Chief Executive’s Report Pre-Draft Consultation 10th July 2015
Fingal Development Plan 2017-2023
CONTENTS
Chief Executive’s Report Pre-Draft Consultation 10th July 2015
Chief Executive Paul Reid
Director of Services Gilbert Power
Senior Planner Rachel Kenny
Design & Publishing Technical Section
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 2017-2023
CONTENTS
PART ONE AN EXPLANATION OF THE LEGISLATIVE REQUIREMENTS FOR THE MAKING OF THE NEW DEVELOPMENT PLAN & CHIEF EXECUTIVE’S REPORT, A DESCRIPTION OF THE CONSULTATION PROCESS, AND AN OVERVIEW OF ISSUES RAISED 1. Purpose and Contents of Chief Executive’s Report 1
2. Legislative Background for the Fingal Development Plan 1
3. Legislative Requirements for Chief Executive’s Report 2
4. Description of Notification Procedure / Consultation Process 3
5. Overview of Issues raised at the Public and Stakeholder Meetings 5
6. Overview of Issues raised from Written and On-Line Submissions 7
7. Approach to Consideration of Submissions and results of Public 9 Consultation/stakeholder Meetings
PART TWO ANALYSIS AND SUMMARY OF THE ISSUES RAISED IN THE SUBMISSIONS RECEIVED BY THE COUNCIL AND AT THE PUBLIC CONSULTATION MEETINGS 1. Introduction 11
2. Submissions from the Eastern and Midland Regional Assembly and 12 National Transport Authority
3. Cross Cutting Themes 18
4. Settlement Strategy 32
5. Placemaking & Communities 40
6. Infrastructure & Movement 51
7. Economic Development 71
8. Green Infrastructure 82
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 2017-2023 CONTENTS
9. Natural Heritage 84
10. Cultural Heritage 88
11. Impacts on the Environment 92
12. Miscellaneous 95
PART THREE CHIEF EXECUTIVE’S POLICY RECOMMENDATIONS BY TOPIC
1. Main Aims of the Development Plan 101
2. Strategic Policy 102
3. Settlement Strategy 103
4. Placemaking & Communities 104
5. Infrastructure & Movement 106
6. Economic Development 108
7. Green Infrastructure 110
8. Natural Heritage 110
9. Cultural Heritage 111 APPENDICES Appendix A i Development Plan Timeline Appendix B ii Lists of written submissions by number and name of persons bodies Appendix C xv List of Prescribed Bodies who were informed of the Review of the Development Plan under the statutory process Appendix D xvii List of those invited to the Stakeholder Meetings
Chief Executive’s Report Pre-Draft Consulation July 2015 Fingal Development Plan 2017-2023 GLOSSARY
A
AA Appropriate Assessment (see also HDA and NIS)
ACA Architectural Conservation Area
AILG Association of Irish Local Government
B
BRE Building Research Establishment (UK)
BRT Bus Rapid Transit
BS British Standards
C
CCMA City and County Managers Association
CEDRA Commission for the Economic Development of Rural Areas
CSO Central Statistics Office
D
DAA Dublin Airport Authority
DAHG Department of Arts, Heritage and the Gaeltacht
DART Dublin Area Rapid Transport
DEP Dart Expansion Programme
DLR Dun Laoghaire-Rathdown County Council
DMURS Design Manual for Urban Roads and Streets
DOCENR Department of Communications, Energy and Natural Resources
DOECLG Department of the Environment, Community and Local Government
DOEHLG Department of the Environment, Heritage and Local Government
DP Development Plan
DTA Dublin Transport Authority
DTO Dublin Transportation Office
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 2017-2023 GLOSSARY
E
EIA Environmental Impact Assessment
EIS Environmental Impact Statement
EMRA Eastern and Midlands Regional Assembly
EPA Environmental Protection Agency
ERBD Eastern River Basin District
EU European Union
ECFRAMS Eastern Catchment Flood Risk Assessment and Management Study
EV Electric Vehicles
F
FCC Fingal County Council
FDI Foreign Direct Investment
FEMFRAMS Fingal East Meath Flood Risk Assessment and Management Study
G
GDA Greater Dublin Area
GDD Greater Dublin Drainage
GDSDS Greater Dublin Strategic Drainage Study
GFA Gross Floor Area
GI Green Infrastructure
GSI Geological Survey of Ireland
H
HDA Habitats Directive Assessment (see also AA and NIS)
HGV Heavy Goods Vehicle
Chief Executive’s Report Pre-Draft Consulation July 2015 Fingal Development Plan 2017-2023 GLOSSARY
HLC Historic Landscape Characterisation
HSA Health and Safety Authority
HSE Health Service Executive
I
IALPA Irish Airline Pilots Association
ICW Integrated Constructed Wetland
ICT Information and Communication Technology
IDA Industrial Development Authority
IPCC Intergovernmental Panel on Climate Change
L
LAP Local Area Plan
LECP Local Economic and Community Plan
LEO Local Enterprise Office
LCDC Local Community Development Committee
LCDP Local Community Development Programme
LCA Landscape Character Assessment
LO Local Objective
M
ML Megalitre
N
NAMA National Asset Management Agency
NBP National Biodiversity Plan
NGO Non-Governmental Organisation
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 2017-2023 GLOSSARY
NHA Natural Heritage Area
NIS Natura Impact Statement (see also AA and HDA)
NPF National Planning Framework
NPWS National Parks and Wildlife Services
NRA National Roads Authority
NSS National Spatial Strategy
NTA National Transport Authority
O
OECD Organisation for Economic Co-operation and Development
OPW Office of Public Works
P
PE Population Equivalent pNHA proposed Natural Heritage Areas
PSV Public Safety Zone
PV Photovoltaics
Q
QBC Quality Bus Corridor
R
RAPID Revitalising Areas by Planning Investment and Development
RAS Rental Accommodation Scheme
REPS Rural Environment Protection Scheme
R&D Research and Development
Chief Executive’s Report Pre-Draft Consulation July 2015 Fingal Development Plan 2017-2023 GLOSSARY
RFF Refuge for Fauna
RMP Record of Monuments and Places
RPG Regional Planning Guidelines
RPS Record of Protected Structures
RSES Regional Spatial and Economic Strategy
S
SAAO Special Amenity Area Order
SAC Special Areas of Conservation
SDCC South Dublin County Council
SDZ Strategic Development Zone
SEA Strategic Environmental Assessment
SFRA Strategic Flood Risk Assessment
S.I. Statutory Instrument
SICAP Social Inclusion and Community Activation Programme
SID Strategic Infrastructure Development
SIU Social Inclusion Unit
SME Small and Medium Enterprise
SMS ‘Sutton-Malahide-Swords’ Cycle Route
SNR Statutory Nature Reserve
SPC Strategic Policy Committee
SPA Special Protection Area
SQ M Square Metres
SUDS Sustainable Urban Drainage Systems
SWRR Swords Western Ring Road
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 2017-2023 GLOSSARY
W
WFD Water Framework Directive
WFDRPA Water Framework Directive Register of Protected Areas
WMU Water Management Unit
WSSP Water Services Strategic Plan
WTP Water Treatment Plant
WWD Waste Water Discharge
WWT Waste Water Treatment
WWTP Waste Water Treatment Plant
Chief Executive’s Report Pre-Draft Consulation July 2015 Fingal Development Plan 2017-2023 PART ONE
LEGISLATIVE BACKGROUND AND PROCESS
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 2017-2023
PART ONE
AN EXPLANATION OF THE LEGISLATIVE REQUIREMENTS & CHIEF EXECUTIVE’S REPORT 1. PURPOSE AND CONTENTS OF CHIEF EXECUTIVE’S REPORT
The purpose of the Chief Executive’s Report is to present the outcomes of the initial consultation process carried out prior to the preparation of the Draft Development Plan. The preparation of report forms part of the statutory procedure for the preparation of a Development Plan set out in the Planning and Development Act 2000-2014. The report is made up of three Parts and four Appendices.
Part One: provides an explanation of the legislative background for the making of a Development Plan, including a description of the steps in the process of making the Plan. The legislative requirement for the Chief Executive’s Report is also outlined, followed by a description of the notification procedure and consultation process. The consultation process, which resulted in 325 submissions together with hundreds of views and ideas recorded at four public consultation evenings and three stakeholder meetings. A broad overview of issues raised at the public and stakeholder meetings, and those raised in the submissions are given. Details of the approach taken in considering the issues raised and submissions received are outlined, before concluding with a description of the next stages in the process towards the making of the new Plan are also outlined.
Part Two: consists of a summary, analysis, and Chief Executive’s Opinion in respect of the issues raised in the written submissions received by the Council, at the public consultation evenings and stakeholder meetings.
Part Three contains the Chief Executive’s Recommendations on policies to be contained in the Draft Development Plan.
Four Appendices are presented at the back of this document:
Appendix A: Development Plan Timeline
Appendix B: Lists written submissions by number and name of persons/bodies.
Appendix C: List of prescribed bodies who were informed of the Review of the Development Plan under the statutory process.
Appendix D: List of those invited to the Stakeholder meetings.
2. LEGISLATIVE BACKGROUND FOR THE FINGAL DEVELOPMENT PLAN The prescribed process and timetable for the preparation of the Fingal Development Plan 2017-2023 is outlined in Appendix A of this report. The process set out in the Planning and Development Act 2000 as amended gives a ninety-nine week period for the adoption of the Plan and involves public consultation at three separate stages which are indicated on the Timetable. The first stage of public consultation ran from 20th March 2015 to the 15th May
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 1 2017-2023 PART ONE
2015 allowing public involvement at an early stage in the Plan preparation process. The early involvement provides an opportunity for all of the stakeholders with an interest in the development of the County – residents, service providers, visitors, investors, etc. to have a greater influence on and sense of ownership of the new Plan.
The Planning and Development Act 2000 - 2014 sets out mandatory objectives which must be included in a Development Plan. These include, inter alia, objectives for the zoning of land, the provision of infrastructure, the conservation and protection of the environment, and the integration of the planning and sustainable development of the area with the social, community and cultural requirements of the area and its population. Other non-mandatory objectives are also referred to in the Planning Act. There is also a requirement for a Strategic Environmental Assessment and Appropriate Assessment of the new Plan.
3. LEGISLATIVE REQUIREMENTS FOR CHIEF EXECUTIVE’S REPORT Under the Planning and Development Act 2000, the Chief Executive, as part of the Development Plan process, is required to prepare a “Chief Executive’s Report” on the submissions and observations received, to respond to the issues raised and to make recommendations on the policies to be included in the draft plan. The legislation also requires that all of the foregoing must be considered against a backdrop of national policy, guidelines and standards.
Section 11(4) of the Planning and Development Plan Act 2000 (as amended) sets out the requirements in relation to the preparation of a Chief Executive’s Report. The Chief Executive’s Report is required to deal with any submission or observations received on foot of the notifications and consultations carried out under Section 11(2) and (3) of the Act), with, inter alia members of the public, prescribed bodies, service providers and An Bord Pleanala. The Report must be prepared not later than 16 weeks after giving notice that the Development Plan is to be reviewed under Section 11(1), which means that in relation to this current process the Report is required to be published by the 10th July 2015.
In accordance with Section 11 (4) (b) the Chief Executive’s Report must:
• List the persons or bodies who made submissions or observations, as well as any persons or bodies consulted
• Summarise the issues raised in the submissions and during the consultations, where appropriate, but shall not refer to a submission relating to a request or proposal for zoning of particular land for any purpose.
• Give the Opinion of the Chief Executive on the issues raised. In this regard the Chief Executive’s Opinion must take into account:
- the proper planning and sustainable development of the area,
- the statutory obligations of any local authority in the area, and
- any relevant policies or objectives of the Government or of any Minister of the Government.
• Finally, the Report must state the Chief Executive’s Recommendations on the policies to be included in the draft Development Plan.
The Chief Executive’s Report must then be submitted to the Members of the Planning Authority or a Committee of the Planning Authority for their consideration.
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Members may then issue directions to the Chief Executive regarding the preparation of the Draft Plan (Section 11(4) (d)). These directions might consist of concerns that Members would like to see addressed or policies/objectives that Members would like to see incorporated into the Draft Plan. The directions must take into account the statutory obligations of the Local authority and any relevant policies or objectives of the Government or of any Minister of the Government.
In issuing directions, Section 11(4)(f) of the Act states that the Members shall be restricted to considering the proper planning and sustainable development of the area to which the development plan relates. Directions must be issued not later than 10 weeks after the submission of the Chief Executive’s Report (In this instance by the 14th August 2015. 4. DESCRIPTION OF NOTIFICATION PROCEDURE / CONSULTATION PROCESS The Pre-Draft consultation stage ran from the 20th March 2015 to the 15th May 2015.
325 submissions were received during the pre-draft consultation period. The views of 148 people who attended the four public consultation evenings held around the County and 69 stakeholder representatives who attended the stakeholder meetings have also been considered. The opinions, views and ideas set out in the written submissions and those expressed and recorded at the consultation/stakeholder meetings related to all aspects of planning. The Council wishes to express its appreciation to those who made submissions and/or attended the public and stakeholder meetings.
The consultation process comprised four main elements:
(a) Public Consultation Evenings
The format for the consultation evenings involved participants being arranged into small groups around individual tables which included at least one facilitator/note taker from the Council. Elected members of the council and local TD’s were adviced of these meetings. Following an introductory presentation, the process was structured around five main broad topics
• Placemaking & Communities
• Infrastructure & Movement
• Economic Development
• Heritage
• Cross Cutting Themes
This process which typically enabled approximately 15 – 20 minutes discussion around each topic area allowed for the airing of views by all of those attending; and the recording of views and opinions that arose in real time. At the conclusion of each meeting an overall summary was reported back to the attendees outlining the most prevalent themes that were discussed.
