 / European Communities (Water Policy) Regulations 2009

12. Include the WFD aim of no deterioration in status of quality of waterbodies

13. Refer to most up-to-date data from the EPA for the Liffey where relevant

14. Reflect the requirement for alignment between the Floods Directive and the Water Framework Directive in the ER.

15. Consider the possible inclusion of additional Environmental Protection Objectives (EPOs) to address sustainable use of natural resources and waste water treatment

16. Reassess the inclusion of GC1 as a mitigation policy for the proposed S2S route

17. Amend errors in the ER where „Water‟ has been inadvertently omitted as a separate environmental receptor

18. Include assessment of secondary, cumulative, synergistic, short, medium and long term, permanent, temporary, positive and negative impacts 19. Assess Zone of influence outside of the plan

20. Consider the possibility of monitoring including thresholds, intervention types, negative and positive effects and coordinated monitoring

21. Address the potential environmental impacts of flood defence infrastructure on the environment in the ER of the SEA.

22. Explore the possibility of mitigation measures using soft defences

23. Update the ER to take account of the exercise undertaken to ensure that objectives in the Draft Plan relate to a relevant policy or set of policies

24. Update Environmental Report to include the following additional Indicators for the Environmental Receptor „Cultural Heritage‟: Number of Formal Advice Statements Issued (Section 57s and Section 5s) Disbursement of 100% of grants issues by the Department of Environment Heritage and Local Government Review and Updating of the Record of Protected Structures on an ongoing basis including Review of RPS in relation to DCIHR Retention of Conservation Officer, City Archaeologist and Teams Number of planning applications / Part VIII applications / Number of strategic plans (development plan, LAPS/Framework Plans/Urban Framework Plans etc) with input from or screened by the City Archaeologist

All changes / updates made to the Environmental Report (ER) will be on public display as an Addendum to the ER at the time of the second public display period, to allow for the Environmental Authorities and all interested parties to make submissions on the Environmental Report, as well as the Proposed Amendments to the Draft Development Plan. Strategic Environmental Assessment

Assessment of Standalone Objectives (DoEHLG Submission)

In response to the DoEHLG which queried the relationship between Policies and Objectives in the Draft Plan submission an exercise was undertaken to ensure that objectives contained in the Development Plan are grouped to the relevant policy or set of policies which they represent a means of achieving at a specific level. It was found that the following objectives are not aligned to any specific policy.

- SCO13 To compile an audit of private areas, adjacent to public thoroughfares, onto which members of the public are invited by the owner (i.e. private landings) that the Council deem to be in need of enhancement

- SIO32 To develop lorry parks and bus parks in suitable locations in co-operation with private enterprise, so as to eliminate the hazards of unsuitable lorry and bus parking in residential and other areas

- GCO39 To seek to provide public access to Fitzwilliam Square Park, and pending the full acquisition of the park for the city, to seek to have it opened on a number of designated open days’. Also to seek to provide public access to the park at Wilton Terrace

- GCO42 To facilitate use of Lansdowne Valley – from Inchicore to Drimnagh Castle – in accordance with the provisions set out in the Drimnagh Integrated Area Plan (June 2009).

Accordingly, an environmental assessment was carried out on them in accordance with SEA methodology – See matrix.

It was found that the implementation of Objectives GC039, SCO13, GC039 & GC42 would have no potential significant adverse negative impacts. Objective SCO13 refers to brownfield sites such as forecourts of filling stations.

While no potential significant adverse impacts were found, it was found that positive impacts would occur for both population & human health and landscape environmental receptors as a result of increase public access to open spaces in the city, enhancement of landscapes elimination of potential hazards caused by unsuitable. Discouraging bus and lorry parking in areas where there are currently significant amounts of i.e. Mountjoy Square, Nassau Street, City Quays, and instead ensuring that such parking takes place in designated bus and lorry parks, would significantly improve the amenities of areas of conservation importance, improve the overall quality of the urban environment. It would also reduce the amount of traffic entering the city centre area in order to access current strategic parking areas in the city centre core.

The detail of the environmental assessment of these standalone objectives is set out on the following table, followed by details linking the policies and objectives of the Draft Plan.

Assessment of Stand PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4 Alone Objectives

SC013 To compile an + 0 0 0 0 0 0 0 0 0 0 0 0 + 0 0 0 audit of private areas, adjacent to public thoroughfares, onto which members of the public area invited by the owner (i.e. private landings) that the Council deem to be in need of enhancement

SI 032 To develop lorry + 0 0 + + + + + 0 0 + 0 + 0 0 0 0 parks and bus parks in suitable locations in co- operation with private enterprise, so as to eliminate the hazards of unsuitable lorry and bus parking in residential and other areas GC039 To seek to provide + 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 public access to Fitzwilliam Square Park, and pending the full acquisition of the park for the city, to seek to have it opened on a number of designated ‘open days’. Also, to seek to provide public access to the park at Wilton Terrace GC042 To facilitate use of + 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Lansdowne Valley – from Inchicore to Drimnagh Castle – in accordance with the provisions set out in the Drimnagh Integrated Area Plan (June 2009)

Strategic Environmental Assessment

Demonstration of link between Objectives and Policies in the Draft Plan

In response to the DoEHLG which queried the relationship between Policies and Objectives in the Draft Plan submission an exercise was undertaken to ensure that objectives contained in the Development Plan are related to a policy or set of policies which they represent a means of achieving at a specific level. It was found that there are four ‘standalone’ objectives i.e. objectives not aligned to any specific policy.

Objectives (in bold) linked to policies

Chapter 4 – Shaping the City

Policy Related Objective SC1 SCO4 SC2 SCO1 + SCO2 + SCO3 + SCO6 SC3 SCO3 SC4 FCO18 SC5 ------SC6 ------SC7 ------SC8 SCO9 SC9 ------SC10 SCO8 + SCO9 SC11 ------SC12 ------SC13 ------SC14 GCO1 +GCO2 SC15 ------SC16 ------SC17 ------SC18 SCO10 SC19 SCO10 + SCO11 SC20 SCO12 SC21 SCO10 + SCO11 SC22 SCO10 SC23 SCO10 SC24 ------SC25 SCO14 SC26 SCO15 SC27 ------SC28 SCO15 SC29 SCO15 SC30 SCO16 SC31 ------

The Following Objective is not aligned to any Policy: SCO13 To compile an audit of private areas, adjacent to public thoroughfares, onto which members of the public area invited by the owner (i.e. private landings) that the Council deem to be in need of enhancement

Chapter 5.1 – Connecting and Sustaining The City’s Infrastructure

Policy Objective(s) SI1 SIO1 + SIO45 SI2 SIO2 SI3 SIO3 + SI04 + SIO5 SI4 SI03 SI5 ------SI6 SIO3 + SI04 SI7 SIO10 + SIO11 + SIO12 + SIO13 + SIO14 + SI015 + SIO16 + SIO17 + SIO18 + SIO19 SI8 SIO10 + SIO11 + SIO12 + SIO13 + SIO14 + SIO16 + SIO17 + SIO18 + SIO19 SI9 SIO20 + SIO21 + SIO22 + SIO23 + SIO24 + SIO25 + SIO26 + SIO27 SI10 SIO28 + SIO29 SI11 SIO30 + SIO31 SI12 SIO30 + SIO31 + SIO33 SI13 SIO30 + SIO31 SI14 ------SI15 ------SI16 ------SI17 ------SI18 SIO34 SI19 SIO35 + SIO36 + SIO37 + SIO39 + SIO40 + SIO41 + SIO42 + SIO43 + SIO44 SI20 ------SI21 SIO46 + SIO47 + SIO48

The Following Objective is not aligned to any Policy: SIO32 To develop lorry parks and bus parks in suitable locations in co-operation with private enterprise, so as to eliminate the hazards of unsuitable lorry and bus parking in residential and other areas

Chapter 5.2 – Water, Drainage, Waste, Energy and Telecommunications Infrastructure

Policy Objective(s) SI22 GCO3 SI23 SIO49 + SIO50 SI24 SIO51 SI25 SIO52 + SIO53 + SIO54 SI26 ------SI27 SIO58 SI28 SIO57 SI29 ------SI30 SIO55 + SIO56 SI31 ------SI32 ------SI33 SIO59 + SIO62 SI34 SIO60 + SIO61 + SIO65 SI34 ------SI35 ------SI36 ------SI37 SIO63 + SIO64 SI39 SIO66 + SIO67 SI40 ------SI41 ------SI42 SIO70 SI43 SIO68 + SIO69 + SIO71 SI44 ------SI45 ------SI46 SIO72 SI47 ------SI48 ------SI49 ------SI50 SIO73 + SIO74 SI51 SIO75 + SIO76 + SIO77 +SIO78 +SIO79 + SIO80 + SIO81 SI52 ------SI53 ------SI54 ------SI55 SIO82 SI56 ------SI57 ------SI58 SIO83 + SIO84 + SIO85 + SIO86 SI59 ------SI60 ------SI61 ------

All objectives in this Chapter flow from a higher level policy. There are no ‘standalone’ objectives.

Chapter 6 Greening the City

Policy Objective(s) GC1 GCO1 + GCO2 GC2 ------GC3 ------GC4 ------GC5 ------GC6 GC05 + GCO34 + GCO35 + GCO36 + GCO37 + GCO38 GC7 GCO4 GC8 ------GC9 GCO8 + GCO9 + GCO10 + GCO11 + GCO12 + GCO13 + GCO14 + GCO33 GC10 GCO6 GC11 GCO7 GC12 ------GC13 ------GC14 GCO15 + GCO17 + GCO33 + GCO41 GC15 GCO16 GC16 ------GC17 GCO18 + GCO19 + GCO20 + GCO21 GC18 ------GC19 ------GC20 GCO32 GC21 ------GC22 ------GC23 GCO22 + GCO25 + GCO40 GC24 GCO22 GC25 GCO22 GC26 GCO22 GC27 GCO22 GC28 GCO22 GC29 GCO23 GC30 GCO23 + GCO26 + GCO27 GC31 GCO23 + GCO25 GC32 ------GC33 GCO30 GC34 GCO24 + GCO29 + GCO30 + GCO31 GC35 ------GC36 GCO28

The following objectives are not aligned with any policy GCO39 To seek to provide public access to Fitzwilliam Square Park, and pending the full acquisition of the park for the city, to seek to have it opened on a number of designated ‘open days’. Also, to seek to provide public access to the park at Wilton Terrace

GCO42 To facilitate use of Lansdowne Valley – from Inchicore to Drimnagh Castle – in accordance with the provisions set out in the Drimnagh Integrated Area Plan (June 2009)

Chapter 7.1 Fostering Dublin’s Character & Culture

Policy Objective(s) FC1 FCO1 + FCO2 FC2 ------FC3 ------FC4 ------FC5 FC03 FC6 FC04 FC7 FC05 + FC06 + FCO12 FC8 FCO4 FC9 FCO9 FC10 ------FC11 FCO7 + FCO10 FC12 ------FC13 FCO11 FC14 ------FC15 ------FC16 FCO13 + FCO14 FC17 FCO15 FC18 FCO8 FC19 ------FC20 ------FC21 ------FC22 FCO16 FC23 FCO17 FC24 FC018 + FC019 + FCO20

All objectives in this Chapter flow from a higher level policy. There are no ‘standalone’ objectives.

Chapter 7.2 – Built Heritage

Policy Objective(s) FC25 FCO33 FC26 ------FC27 FCO21 + FCO22 +FCO26 FC28 ------FC29 FCO23 FC30 ------FC31 ------FC32 ------FC33 ------FC34 FCO25 FC35 FCO24 + FCO37 FC36 FCO27 FC37 ------FC38 FCO28 FC39 ------FC40 ------FC41 ------FC42 ------FC43 ------FC44 ------FC45 FCO29 + FCO31 FC46 FCO30 FC47 ------FC48 FCO36 FC49 FCO32 + FCO35 + FCO38 FC50 FCO39 FC51 ------FC52 FCO34 FC53 ------FC54 ------FC55 ------FC56 ------FC57 ------FC58 FCO41 + FCO44 FC59 ------FC60 FCO40 FC61 FCO42 FC62 FCO43 FC63 FCO45 + FCO46

All objectives in this Chapter flow from a higher level policy. There are no ‘standalone’ objectives.

Chapter 8 – Making Dublin the Heart of the Region

Policy Objective(s) HR1 ------HR2 ------HR3 HR01 + HR02 HR4 ------HR5 ------HR6 ------HR7 ------HR8 HR03 HR9 ------HR10 ------HR11 ------

All objectives in this Chapter flow from a higher level policy. There are no ‘standalone’ objectives.

Chapter 9 – Revitalising the City’s Economy

Policy Objective(s) RE1 REO1 RE2 ------RE3 ------RE4 REO2 + REO3 RE5 ------RE6 REO4 RE7 ------RE8 ------RE9 ------RE10 REO5 RE11 ------RE12 RE06 RE13 ------RE14 REO7 RE15 REO8 RE16 REO9 RE17 ------RE18 ------RE19 ------RE20 ------RE21 ------RE22 ------RE23 ------RE24 REO10 RE25 ------RE26 REO11 RE27 REO14 RE28 REO12 RE29 REO13 RE30 ------

Chapter 10 – Strengthening the City as the National Retail Destination

Policy Objective(s) RD1 ------RD2 ------RD3 ------RD4 ------RD5 ------RD6 ------RD7 ------RD8 ------RD9 ------RD10 RD04 RD11 RD01, RD02 & RD03 RD12 ------RD13 ------RD14 ------RD15 ------RD16 ------RD17 ------RD18 ------RD19 ------RD20 ------RD21 ------RD22 ------RD23 ------RD24 ------

All objectives in this Chapter flow from a higher level policy. There are no ‘standalone’ objectives.

Chapter 11 – Providing Quality Homes in a Compact City

Policy Objective(s) QH1 ------QH2 ------QH3 ------QH4 ------QH5 ------QH6 ------QH7 ------QH8 ------QH9 ------QH10 ------QH11 ------QH12 ------QH13 ------QH14 ------QH15 ------QH16 ------QH17 ------QH18 ------QH19 ------QH20 ------QH21 ------QH22 ------QH23 ------QH24 SCO5 QH25 QHO1 QH26 ------QH27 ------QH28 ------QH29 ------QH30 ------All objectives in this Chapter flow from a higher level policy. There are no ‘standalone’ objectives.

Chapter 12 – Creating Good Neighbourhoods and Successful Communities

Policy Objective(s) NC1 SCO7 NC2 ------NC3 ------NC4 ------NC5 ------NC6 ------NC7 ------NC8 ------NC9 NCO1 NC10 ------NC11 ------NC12 ------NC13 ------NC14 ------NC15 ------NC16 ------NC17 NCO2 NC18 ------NC19 ------NC20 NCO3, SCO5 NC21 ------NC22 ------NC23 ------

All objectives in this Chapter flow from a higher level policy. There are no ‘standalone’ objectives.

Strategic Environment Assessment

Assessment of Proposed Amendments Arising from Manager’s Recommendations (amended or new polices and new standalone Objectives)

This section of report describes the potential significant impacts on the environment as a result of any proposed new policies, reworded policies and any new objectives not aligned with any particular policy. The report should be read in conjunction with the environmental assessment detailed in the matrix accompanying this report and also the Environmental Report (December 2009).

This assessment focuses on the recommendation to amend policies or standalone objectives on the basis that these set the parameters for all other issues and consist of the substructure changes which may influence other more minor elements of the Plan. Any changes to the Environmental Report as a result of any amendments to the draft plan will be put on a public display for consultation (2nd public display).

Environmental Consequences of Proposed Amendments Resulting from Submissions

Proposed amendments to the draft plan are in Bold and comprise mainly of amendments to policies in the draft plan, with some new policies proposed and one new objective not aligned with any policy.

Assessment with regard to the potential significant environmental impacts of the proposed amendments are in italics.

Any revised assessments of policies as a result of proposed amendments, either positive, negative or neutral, are highlighted in the accompanying matrix by way of +, - or 0.

Chapter 4 – Shaping the City

There are no new or amended policies or new objectives for this chapter, arising from the Manager’s Recommendations. A number of amendments relating to the corresponding standards section (17.6 – Building Height in a Sustainable city) are proposed. However, these are considered a refinement of the existing approach and it still remains policy to protect and enhance the intrinsic quality of Dublin as a predominantly low-rise city with taller buildings in limited locations (SC15); to protect and enhance the skyline of the inner city (SC16); and to promote a co-ordinated approach to taller buildings (SC17).

Chapter 5.1 – Connecting and Sustaining the City’s Infrastructure

New Policy Proposed to be Inserted into Draft plan (Unnumbered) : To support relevant transport agencies, providers and adjoining local authorities in assessing the feasibility of developing Bus Rapid Transit systems within the Greater Dublin Area. The proposed new policy would result in only additional positive impacts on the environment, in particular on the following environmental receptors – (i) population and human health (ii) Air, (iii) and Material Assets

New Policy: It is the policy of Dublin City Council to support the provision of a link between north Dublin Port and the Southern Cross/South Eastern Motorway via an eastern bypass of the City, in conjunction and co-operation with other transport bodies, the National Roads Authority and local authorities. The preferred method is by means of a bored tunnel and the preferred route is under Sandymount and Merrion Strand and Booterstown Marsh. However, the route and detailed design of the link road will be subject to an Environmental Impact Assessment and all statutory requirements, including a public consultation process, by the relevant authorities. An Appropriate Assessment of the proposed project for the entire route is also required in accordance with the Habitats Directive The proposed new policy could result in potential significant impacts on a number of environmental receptors given that the details of the project are unknown at this stage. However, the policy has been devised to minimise environmental impacts on the basis that the route and the detailed design will be determined by environmental criteria as part of EIA and AA assessments at project level. Nonetheless, the environmental receptors potentially impacted upon at this stage are: (i) Population and Human Health, (ii) Biodiversity, Flora and Fauna, (iii) Air, (iv) Climatic Factors, iv) Material Assets, (vi) Cultural Heritage and (vii) Landscape and Soils.