Before and after the meeting there was also the opportunity to discuss informally any issues in greater detail as well as a demonstration on to how to formally make a submission on- line.
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 3 2017-2023 PART ONE
The format was considered to be very successful in obtaining feedback from those who attended the evenings.
148 persons attended four evening meetings, which were held in the following locations and on the following dates:
Date Venue Attendance 14th April 2015 Marine Hotel, Sutton 18 21st April 2015 Carnegie Court Hotel, Swords 53 23rd April 2015 Bracken Court Hotel, Balbriggan 52 28th April 2015 Fingal County Council’s Civic Office, Blanchardstown 25
(b) Stakeholder Meetings
Three consultation meetings were held with the main organisational stakeholders:
Date Venue Attendance 20th April 2015 Business 32 6th May 2015 Community, Voluntary & Environment 27 7th May 2015 Public and State 10
The aim of these meetings was to discuss issues, which are likely to have a significant bearing on Development Plan policy. Each stakeholder meeting followed a similar format to that of the public meetings. However, while the meetings involving the Community, Voluntary & Community Organisations and the Public and State Bodies followed the broad themes of Placemaking & Communities, Infrastructure & Movement, Economic Development, Heritage and Cross Cutting Themes; the Business Stakeholder meeting was arranged by the following themes:
• Fingal Opportunities & Weaknesses
• Industrial/High Technology/Office & Business Parks
• Retail/Town Centres
• Rural Economy
• Tourism
• Cross Cutting Themes
This was considered to be more appropriately focussed on broad theme areas more likely to be relevant to concerns of the business community, without precluding the discussion of other issues as they arose.
The format of the meetings and the main themes were again considered to be successful in ensuring that within a broad structure there was ample opportunity to allow a wide airing of views and opinions.
Lists of those organisations invited are included in Appendix D.
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(c) Publicity
On the 20th March 2015 an advertisement was placed in the Irish Times newspaper announcing the commencement of the review of the Development Plan. The Council also wrote to all of the prescribed bodies informing them of the review and inviting submissions and observations (see Appendix B).
A press release was sent to local and national papers in March 2015 giving details of the commencement of the development plan process, the public meetings arranged and how members of the public could become involved and make submissions. The release also encouraged people to the dedicated website for further information.
In order to ensure adequate information was available for interested people, groups and organisations, a plain language Consultation Booklet Fingal Development Plan 2017-2023 – Be part of it / Plean Forbartha Fhine Gall 2017-2023 Bi pairteach ann was published, in both English and Irish. The booklet formed the basis for the public consultation process. The booklet was distributed to households in Fingal as well as made available in libraries, community centres and Council Offices throughout the County.
An interview on local radio was used to promote the consultation process and public meetings. Social media was also used to disseminate information through Twitter and Facebook, along with more traditional posters in public areas to promote awareness of, and participation in the process.
(d) On – Line
Details of the Development Plan review together with other relevant documents were also placed on the Council Website. Furthermore, submissions could also be made via the web. Of the 325 submissions received in total, 178 were submitted on-line, representing 54.8% of the total submissions received during the consultation period; 86 submissions were received by post (26.4% of the total) and 61 received by email (18.8% of the total) during the consultation period.
During the public consultation period there were in excess of 9,200 ‘hits’ or unique page views on www.fingal.ie/devplan.
5. OVERVIEW OF ISSUES RAISED AT THE PUBLIC AND STAKEHOLDER MEETINGS After each meeting, compilation of issues was carried out followed by systematic categorisation of the topics and issues raised. Some 148 people attended the 4 public evenings held whilst 69 attended the 3 stakeholder meetings. A wide range of topics and concerns were raised, relating to all parts of the County.
In excess of 2,380 individual views and opinions were expressed over these meetings ranging from broad strategic issues to very detailed and focussed comments.
Figures 1 – 3 below give an indication in approximate terms of each of the broad themes raised at the meetings in percentage terms.
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 5 2017-2023 PART ONE
Fig. 1
In the region of 1,400 individual comments were recorded at the four public meetings.
Fig. 2
In the region of 470 individual comments were recorded at the two public meetings.
Fingal Development Plan 6 Chief Executive’s Report Pre-Draft Consulation July 2015 2017-2023 PART ONE
Fig. 3
Breakdown of Main Views/Concerns Raised at the Business Stakeholders Meeting
In the region of 530 individual comments were recorded at the Business Stakeholder Meeting.
How the Council further analysed the above is discussed later in this report.
6. OVERVIEW OF ISSUES RAISED FROM WRITTEN AND ON-LINE SUBMISSIONS 325 submissions (178 on-line; 86 by post; and 61 by email) were received during the consultation process. The number of submissions and observations received highlights the significant level of public interest in the plan-making process and the expectations for the Draft Development Plan itself, which will follow later in the year. There will be a further opportunity to make submissions when the Draft Plan is published in February 2016.
Upon receipt each, submission was initially allocated as an observation under the main high level topic/theme headings outlined in the Consultation Booklet. The submissions were then further broken down and categorised into observations by sub themes. This exercise identified approximately 920 separate observations included in the 325 submissions received; and made it possible to handle and analyse the submissions received in a coherent manner to ensure views were best represented for examination.
Figure 4 below illustrates the initial analysis at the first higher level topic/theme category. It provides an indication of what were the main areas of concern and issues that the Draft Plan should address.
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Fig. 4 Breakdown of Main issues Raised in the Submissions Received by theme/topic
Topic Percentage Cross Cutting Themes 4.75 Settlement Strategy 17.21 Placemaking and Communities 18.55 Infrastructure and Movement 24.48 Economic Development 12.61 Green Infrastructure 3.41 Natural Heritage 6.23 Cultural Heritage 4.45 Environmental Assessments 0.74 Miscellaneous 7.57
Included in the 325 submissions 17 of, in part at least, concerned rezoning proposals. Rezoning proposals are legally excluded from consideration at this stage of the process. The purpose of this stage of the Development Plan making process (the pre-Draft stage) is to set an overall strategy for the development of the County and a broad policy structure for the Draft Plan. The proper planning and sustainable development of the area requires that such a framework be agreed and that the re-zoning of land can only be considered in the context of this framework and of the overall land use zoning of the County.
It would therefore be premature at this early stage of the process to make determinations on individual re-zoning proposal. When a strategy and a set of policies have been determined, the issue of zoning will be considered in accordance with criteria for zoning set out below. The criteria are designed to allow the objective, consistent and transparent evaluation of proposals. The criteria will include:
• National/Regional/Local Policy context
• Assessment of Need
• Water, Drainage and Road Infrastructure (existing and planned)
• Supporting Infrastructure
• Physical Suitability
• Sequential approach
• Strategic Environmental Assessment/Appropriate Assessment.
For completeness the 17 submissions will be referenced in Part 2 of the report under Miscellaneous.
Fingal Development Plan 8 Chief Executive’s Report Pre-Draft Consulation July 2015 2017-2023 PART ONE
7. APPROACH TO CONSIDERATION OF SUBMISSIONS AND RESULTS OF PUBLIC CONSULTATION/STAKEHOLDER MEETINGS An analysis of the submissions and the results of the public consultation/stakeholder meetings was carried out and the topics and issues raised have been extracted and categorised. This is dealt with in greater detail in Part Two of this report. It is possible to see overall themes reflecting the concerns of the public emerging in this process. This report analyses these themes and, having regard to national, regional and local policies and guidelines, suggests how policies might be incorporated into the new Draft Plan.
In Part Two, the Issues raised in submissions and from public consultation/stakeholder meetings are summarised and analysed under the following headings:
• Introduction
• Submissions from the Regional Authority (Eastern and Midland Regional Assembly) and National Transport Authority.
• Cross Cutting Themes
• Settlement Strategy
• Placemaking and Communities
• Infrastructure and Movement
• Economic Development
• Green Infrastructure
• Natural Heritage
• Cultural Heritage
• Impacts on the Environment
• Miscellaneous
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 9 2017-2023 PART ONE
Fingal Development Plan 10 Chief Executive’s Report Pre-Draft Consulation July 2015 2017-2023 PART TWO
ANALYSIS AND SUMMARY OF ISSUES RAISED
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 2017-2023
PART TWO INTRODUCTION
ANALYSIS AND SUMMARY OF THE ISSUES RAISED 1. Introduction This Part of the Report considers and analyses the issues in the 325 written submissions and in doing so also incorporates those issues raised at the public consultation and stakeholder meetings.
Each of the 325 submissions received has been allocated a unique reference: for example P00064/1155. This referencing system identifies an individual submission, while the final four digits refer to the Development Plan Initial Submission Stage. As the final four digit are common to all submissions made in this Report only the first five digit reference, preceded by the letter ‘P’ is recorded here. As statutorily required the individual submissions received are listed in Appendix B.
Submissions are discussed under high level themes identified, and listed below. This begins with a separate analysis of the submissions received from the Eastern & Midland Regional Assembly and the National Transport Authority, to accord with legislative requirements (Section 11 (4) (bb) and (bc) of the Planning and Development Act 2000 (as amended) refers).
Each broad theme is considered by first setting out the Strategic Context, followed bya Summary of the Issues Raised before providing the Chief Executive’s Opinion on the main issues.
The submissions are discussed under the following headings:
• Eastern & Midland Regional Assembly
• National Transport Authority
• Cross Cutting Themes
• Settlement Strategy
• Placemaking and Communities
• Infrastructure and Movement
• Economic Development
• Green Infrastructure
• Natural Heritage
• Cultural Heritage
• Impacts on the Environment
• Miscellaneous
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 11 2017-2023 PART TWO EMRA & NTA SUBMISSIONS
2. SUBMISSIONS FROM EMRA & NTA ISSUES RAISED BY THE EASTERN & MIDLAND REGIONAL ASSEMBLY (SUBMISSION NO. P00034) Introduction and Legislative Context
The submission provides a detailed background to the purpose of the Regional Planning Guidelines. Details the new proposed Regional Assembly Structure and outlines the purpose of the proposed new Regional and Economic Strategies.
The new Regional Spatial and Economic Strategies will support the implementation of the National Spatial Strategy (NSS) and the economic policies and objectives of the Government by providing a long-term strategic planning and economic framework for the development of the Region.
The submission notes that the status of current RPGs 2010–2022 is enshrined in the Local Government Reform Act 2014.
Submission acknowledges that it is unlikely that the time frame for the adoption of the Regional Spatial Economic Strategies (RSES) will coincide with the Development Plan Review process for Fingal.
Development Plan Format
The submission acknowledges the challenge faced by planning authorities in fulfillng all legal obligations that a Development Plan must address while producing a legible accessible document for all. In particular in relation to Development Plan mapping, all of Fingal is covered by mapping, the online viewer on the Council website is cited as a good example of a user friendly tool to access the detailed level of mapping.
Cross Cutting Themes
The submission notes the clear necessity for integrating climate change into the strategy approach and strategic objectives of the Development Plan in conjunction with the National Climate Change Adaptation Framework.
It is also suggested that resilience is a principle that could underpin the Development Plan.
Settlement Strategy
In respect of Settlement Strategy it recommends that the growth scenario and settlement strategy for Fingal supports key elements of the RPG settlement strategy, informed by the regional population and housing targets established within RPGs, whilst incorporating current data, in a holistic approach to produce an evidence based core strategy. It is also suggested that an integrated approach is taken to settlement, employment and transport policy, as advocated by the RPGs. A significant challenge of the Development Plan will be to meet the current market demand for housing supply specifically low density housing and the requirement in the core strategy to align with RPGs and NSS. An evidence based core strategy complemented by an analysis of current data trends in particular the Central Statistics Office (CSO) Regional projections, and the housing strategy could address this.
12 Chief Executive’s Report Pre-Draft Consulation July 2015 Fingal Development Plan 2017-2023 PART TWO EMRA & NTA SUBMISSIONS
Placemaking and Communities
RPGs supports planning for all sectors of the community and quality of life should form a central part of policy making. Regard should be had to delivering housing that follows the model of sustainability with a sufficient level of density that will be supported and integrated with a range of accessible community facilities, and where development is closer to public transport corridors and nodes density should be increased.
Infrastructure and Movement
Regional sustainable growth can only be achieved through the provision of high quality infrastructure, by the alignment of land use planning and transport planning, water services, energy supply and waste management. Additional infrastructure capacity to facilitate regional sustainable growth within the metropolitan city, of which Fingal is a part, is supported.
Achievements in supporting sustainable transportation in Fingal is recognised, however current trends are still disposed towards the private car and mode share needs to shift to more sustainable options. Policies promoting higher densities for employment and residential uses around public transport should be retained, with a consistency between transport planning, spatial planning and land use management to aid reduced travel demand, reduced distances and encourage a sustainable change in modal shift. Policies such as promoting higher densities for employment and residential uses around public transport, should be retained in the Development Plan.
Economic Development
The RPGs identify Swords and Blanchardstown as primary Economic Growth Towns within the Gateway Core Economic area, and are considered strategic employment centres that are drivers within the core of the GDA for sustained international and regional economic development and growth.
Given the amount of economic zoned lands in Fingal the submission the notes that the core strategy should address the location of current employment in the County, assess employment trends, typology and demands in the County in determining future and additional economic land use requirements for Fingal.
It is considered that retail policies and retail development within Fingal support the policies and recommendations of the Strategy for the Greater Dublin Area and economic growth areas as identified within the RPGs, and follow the Retail Planning Guidelines for Planning Authorities 2012; in particular as this applies to the Retail hierarchy in RPGs and the Retail Strategy.
The submission notes the role Local Economic and Community Plans (LECPs) as a central component to local authority’s role in economic development. The Regional Assembly’s statutory function in their preparation to ensure consistency is outlined along with a commitment to continue to consult with Fingal during the preparation, consultation and development of LECPs.