Chapter 5.2 – Water, Drainage, Waste, Energy and Telecommunications

SI39 To promote the achievement of good ecological status, good ecological potential and good chemical status for all waterbodies in the City by 2015 This amended policy will have additional beneficial impacts on the environment, in particular on the Biodiversity, Flora and Fauna (BFF) indicators.

SI40 To ensure the upgrading of wastewater infrastructure and to facilitate the provision and safeguarding of infrastructure corridors required to facilitate sustainable development in the city region This amended policy will have additional beneficial impacts on the environment, in particular on the Biodiversity, Flora and Fauna (BFF) indicators.

SI41 To support the development of the Greater Dublin Regional Wastewater Treatment Plant, Marine Outfall and orbital Sewer to be located in the northern part of the Greater Dublin Area to serve the Dublin Region as part of the Greater Dublin Strategic Drainage Strategy This amended policy will have additional beneficial impacts on the environment, in particular on the Biodiversity, Flora and Fauna (BFF) environmental receptors.

SI46 To comply with the Planning System and Flood Risk Management Guidelines for Planning Authorities, published by the Department of the environment, Heritage and Local Government when assessing planning applications and in the preparation of plans both statutory and no statutory This amended policy will have additional beneficial impacts on the environment, in particular on the Biodiversity, Flora and Fauna (BFF) environmental receptors.

SI49 To require the use of Sustainable Urban Drainage Systems in all new developments, where appropriate, set out in The Greater Dublin Regional Code of Practice for Drainage Works. The following measures will apply: -The infiltration into the ground through the development of porous pavement such as permeable paving, swales, detention basins. The holding of water in storage areas through the construction of green roofs, rainwater harvesting, detention basins, ponds, wetlands -the slow down of the movement of water This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

SI50 To monitor and improve air quality in accordance with national and EU policy directives on air quality and where appropriate promote compliance with established targets This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

SI58 To promote energy efficiency, energy conservation, and the use of renewable energy in existing and new developments This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

New Policy (Unnumbered) Proposed to be Inserted into Draft plan: To protect the city’s ground water resources The implementation of this proposed new policy would result in only positive impacts on the environment, in particular on the following environmental receptors – (i) Population and Human Health, (ii) Biodiversity, Flora and Fauna and (iii) Water

New Standalone Objective (unnumbered) Proposed to be Inserted into Draft Plan: It is an objective of Dublin City Council to require that all developments should include a Wastewater Discharge Plan to accompany any application demonstrating to the satisfaction of the Planning Authority that the proposed development, in conjunction with the existing discharges, would not cause non compliance with the combined approach as defined in the Waste Water Discharge (Authorisation) Regulations 2007 The implementation of this proposed new policy would result in only positive impacts on the environment, in particular on the following environmental receptors – (i) Population and Human Health, (ii) Biodiversity, Flora and Fauna and (iii) Water

Chapter 6 Greening the City

GC5 It is the policy of Dublin City Council to ensure high standards of amenity and landscape incorporating principles of ecological planting in design on key avenues in the city area between the canals. (see Chapter 17 Development Standards) This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

GC6 to protect and improve the natural character of watercourses and to promote access, walkways and other compatible recreational uses along them that do not negatively impact on biodiversity. This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

GC9 It is the policy of Dublin City Council to continue to protect and enhance the landscape and green spaces through sustainable design and planning for both the existing community and for future generations in accordance with the principles of the European Landscape Convention This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

GC14 To continue to manage, protect and/or enhance public open spaces to meet the social, recreational, conservational and ecological needs of the city and to consider the development of appropriate complementary facilities which do not detract from the amenities of spaces This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

GC20 It is the policy of Dublin City Council to develop sustainable coastal, estuarine, canal and riverine recreational amenities to enhance appreciation of the natural assets of the coast, estuaries, rivers and canals This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009) GC22 To seek the continued improvement of water quality, bathing facilities and other recreational opportunities in the coastal, estuarine and surface waters in the city and to protect the ecology, biodiversity, landscape and wildlife of Dublin Bay This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

GC25 To conserve and manage all Natural Heritage Areas, Special Areas of Conservation and Special Protection Area identified and designated, or proposed to be designated, by the Department of Environment, Heritage and Local Government. These designations will allow for protection in the event of any approved boundary changes This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

GC30 To provide children’s playgrounds to an appropriate standard of amenity, safety and accessibility and to create safe and accessible places for socialising and informal play and for connecting with nature and art, having regard to the City of Dublin Play Plan This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

GC34 To recognise and support the role of the private sector in providing specialist play facilities including climbing walls, table tennis tables etc, both indoor and outdoor, and subject to zoning specifications This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

GC32 To support the implementation of the City of Dublin Play Plan This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

Chapter 7 – Fostering Dublin’s Character and Culture

FC1 To lead and support the development of a shared vision for culture in the city in collaboration with cultural institutions and cultural bodies based both citywide and nationally This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

New Policy (unnumbered) proposed to be Inserted To cooperate and facilitate partnerships with relevant agencies for the continued development of integrated policies in order to reinforce the character, cultural significance and tourism potential of the historic areas in the city The implementation of this proposed new policy would result in only positive impacts on the environment, in particular on the following environmental receptors – (i) Population and Human Health and (ii) Cultural Heritage

New Policy - Unnumbered To investigate the feasibility of a dedicated Museum of Dublin with a range of stakeholders including OPW, the National Cultural Institutions, The Heritage Council and relevant departments within the City Council, in recognition of the wide range of cultural artefacts relating to the history and development of the City The implementation of this proposed new policy would result in only positive impacts on the environment, in particular on the following environmental receptors – (i) Population and Human Health and (ii) Cultural Heritage

New Policy - Unnumbered To have regard to the National Monuments Legislation, National Policy documents and Guidelines and Code of Practice that protects sites and monuments (listed in Appendix 29) The implementation of this proposed new policy would result in only positive impacts on the environment, in particular on the following environmental receptors – (i) Population and Human Health and (ii) Cultural Heritage

New Policy Unnumbered To seek the repair and retention of shop and pub fronts of architectural interest The implementation of this proposed new policy would result in only additional positive impacts on the environment, in particular on the following environmental receptors – (i) Population and Human Health and (ii) Cultural Heritage

FC26 To seek the protection of the built heritage of the city that makes a positive contribution to the character, appearance and quality of local streetscapes and the sustainable development of the city This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

FC27 To include those structures considered to be of special architectural, historical, archaeological, artistic, cultural, scientific, social or technical interest in the Record of Protected Structures. To protect these structures, their curtilage and the setting from any works that would cause loss or damage to their special character This amended policy will have additional beneficial impacts on the environment, in particular on the Landscape and Soils environmental receptor

FC33 To protect the special interest and character of protected structures while complying with the requirements of fire safety and energy efficiency improvements This amended policy will have additional beneficial impacts on the environment, in particular on the following environmental receptors: (i) Air and (ii) Climatic Factors

FC34 To consider new uses which are compatible with the character of protected structures The implementation of this proposed new policy would result in only positive impacts on the environment, in particular on the following environmental receptors – (i) Population and Human Health and (ii) Cultural Heritage

FC39 To protect the special interest and character of protected structures and Architectural Conservation Areas while striving to meet the requirements for access for all in as far as practicable in accordance with Section 29 of the Disability Act 2009 This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

FC43 To protect and enhance the important civic design character of Dublin’s Quays, squares and historic public spaces This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

FC45 To conserve the unique characteristics of Dublin’s Historic Villages and promote conservation of their architectural features and streetscapes by assessment, research, community consultation and appropriate designations and protection policies This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009) FC56 To promote the awareness of Dublin’s military, industrial and maritime heritage This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

FC61 To promote the awareness of the international significance of Viking and Medieval Dublin and to investigate key medieval sites and to conserve their character, setting and amenity through Irish National Strategic Archaeological Research (INSTAR) Medieval Research Agenda and other initiatives This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

Chapter 8 – Making Dublin the Heart of the Region

HR7 To support the network of economic clusters and transboundary Innovation corridors in the polycentric city region as identified in the Economic Development Action Plan for the Dublin City Region This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

Chapter 9 – Revitalising the City’s Economy

RE2 To promote and enhance the role of Dublin as the national economic engine and driver of economic recovery and growth; with the city centre as its core economic generator. To promote and enhance the city’s competitiveness and address deficits, to improve the business environment so that existing jobs are supported and employment generated, and be creative and practical in its Reponses to present economic challenges This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

RE4 To take a positive and pro-active, approach when considering the economic impact of major planning applications in order to support economic development, enterprise and employment growth and also to deliver high quality outcomes (see chapter 16 for guiding principles); to have consideration to the implementation of the recommendations of the Lord Mayor’s Commission on Employment This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

RE10 To promote and facilitate the economic and employment generating and regeneration potential of the locally traded services sector, making the city more attractive/vibrant for residents, shoppers, visitors and workers, and to recognise the clustering benefits of, for example, cafes and restaurants This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

RE12 To promote and facilitate Dublin as a creative and innovative city that is globally competitive and an internationally linked, attractive, open and innovative city (ii) To recognise that cities are crucibles of innovation and that the city centre Z5 zoned area / inner city is the crucial metropolitan and national resource for innovation, and to promote the urban factors of proximity and diversity that are spurs to innovation This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

RE14 To promote and facilitate the development and growth of Dublin’s existing and emerging creative industries, including cultural enterprises and tourism, the film industry, Green/Clean technologies and other potential high growth sectors. To promote the highest quality provision of Broadband (e.g. 100Mbps) in the city and to prepare conditions to be attached to appropriate planning permissions requiring infrastructure to be provided This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

RE15 To promote and facilitate economic development and clustering taking place along the southern, Metro North and Naas Road/ Rail Innovation Corridors within the Dublin City Region. To promote and facilitate the city centre being the economic engine of the region This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

RE16 To promote and facilitate the further development of clusters within the city thereby generating competitiveness, productivity and innovation benefits. To promote east-west linkages along the Liffey and north-south linkages Digital Hub – Grangegorman This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

RE17 To encourage the regeneration of the city centre zoned area through the promotion and facilitation of innovation clusters and the intensification of existing clusters such as the Mater Hospital, James’s Hospital and the Digital Hub. To recognise the strategic role of the hospital complexes in the city including the Children’s Hospital of Ireland and to support the provision of the appropriate volume of floor space and associated facilities necessary to secure the delivery of their services and potential; having regard to their national medical function, their role as a major employer in the city, as a generator of significant economic benefits for the economy of Dublin’s inner city, and a promoter of the knowledge economy through research and education links with third level colleges in the city This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

RE20 To promote and facilitate the supply of commercial space, where appropriate, e.g. retail and office including larger floorplates and quantums suitable for indigenous and FDI HQ type uses, as a means of increasing choice and competitiveness, and encouraging indigenous and global HQs to located in Dublin (ii) to consolidate employment provision in the city by incentivising and facilitating the high quality redevelopment of obsolete office stock in the city This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

RE27 To promote and enhance Dublin as a world class tourist destination for leisure, culture, business and student visitors. This amended policy will have additional beneficial impacts on the environment, in particular on the Cultural Heritage environmental receptor

RE28 To promote the optimum benefits (including the international marketing benefits) to the city of the Convention Centre Dublin as well as all other major visitor attractions such as IMMA, Collins Barracks, the Phoenix Park and the Guinness Storehouse, and to promote the Convention Centre Dublin area as a major business, tourism, hotel, entertainment and leisure destination of international standard This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

RE29 To promote Dublin as an International Education Centre/Student City, as set out in national policy, and to support and encourage provision of necessary infrastructure such as colleges (including English Language Colleges) and high quality custom built and professionally managed student housing; having regard to the fact that student communities are a strategic resource for urban development and in particular for regeneration; and recognising the considerable benefits arising such as employment generation, improved educational achievements for our higher educational institutions, enhanced trade links and tourism, innovation and enterprise generation (the Silicone Valley effect) This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

New Policy (unnumbered) Proposed to be Inserted: To develop appropriate tourism infrastructure, including signage, information, tourism trails, cafes, toilets, public transport, car and coach parking in the main tourist areas, and to facilitate and encourage computerised information points for visitors The implementation of this proposed new policy would result in positive impacts on the environment, in particular on the following environmental receptors – (i) Population and Human Health and would result in some positive impacts on cultural heritage. However encouraging commuting and additional bus and coach traffic into the main tourist areas by providing car and bus parking would have potential adverse impacts on cultural heritage in terms of coach & bus parking potentially being increased around such significant conservation areas in the historic core. It may also have potential significant adverse impacts on material assets (transport) and it reduces the potential a greater modal shift from private car to more sustainable forms of transport.

Chapter 11 – Providing Quality Homes in a Compact City

QH 10 To promote more sustainable development through energy and water use efficiency, increasing the use of renewable energy, and improved energy performance of all new development throughout the City by requiring planning applications to be supported by information indicating how the proposal has been designed in accordance with Guiding Principles and Development Standards set out in the Development Plan. This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

QH17 To ensure apartment developments on City Council sites are models of international best practice and deliver the highest quality energy and water efficient apartment homes with all the necessary support infrastructure such as public parks and suitable shops contributing to the creation of attractive, sustainable, mixed-use and mixed income neighbourhoods This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

QH29 To ensure that all proposals to provide or extend homeless accommodation or support services shall be supported by information demonstrating that the proposal would not result in an undue concentration of such uses in an area This proposed amendment would not change the environmental assessment in the Environmental Report (December 2009)

Chapter 12 – Creating Good Neighbourhoods and Successful Communities

(New Policy Unnumbered) To promote sustainable neighbourhoods which cater to the needs of persons in all stages of their lifecycle i.e. children, people of working age, elderly, people with disabilities The implementation of this proposed new policy would result in only positive impacts on the environment, in particular on the following environmental receptors – (i)Population and Human Health (ii) Air (iii) Climatic Factors and (iv) Material Assets

Chapter 15 Land Use Zoning

This chapter sets out the overall land use and zoning policy of the Plan. The overall approach is derived from the core strategy, and the key principles of this zoning approach are set out in the Section 15.1.

The key principles of the zoning approach remain largely unchanged, as a result of the manager’s recommendation. There is a relatively minor change in relation to Z10B and Z12, with the omission of Z10B and incorporation of this zoning objective provision in to Z12, albeit with greater emphasis on sustainability in terms of the mix of uses determined by proximity to existing district centres or public transport.

In terms of amendments to site specific zoning the rationale for changes to the maps accords with the policy approach as set out in Section 15.1 Zoning Principles

There is no recommendation for re-zoning of significant land banks for residential purposes, on the basis that there is sufficient capacity to meet the housing needs of the city, as set out in the Housing Strategy, Furthermore, any recommendations to re-zone lands as resource lands (Z15) would likely to have a neutral or positive impact on the environment. Assessment of Proposed Amendments Arising from Manager’s Recommendations)

PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4

New Policy Unnumbered + 0 0 + 0 + + + 0 0 + 0 0 0 0 0 0 To support relevant transport agencies, providers and adjoining local authorities in assessing the feasibility of developing Bus Rapid Transit systems within the Greater Dublin Area

It is the policy of Dublin ? ? ? ? ? ? ? ? 0 0 ? ? 0 ? 0 0 0 City Council to support the provision of a link between north Dublin Port and the Southern Cross/South Eastern Motorway via an eastern bypass of the City, in conjunction and co- operation with other transport bodies, the National Roads Authority and local authorities. The preferred method is by means of a bored tunnel and the preferred route is under Sandymount and Merrion Strand and Booterstown Marsh. However, the route and detailed design of the link road will be subject to an Environmental Impact Assessment and all statutory requirements, including a public consultation process, by PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4 the relevant authorities. An Appropriate Assessment of the proposed project for the entire route is also required in accordance with the Habitats Directive

SI39 To promote the + + + 0 0 0 0 0 + 0 0 0 0 0 0 0 0 achievement of good ecological status, good ecological potential and good chemical status for all waterbodies in the City by 2015

SI40 To ensure the + + + 0 0 0 0 0 + + 0 0 0 0 0 0 0 upgrading of wastewater infrastructure and to facilitate the provision and safeguarding of infrastructure corridors required to facilitate sustainable development in the city region

SI41 To support the + + + 0 0 0 0 0 + + 0 0 0 0 0 0 0 development of the Greater Dublin Regional Wastewater Treatment Plant, Marine Outfall and orbital Sewer to be located in the northern part of the Greater Dublin Area to serve the Dublin Region as part of the Greater Dublin Strategic Drainage Strategy PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4

SI46 To comply with the + + + 0 0 0 0 + 0 0 0 0 0 + 0 0 0 Planning System and Flood Risk Management Guidelines for Planning Authorities, published by the Department of the environment, Heritage and Local Government when assessing planning applications and in the preparation of plans both statutory and no statutory

SI49 To require the use of + + + 0 0 0 0 + 0 + 0 0 0 0 0 0 0 Sustainable Urban Drainage Systems in all new developments, where appropriate, set out in The Greater Dublin Regional Code of Practice for Drainage Works. The following measures will apply:

-The infiltration into the ground through the development of porous pavement such as permeable paving, swales, detention basins.