Green Infrastructure
Acknowledges and welcomes the previous approach to Green Infrastructure by Fingal in the current Plan. It is considered that Green Infrastructure policies can be further evolved in this Development Plan review process.
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 13 2017-2023 PART TWO EMRA & NTA SUBMISSIONS
Natural Heritage
Regard should be had to the draft National Landscape Strategy 2014.
Cultural Heritage
Attention is made to the RPGs where the range of cultural assets within Fingal and their relevant designations, details strategic policy with adjunct commentary on the protection, enhancement and integration into new development of the built heritage are noted. This includes details strategic policy on the natural environment in particular designated sites and extended ecological sites to protect and conserve the natural environment.
Impacts on the Environment
Suggest Development Plan policies to deliver a vision for the county should be informed by and compliant with national, EU and international law including environmental directives, and consideration of flood risk and flood risk management plans, climate change mitigation and adaptation, river basin management plans, impacts on water quality, biodiversity and landscape assessment. This should include health impact assessment as part of the SEA. CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - EASTERN AND MIDLAND REGIONAL ASSEMBLY The overall contents of the submission are noted.
The role of the Regional Assembly is acknowledged and this will be incorporated into the new Plan. The commitment of the Assembly to the process and to consult and work with the Council generally is welcome, particularly with the Development Plan and the LECP.
The acknowledgement of the mis-match of the time-frame between the pending review of the NSS and subsequent preparation of the RSES and the Fingal Development Plan is welcomed; as this will present uncertainties which the Council will have to address in an appropriate manner as the development plan process progresses.
The need to meet the market demand for housing supply, particularly lower density housing and the requirement for the core strategy to align with RPGs and NSS is a challenge that will have to be addressed in the Draft Plan. In doing so the Council will develop an evidence based core strategy using available sources of material as appropriate, ensuring that development is supported and integrated with a range of accessible community facilities in a sustainable manner.
Planning for all sectors of the community and quality of life should be addressed in the Draft Plan.
Acknowledgement of and support for additional infrastructure to facilitate regional sustainable growth within the metropolitan city, is particularly welcomed. As is the recognition of the Council’s achievements in supporting sustainable transport, a theme that will be continued through into the new Development Plan as the Council seeks to improve the modal shift away from the private car to more sustainable forms of transport, through appropriate land –use zoning, density considerations etc.
The Draft Plan should build on the strategic location of the County and the role Swords and Blanchardstown as primary Economic Growth Towns, as identified in the RPGs, within the Gateway Core Economic Area, as strategic employment centres and drivers within the GDA for sustained international and regional economic development. Existing and future employment lands will be reviewed during the Development Plan process to ensure the
14 Chief Executive’s Report Pre-Draft Consulation July 2015 Fingal Development Plan 2017-2023 PART TWO EMRA & NTA SUBMISSIONS
potential for sustainable economic growth maximised in appropriate locations. This will be supported by the LECP.
Green infrastructure policy will be further developed in the Draft Plan.
The National Landscape Strategy has subsequently been published and the Draft Plan should take this into account.
Appropriate policies will also be developed to ensure the continued conservation of the County’s cultural and natural heritage.
The Draft Plan will be informed by, and compliant with national, EU and International law including environmental directives, and consideration of flood risk and flood risk management plans, climate change mitigation and adaptation, river basin management plans, impacts on water quality, biodiversity and landscape assessment. The SEA will examine impacts on health. ISSUES RAISED BY THE NATIONAL TRANSPORT AUTHORITY (SUBMISSION NO. P00064) General
The submission details the National Transport Authority’s (NTA) functions assigned to the preparation of a Development Plan as matters addressing the transport investment priorities for the period of the development plan; and the scope, if any, to maximise the performance of the transport system by effective land use planning; and recommendations on such matters to be addressed in the development plan to ensure the effective integration of transport and land use planning.
Transport Investment Priorities
The NTA is currently preparing a Transport Strategy for the Greater Dublin Area (GDA), which was due to go on public consultation in June 2015, finalised and published in autumn 2015. The Strategy will set out a programme for investment in strategic transport across the GDA to 2035. It will have a critical bearing on the location, timing and scale of development in Fingal. It is essential that the Draft Plan fully reflects the proposed transport options set out in the NTA Transport Strategy, including the GDA Cycle network.
The NTA Integrated Implementation Plan sets out an infrastructure investment programme with key objectives and outputs for 2013-2018, with work also ongoing through the Sustainable Transport Measures Grants Programme. It is suggested that the Development Plan reflects the implementation of these initiatives.
Protecting Strategic Transport Infrastructure
The forthcoming NTA Transport Strategy will provide a basis for the future location, timing and scale of new development; it is vital that existing strategic infrastructure is utilised and managed appropriately to ensure transport in Fingal and the Greater Dublin area continues to function into the future.
It is recommended that policy on zoning for employment uses protects investment in the national road network, thus preventing inappropriate levels of commuter traffic from using such routes.
The M1 and M50 are vital economic corridors for Dublin and the east coast in general,
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and should not be used to facilitate the development of employment which would be more appropriately developed close to existing public transport services and/or the key settlements of Swords, Blanchardstown or within Dublin City Centre. In particular, substantial development at the Airport should not proceed until it is clearly demonstrated that it will not have a significant impact on the carrying capacity of the M1 or the M50, and any development would not impact on national accessibility to the Airport.
Significant future employment development in the vicinity of strategic road networks will be dependent on the ability to provide an appropriate level of non-car based transport options.
General Land Use Recommendations: Integration of Land Use and Transportation
The NTA requests that the key trip destination focused principles related to optimising the integration of land use and transport are included as follows:
• High volume, trip intensive developments, such as offices and retail, should primarily be focused into Swords and Blanchardstown town centres, and at selected locations adjacent to high capacity public transport
• The role and function of district centres and neighbourhood centres should be supported and promoted in order to exploit the levels of accessibility offered by public transport, walking and cycling at these locations
• Except in limited circumstances, such as where specific physical requirements exist for the siting and operation of a particular land use, trip intensive developments or significant levels of development should not occur in locations not well served by existing or committed high quality public transport
• The strategic function of the M1, M2, N3 and M50 should be maintained by limiting the extent of development that would give rise to the generation of local car-based traffic on the national road network
• All non-residential development proposals should be subject to maximum parking standards and should vary spatially on the basis of centrality and the level of public transport provision
• In locations where the highest intensity of development occurs, an approach that caps car parking on an area-wide basis should be considered
• For all major employment developments and all new and extended schools, travel plans should be conditioned as part of planning permissions and be carried out in a manner consistent with existing guidance.
The submission requests that key origin-focused principles related to optimising the integration of land use and transport are included as follows:
• Residential development located approximate to high capacity public transport should be prioritised over development in less accessible locations such as the urban fringe or villages beyond the contiguous built-up urban footprint
• To the extent practicable, residential development should be carried out sequentially, whereby lands which are, or will be, most accessible by walking, cycling and public transport – including infill and brownfill sites – are prioritised Submission requests that in relation to planning at a local level, the following key principles are included:
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• Planning should promote walking, cycling and public transport by maximising the number of people living within walking and cycling distance of their neighbourhood or district centres, public transport services and other services such as schools
• Density gradients should be applied across development areas whereby high- density development is focused on centres and public transport with medium-low density development further away
• New development areas should be fully permeable for walking and cycling and the retrospective implementation of walking and cycling facilities should be undertaken where practicable in existing neighbourhoods
• Where possible developments should provide for filtered permeability
• To the extent practicable, proposals for right of way extinguishments should only be considered where they do not result in more circuitous walking and cycling trips for local residents accessing public transport, or local destinations.
CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - NATIONAL TRANSPORT AUTHORITY THE Overall contents of the submission are noted.
With regard to transport investment priorities the preparation of the Draft Plan and its content will be informed by the land-use and transportation policies contained within both the NTA’s GDA Transport Strategy and the NTA Integrated Implementation Plan (IIP). This includes the Greater Dublin Area Cycle Network Plan 2014, where particular reference is made to primary routes and proposed greenways in the County. The Draft Plan will also seek to reflect the infrastructure investment programme contained within the IIP as it relates to Fingal and the on-going work between the NTA and the Council on the Sustainable Transport Measures Grants Programme.
The current Development Plan provides for an integrated approach to land use and ground transportation, aimed at securing a modal shift to more sustainable modes of transport. The Draft Plan should continue with this policy and support land use patterns which reduce the need to travel and support public transport and demand management. The current and future operational, safety, technical and developmental requirements of Dublin Airport must be safeguarded through the protection and enhancement of surface access to and from the Airport. Specific comments made relating to the protection of strategic transport infrastructure are noted and will be taken into account during the preparation of the Draft Plan.
The Core Strategy in the Draft Plan will set out the settlement strategy for the County including the quantum, location and phasing of development. The Strategy will be consistent with the Regional Planning Guidelines (or the Regional Spatial and Economic Strategy should it be adopted prior to the Draft Plan) and government policy on density. In relation to general land use recommendations contained in the submission the key principles recommended for the integration of land use and transport are generally considered to be of merit with many of the issues raised already incorporated in the current Plan. Existing principles and policies will be reviewed during the preparation of the Draft Plan, and should continue to support and promote walking and cycling and require good connectivity between key settlements and destinations and at the local level within the County. Public transport should also continue to be prioritised by safeguarding future rail and bus routes and promoting the provision and improvement of QBCs, BRT and bus priority measures. Demand management should be considered through the requirement for mobility management and travel plans for new developments, both residential and commercial and for schools. Approaches to car parking and other specific recommendations, outlined in the submission, should also be reviewed as part of the Draft Plan.
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3. CROSS CUTTING THEMES The Draft Plan should be underpinned by the four cross cutting themes of sustainable development, climate change adaptation, social inclusion and high quality design. Issues relating to these four key overarching strands should permeate the policies and objectives of all topic areas including: Settlement Strategy, Placemaking and Communities, Infrastructure and Movement, Economic Development, Green Infrastructure, Natural Heritage, Cultural Heritage and Impacts on the Environment to be included in the Draft Plan.
The most important policy / guidance documents are first highlighted. The submissions received for the four cross cutting themes are then considered in turn, followed by the Chief Executive’s Opinion. From the outset it should be noted that given the cross cutting nature of the themes, issues identified in this part of the Report may also be repeated under the individual topic headings that follow later.
STRATEGIC CONTEXT The strategic context for each cross cutting theme is noted below, drawing attention to the most salient legislation, plans and policies. While the documents noted are not an exhaustive list they provide an indication of the broad areas the Draft Plan should take account of during the Plan making process. Further reference to these and other documents will be made when considering each topic area later in this Report as appropriate.
Sustainable Development
At an international level the Rio Declaration on Environment and Development 1992 and the Kyoto Protocol, 1997 are seen as key conventions upon which discussions around sustainable development has evolved. The Rio Declaration defined the rights of people to be involved in the development of their economies, and the responsibilities of human beings to safeguard the common environment. It emphasizes that long term economic progress is only ensured if it is linked with the protection of the environment. The Kyoto Protocol is an international treaty that commits State Parties to reduce greenhouse gases emissions. It was adopted in 1997 and came into force in 2005.
At a national level sustainable development is promoted in a number of plans, strategies and studies including the National Spatial Strategy 2002-2020, Transport 21 (2008); Smarter Travel – A Sustainable Transport Future, 2009; Towards Sustainable Local Communities, Guidelines on Local Agenda 21, 2001; Making Ireland’s Development Sustainable, 2002; and the National Biodiversity Plan, 2011-2016.
From these documents at a County level, plans such as the Fingal Biodiversity Plan 2010-2015 have evolved.
Climate Change Adaptation
Following the Rio and Kyoto Declarations the EU is taking a leading role on climate change and to this end has established a roadmap with targets to be achieved for 2020, 2035 and 2050. The most immediate targets are set out in the Climate and Energy Package 2020, which is a set of binding legislation that Ireland has signed up to enforce. Enacted in 2009, Ireland has been developing a response in order to meet the challenges posed by climate change and its international obligations. This includes at a national level the publication of the National Climate Change Strategy 2007-2012 and the National Climate Change Adaptation Framework 2012. A Climate Change and Low Carbon Development Bill 2015 is progressing towards enactment.
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Other Directives, Frameworks and Strategies that are relevant to climate change, directly and indirectly, include Delivering a Sustainable Energy Future for Ireland – The Energy Policy Framework (White Paper 2007-2020).
Social Inclusion
The Barcelona Declaration followed a conference entitled ‘The City and the Disabled’ held in 1995, and is seen by many as the most important European convention on accessibility.
At a national level relevant legislation includes the Local Government Act 2001 and the Disability Act, 2005. There is also the forthcoming Urban Regeneration and Housing Bill, 2015.
In addition to legislative requirements the Government has also produced a number of plans and strategies focusing on aspects of social inclusion. In particular these include The National Anti-Poverty Strategy, 1997; The National Plan for Social Inclusion, 2007-2016; the National Development Plan, 2007-2013; and the programme Towards 2016 – 10 year Social Partnership Programme. In addition there are specific Plans and strategies that focus on the needs of particular sections of the community such as the National Childcare Strategy, 2006- 2010 focusing on younger people, and the Traveller Interagency Plan, 2008 concerned with addressing the needs of the traveller community.
At a County level social inclusion is being embedded in the Council’s Local Economic and Community Plan (LECP), Social Inclusion and Community Activation Plan (SICAP), and Local and Community Development Programmes. The Council has also a Fingal Age Friendly Strategy, 2012-2017.
High Quality Design
Government guidance promoting high quality design in development layout, buildings, and residential layout are important to informing the Draft Plan. Important guidance documents include the Design Manual for Urban Roads and Streets, 2013, Sustainable Residential Development in Urban Areas, DOEHLG (2009); the Urban Design Manual – A Best Practice Guide, DOEHLG (2009); Delivering Homes Sustaining Communities – Statement on Housing Policy, DOEHLG (2007); Sustainable Urban Housing: Design Standards for Apartments, DOEHLG (2007); and Architectural Heritage Protection Guidelines, (2005). Other documents include Development of Large Scale, Rail Focused Residential Areas in Dublin, (2013). These are referenced in more detail in the Report.
SUMMARY OF ISSUES RAISED Submissions Received During the Consultation Process
P00007, P00023, P00034, P00038, P00042, P00048, P00050, P00070, P00080, P00083, P00101, P00106, P00110, P00121, P00123, P00131, P00135, P00173, P00181, P00182, P00185, P00187, P00192, P00195, P00203, P00208, P00213, P00214, P00215, P00226, P00233, P00322, P00327. For clarity the issues have been analysed under separate headings, with the Chief Executive’s Opinion relating to these issues given immediately thereafter.
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Sustainable Development A number of submissions welcomed the emphasis on putting sustainable development at the core of the Draft Plan and supported the creation of the Draft Plan as a process of policy analysis, and the integration of Strategic Environmental Assessment (SEA) from the start. These submissions highlighted that sustainable development should be prioritised in Fingal and it should include high quality housing, local employment initiatives, provision of shopping and leisure facilities, education and training, healthcare facilities, promotion of tourism and heritage, maintaining horticultural tradition and environmental protection.
The need for a clearer definition of how the sustainability of development is measured, to ensure that the term ‘sustainable development’ has meaning was raised in a number of submissions. A range of metrics/measuring tools setting out clear targets in the various Development Plan themes and allowing for a proper evaluation of sustainable development to be made was also suggested.
The importance of joined-up thinking and planning between local authorities and Government Departments working together was highlighted in a number of submissions, i.e. sufficient school places should be available when new developments are permitted.
The importance of sustainable transport models and the importance of locating communities and their facilities (including schools, places of employment etc.) close to public transport were raised on a number of occasions. Developments need to be ‘future-proofed’. The importance of walkways and cycle ways was also highlighted. It was suggested that climate change and sustainability could be addressed by improving the quality and choice of modes of transport particularly cycling, walking and public transport, thus reducing car dependency.
The need for matching the skill set of the population with local employment opportunities was noted in submissions as being a critical element in sustainable development.
Issues regarding sustainable design were raised a number of times. Provision should be made for grey-water systems in new housing estates, water conservation measures should be promoted and Sustainable Urban Drainage Systems (SuDs) measures incorporated into new development schemes. It was noted that Government grants for insulation retro-fitting, solar panels, etc. have been very successful and should be continued. The promotion of bio-degradable packaging and recycling centres and highlighting the need for incentives for the installation of sustainable energy devices and reduced costs of water butts, solar panels, etc. was advocated.
The need for a sustainable development ‘centre’ to demonstrate sustainable design and techniques was raised suggesting that self-sufficiency and agri-business models for growing our own food could be central themes. It was suggested that this centre could highlight good practices and energy saving techniques which would offer cost-savings to householders and businesses and would raise discussions on concepts for future living. Such a centre could be run by companies within Fingal who offer such services. Another submission promoted the development of a self-sufficient farming community with eco- friendly housing, renewable energy sources and eco-farming.
The creation of a ‘sustainability concept project’ was raised in one submission, which would be based on the cross-cutting themes of the Draft Plan. A ‘Fingal Food Forest’ idea was advocated with a strong focus on permaculture and sustainable living.
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The UK’s National Planning Policy Framework was referenced where three dimensions to sustainable development are identified and outlines the economic, social and environmental role which local authorities play. It was suggested that there are opportunities in Fingal in which these three dimensions of sustainable development could be achieved in harmony.
One submission notes that Dublin Airport is embracing sustainability and that it monitors its emissions in a new energy centre in Terminal 2. Every single project in Dublin Airport is assessed in terms of sustainability.
CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - SUSTAINABLE DEVELOPMENT An important element of the sustainable development thread in the Draft Plan will be Strategic Environmental Assessment (SEA) and Appropriate Assessment (AA), which are required under European legislation and provide a high level of protection for the environment. The importance of the SEA process and the need for this process to be ongoing and iterative is noted and covered later in this Report.
The Draft Plan should adopt the principle of sustainable development by promoting and encouraging the integration of economic, environmental, social and cultural issues into local policies, objectives and programmes. The location of residential land will be considered on the basis of proximity to transport and other services such as employment, shopping and education. It is agreed that infrastructural investment should be prioritised in tandem with new development, to ensure that facilities are in place for new communities. The Council should continue to be guided by Government Guidelines in relation to new development design, density, layout, etc. and the need to ensure integration of investment in infrastructure in tandem with land use planning. Short term market demands should not undermine the need for sustainable development in the medium to longer term.
Development Plans are required to contain objectives for the promotion of sustainable settlement and transportation strategies in urban and rural areas, including the promotion of measures to reduce energy demand, man-made greenhouse gas emissions and address the necessity for adaptation to climate change, having regard to location, layout and design of new development. All developments above a certain size threshold and all schools are required to develop a Workplace Travel Plan / Mobility Management Plan as part of Smarter Travel, the National Transport Policy and in accordance with National Transport Authority Guidelines.
Submissions regarding the need for a clearer definition of how sustainability is measured have been noted. Section 15 of the Planning and Development Act 2000 (as amended) states that “The Chief Executive of a Planning Authority shall, not more than 2 years after the making of a development plan, give a report to the members of the authority on the progress achieved in securing the objectives referred to…” This report assists the Local Authority in establishing whether the objectives are being met. In addition, under the SEA process – which looks at the impacts of the Draft Plan on the environment, a report will also be prepared which examines certain environmental indicators in the County. These measures will assist the Council in evaluating progress made in relation to implementing the objectives of the Draft Plan.
As part of the Draft Plan process the Council has a statutory obligation to consult with adjoining local authorities and other prescribed bodies who have a role to play in the preparation of the Draft Plan. In addition in a number of different forums, the Council engages with neighbouring authorities and other organizations across a range of issues on an on-going basis.
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The Council recognises the benefits that green roofs, green walls, solar panels, rainwater harvesting, grey-water schemes and other sustainable design features can have on promoting sustainable development. There are an increasing number of examples of such measures in place within the County. Existing policies in the current Development Plan should be reviewed and updated, where appropriate. The Council should continue to promote high standards in terms of energy reduction, sustainability and energy efficient development.
There were a number of submissions proposing sustainable community projects/ sustainable development centres/Fingal Food Forest/self-sufficient farming community project, etc. Fingal has high quality agricultural land on which it is agreed there is a need to promote suitable sustainable agricultural, horticultural, and woodland development. Zoning objectives will focus on promoting sustainable rural land uses. Suitable rural businesses should be accommodated in appropriate locations defined within the zoning objectives of the Draft Plan.
The Council welcomes the detail of reference materials provided in relation to the UK’s National Planning Policy framework and will endeavour to examine this literature for the Draft Plan.
The reduction in emissions and the creation of the new energy centre in Terminal 2, Dublin Airport and its policy to assess airport projects in terms of sustainability is welcomed.
Climate Change Adaptation A number of submissions highlighted the importance of climate change and the need for a clear focus and strategy in the Draft Plan. A strong emphasis on climate change is appropriate and to be welcomed. Submissions note that climate change mitigation requires fundamental changes to many areas of society and economy and that local government faces this challenge in every area of its activity. It is noted that the Council should engage in the international co-operation of local authorities facing the challenge of climate change mitigation and adaptation, such as by joining the Covenant of Mayors referred to in the climate working paper, and the International Council on Local Envrionmental Initiatives.
One submission makes reference to learning from best practice in the Intergovernmental Panel on Climate Change (IPCC) which gives a comprehensive overview of research on climate change, including adaptation and mitigation, and developing local strategies to prevent and respond to climate change.
Submissions highlight that the Council has already shown itself to be a leader in thinking about green infrastructure and local biodiversity, but more awareness is needed to educate people regarding climate change and reducing CO2 omissions. Green Infrastructure and climate change mitigation and adaptation are intimately related and one submission refers to a report: ‘Ireland’s Biodiversity: Our Natural Ally in the Fight Against Climate Change’ from the Irish Environmental Network. Aspects of particular relevance to Fingal include the consideration of climate mitigation and adaptation in coastal zone management.
The serious threat and potentially costly issues arising from climate change were common themes raised. The environment, biodiversity and ecological sustainability should be themes that link and underpin all sections of the Draft Plan. It was noted that Fingal is already prone to flooding and sea encroachment and both of these issues are likely to increase in frequency and severity due to climate change. Food production and living space will be compromised if steps are not taken.
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The effects of CO2 in particular on climate change was noted in a significant number of submissions received, suggesting actions to be taken to achieve the required reduction in greenhouse gas emissions if Ireland is to meet internationally agreed targets. Transportation is viewed as one of the key elements contributing to greenhouse gas emissions. One submission cited targets set out in the Government Electric Transport Programme for 2020. The ESB is currently working towards providing a charging infrastructure to support up to 10% of all vehicles being electric by 2020 and recommended an increase in the number of parking spaces to be equipped with fully functional charge points.
Another submission notes that ‘Policy CLIP1’ of the Regional Planning Guidelines confirms that climate change has an influence on a cross section of themes including transportation, water provision and distribution of population. This submission notes that there is a clear necessity for integrating climate change considerations into the strategy approach and strategic objectives of the Draft Plan in conjunction with the National Climate Change Adaptation Framework.
Resilience was raised as another principle that could underpin the Draft Plan as a concept and it is described as ‘the ability of a system, community or society exposed to hazards to resist, absorb, accommodate to and recover from the effects of a hazard in a timely and efficient manner, including through the preservation and restoration of its essential basic structures and functions. (UNISDR, 2009)’. The submission notes that this can be broken down and applied to critical infrastructures such as the supply of basic services like water, food, energy, transport, housing / shelter, communications, finance and health.
A number of submissions noted that the most effective way of combating climate change is to counteract it with new carbon sinks, i.e. plants and trees. Agro-ecology measures were suggested, noting that perennial plant species are more resilient to changes in the environment and require little or no additional maintenance, and would support the creation of an abundant landscape based on the principles of permaculture.
The development of a carbon-neutral town in Fingal should be explored; for example in Skerries, and could be developed as a 3-way partnership with community bodies, local government and central government. The Low Carbon City Plan 2011-2015 for Freemantle, Australia was cited as an example.
Flooding and coastal erosion were raised as issues in a number of submissions; as was the need to learn from recent flooding and subsidence events on Howth Peninsula and elsewhere. An increased awareness of the forces of nature is required and the building of coastal defences should be considered. One submission requested the development of guiding principles on how best to manage coastal erosion and flooding in Howth / Sutton (and elsewhere), in the absence of a National Coastal Policy.
In terms of new development, submissions received encourage the use of green roofs, green streets or other green infrastructure approaches in new or existing development to provide solutions in relation to water management and the need to adapt to the predicted impacts of climate change. Commercial developments should provide green energy solutions. Solar panels should be incorporated into new development, where appropriate.
The importance of embodied energy was raised in one submission. It was suggested that the Council should consider steps to be taken through the Draft Plan to encourage construction projects which embody low carbon and energy, that could make a significant contribution to the reduction of CO2 and energy consumption in Ireland. By reducing the levels of embodied CO2, the Council would go beyond ‘adaptation’ to the effects of climate change and take the advanced step of actually ‘mitigating’ against these effects.
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One submission noted the increase in cattle numbers and the need to look at anaerobic digestion.
It was also noted in one submission received that advances in aviation technology in airframe and engine design have contributed to a cleaner, greener and quieter environment. CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - CLIMATE CHANGE ADAPTATION The Draft Plan should set out the overall strategy for the proper planning and sustainable development of an area and must include objectives which promote sustainable settlement and transportation strategies including measures to reduce energy demand, measures to reduce greenhouse gas emission and address the necessity of adaptation to climate change. The Draft Plan should contain many policies, which should in themselves impact on usage of non-renewable energy sources.
The importance of factoring climate change adaption measures into the Draft Plan is recognised and the Draft Plan should have regard to the National Climate Change Adaptation Framework, Building Resilience to Climate Change (2012), which requires the integration of adaptation and mitigation measures. The DOECLG has been identified as the lead body on National Adaptation policy. Local Authorities have been given the role to prepare local adaptation plans through the Development Plan review process. The Draft Plan policies should be informed and shaped by Environmental Directives.
The Climate Action and Low Carbon Development Bill 2015 established the national objective of transition to a low carbon, climate resilient and environmental sustainable economy in the period up to and including the year 2050. The Draft Plan should contain adaptation and mitigation measures and actions to address Climate Change and the Council recognises the need for the development of a robust strategy to increase climate resilience. Mainstream policies should be incorporated into the Draft Plan and integrated with National Plans and those of neighbouring Local Authorities.
The detail of reference materials provided in submissions in relation to the Covenant of Mayors, the International Council on Local Environmental Initiatives and the Intergovernmental Panel on Climate Change (IPCC), ‘Ireland’s Biodiversity: Our Natural Ally in the Fight Against Climate Change’ and The Low Carbon City Plan 2011-2015, Freemantle, Australia’ is welcomed. Issues raised should be explored and where appropriate used to inform the preparation of the Draft Plan.
The Council acknowledges the importance of resilience underpinning the Draft Plan as a key concept and its significance as a cross-cutting theme is noted. It is considered that ‘resilience’ should be built into the strategic policies and recommendations of each of the four cross- cutting themes (sustainable development, climate change, social inclusion and high quality design) and be an underpinning theme throughout the Draft Plan.