The holding of water in storage areas through the construction of green roofs, rainwater harvesting, detention basins, ponds, wetlands

-the slow down of the movement of water PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4

SI50 To monitor and + 0 0 + 0 0 0 0 0 0 0 0 0 0 0 0 0 improve air quality in accordance with national and EU policy directives on air quality and where appropriate promote compliance with established targets

SI58 To promote energy + 0 0 + 0 + + + 0 0 0 0 0 0 0 0 0 efficiency, energy conservation, and the use of renewable energy in existing and new developments

(Proposed New Policy - + + + 0 0 0 0 0 + 0 0 0 0 0 0 0 0 unnumbered) To protect the city’s ground water resources

GC5 It is the policy of Dublin + + + + + 0 0 + + 0 + 0 + + + + + City Council to ensure high standards of amenity and landscape incorporating principles of ecological planting in design on key avenues in the city area between the canals. (see Chapter 17 Development Standards)

GC6 to protect and improve + + + 0 + + + + + 0 + + + + + + + the natural character of watercourses and to promote access, walkways and other compatible recreational uses along them that do not PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4 negatively impact on biodiversity.

GC9 It is the policy of Dublin + + + + + 0 0 + 0 0 0 0 + + + + 0 City Council to continue to protect and enhance the landscape and green spaces through sustainable design and planning for both the existing community and for future generations in accordance with the principles of the European Landscape Convention

GC14 To continue to + + + 0 + 0 0 0 0 0 0 0 + 0 0 0 0 manage, protect and/or enhance public open spaces to meet the social, recreational, conservational and ecological needs of the city and to consider the development of appropriate complementary facilities which do not detract from the amenities of spaces

GC20 It is the policy of + 0 0 0 0 0 0 + 0 0 + 0 0 0 0 0 0 Dublin City Council to develop sustainable coastal, estuarine, canal and riverine recreational amenities to enhance appreciation of the natural assets of the coast, estuaries, rivers and canals

GC22 To seek the continued + + + 0 0 0 0 0 + 0 + 0 0 0 0 + + improvement of water quality, bathing facilities and PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4 other recreational opportunities in the coastal, estuarine and surface waters in the city and to protect the ecology, biodiversity, landscape and wildlife of Dublin Bay

GC25 To conserve and + + + 0 0 0 0 0 + 0 0 0 0 + + + 0 manage all Natural Heritage Areas, Special Areas of Conservation and Special Protection Area identified and designated, or proposed to be designated, by the Department of Environment, Heritage and Local Government. These designations will allow for protection in the event of any approved boundary changes

GC30 To provide children’s + 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 playgrounds to an appropriate standard of amenity, safety and accessibility and to create safe and accessible places for socialising and informal play and for connecting with nature and art, having regard to the City of Dublin Play Plan

GC34 To recognise and + 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 support the role of the private sector in providing specialist play facilities including climbing walls, PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4 table tennis tables etc, both indoor and outdoor, and subject to zoning specifications

GC32 To support the + 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 implementation of the City of Dublin Play Plan

FC1 To lead and support the + 0 0 0 0 0 0 0 0 0 0 0 + 0 0 0 0 development of a shared vision for culture in the city in collaboration with cultural institutions and cultural bodies based both citywide and nationally New Policy Unnumbered + 0 0 0 0 0 0 0 0 0 0 0 + 0 0 0 0 To cooperate and facilitate partnerships with relevant agencies for the continued development of integrated policies in order to reinforce the character, cultural significance and tourism potential of the historic areas in the city New Policy - Unnumbered + 0 0 0 0 0 0 0 0 0 0 0 + 0 0 0 0 To investigate the feasibility of a dedicated Museum of Dublin with a range of stakeholders including OPW, the National Cultural Institutions, The Heritage Council and relevant departments within the City Council, in recognition of the wide range of cultural artefacts relating to the history and development of the City PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4

New Policy - Unnumbered + 0 0 0 0 0 0 0 0 0 0 0 + + 0 0 0 To have regard to the National Monuments Legislation, National Policy documents and Guidelines and Code of Practice that protects sites and monuments (listed in Appendix 29) New Policy Unnumbered + 0 0 0 0 0 0 0 0 0 0 0 + 0 0 0 0 To seek the repair and retention of shop and pub fronts of architectural interest. FC26 To seek the + 0 0 0 0 0 0 0 0 0 0 0 + 0 0 0 0 protection of the built heritage of the city that makes a positive contribution to the character, appearance and quality of local streetscapes and the sustainable development of the city FC27 To include those + 0 0 0 0 0 0 0 0 0 0 0 + + 0 0 0 structures considered to be of special architectural, historical, archaeological, artistic, cultural, scientific, social or technical interest in the Record of Protected Structures. To protect these structures, their curtilage and the setting from any works that would cause loss or damage to their special character FC33 To protect the special + 0 0 + 0 + + + 0 0 0 0 0 0 0 0 0 interest and character of protected structures while complying with the requirements of fire safety PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4 and energy efficiency improvements FC34 To consider new + 0 0 0 0 0 0 0 0 0 0 0 + 0 0 0 0 uses which are compatible with the character of protected structures FC39 To protect the special + 0 0 0 0 0 0 0 0 0 0 0 + 0 0 0 0 interest and character of protected structures and Architectural Conservation Areas while striving to meet the requirements for access for all in as far as practicable in accordance with Section 29 of the Disability Act 2009 FC43 To protect and + 0 0 0 0 0 0 0 0 0 0 0 + + 0 0 0 enhance the important civic design character of Dublin’s Quays, squares and historic public spaces FC45 To conserve the + 0 0 0 0 0 0 0 0 0 0 0 + + 0 0 0 unique characteristics of Dublin’s Historic Villages and promote conservation of their architectural features and streetscapes by assessment, research, community consultation and appropriate designations and protection policies

FC56 To promote the + 0 0 0 0 0 0 0 0 0 0 0 + 0 0 0 0 awareness of Dublin’s military, industrial and maritime heritage

FC61 To promote the + 0 0 0 0 0 0 0 0 0 0 0 + 0 0 0 0 awareness of the international significance of PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4

Viking and Medieval Dublin and to investigate key medieval sites and to conserve their character, setting and amenity through Irish National Strategic Archaeological Research (INSTAR) Medieval Research Agenda and other initiatives

HR7 To support the network + 0 0 + 0 0 + 0 - - 0 0 0 0 0 0 0 of economic clusters and transboundary Innovation corridors in the polycentric city region as identified in the Economic Development Action Plan for the Dublin City Region

RE2 To promote and + 0 0 0 0 + + + - 0 + 0 0 0 0 0 + enhance the role of Dublin as the national economic engine and driver of economic recovery and growth; with the city centre as its core economic generator. To promote and enhance the city’s competitiveness and address deficits, to improve the business environment so that existing jobs are supported and employment generated, and be creative and practical in its Reponses to present economic challenges PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4

RE4 To take a positive and + 0 0 + 0 + + + - 0 + 0 0 0 0 0 + pro-active, approach when considering the economic impact of major planning applications in order to support economic development, enterprise and employment growth and also to deliver high quality outcomes (see chapter 16 for guiding principles); to have consideration to the implementation of the recommendations of the Lord Mayor’s Commission on Employment RE10 To promote and + 0 0 + 0 + + + - 0 + 0 0 0 0 0 + facilitate the economic and employment generating and regeneration potential of the locally traded services sector, making the city more attractive/vibrant for residents, shoppers, visitors and workers, and to recognise the clustering benefits of, for example, cafes and restaurants

RE12 To promote and + 0 0 + 0 + + + - 0 + 0 0 0 0 0 + facilitate Dublin as a creative and innovative city that is globally competitive, internationally linked, attractive and open (ii) To recognise that cities are crucibles of innovation and that the city centre Z5 zoned area / inner city is the crucial metropolitan PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4 and national resource for innovation, promoting proximity and diversity of uses that foster innovation RE14 To promote and + 0 0 + 0 + + + - 0 + 0 0 0 0 0 + facilitate the development and growth of Dublin’s existing and emerging creative industries, including cultural enterprises and tourism, the film industry, Green/Clean technologies and other potential high growth sectors.

RE15 To promote and + 0 0 + 0 + + + - 0 + 0 0 0 0 0 + facilitate economic development and clustering taking place along the southern, Metro North and Naas Road/ Rail Innovation Corridors within the Dublin City Region. To promote and facilitate the city centre being the economic engine of the region

RE16 To promote and + 0 0 + 0 + + + - 0 + 0 0 0 0 0 + facilitate the further development of clusters within the city thereby generating competitiveness, productivity and innovation benefits. To promote east- west linkages along the Liffey and north-south linkages Digital Hub – Grangegorman PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4

RE17 To encourage the + 0 0 + 0 + + + - 0 + 0 0 0 0 0 regeneration of the city centre zoned area through the promotion and facilitation of innovation clusters and the intensification of existing clusters such as the Mater Hospital, James’s Hospital and the Digital Hub. To recognise the strategic role of the hospital complexes in the city including the Children’s Hospital of Ireland and to support the provision of the appropriate volume of floor space and associated facilities necessary to secure the delivery of their services and potential; having regard to their national medical function, their role as a major employer in the city, as a generator of significant economic benefits for the economy of Dublin’s inner city, and a promoter of the knowledge economy through research and education links with third level colleges in the city

RE20 To promote and + 0 0 + 0 + + + - 0 + 0 0 0 0 0 + facilitate the supply of commercial space, where appropriate, e.g. retail and office including larger floorplates and quantums suitable for indigenous and PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4