The Council is responsible for the management of surface water at a local level and the Office of Public Works (OPW) has responsibility for flood risk management at a strategic level. The OPW began a national programme for river catchment based Flood Risk Assessment and Management with the Eastern Catchment Flood Risk Assessment and Management Study (ECRFAMS) which commenced in June 2011. This study will review the areas previously examined under FEMFRAMS such as the Turvey River and Ballyboghil River and the Tolka Flood study. As of June 2015, the OPW have produced draft flood maps for the Areas of Further Assessment in the Eastern District. The draft flood maps show areas that are potentially at risk of flooding under a range of different scenarios, e.g. following periods of heavy rainfall or during times of high tide or times when wave overtopping may occur. This study should be used to inform the Draft Plan.
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The effects of Climate Change particularly reduced base flows in streams and rivers, high intensity rainfall events and rising sea levels are taken into consideration in the design of all new projects and developments. The Council supports the precautionary principle whereby action is taken now to avoid possible environmental degradation in the future. The Council should restrict development located in floodplains and vulnerable coastal areas.
Parts of Fingal are located on land that is below the average maximum high tide level, and / or located on land within the floodplain of a river. Climate change, in combination with the ongoing urbanization of catchments, means that the flood risk to property is continually changing. In order to minimize the impact of an increased future flood risk, there are various steps that local authorities can take, including stormwater attenuation and control of development in flood plains. Policies requiring the preparation of Strategic Flood Risk Assessments and the inclusion of Sustainable Urban Drainage Systems (SuDs) and Integrated Constructed Wetlands in applications for development should be included in the Draft Plan. SuDs measures suitable to the scale and location of development should be required for all new developments as appropriate.
The Council recognises the need for quality, cost effective, reliable sources of power capable of meeting future demand in the most environmentally sustainable manner possible. The Council should support and facilitate the continual improvement and provision of the County’s electricity supply in line with Government policy. Incorporation of renewable energy technologies in new development is required as part of the Building Regulations and the Draft Plan should emphasise the importance of renewable energy technologies.
Current Development Plan policy (Objective TO69) in relation to electric vehicles and charging facilities should be updated as appropriate and carried forward into the Draft Plan.
The promotion of larger scale renewable energy technologies such as windfarms, tidal and wave, solar, geo-thermal and bio-mass should also be explored in the Draft Plan. The Council should balance the benefits of developing more sustainable forms of energy generation against any local environmental impacts. Energy conservation and the use of sustainable materials will continue to be important in new developments. To achieve emissions reductions, whilst maintaining the current land use mix with increasing population pressure, a policy of high density (not necessarily high-rise), compact building development that is co-ordinated with transport policy should be prioritised in the Draft Plan, in line with international best practice.
The submission advising that advances in aviation technology in aeroplane airframe and engine design have resulted in a cleaner, greener and quieter environment is noted.
Social Inclusion One submission noted that social inclusion is a two-way process. The ‘dominating majority’ should be assisted/trained so that they are comfortable in embracing the “excluded” minority, and don’t feel threatened by different cultures.
A number of submissions noted the importance of the Irish language and the need for a greater focus on it within the County. ‘Bi-lingual Fingal’ should underpin the principles of the Draft Plan. There is a need for full and equal access to information and resources, with an equal range of services available in both Irish and English. The Council’s Irish Language Development Officer should actively engage with local Gaelscoileanna. The Draft Plan should also make improved provision for the needs of Irish speaking residents of the County, through the creation of a bilingual website, publish Irish language application forms, and have occasional press releases in Irish. Bilingual signage could also be promoted. Another
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submission noted the high number of Eastern Europeans living in Fingal and advocated the publication of County documents in Polish and other languages, given the varied nationality of many of Fingal’s residents.
The need for more resources for community based strategies to promote social inclusion was highlighted in a number of the submissions received, with particular focus on cultural integration of different nationalities. Initiatives such as Culture Days would raise community spirit and pride.
The promotion of businesses and social inclusion was raised in one submission with the suggestion to promote a new community based project called the ‘Woman’s Place’, a dedicated, friendly and welcoming meeting place for women. This would enhance the wellbeing of women in certain parts of the County.
Another submission noted that attempts at social inclusion are counter-productive and that this element of society is self-managing, if left to itself.
One submission praised The Yellow Flag Integration Programme, which has proved to be very successful in encouraging children in primary schools to recognise, accept and celebrate differences in race and ethnicity. It was advised that this should be put on a more structured basis and referenced within the Draft Plan.
The diversity of religious groupings in the County was noted in a number of submissions received, with some recommending new ways of thinking to provide adequate places of worship for different groups. Examples included the provision of enhanced community facilities and also examining and broadening the permitted uses in some zoning categories.
It was suggested that the Council should build upon a progressive mixed housing strategy to create a shared community resource further integrating a broad socio-economic mix, which would foster a sense of community ownership to address marginalisation.
The need to provide more sheltered accommodation for the elderly, both publicly and privately financed was noted. One submission cited the need for an ‘age friendly’ policy for different towns in the County and for the Council to focus on better services for the elderly.
Aspects of Social and Affordable Housing were raised in a number of submissions. Suggestions included that specific housing for parts of the County should have different standards to reflect the different needs of that population i.e. students, older people, disabled persons; such housing should be given to people from the area that they are from e.g. units in Garristown should accommodate people from Garristown; and social and affordable units should be interspersed with new units rather than stand-alone estates.
A key theme in a number of submissions requests that social and affordable housing should be spread across all areas of the County based on need and that the distribution be carefully assessed and improved, to avoid concentrations of social housing in particular areas. Social housing must form part of mixed developments and should be to passive house design standards.
Homes enabling people to ‘trade-down’ or downsize need to be located close to existing facilities and transport hubs.
A range of submissions referred to community involvement in the development management process and it was noted that the Draft Plan should be community-led taking into account the needs and aspirations of the communities. The Council needs to develop a strategy to ensure that the community has a strong voice in any Plan, which puts the citizen at the heart of decision making. Investing in the Council’s Community Department is
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seen as an essential and necessary element of this strategy.
The provision of facilities such as communal seating areas in new schemes would encourage community integration and that gated schemes hinder social inclusion. It was also suggested that all bodies need to work better together to provide a more joined-up approach to co-ordination of services.
Council support is required in all areas. There is a need for better employment opportunities for people with disabilities and more support needed for access to adult education. Submissions noted the need for more facilities for teenagers and young people, including youth clubs.
One submission noted that sports clubs have been very successful at integrating different groups within a community and that more support is needed for sporting facilities as they play an important role in social inclusion in new communities.
CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - SOCIAL INCLUSION The Council is committed to developing a more socially inclusive society and promoting participation and access for all. The National Development Plan 2007-2013, the National Anti-Poverty Strategy 1997, Building An Inclusive Society 2002, the National Action Plan for Social Inclusion 2007-2016 and Towards 2016 are the national documents informing the development of a socially inclusive Fingal. A profile of poverty and social exclusion in the County has been developed by the Council’s Social Inclusion Unit (SIU). The Draft Plan should be proofed to ensure it has a strong social inclusion focus, with particular regard to the identified target populations and the disadvantaged areas of the County. The Draft Plan should seek to ensure that social inclusion continues to underpin all policies and objectives.
Under Section 11 and 15 of the Official Languages Act 2003, The Minister for Arts, Heritage & the Gaeltacht has confirmed the nd2 Irish Language Scheme, which commenced in February 2015 and shall remain in force for a period of 3 years. The primary objective is to ensure better availability and a higher standard of public services through the Irish language. The Council is committed to the promotion of Irish and to the assessment on an ongoing basis of the level of demand for services in Irish. It ensures that anyone who wishes to conduct their business through Irish is facilitated. The Council also has an Irish Language Officer and the Draft Plan should reflect the importance and promotion of the Irish Language in its policies and objectives.
Submissions relating to the publication of documents/holding of evening meetings in other languages have been noted and the Council should consider the facilitation of interpreters / translation services if sufficient demand is demonstrated and resources allow.
The development of sport and recreational facilities and community-related projects should be supported in the Draft Plan and implemented through the Council’s Capital Programme. The Council should engage with key stakeholders/community groups to develop shared responsibility for community development within the County. A key aim of the Council should be to ensure that everyone has the opportunity to participate in and contribute to community life.
The Council should continue to support the Yellow Flag Integration Programme in primary schools and other measures to recognise, accept and celebrate differences in race and ethnicity. However, the provision of specific training within local schools is a matter for each school and cannot be provided for within the Draft Plan review process.
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The Draft Plan, in conjunction with and through the Local Area Plan and Development Management processes, should ensure, where possible, the timely and accessible provision of community services and resources, including schools, religious places of worship, community and health facilities.
It is acknowledged that it is desirable that in many instances homes should be habitable for a lifetime and not just for certain stages of a person’s life. However there is also a required for a mix of housing types to allow for movement within the housing market. There is a need to provide homes for older people (trade-down units) to allow people to continue living in their community. Policies in the Draft Plan should be supportive of Housing Associations and other groups who wish to provide specialised housing solutions in this regard. Such facilities are best located within existing settlements where public services are available and where the occupants have some degree of access to shops and other social infrastructure and can more readily interface with their local community. The Draft Plan should also encourage the provision of a mix of units, which are flexible in design and can adapt to the changing requirements of family life cycles.
The Housing Strategy under Part V of the Planning and Development Act 2000 (as amended) should examine the existing and likely future housing need across the County and should form an integral part of the Draft Plan. The needs assessment, carried out as part of the preparation of the Strategy will assess all housing needs for all types of housing across the County, including the elderly, accommodation for travellers and the homeless.
Revisions to Part V of the Planning and Development Act, 2000-2014 are currently being progressed through legislation. The Urban Regeneration and Housing Bill, 2015 proposes to reduce the social and affordable requirement to 10% with the general principle being to deliver housing on site. Any changes to legislation relating to Part V should be be closely monitored and included in the Council’s Housing Strategy.
The level of public consultation carried out is detailed in Part One of this Report. The public consultation process was conducted in accordance with the Planning and Development Act, 2000 (as amended). The level of public consultation at this first stage of the plan preparation process has been comprehensive and inclusive. Every effort was made to ensure that all members of the public and stakeholders had an opportunity to have their say in an open, accessible and transparent way.
The need for a range of community facilities, resources and the important role of community groups is recognised by the Council and developing sustainable communities should be a key objective of the Draft Plan. Social infrastructure is recognised as being of as much importance as physical infrastructure and social inclusion should be a key issue which should underpin the Draft Plan. The Council has strong links and interaction with existing community groups and this liaison and interaction should continue. The timely and accessible provision of community services and resources necessary for the creation of sustainable communities should be supported in the Draft Plan.
The Local Government Act 2014 established the Fingal Local Community Development Committee which will oversee the Social Inclusion and Community Activation Programme (SICAP), which is aimed at delivering quality supports and interventions to the communities and individuals in the County most in need. SICAP has been developed within Ireland’s dynamic social and economic landscape as the successor programme to the Local and Community Development Programme (LCDP) 2009-2014. The design of SICAP was informed by the views of the community and voluntary sector, in conjunction with Government and statutory priorities and aims to reduce poverty and promote social inclusion and equality through local, regional and national engagement and collaboration. Programme Implementers, with the support of Local Community Development Committees (LCDCs), will
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target those who are the most disadvantaged and excluded in society.
The Council is committed to developing a more socially inclusive society and promoting participation and access for all. The Draft Plan should continue to promote ‘access for all’ in new developments, and accord with Building Control requirements.
The Council recognizes the importance of sports and recreational development and the role it and related activities play in local communities. Sports development and recreation will be encouraged through a series of objectives / policies that should be examined in the preparation of the Draft Plan.
Submissions relating to specific local areas, that in themselves are not strategic in nature, should be considered as appropriate when preparing the Draft Plan.
High Quality Design The issue of poor quality in a number of developments was raised in a number of submissions, particularly some residential developments in Balbriggan. The importance of good design was raised and it was noted that new housing developments should be designed to ensure easy passive surveillance, elimination of laneways, blind spots and potential areas of anti- social behaviour. The achievement of a minimum ‘A’ energy rating was noted as being important for all new developments.
High quality design and architecture that is in keeping with local architectural heritage should be promoted by having a strong policy on urban regeneration in the Draft Plan. One submission suggested that new apartment developments should have a minimum size to ensure a high standard of living and apartments should be located close to urban centres.
One submission requested a design guide, which should encourage low maintenance finishes and have regard to principles of crime prevention. Acoustic recommendations to mitigate against noise pollution between units was cited as an important consideration in new development. Design approaches to industrial / commercial / science and technology zoned lands should be designed and maintained to a high standard. The Council should learn lessons from the past and the overall design of areas should be carefully considered with infrastructure, sustainable transport and community facilities in place in tandem with new development.
Submissions received noted that high quality design should be promoted, but it must also be carried through to completion. The Council should support houses which are designed with higher energy ratings, provided that the extra capital cost can be recouped from energy savings within a reasonable term. It was noted in submissions received that sustainable design standards in housing need to be improved. The Council should encourage passive house design; although objectives and standards would have to be practical and be implementable. Sustainability should be a key focus of new developments with requirements for green roofs, solar panels and passive house standards. Rainwater harvesting should always form part of planning applications.
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The primary importance of energy efficiency in new development was emphasised in a range of submissions and that the County should set requirements for passive house or similar standards such as zero-carbon or low energy buildings. The Draft Plan should also consider how the Council can, directly or indirectly bring existing housing stock up to a higher standard of energy demand and ventilation to improve public health, address fuel poverty, social inclusion and reduce energy demand and associated emissions. Other elements of sustainable building were noted in submissions received and should be reflected in the content of the Draft Plan, with embodied carbon emissions of buildings and material sustainability of construction addressed.
Designs for adaptive re-use and for destruction and reuse / recycling were noted as important issues that the Draft Plan should address.
One submission noted the importance of having minimum densities set within the Draft Plan and highlighted the need to avoid conflicting policies such as restrictions on heights. Restricting the height of apartment development can have unintended consequences in terms of making basement car parking unviable with resultant requirement for surface parking, etc.
CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - HIGH QUALITY DESIGN The Council has demonstrated its commitment to quality architecture both in the promotion of the best of contemporary architecture and in the conservation of the County’s architectural heritage. High quality design is an underlining principle in the current Development Plan and it should continue to underpin planning policies in the preparation of the Draft Plan.
Using local area planning, masterplanning and the development management processes, the Council seeks to continually improve the design and standard of residential development. In all areas of the County the Draft Plan should ensure sustainable patterns of development and a high quality of design are achieved so that all remain attractive and retain their distinctive character. The Draft Plan should set out a range of objectives aimed at creating well designed environments for both rural and urban settings. An overarching aim should be to create and sustain people-friendly places for the benefit of the residents and businesses of the County, whilst supporting developers seeking to deliver the highest quality design solutions.
The design and layout of new areas should be informed by Guidance Documents issued by Government, including Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (2009), the Design Manual for Urban Roads and Streets (2013) and the Sustainable Urban Housing: Design Standards for New Apartment Guidelines for Planning Authorities (2007). Local Area Plans and Masterplans prepared for specific areas should provide a more detailed assessment in terms of densities and design criteria.
The Council should continue to be guided by Government Guidelines in relation to new development and to the need to ensure integration of investment in infrastructure in tandem with land use planning. Short term market demands cannot undermine the need for sustainable development in the medium to longer term.
The provision of new residential development will be on the basis of best practice in terms of layout and high quality design. Similarly the provision of services and communal areas of open space and seating / playgrounds should be provided according to best principles. Standards and quantities should be reviewed in the preparation of the Draft Plan. The Draft Plan should also ensure that access to and permeability within housing areas is promoted.
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Development Plans are required to contain objectives for the promotion of sustainable settlement and transportation strategies in urban and rural areas, including the promotion of measures to reduce energy demand, man-made greenhouse gas emissions and address the necessity for adaptation to climate change, having regard to location, layout and design of new development. Existing policies in the current Development Plan should be reviewed and updated, where appropriate.
Policies requiring the preparation of Strategic Flood Risk Assessments and the inclusion of Sustainable Urban Drainage Systems and Integrated Constructed Wetlands in applications for development should be included in the Draft Plan.
The Draft Plan should continue to promote and deliver safe living environments throughout the County. It is acknowledged that a reduction in crime and anti-social behaviour can be achieved through the careful consideration of the building layout and the environmental design of a development. Current Development Plan policy (Objective UD13) in relation to the inclusion of crime prevention measures in new developments should be updated as appropriate and carried forward into the Draft Plan.
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4. SETTLEMENT STRATEGY STRATEGIC CONTEXT
National Spatial Strategy 2002-2020 (NSS)
The Strategy favours the physical consolidation of the metropolitan area as an essential requirement for a competitive Dublin. The NSS seeks to sustain Dublin’s role as the engine of the national economy while strengthening the drawing power of other areas, bringing people, employment and services closer together to create a better quality of life - less congestion, less long distance commuting, more regard to the quality of the environment and increased access to services like health, education and leisure. The NSS is due to be reviewed but remains in force at present.
Regional Planning Guidelines for the Greater Dublin Area 2010-2022 (RPGs) The Guidelines set household and population projections for their 12 year period and ad- dress the settlement strategy for the Greater Dublin Area (GDA) setting out strategic recom- mendations. These include the requirement for each Council to address through it’s Core Strategy how it will meet the housing targets set out in the RPGs. A ratio of housing to be delivered within the Metropolitan and Hinterland area is prescribed, for Fingal the ratio is 85:15 respectively. The RPGs and the associated population and housing targets are due to be reviewed by the end of 2016 as part of the new Regional Spatial and Economic Strategies under the restructured Eastern and Midland Regional Assembly. Development Plans Guidelines for Planning Authorities, 2007
These Guidelines set out a framework for development plans to ensure that they set out high standards. Zoning must be justified on the basis of a realistic assessment of need and must support the aims and strategy of the plan. It is noted that land is a finite resource and the importance of efficiently using it. The re-development of previously developed land (“brownfield”) and the conversion and re-use of existing buildings is emphasised. Development plans should have sufficient zoned land for nine years, three years in excess of the plan period. The location of this land should take account of the location policies in Section 5.3 of the NSS and demands of individual landowners should not distort the preferred amount and location of lands to be zoned. A logical sequential approach should be taken to the zoning of land for development, extending outwards from the centre of an urban area with preference given to lands closest to the core and public transport routes. There should be an avoidance of ‘leapfrogging’ into more remote areas.
Sustainable Residential Development in Urban Areas 2009
These Guidelines deal with development in larger urban centres, towns and villages as well as individual homes and their surroundings. They continue to promote increased residential density where appropriate, especially where close to existing or future public transport routes. The Guidelines emphasise the qualities which make for successful places and the need for high quality, sustainable design and layout and good quality living environment including the availability of adequate shopping, social, childcare, transport and leisure infrastructure.
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Fingal County Council Housing Strategy 2011-2017
The Housing Strategy provides for the development of sufficient housing to meet the needs identified in the Regional Planning Guidelines. The Draft Plan will incorporate an updated Housing Strategy.
Local Economic and Community Plan (LECP)
The Local Government Reform Act 2014 provided local authorities with an enhanced and clearer role in economic development and enterprise support and the framework for a more joined-up approach to local and community development programming. The mechanism for the achievement of this new role is through Local and Economic Community Plans. The purpose of the LECP is to identify and implement actions to strengthen and develop the economic and community dimensions of each local authority area over a six year period in a manner that both reflects and supports the implementation of the existing Regional Planning Guidelines and proposed Regional Spatial and Economic Strategies. The Council’s first LECP is due to be published in September 2015 and it will set out goals and targets for the economic and community development of the County. The LECP must be consistent with the Development Plan.
SUMMARY OF ISSUES RAISED This section of the Report deals primarily with residential lands and related issues. Em- ployment lands, while part of an overarching core strategy, are dealt with in the Economic Development section of this Report.
Submissions Received During the Consultation Process
P00019, P00024, P00025, P00027, P00033, P00035, P00041, P00048, P00049, P00051, P00054, P00055, P00056, P00057, P00058, P00071, P00072, P00074, P00077, P00082, P00083, P00088, P00091, P00092, P00094, P00095, P00097, P00101, P00102, P00103, P00108, P00111, P00112, P00113, P00121, P00131, P00132, P00135, P00142, P00147, P00152, P00157, P00158, P00164, P00165, P00166, P00168, P00173, P00174, P00175, P00178, P00180, P00181, P00186, P00187, P00188, P00192, P00196, P00198, P00201, P00203, P00204, P00208, P00210, P00212, P00217, P00218, P00221, P00225, P00228, P00230, P00233, P00235, P00236, P00238, P00242, P00243, P00244, P00246, P00254, P00257, P00258, P00262, P00263, P00264, P00266, P00269, P00272, P00275, P00279, P00281, P00283, P00284, P00285, P00288, P00291, P00292, P00293, P00296, P00297, P00298, P00301, P00302, P00304, P00305, P00306, P00308, P00310, P00312, P00314, P00318, P00322, P00323, P00324, P00325, P00326
Note: The submissions from the Eastern and Midland Regional Assembly (P00034) and the National Transport Authority (P00064) in relation to the Settlement Strategy have been dealt with separately. Core Strategy A number of submissions have suggested that there should be an increase, in various locations across the County, in the amount of land zoned for residential development to meet the requirements set out in the RPG targets. It is considered increasing residential supply is the single biggest issue for the Draft Plan. The need to consolidate existing settlements is recognised in many submissions along with the need to integrate land use and transport infrastructure. It is considered infrastructure should be in place before houses are built. Other submissions emphasise the need for flexibility to allow housing to be built ahead
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of infrastructure. The importance of the Metropolitan Area for accommodating growth is stressed and it is considered Swords should be developed in line with the Swords Strategic Vision. It is suggested the north county towns should be developed to support a more frequent train service and shuttle buses to local stations.
Other submissions indicate that there is no requirement for more land to be zoned and that the Council should focus on infill and brownfield development to deliver new housing. Objectives RD01 and RD10 in the current Development Plan relating to consolidation and brownfield/infill sites should be maintained. It is contended zoning on edge of towns when there are existing vacant sites is unsustainable. A policy should be adopted to redevelop multiple small scale sites. It is noted there are areas of existing sprawl which threaten the green character of Fingal and open space should not be developed.
There is agreement with the approach to provide new homes in identified serviced centres. Furthermore it is suggested that Local Area Plans (LAPs) should be completed quickly and provide the mechanism and certainty to aid in housing delivery and the funding for it. Some submissions have suggested that masterplans should replace LAPs, particularly where services and infrastructure are considered already to be in place. LAPs should be regularly evaluated to ensure management of changes and existing LAPs ‘re-adopted’ in the Draft Plan. It is requested the status of urban design and landscape masterplans prepared as part of expired LAPs should be clarified.
A number of submissions have suggested a review of current zonings for different uses, e.g. General Employment (GE) in Rush. Other submissions have indicated that zoning should be maintained in specific areas e.g. Metro Economic Corridor (ME) zoning. In other ME areas it is seen as important that at least some lands are released notwithstanding delay in delivery of transport infrastructure.
Overall, numerous submissions consider development should be planned and phased.
Place specific requests noted further development in Lusk should be incremental rather than large scale, Castleknock should be designated ‘Metropolitan Area – Small Town’ not ‘Metropolitan Area – Consolidation Area within Gateway’ and the South Fringe area should be designated as a Strategic Development Zone (SDZ) in collaboration with Dublin City. The Dunsink and Scribblestown areas are also identified as strategic areas for growth.
Irish Water has stated that it is their objective to provide water supply and wastewater infrastructure to meet domestic requirements of the Settlement and Core Strategy of Development Plans which are in accordance with RPGs and the National Spatial Strategy. The Council is asked to consider the implications on water services when determining the Core Strategy. Rural Settlement Strategy
A number of submissions expressed agreement with the general principle of the settlement policy for housing in the countryside but indicated that it should be less restrictive for different reasons including to: allow young emigrants to return home; allow reward to family members for unpaid work on family farm; allow for all children to get a site; allow a sibling’s home to relate to family ties and not just a parents home; exceptional health grounds. At present, Table RH03 excludes young people who are returning home and this should be examined. It is noted the rural settlement policy in relation to rural employment is at odds with the Sustainable Rural Housing Guidelines and clarity on this and what constitutes rural employment is requested. Furthermore, it is contended there is contradiction in the Plan at Table RH02, which indicates how many people are entitled to a house under close family ties. The documentation required for demonstration of compliance with rural settlement
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strategy should be reviewed. A number of submissions note existing farming families’ sons/ daughters do not get paid and there is a need to review Objective RH12 in this regard. Farm family clustering advocated.
Various submissions have indicated that inappropriate rural development is being permitted. The character of the rural villages should be protected with a ban on homes becoming businesses in the vicinity of the village.
It is requested that village boundaries are expanded to ensure delivery of sufficient housing to meet targets and demand. Furthermore, it is requested that rural village LAPs and infrastructure are completed to allow delivery of housing. It is submitted the LAPs for the existing rural villags of Garristown, Oldtown and the Naul are reactivated and Ballymadun should be designated as a rural village given its existing services. Some submissions suggested amending and extending the boundaries of Rural Clusters with some submissions suggesting new ones. Housing Strategy
It is considered the Council faces a major challenge in providing sufficient social housing to meet a high level of demand and to overcome homelessness. There is an urgent need for more housing in Fingal, given the massive waiting list for social housing a greater proportion of units built should cater for this section. It is recommended current vacant housing stock be used as an interim measure. It is also considered there is a need for accommodation of various types for homeless people throughout the County and in particular Dublin 15, to maintain family support networks and to avoid disruption to children’s education.
Various submissions suggest a key principle of the Draft Plan should be that there will be no homeless citizens and families. There should be a fair and equal distribution of social housing across the County and a wide variety of sites identified to ensure a reasonable share of government funding. A number of submissions consider the allocation of social housing to Balbriggan should stop until more equitable distribution across the County has taken place and it is considered that social housing must form part of new developments. It is also requested that the Council investigate a scheme for private investment in social housing.
It is requested that more clarity is provided regarding requirement for the social and affordable housing provision in the Development Plan and the actual number of units provided.
Some submissions indicate a preference should be given to locals on the housing list the longest and social housing should be provided for local people only. The housing allocation policy should be reconsidered with an emphasis on locals being housed in their own communities.
Local Authorities should be encouraged and supported in establishing housing trusts under their control. It is recommended the affordable housing scheme is re-established and Part V of the Planning and Development Act 2000 is strengthened. More affordable housing is considered necessary to allow young people to move out of the family home.
It is suggested that both the Housing Strategy and Part V of Planning Acts should be amended to reflect the issue of specific housing requirements for specific user needs.
The issue of Part V and its viability for developer needs to be addressed and it is requested that requirements relating to ‘housing with care’ are clarified and provided for in the Housing Strategy. It is also suggested that Part V requirements should be advanced with the
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developer prior to a planning application being submitted.
It is requested that sites for Traveller family networks are identified in Fingal. Housing and Density
Submissions were made for a variety of density restrictions in different areas of the County. It is considered residential densities should be in line with the Department’s Guidelines on Sustainable Residential Development in Urban Areas. Density should be a product, not a determinant, of design. A general thread of density should be taken county wide and then assessed on a case by case, site specific basis. Land-banks in the County should be audited for appropriate density targets and it is requested that areas with density caps or restrictions should be reviewed. A flexible policy on density is requested. This should ensure new housing meets the needs of all of the population and provides sufficient choice.