FDI HQ type uses, as a means of increasing choice and competitiveness, and encouraging indigenous and global HQs to located in Dublin (ii) to consolidate employment provision in the city by incentivising and facilitating the high quality redevelopment of obsolete office stock in the city

RE27 To promote and + 0 0 + 0 + + + - 0 + 0 + 0 0 0 + enhance Dublin as a world class tourist destination for leisure, culture, business and student visitors

RE28 To promote the + 0 0 + 0 + + + - 0 + 0 0 0 0 0 + optimum benefits (including the international marketing benefits) to the city of the Convention Centre Dublin as well as all other major visitor attractions such as IMMA, Collins Barracks, the Phoenix Park and the Guinness Storehouse, and to promote the Convention Centre Dublin area as a major business, tourism, hotel, entertainment and leisure destination of international standard

RE29 To promote Dublin as + 0 0 + 0 + + + - 0 + 0 0 0 0 0 + an International Education Centre/Student City, as set PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4 out in national policy, and to support and encourage provision of necessary infrastructure such as colleges (including English Language Colleges) and high quality custom built and professionally managed student housing; having regard to the fact that student communities are a strategic resource for urban development and in particular for regeneration; and recognising the considerable benefits arising such as employment generation, improved educational achievements for our higher educational institutions, enhanced trade links and tourism, innovation and enterprise generation (the Silicone Valley effect)

(New Policy Unnumbered) + 0 0 0 0 0 0 0 0 0 + / - 0 + / - 0 0 0 0 To develop appropriate tourism infrastructure, including signage, information, tourism trails, cafes, toilets, public transport, car and coach parking in the main tourist areas, and to facilitate and encourage computerised information points for visitors PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4

QH 10 To promote more + 0 0 + 0 + + + 0 0 0 0 0 0 0 0 0 sustainable development through energy and water use efficiency, increasing the use of renewable energy, and improved energy performance of all new development throughout the City by requiring planning applications to be supported by information indicating how the proposal has been designed in accordance with Guiding Principles and Development Standards set out in the Development Plan.

QH17 To ensure apartment + 0 0 + 0 + + + 0 0 + 0 0 0 0 0 0 developments on City Council sites are models of international best practice and deliver the highest quality energy and water efficient apartment homes with all the necessary support infrastructure such as public parks and suitable shops contributing to the creation of attractive, sustainable, mixed-use and mixed income neighbourhoods QH29 To ensure that all + 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 proposals to provide or extend homeless accommodation or support services shall be supported by information PH1 BFF1 BFF2 A1 A2 CF1 CF2 CF3 W1 W2 MA1 MA2 CH1 LS1 LS2 LS3 LS4 demonstrating that the proposal would not result in an undue concentration of such uses in an area (New Policy Unnumbered) + 0 0 + 0 + + + + 0 + 0 0 0 0 0 0 To promote sustainable neighbourhoods which cater to the needs of persons in all stages of their lifecycle i.e. children, people of working age, elderly, people with disabilities

New Standalone Objective + + + 0 0 0 0 0 + 0 0 0 0 0 0 0 0 - It is an objective of Dublin City Council to require that all developments should include a Wastewater Discharge Plan to accompany any application demonstrating to the satisfaction of the Planning Authority that the proposed development, in conjunction with the existing discharges, would not cause non compliance with the combined approach as defined in the Waste Water Discharge (Authorisation) Regulations 2007

Appropriate Assessment Submission Number(s): 2840, 2912, 2946, 2947, 2959, 3142, 3144

Section: Appropriate Assessment

Summary of Issues The three Environmental Authorities raised the following issues

1. The Environmental Protection Agency suggests that the Plan should include a clear policy/objective within Section 6.4.6 Biodiversity that sets out a requirement for an AA Screening for new/reviewed/amended Plans or proposed projects, being prepared by the local authority for the plan area that may have the potential to impact on Natura 2000 Sites.

2. The Department of Environment, Heritage and Local Government a) It is recommended that on page 25 of the Appropriate Assessment the European Communities (Natural Habitats) Regualtions, 1997 should be added to the list of Natioanl Legislation. b) The AA has only assessed the impact of policies and not of objectives. It is not clear however which objective relates to which policy. It is unclear if an assessment of objectives would be included by assessing only the policies. c) There is an error in tables 4 & 5 of the AA in that policy numbers 34 & 35 in table 4 on page 17 are in fact policy numbers 35 & 36. In addition mitigatory policies SI48, SI49 & QH22 do not appear in table 5. d) Some polices such as SC2 in Appendix 1 of the AA have been screened out and listed as having a positive impact. It is unclear how such polices will have appositive impact on Natura 2000 sites. It should also be noted that AA screening is to determine if a policy will have a significant effect on a Natura 2000 Site which can include both a positive and a negative effect. e) Policy SI47 regarding flood plans has been screened out due to the reason given that it will protect the River Tolka and River Liffey and SPA‟s from flooding and it is unclear how preventing this flooding will positively impact on SPA‟s. f) In relation to policy SI17 (Eastern Bypass) it is considered appropriate to liaise with Dun Laoghaire Rathdown County Council to seek to ensure that both plans are compatible with each other. g) It is recommended that Dublin City Council seek to ensure that the proposed S2S route is treated in a similar manner between both Dublin City Council and Dun Laoghaire Rathdown County Council. The rational for screening out policy GC20 should be amended

Mitigation measures for policy GC36 are set out under GC35 should in fact be numbered GC36.

Policy SI33 should be screened in for assessment as one of the options being discussed is bringing water from the River Shannon due to the potential ex-situ impacts.

Policy SI41 should be screened in for assessment as it is suggested that the development of a second waste water treatment plant and an orbital sewer has the potential to negatively impact on the natural heritage and in particular Natura 2000 sites.

3. The Department of Communications, Energy and Natural Resources has no comment to make at this time in relation to the Appropriate Assessment of the Draft Development Plan.

Other Submissions l) A submission states that there are significant populations of Brent Geese on the South Dublin Bay Natura 2000 site and developments in this area would be open to challenge under EU legislation. It is also suggested that there is a need for a Protected Bird Species Management Plan for South Dublin Bay. m) A submission from the Green Party states that the Eastern Bypass would have a detrimental impact on a Natura 2000 site and could result in significant flooding and coastal erosion problems in other coastal locations. n) A submission from the Green Party states that the Eastern Bypass would have a detrimental impact on a Natura 2000 site and could result in significant flooding and coastal erosion problems in other coastal locations. o) One submission suggests that the proposal to include such lands, and adjacent lands, in Strategic Development and Regeneration Area SDRA6 (Poolbeg) is open to challenge under EU environmental legislation. Development adjacent to these lands, especially which would increase uncontrolled recreational use in the vicinity, would be to the detriment of the Brent Geese.

It is also submitted that Dublin's Biodiversity Action Plan does not refer to the protected bird species in or adjacent to South Dublin Bay. Therefore its use as a monitoring scheme to monitor the effectiveness of mitigation measures GC22 (improvement of recreational amenities in costal waters and to protect wildlife), GC24 (to protect EU designated flora, fauna and habitats), GC25 (to conserve and manage NHAs, SACs and SPA)s, GC26 (conservation of areas of natural environmental value) as listed on pages 39-41 of the Appropriate Assessment document, will not be adequate in the case of South Dublin Bay. Manager's Response 1. In response to the Environmental Protection Agency’s submission it is considered appropriate to insert a new policy within Section 6.4.6 Biodiversity that sets out a requireme1nt for an AA Screening for new/reviewed/amended Plans or proposed projects, that may have the potential to impact on Natura 2000 Sites. 2. The Department of Environment, Heritage and Local Government submission a) It is considered appropriate to add the European Communities (Natural Habitats) Regulations, 1997 (SI No.94 of 1997) and its amendments (SI No. 233 of 1998 and SI No. 378 of 2005) to the list of National Legislation listed on page 25 of the Appropriate Assessment. b) The Appropriate Assessment for the Draft Dublin City Development Plan 2011-2017 commenced and was undertaken for the Manager‟s Proposed Draft Plan (12 October 2009) and the Draft Plan (21 December 2009) prior to the publication of the Draft Guidelines “Appropriate Assessment of Plans and Projects in Ireland” (upon which the City Council has made a sperate submission) and in the absence of any national guidance on an appropriate methodology, save for the Circular Letter SEA 1/08 & NPWS 1/08. The objectives contained in the Draft Development Plan essentially represent the means of achieving policies at a specific level and the objectives consist of a series of subsidiary action items that flow from a group of policies, or indeed in some instances a singular policy. (See Glossary for definitions for polices/objectives) However, it is accepted that there may be some cases where an objective or a small number of objectives which may require to be screened independently to establish their potential to impact upon any of the identified Natura 2000 sites. It is considered appropriate as a precautionary measure to undertake an exercise to ensure that objectives contained in the Development Plan are grouped to the relevant policy or set of policies which they represent a means of achieving at a specific level. If an objective is found to have policy implications or requires to be screened independently the appropriate assessment of the Development Plan will be updated accordingly. c) The anomalies which have been highlighted regarding numbering are noted and will be corrected accordingly. d) The comment in relation to the rational for screening some polices out in table 1 of Appendix 1 of the AA is noted. It is considered appropriate to undertake a review of the Appropriate Assessment Screening and where it is found that policies which have no impact on the integrity of the identified Natura 2000 sites but which have a positive impact on the built environment etc, these policies will be screened out rather than in as is the case currently. The rational for screening a number of policies out in Table 1 has been reviewed and the screening assessment has been updated accordingly. The following policies have been screened out as having no potential impacts SC2, SC30, SI2, SI4, SI10, SI57, SI61, QH8, QH10, QH13. e) The reason for screening out Policy SI47 as highlighted by the DOEHLG will be amended accordingly in appendix 1 of the Appropriate Assessment. f) Dublin City Council has liaised with Dun Laoghaire Rathdown County Council to ensure that both Development Plans are compatible with each other in respect to the Eastern Bypass. The Appropriate Assessment will be amended accordingly. g) Dublin City Council has also liaised with Dun Laoghaire Rathdown County Council to ensure that both Development Plans are compatible with each other in respect to the proposed Sutton to Sandycove Coastal Greenway (S2S). The Appropriate Assessment will be amended accordingly. h) It is appropriate to amend the reason for screening out Policy GC20 as requested by the Department of Environment Heritage and Local Government. i) Thenumbering system will be amended accordingly to ensure that Policy GC35 is renumbered GC36.