Some submissions noted that densities of 35-50 units per hectare do not produce a relaxed safe environment; unlike in older housing estates where people felt ‘at home’ when outside and which had greens. It was also suggested that densities should be reduced to ensure that all dwellings have adequate garden and living space and off road car parking and restrict the height of all dwellings to 2.5 storeys. However, other submissions requested that densities be increased on lands already planned for housing to reduce the need to eat into amenity and agricultural lands. It was suggested that competing policies within the Development Plan undermine the achievement of higher densities and 50 units per hectare allows for a good variety of dwelling types within an attractive environment. The lack of height restrictions in the current Development Plan was welcomed.
In relation to specific areas, it was requested that densities should be reviewed in South Fringe area. It was also considered the Maynooth railway line does not have the services to support higher densities along the rail line and low density developments should be favoured here and in coastal and rural villages such as Rush, Lusk, Skerries and Naul.
Overall, it was considered the requirement for density should be balanced against the preservation of the amenity and tourist value of the area. Moderate density within a high quality master planned environment was considered to represent an appropriate treatment for edge of settlement.
There is a need for a good housing mix and the Council must learn from past mistakes. Numerous submissions considered smaller housing estates work better and it is essential there is an appropriate type and range of family housing in each area which is responsive to demographics. An appropriate housing mix should allow for people to move within the same area as their needs change. A range of submissions noted a shortage of sheltered housing in different areas of the County. A wider roll out of sheltered housing should be promoted to allow older persons to ‘trade down’ to housing within the existing areas.
It is submitted there is a need to focus on providing housing for different types of tenure, including the rental market. Furthermore, development standards should be relaxed for ‘rental only’ properties, here there is a need to consider models which allow mixed apartment sizes, more common areas and shared facilities. There is a requirement for smaller units that meet future market demand but also ensure affordability and flexibility.
It is requested the Council is not overly prescriptive in assigning blanket housing type or mix. One submission suggests that if the Council holds out for the return of a healthy apartment market there is a real risk that the mismatch between housing demand and supply will be exacerbated. It is indicated that developers should be allowed to respond to the micro demographic structure of the locality and the needs of the market.
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Various submissions indicated there is a need for an appropriate scale and type of housing development which respects and enhances the character of the particular area. Apartments are considered not suitable for all areas with a number of areas specifically identified as unsuitable/suitable. An emphasis on quality is requested. It is advised fewer one/two bed apartments required as they are only suitable for young singles/older retirees. Where apartments will be permitted it is requested they are larger with space for children to play, green space, playgrounds etc. Any new apartment development should be suitable for lifelong living with access to communal areas, washing and storage areas. A number of submissions consider apartments should be located near mass public transport services such as the DART. It is requested the ban on studio apartments should be reviewed and management companies should be limited to apartment complexes only. Greenbelts
A substantial number of submissions highlighted the importance of Greenbelts and consider these areas should be protected. An additional “green zone” should be established between Fingal, Dublin City and Meath. The greenbelts surrounding Malahide, between Skerries and Balbriggan and Lusk and Loughshinny were identified as specific areas to be protected. It was requested that best use of all greenbelt lands should be considered, these areas have been a central element of spatial planning in Fingal and successful in ensuring credible development boundaries.
A number of submissions considered certain greenbelt zonings should be reviewed, particularly where encroachment has occurred or where there is an overarching strategic benefit to rezone.
CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - SETTLEMENT STRATEGY Core Strategy
The Planning and Development Act, and the requirement for inclusion within the Development Plan of a core strategy, places a statutory obligation on planning authorities to ensure that sufficient land is zoned to meet housing requirements over the plan period. The Draft Plan should incorporate an evidence based Core Strategy which should set out a medium to longer term strategy for the spatial development of the County identifying the quantum, location and phasing of proposed development.
The framework for the Council’s settlement strategy is set out in the Regional Planning Guidelines. The strategy is based on a differentiation of towns within the Metropolitan Area of the county and those within the Hinterland Area (these areas being defined at regional level). The thrust of the settlement strategy is to consolidate urban areas around the Dublin Gateway and integrate investment in infrastructure, in particular public transport, with land use planning. The Draft Plan should continue to pursue the existing settlement strategy with the key growth areas within the Metropolitan Area being Swords and Blanchardstown while Balbriggan is the key growth town within the Hinterland Area. The targets for population and housing should be allocated in the Draft Plan in accordance with the settlement strategy and the policy of consolidation.
The Council must be ‘consistent with’ the current RPG housing targets. However, these targets were set using data from the 2006 Census and need to be reviewed. This review has been delayed by the need to have a new National Planning Framework to guide any
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new Regional Spatial and Economic Strategy prepared by the new Eastern and Midland Regional Assembly. It is unlikely that new Regional Strategies will be produced before the end of 2016. Any new targets will be kept under review by the Council during the Draft Plan process and incorporated where possible within the set timeframes.
For the Draft Plan, based on the current RPG targets and the development in the county since the beginning of 2011, there will be a requirement to provide 38,199 residential units up to 2023, increasing to 48,054 up to 2026.
The review of the Development Plan offers an opportunity to refine and improve the land use zoning objectives and uses and the location of certain types of zoning. Zoning along the Metro Economic Corridor has been adversely affected by the delay in the delivery of Metro North in particular and should be reviewed as part of the preparation of the Draft Plan. It is important that the potential of these lands for higher density development is not compromised while recognising that development should not be unduly delayed. Rural Settlement Strategy
The Council should have regard to national policy and guidance and notes the fact that the rural area of Fingal is described in policy and guidance documents as an area under strong urban pressure. It is considered that there is a continued requirement for a strong rural housing policy and rural settlement strategy to reduce urban sprawl, ensure the integrity of the countryside and the viability of the rural villages. Energy efficiency, Climate Change & Adaption, and Sustainability should continue to be important pillars of the Draft Plan.
Accommodating the requirement for housing within the rural area, including the rural villages and rural clusters, of Fingal should be met within the Rural Settlement Strategy as part of the wider Settlement Strategy for the County. This Strategy will ensure that the rural resource is enhanced, while making provision for locals who have a genuine rural- generated housing need. This strategy will also play an important role in the development of the rural villages and clusters. The requirement of a time limit on the occupancy of a rural home and appropriate documentation is considered necessary to ensure that only those with genuine local rural-generated housing needs can apply for planning permission for a rural house and is supported by government guidance. Housing Strategy
The Housing Strategy, which will be prepared as part of the Draft Plan, should ensure that the County provides for the housing of the existing and future population in a sustainable manner. The Strategy is required to provide for different housing needs, including social and affordable housing, and all forms of sheltered or specialised housing. The issues raised in the submissions should be looked at as part of the review of the Strategy.
Revisions to Part V of the Planning and Development Act, 2000-2014 are currently being progressed through legislation. The Urban Regeneration and Housing Bill, 2015 proposes to reduce the social and affordable requirement to 10% with the general principle being to deliver housing on site. Any changes to legislation relating to Part V should be closely monitored and included in the Housing Strategy.
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Housing and Density
The Council should continue to be guided by Government guidelines in relation to density and to the need to ensure integration of investment in infrastructure with land use planning. Short term market demands cannot undermine the need for sustainable development in the medium to longer term. The Council has collaborated with the NTA and other Dublin Local Authorities in a pragmatic and flexible manner to facilitate an incremental development approach through a ‘kick start’ to development. This approach accords with the NTA and DoECLG publication Development of Large-Scale, Rail Focussed Residential Areas in Dublin (2013) to deliver to the overall planned densities over the longer term.
The promotion of high quality design and standards and a good housing mix is an important component in creating a competitive Fingal by ensuring choice and a good quality of life for residents and should continue to be pursued in the Draft Plan. The need to accommodate different types of housing within an area to provide for all stages of the life cycle and allow people to ‘trade down’ is recognised. It is important that any proposals to increase standards above national regulations and guidance are balanced against any potential negative impact on supply and affordability. Greenbelts
The use of a permanent area of green countryside, or greenbelts, which is generally given over to rural uses within strategic areas of Fingal is important for the health and sustainability of the county. Greenbelts are a recognised policy instrument for ensuring clear separation between rural and urban areas, as well as between different urban areas. The Regional Planning Guidelines for the Greater Dublin Area 2010-2022 state that greenbelts ‘divide the built up areas of towns from each other or the city (and) shall be identified as long term green belt lands to avoid their future coalescence and the loss of definition between rural and urban places’. The review of the Development Plan presents an opportunity to encourage positive uses within them while still maintaining their core function in spatial planning terms.
The detailed contents of the submissions on the Settlement Strategy are noted and should be considered, where appropriate, during the preparation of the Draft Plan.
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5. PLACEMAKING AND COMMUNITIES STRATEGIC CONTEXT The Development Plan has a central role in developing our sense of place, identity and character and helping to provide the type of living accommodation and environment in which to enjoy our preferred lifestyle. Good planning and development can positively impact on our health and sense of well-being. There is also clear evidence that good quality public spaces, well designed buildings and a green public realm have a positive effect on economic growth and are therefore important considerations in making Fingal more attractive to both local and global business.
National Spatial Strategy 2002–2020 (NSS)
The NSS aims to achieve a better balance of social, economic and physical development and population growth across the country. For Dublin, it states that the physical consolidation of Dublin, supported by effective land use policies for the urban area itself, is an essential requirement for a competitive region. The NSS acknowledges that physical and cultural liveliness will be required to ensure that there is a combination of attractive social and cultural facilities for both people and business. Progress towards more successful and attractive larger urban areas will continue to require targeted, area based measures and priorities. It is recognised that good quality, well designed and serviced housing is essential. Consolidation and concentration of development should be in places where the integration of employment, services, retail and transport should be possible. Section 5.4 sets out general considerations for the design and layout of urban areas of varying sizes with an emphasis on the quality of the open spaces, public parks and amenity areas as key contributions to quality of life.
The NSS also sets out policies which will assist the rural areas to contribute to more balanced regional development. The NSS states that to strengthen the rural economy, it is necessary to secure agriculture, diversify rural employment options and stabilise the rural population while ensuring the landscape is protected.
Regional Planning Guidelines for the Greater Dublin Area 2010 – 2020 (RPGs)
These Guidelines will continue to be regional policy until replaced by Regional Spatial and Economic Strategies (RSES) which are to be produced by the new Regional Assemblies in 2016.
The RPGs set out critical elements of social infrastructure which are key to building sustainable communities and enhancing quality of life across the Greater Dublin Area (GDA). The Guidelines state this aspect has an important supporting role to the Settlement Strategy for the GDA. Central elements of this are design quality, sustainable densities, integration of housing strategies, schools and crèche provision, leisure and recreational facilities, healthcare, community facilities, and the role of the arts and culture including the Irish language to supporting and enriching the many communities and places of the GDA.
Local Economic and Community Plan (LECP)
The purpose of the LECP, as provided for in the Local Government Reform Act 2014, is to set out, for a six-year period, the objectives and actions needed to promote and support the economic development and the local and community development of the relevant local authority area, both by itself directly and in partnership with other economic and community development stakeholders. The Fingal LECP is currently being prepared.
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Sustainable Residential Development in Urban Areas, 2009 and accompanying Urban Design Manual - A Best Practice Guide, 2009
These Guidelines address development in larger urban centres, towns and villages as well as individual homes and their surroundings. Increased residential density is promoted at appropriate locations, especially where development is close to existing or future high quality public transport routes. The Guidelines emphasise the qualities which make for successful places and the need for high quality, sustainable design and layout, good quality living environment including the availability of adequate shopping, social, childcare, transport and leisure infrastructure.
Delivering Homes Sustaining Communities – Statement on Housing Policy (2007)
The document sets out how to improve the Irish housing environment and deliver sustainable communities. The timely provision of social and physical infrastructure such as schools and amenities is considered essential.
SUMMARY OF ISSUES RAISED Submissions Received During the Consultation Process
P00005, P00011, P00013, P00014, P00017, P00021, P00026, P00031, P00034, P00036, P00038, P00040, P00042, P00043, P00044, P00045 P00048, P00050, P00052, P00058, P00060, P00063, P00066, P00068, P00069, P00070, P00072, P00077, P00080, P00081, P00082, P00083, P00084, P00086, P00088, P00089, P00092, P00096, P00100, P00101, P00105, P00108, P00109, P00111, P00114, P00118, P00119, P00121, P00123, P00125, P00130, P00131, P00133, P00135, P00137, P00138, P00139, P00140, P00141, P00144, P00147, P00148, P00160, P00164, P00165, P00167, P00168, P00169, P00170, P00171, P00173, P00174, P00177, P00178, P00179, P00181, P00182, P00184, P00185, P00187, P00188, P00190, P00192, P00193, P00194, P00198, P00199, P00202, P00203, P00204, P00206, P00207, P00208, P00209, P00216, P00217, P00218, P00223, P00225, P00226, P00228, P00230, P00233, P00236, P00237, P00242, P00243, P00249, P00254, P00264, P00265, P00266, P00268, P00269, P00272, P00286, P00290, P00293, P00294, P00299, P00316, P00319, P00321, P00322, P00323 Sustainable Communities
In general, the majority of submissions seek to strengthen the County’s towns, villages and local centres through the intensification of uses within the centres and focusing commercial and retail uses in areas where there is adequate infrastructure.
Issues expressed related, in general, to education, adequacy of infrastructure, delivery of infrastructure and facilities, and the needs of specific areas and for specific groups. Issues were also raised about specific community requirements for individual sites located throughout the County.
A large number of submissions highlighted the importance of making provision for educational facilities throughout the County.
A number of submissions indicate that more community input is needed for the sustainable development of the County’s towns and villages. Suggestions include the type and nature of facilities needed in an ideal community. Submissions from residents associations and community groups emphasise the need for creating better places to live and the importance of building sustainable communities.