J) Dublin City Council acting on behalf of the local authorities in the Dublin Region is currently studying a number of options for developing a new long term water supply for the city and region. The current study is entitled „Water Supply Project – Dublin Region (Draft Plan)‟.This draft plan has been subject to a Habitats Directive Assessment. It is neither a policy nor an objective of the Draft Dublin City Development Plan to abstract water from the River Shannon. Accordingly it is considered inappropriate to screen in policy SI33. k) It is acknowledged that Policy SI41 has the potential to impact negatively on the natural heritage and in particular Natura 2000 sites. This policy will be screened in and brought forward to stage two of the Appropriate Assessment.

3. The submission from the Department of Communications, Energy and Natural Resources is noted.

Other Submisisons l) The importance of South Dublin Bay is fully acknowledged and is reflected in policies and objectives of the Development Plan. It is also proposed to insert a new policy to Section 6.4.6 of the Development Plan to ensure that any plan or project with the potential to give rise to significant direct, indirect or secondary impacts on a Natura 2000 site(s) shall be subject to appropriate assessment procedures in accordance with Article 6(3) of the Habitats Directive. It is the goal of National Parks & Wildlife Service to draw up conservation plans for all areas designated for nature conservation. Currently, such plans include a management framework section that outlines objectives and strategies. m) Policy SI17 supports the provision of an Eastern bypass route. However, this policy statement states that the precise alignment and detailed design of the route shall be subject to an Environmental Impact Assessment, and all statutory requirements, including the requirements of the Habitats Directive. The Appropriate Assessment of the Draft Plan acknowledges the potential impact of the proposed project on Natura 2000 sites and provides mitigation measures. An in depth assessment of the potential impacts of the proposed Eastern Bypass Route on Natura 2000 sites would be carried out in the habitats directive screening pertaining to the individual project. n) The Poolbeg Peninsula is included in the Docklands Masterplan and significant parts are included in the proposed Poolbeg Planning Scheme. Dublin City Council under Section 24 (5) (a) of the Dublin Docklands Development Authority Act, 1997 in its role as planning authority is required to be consistent with the Dublin Docklands Master Plan. It is therefore considered appropriate that the Development Plan should take cognisance of the Planning Scheme. It should be noted that the Draft Poolbeg Planning Scheme was subjected to Appropriate Assessment which is contained in the Environmental Impact Assessment of the Planning Scheme.

The Biodiversity Action Plan includes all designations, including South Dublin Bay cSAC and Sandymount Strand/Tolka Estuary SPA, which were current at the time of publication (2008). The Biodiversity Action Plan remains in effect until 2012, when it will be updated and will include all designated areas in existence at that time. Protected bird species are listed on p. 39 for the Special Protection Areas and on pp. 51-52. The Biodiversity Action Plan also includes a list in Appendix 3 of Breeding, Wintering and Migrant Birds of Dublin City and Bay on pp. 53-56 which notes those species designated and the Annex in which they are listed in the Directive. Therefore, it is directly applicable to the mitigatory measures stated. Species Action Plans are the responsibility of the NPWS. It is understood that the NPWS is drawing up a Brent Geese Management Plan for the Greater Dublin Area, including South Dublin Bay, and meeting with all the local authorities. However, Dublin City Council Biodiversity Office has given a commitment to participate in this process of drawing up the Management Plan. Manager's Recommendation 1. Insert new policy GC28A to Section 6.4.6 on page 76 of the Draft Development Plan directly after Policy GC28 as follows:

It is the Policy of Dublin City Council that any plan or project with the potential to give rise to significant direct, indirect or secondary impacts on a Natura 2000 site(s) shall be subject to an appropriate assessment in accordance with Article 6(3) of the Habitats Directive.

2. a) Insert the following bullet point on page 25 of the Appropriate Assessment

- The European Communities (Natural Habitats) Regulations, 1997 (SI No.94 of 1997) and its amendments (SI No. 233 of 1998 and SI No. 378 of 2005) b) This exercise was undertaken and it was found that the following objectives are not aligned to any specific policy. Accordingly they were screened for Appropriate Assessment;

SCO13 To compile an audit of private areas, adjacent to public thoroughfares, onto which members of the public are invited by the owner (i.e. private landings) that the CSCO13 ouncil deem to be in need of enhancement.

SIO32 To develop lorry parks and bus parks in suitable locations in co-operation with private enterprise, so as to eliminate the hazards of unsuitable lorry and bus parking in residential and other areas.

GCO39 To seek to provide public access to Fitzwilliam Square Park, and pending the full acquisition of the park for the city, to seek to have it opened on a number of designated open days‟. Also to seek to provide public access to the park at Wilton Terrace.

GCO42 To facilitate use of Lansdowne Valley – from Inchicore to Drimnagh Castle – in accordance with the provisions set out in the Drimnagh Integrated Area Plan (June 2009).

Objectives GC039, SCO13 & GC42 were found to have no potential impact on the integrity of the identified Natura 2000 sites. Objective SCO13 refers to brownfield sites such as forecourts of filling stations.

Objective SIO32 has the potential to impact on the integrity of the identified Natura 2000 sites and it is recommended that this objective be screened in. The following policies will serve as mitigation measures;

- GC28A That any plan or project with the potential to give rise to significant direct, indirect or secondary impacts on a Natura 2000 site(s) shall be subject to an appropriate assessment in accordance with Article 6(3) of the Habitats Directive.

- SI39ATo protect the city‟s ground water resources in accordance with The Water Framework Directive. - SI49 To require the use of Sustainable Urban Drainage Systems in all new developments, where appropriate, set out in The Greater Dublin Regional Code of Practice for Drainage Works.

These findings will be incorporated into the update/addendum of the AA. c) Amend Table 4 & 5 of the Appropriate Assessment as follows; - Renumber policies GC34 & GC35 to GC35 & GC36 in table 4 - Add policies SI48, SI49 & QH22 to table 5 d) This exercise was undertaken and it was found that the following policies can be screened out as having no potential impacts on the identified Natura 2000 sites;

SC2, SC30, SI2, SI4, SI10, SI57, SI61, QH8, QH10, QH13. It is recommended that the screening document (appendix 1 of the Appropriate Assessment) be updated accordingly. It is also recommended that the aforementioned policies also be removed from table 5: Mitigatory Policies on page 21 of the Appropriate Assessment. e) Amend the reason for screening out Policy SI47 on page 18 of Appendix 1 of the AA From: Positive Impacts Only

To: No potential Impacts f) Amend the wording of policy SI17 on page 49 of the Draft Development Plan

From: It is the policy of Dublin City Council to support the provision of an Eastern Bypass route. This route shall link the northern port to the Southern Cross/South Eastern Motorway by way of a bored tunnel under Sandymount, Merrion Strand and Booterstown Marsh. The precise alignment and detailed design of this route shall be subject to an Environmental Impact Assessment, and all the statutory requirements, including the requirements of the Habitats Directive, shall respect the amenity of the River Liffey Estuary and Dublin Bay and shall be subject of a future plan variation.

To: It is the policy of Dublin City Council to support the provision of a link between north Dublin Port and the Southern Cross/South Eastern Motorway via an eastern bypass of the City, in conjunction and co-operation with other transport bodies, the National Roads Authority and local authorities. The preferred method is by means of a bored tunnel and the preferred route is under Sandymount and Merrion Strand and Booterstown Marsh. However, the route and detailed design of the link road will be subject to an Environmental Impact Assessment and all statutory requirements, including a public consultation process, by the relevant authorities. An Appropriate Assessment of the proposed project for the entire route is also required in accordance with the Habitats Directive. g) Amend the wording of (i) Objective GCO2

From: To progress a cycle and walking route along a continuous coastal route from Sutton to Sandycove (often referred to as the S2S route.

To: To promote the development of the Sutton to Sandycove Cycletrack Scheme (S2S) as a key objective in both ‘Smarter Travel’ and in the ‘National Cycle Policy Framework’ subject to the appropriate environmental assessments, including any assessment required under article 6(3) of the Habitats Directive. Subject to compliance with environmental regulations and statutory approvals, completion of this project is recognised as a significant development of Dublin Bay with potential recreational and tourism benefits, as well as providing a traffic-free cycleway for both recreation and commuter cyclists.

As Objective GC02 is linked to policy GC1, it is recommended policy GC1 be screened in as having potential to impact on the integrity of the identified Natura 2000 sites. The following policies will serve as mitigation measures;

GC28A that any plan or project with the potential to give rise to significant direct, indirect or secondary impacts on a Natura 2000 site(s) shall be subject to an appropriate assessment in accordance with Article 6(3) of the Habitats Directive. Policy GC6 To protect and improve the natural character of watercourses and to promote access, walkways and other compatible recreational uses along them that do not negatively impact on biodiversity. Policy GC9 To continue to protect and enhance the landscape and green spaces through sustainable design and planning for both the existing community and for future generations in accordance with the principles of the European Landscape Convention. Policy GC20 To develop sustainable coastal, estuarine, canal and riverine recreational amenities to enhance appreciation of the natural assets of the coast, estuaries, rivers and canals. Policy GC24 To protect flora, fauna and habitats, which have been identified by the Habitats Directive, Birds Directive, Wildlife Act 1976 (as amended), the Flora Protection Order (S.I. no. 84 of 1999), and the European Communities (Natural Habitats) Regulations 1997 (S.I. no. 94 of 1997) Policy GC26 To seek the conservation and management of areas of natural environmental value. Policy GC27 To conserve priority species, habitats, and natural heritage features identified in the Biodiversity Action Plan for priority conservation measures. Policy GC28 To have regard to the conservation and enhancement of significant non-designated areas of ecological importance in accordance with development standards set out in this plan. Policy GC25 To conserve and manage all Natural Heritage Areas, Special Areas of Conservation and Special Protection Area identified and designated, or proposed to be designated, by the Department of Environment, Heritage and Local Government. These designations will allow for protection in the event of any approved boundary changes by the Department of Environment, Heritage and Local Government. h) Amend the reason for screening out policy GC20 from “Positive Impacts Only” to “Policies GC24-28 protect biodiversity and designated sites along with Policy GC21 which seeks to cooperate with Dublin Taskforce to work towards developing a framework for a coastal zone management plan for Dublin Bay. Furthermore, Dublin City Council has liaised with NPWS on the management of beaches and produced a management plan for North Bull Island". i) Amend Table 4 & 5 of the Appropriate Assessment as follows: Renumber policies GC34 & GC35 to GC35 & GC36 in table 4. j) Retain as existing k) Screen in Policy SI41 at the screening assessment stage as having a potential negative impact on the integrity of the identified Natura 2000 Sites and carry the policy forward to appropriate assessment stage. The following policies will serve as mitigation measures;

GC28A That any plan or project with the potential to give rise to significant direct, indirect or secondary impacts on a Natura 2000 site(s) shall be subject to an appropriate assessment in accordance with Article 6(3) of the Habitats Directive. Policy GC24 To protect flora, fauna and habitats, which have been identified by the Habitats Directive, Birds Directive, Wildlife Act 1976 (as amended), the Flora Protection Order (S.I. no. 84 of 1999), and the European Communities (Natural Habitats) Regulations 1997 (S.I. no. 94 of 1997) Policy GC25 To conserve and manage all Natural Heritage Areas, Special Areas of Conservation and Special Protection Area identified and designated, or proposed to be designated, by the Department of Environment, Heritage and Local Government. These designations will allow for protection in the event of any approved boundary changes by the Department of Environment, Heritage and Local Government. Policy GC26 To seek the conservation and management of areas of natural environmental value. Policy GC27 To conserve priority species, habitats, and natural heritage features identified in the Biodiversity Action Plan for priority conservation measures. GC28A That any plan or project with the potential to give rise to significant direct, indirect or secondary impacts on a Natura 2000 site(s) shall be subject to an appropriate assessment in accordance with Article 6(3) of the Habitats Directive. Policy GC24 To protect flora, fauna and habitats, which have been identified by the Habitats Directive, Birds Directive, Wildlife Act 1976 (as amended), the Flora Protection Order (S.I. no. 84 of 1999), and the European Communities (Natural Habitats) Regulations 1997 (S.I. no. 94 of 1997) Policy GC25 To conserve and manage all Natural Heritage Areas, Special Areas of Conservation and Special Protection Area identified and designated, or proposed to be designated, by the Department of Environment, Heritage and Local Government. These designations will allow for protection in the event of any approved boundary changes by the Department of Environment, Heritage and Local Government. Policy GC26 To seek the conservation and management of areas of natural environmental value. Policy GC27 To conserve priority species, habitats, and natural heritage features identified in the Biodiversity Action Plan for priority conservation measures. Policy GC22 To seek the continued improvement of water quality, bathing facilities and other recreational opportunities in the coastal, estuarine and surface waters in the city and to protect the ecology and wildlife of Dublin Bay.

3. Retain as existing

Other Submissions l) Retain as existing m) Retain as existing n) Retain as existing

The AA will be updated to take account of the above recommendations by way of addendum which will form part of the display material for the second public display and submissions will be invited from members of the public on the AA as well as the proposed amendments to the Draft Development Plan. Screening of the proposed amendments to policies and non aligned objectives set out in the Manager’s Report of the Draft Development Plan May 2010 to determine the potential impact on the integrity of Natura 2000 sites Policy/Objective Potential Impact Amend wording of Policy SI50 No Potential Impacts Amend wording of Policy SI58 No Potential Impacts Amend wording of Policy SI46 No Potential Impacts Amend wording of Policy SI39 Positive Impacts Insert new Policy SI39A Positive Impacts Amend wording of Policy SI49 Positive Impacts Amend wording of Policy SI40 No Potential Impacts Amend wording of Policy SI41 Potential Negative Impacts (Already screened in for AA - Mitigation measures provided) Insert new Objective SIO72 No Potential Impacts Amend wording of Policy HR7 No Potential Impacts Amend wording of Policy RE2 No Potential Impacts Amend wording of Policy RE4 No Potential Impacts Amend wording of Policy RE10 No Potential Impacts Amend wording of Policy RE14 No Potential Impacts Amend wording of Policy RE15 No Potential Impacts Amend wording of Policy RE16 No Potential Impacts Amend wording of Policy RE17 No Potential Impacts Amend wording of Policy RE20 No Potential Impacts Amend wording of Policy RE27 No Potential Impacts Amend wording of Policy RE28 No Potential Impacts Amend wording of Policy RE29 No Potential Impacts Insert new Policy RE30A No Potential Impacts Insert new Policy NC23A No Potential Impacts Amend wording of Policy SC13 No Potential Impacts Insert new Policy SI07A No Potential Impacts Amended wording of Objective SIO32 Potential Negative Impacts (Recommended to be screened in for AA – Mitigation measures provided) Amend wording of Policy GC9 Positive Impacts Amend wording of Policy GC20 Positive Impacts Amend wording of Policy GC25 Positive Impacts Amend wording of Policy GC33 Positive Impacts Amend wording of Policy GC30 Positive Impacts Amend wording of Policy GC31 Positive Impacts Amend wording of Policy GC14 Positive Impacts Amend wording of Policy GC5 Positive Impacts Amend wording of Policy GC6 Positive Impacts Amend wording of Policy GC22 Positive Impacts Insert new Policy GC28A Positive Impacts Amend wording of Policy FC33 No Potential Impacts Amend wording of Policy QH10 No Potential Impacts Amend wording of Policy QH17 No Potential Impacts Amend wording of Policy QH29 No Potential Impacts Amend wording of Policy FC1 No Potential Impacts Insert new Policy FC26A No Potential Impacts Screening of the proposed amendments to policies and non aligned objectives set out in the Manager’s Report of the Draft Development Plan May 2010 to determine the potential impact on the integrity of Natura 2000 sites Amend wording of Policy FC26 No Potential Impacts Amend wording of Policy FC27 No Potential Impacts Amend wording of Policy FC34 No Potential Impacts Amend wording of Policy FC33 No Potential Impacts Amend wording of Policy FC36 No Potential Impacts Amend wording of Policy FC39 No Potential Impacts Amend wording of Policy FC43 No Potential Impacts Amend wording of Policy FC45 No Potential Impacts Removal of policy FC47 & FC48 No Potential Impacts Amend wording of Policy FC56 No Potential Impacts Amend wording of Policy FC61 No Potential Impacts Insert new Policy FC62A No Potential Impacts Insert new Policy FC62B No Potential Impacts

The above policies/objectives were screened by a person with ecological expertise.