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The issue of providing adequate infrastructure and facilities for both the existing population and the future population was raised. Submissions referenced the need to consider the demographic profile of the future population. Submissions also referenced the needto increase promotion of social infrastructure, recreation and sport. It was felt that infrastructure should be provided in tandem with residential developments and should meet the needs of the future residents. This was raised in a number of submissions. The provision of a variety of facilities for older people was raised and it is considered they should be located close to other facilities. Age & dementia friendly public spaces, transport and buildings should be catered for. Shopping centres are highlighted as not being as “age-friendly” as they could be and improvements are needed.
A number of submissions raised concerns about the adequacy of community services and facilities in specific locations. These include (but are not limited to) Rush, Balbriggan, Castleknock & Coolquay.
Other submissions included the need to protect the character and regenerate the Rural Villages, through a variety of means. It was suggested that the existing Local area Plans and Village Design Statements should be re-examined. The historic core of villages should be retained and protected; Castleknock was specifically mentioned in this regard.
St Margaret’s was highlighted as an area which is not identified as a Rural Village. This area should be given proper consideration regarding existing and proposed uses.
It was requested that the Council support the consolidation of Local Centre services and amenities through the adoption of policy that facilitates a broader range of retail and community uses at these centres, appropriate to their scale, function and local catchment.
The process of building policy based on environmental sustainability needs to fully include public health considerations. A “Healthy Fingal” should be a central role of the Draft Plan.
Consideration should be given to developing a co-operative housing model in conjunction with the Council.
One submission suggested a more appropriate name is given for the South Fringe area -Fingal South is suggested. Public Realm
The issue of public realm and the need for improvement in this area was raised in a large number of submissions. Specifically it is considered the visual appearance of a number of urban centres, towns and villages could be improved.
In particular it was noted that:
• Portmarnock lacks a town centre and this should be improved.
• Lusk has a sense of place that should be retained and fostered.
• The recent Masterplan for Swords Castle should contain additional pedestrian routes to and from the town centre. Pedestrian links in Swords need to be improved and strengthened. The Castle Shopping Centre is a strategic site and the provision of a pedestrian walk along the river here should form part of the plan.
• The appearance of Swords Main Street needs to be improved.
• Improvements in the public realm in Balbriggan could help bring people back into the town centre.
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• The sense of “village” of Malahide is emphasised as one its characteristics. This character should be protected and enhanced.
• Castleknock requires a new Urban Centre Strategy. The village core should be enhanced through undergrounding of cables, improving street lighting & signage and enriching the historic core.
• Planning should protect the distinctive village environment in the historic villages of Castleknock, Blanchardstown and Clonsilla.
• The Main Streets of the villages should be regenerated.
• The Council should work with Waterways Ireland to ensure the towpaths along the Canal are maintained.
It is considered that important whatever changes take place, individual locations should retain their sense of place and local distinctiveness. Community Facilities
There is a need for facilities which cater for all elements of society, children, young people, the disabled and the elderly. All new development should be community focused and development should be on the basis of building communities. Social infrastructure should be provided for new communities. These facilities should be provided in tandem with residential development.
It is noted there is a lot of community and voluntary interaction in different communities throughout the County. These contribute to a strong sense of community and should be harnessed for the good of the community. There is a need for greater interaction between the Council and existing community groups.
Community centres should be provided at the same time as housing is provided and in close proximity to those who use them. The facilities should be operated by the Council in conjunction with the communities.
The need to provide libraries at specific locations within the County and the potential of libraries to supplement the educational needs of those living locally emerged as an issue.
Planning guidelines should be provided for places of worship. A number of religious groups have requested individual sites for community centres and/or places of worship.
Schools should be planned close to other community facilities so these can be shared. Multi-campus school arrangements should be facilitated. Fingal needs to take a proactive approach to identify areas where new schools will be required. Lands adjacent to existing schools should be protected for possible future education use. The need for a second level Irish language school is highlighted; with Dublin 15 a suggested location for such a school. Any new school should have facilities for children with special needs. Alternative locations for a secondary school in Rush are suggested in a number of submissions. A number of submissions indicate the need for new schools in a variety of locations throughout the County. A diverse range of schools should be provided. The Council should have regard to the provisions of the government guidelines The Provision of Schools & the Planning System, as published in 2008.
The need for primary health care centres throughout the County is highlighted. These should include multi-disciplinary therapy services. There needs to be an appropriate zoning to allow medical uses to be provided within a community setting. A suggestion is given for
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a location for a Curam (mental health centre) in Swords. Drug rehabilitation services also need supplementary support.
The Department of Justice & Law Reform notes they are currently examining a number of alternative options to determine whether the lands at Thornton Hall might be potentially suitable to accommodate other public sector requirements.
New graveyard facilities are required and it is requested that support for the development of crematoria is continued. A policy to facilitate the development of allotments should form part of the Draft Plan.
Sport and recreation has significant health and social benefits for the community. A large number of specific facilities in specific locations have been requested. These include athletic tracks, all-weather pitches, grass pitches, tennis courts, swimming pools and outdoor water sporting facilities. It is considered there is a deficit of facilities in some areas. Dublin 15 is highlighted as such an area. One suggestion in particular suggests Dublin 15 is developed as a sporting hub in conjunction with the National Aquatic Centre and Sports Campus Ireland.
Dublin GAA County Board have made a detailed submission in relation to the provision & upgrading of GAA facilities.
Sporting and community organisations in Lusk have developed a long-term sports plan for Lusk, “Lusk Community 2020 Sports Plan”. It is requested the Council has regard to this document.
The provision of more playgrounds in specific locations was suggested. Skateparks are also requested. It is also suggested that some playgrounds “blight” our environment. Design & Standards
Developments should be designed with the needs of the community in mind and proper facilities provided.
A large number of submissions raised concerns regarding the lack of standards for new developments, the negative visual impact of unfinished developments and the lack of investment in the main streets.
It is considered different forms of residential layout should be provided including village type streetscapes, cul-de-sac development with areas of green space. New developments should be permeable with lots of green spaces and optimal provision of community facilities. The layouts of residential schemes should encourage social interaction, cycling and walking and promote supervision of areas. Housing developments should be designed in such a way as to ensure passive surveillance, elimination of laneways and other blind spots. It is requested that better refuse facilities and safe bicycle storage facilities be considered at design stage for residential developments. Guidelines for acceptable boundary treatments are required and should be developed. New developments should be named in Irish as well as in English. Gated developments should not be permitted.
The preference for a move away from apartment developments to traditional housing estates came across in a number of submissions. A number of submissions contend garden sizes for new residential developments are too small. However one submission did note the 75sqm requirement for 4 or more bedroom dwellings is onerous and this should be reduced. The development of small, functional, low maintenance open spaces should be encouraged and off-street car parking provided. It is suggested that there should be a limit in the size of individual housing estates. There should be a variety of housing types within
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residential estates. Social housing should be planned in small groups within private housing developments.
It is noted there is a need to focus on tenure diversity and to encourage stock rotation, to avoid a large number of one and two person households continuing to live in large family dwellings.
It is requested the existing development management standards should be maintained in relation to quantitative and qualitative requirements for housing layouts and more flexibility is encouraged. Flexibility is also required in relation to the mix of housing types required.
Regarding apartment developments the Council should recognise that one size does not fit. Flexibility in regard to building heights is requested.
It is also noted that existing Building Regulations require high standards of energy efficiency. It is requested no additional requirements are placed on developers. Current building standards and codes are considered, by some, unnecessarily restrictive and do not guarantee high-quality build while others suggested that all new housing developments should have solar panels and rainwater storage. Better noise insulation measures are also suggested.
The towns and villages of the County need to be improved to increase their attractiveness and maintain their existing characters. High quality street furniture and improvements to the main streets are suggested. Different paving types and high quality landscaping help to improve the quality of the public realm. There is a need for more bins and increased frequency of collection.
Some towns & villages have derelict and vacant sites. Policies are required to ensure that vacant units are put to good use and provide activity.
It is noted some existing social housing has a poor appearance and should be improved.
Urban Centre Strategies are suggested in a number of locations, including, Rush, Castleknock & Portmarnock. These should be prepared by independent consultants.
Problems in public order should be addressed by the provision of community policing, additional lighting, security cameras and passive supervision.
One submission suggests standards are required for the provision of seasonal accommodation for the horticultural industry. This accommodation is best provided through the provision of mobile homes, portacabins or similar type structures catering for the needs of workers staying for 3, 6 or 9 months at a time.
Open Space
A number of submissions indicate the need for more open space at specific locations around the County. There is a need for a greater variety of activities and events that can be accommodated in the public parks. Facilities such as coffee shops, playgrounds, dog runs skate parks, adult exercise equipment are suggested. The provision of more playgrounds is requested a number of times and existing ones should be maintained and improved where required. It is also noted Park Rangers are critical to the operation of successful parks.
Parks should be multi-functional, incorporating walking, sports, exercising equipment, dog runs, skate parks, etc. It is also considered safety and security should be part of the design process of parks. Small parks and kick-about areas should be developed to facilitate the
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active participation of children in games. Recreational hubs should be extended, be well- designed, floodlit and flexible. The provision of facilities through public-private partnerships should be considered.
The design and management of open space can respect and enhance the character and distinctiveness of an area. The need to maintain existing open spaces is highlighted by a number of people. The need to cut grass more frequently is emphasised. A new approach is required for the maintenance of both new and existing open spaces. The one-size-fits- all approach to open space doesn’t take account of different development pressures or market demand. It also doesn’t consider existing parks and recreational areas. A number of submissions request a greater emphasis on qualitative design standards.
One submission emphasises that good quality open spaces showcase the work and value of the Council. In areas where there is a good mix of social spaces, the quality of life is improved. In order to continue this, the Council should benchmark itself against other local authorities in Ireland and internationally, a minimum amount of green space should be provided for each residential area and a community funding initiative should be considered to reward volunteers in this area.
St. Catherine’s Park, Lucan was cited as an example of a good park and other similar parks should be developed in the Fingal area. A number of people suggest a linear park along the Strawberry Beds. Other spaces which are suggested for improvements or as a new amenity space include Shackleton Gardens and Mills, Tolka Valley, Liffey Valley, Balleally Landfill, Dunsink Landfill, the Royal Canal, Rush & Balbriggan Town Park. One submission suggests the development of Balleally as an open space represents an opportunity to develop the area for the benefit of the local environment. Projects such as Fingal Food Forest would be suitable.
The maintenance of demesne lands can use a lot of resources.
There is a request for a qualitative and not a quantitative policies to address provision of quality green space. The 10% on site open space requirement is overly restrictive and constrains development potential on site. There are also often conflicting interests in the provision of open space and Sustainable Urban Drainage Systems (SuDs), the requirements of which often reduce the net developable area of the site.
More community development within parks and open spaces should be encouraged.
The Royal Canal Park Community Association requests there is more interaction between Fingal and Dublin City Councils regarding the potential of Cardiffsbridge Park, the proposed park at Dunsink and the relationship with the Tolka Valley Regional Park.
It is also requested that the Council take in charge some particular open spaces.
Parks and sports areas should be within reach of communities with better signage; and be better utilised and made available for more events.
The number of large trees outside houses should be reduced. The trees in Castleknock Park should be removed on safety grounds and new ones planted.
It is asked if links are proposed with the Ancient Eastern Way.
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CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - PLACEMAKING AND COMMUNITIES Sustainable Communities
The current Plan supports the development of a hierarchy of high quality, vibrant, consolidated and attractive urban settlements with open countryside and green belt lands that separate the urban areas. These characteristics along with the rural hinterland and villages help to define the character of Fingal, providing a sense of place and local identity. The maintenance of this general pattern of development is important for the sound and sustainable development of the County. The Draft Plan should seek to provide a well- designed built environment with a proportionate scale of development: of sufficient size, scale and density with the right layout to support basic amenities for the community, minimising the use of resources (including land), while maximising efficiencies (including energy); including a well-integrated mix of good quality homes of different types to support a range of household sizes, ages and incomes; buildings that can adapt to meet different needs over time.
The Council acknowledges there is a wide range of community facilities, civic facilities and social services existing in the County. The protection of existing resources through appropriate policies and objectives and facilitation and support to the development and expansion of facilities and services throughout the County should continue to be important, based on identified need, to deliver a high quality of life for all communities in Fingal.
The Draft Plan should incorporate an evidence based core strategy that should outline the existing and proposed future distribution of population in the County within a settlement hierarchy that is consistent with the Settlement Strategy set out in the RPGs. The core strategy should form the basis for policies and objectives in relation to the spatial distribution of community infrastructure.
The Draft Plan should examine the existing settlements including the villages and rural clusters and give consideration to the most appropriate designation, depending on their location, infrastructure and their place within the Settlement Strategy. The possible extension of existing development boundaries, whether inside the Metropolitan area or not, should also be given due consideration.
Creating a healthy environment includes planning for minimal ecological impact, minimal waste or pollution, maximum recycling, protection and enhancement of the natural environment, wildlife and biodiversity. A key challenge is to create healthy and safe environments for all, and maintain an ecologically resilient environment. The Draft Plan should continue to promote the policies outlined in the current Development Plan aimed at creating a healthy environment.
Consideration should be given in relation to the provision/development of various housing models.
The naming of new areas is part of an existing naming and numbering process undertaken through development management, as such is not directly a matter for the Development Plan.
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Public Realm
An overarching aim of the current Development Plan is to create and sustain people-friendly places for the benefit of the residents and businesses of Fingal, whilst endeavouring to support developers seeking to deliver the highest quality design solutions. The Council recognise that investing in good urban design can create economically successful development that functions well and has a lasting effect into the future. It is important to promote public spaces and routes that are attractive, safe, uncluttered and work effectively for all in society, including disabled and elderly people. Furthermore, the Council should continue to support character in local areas by responding to, and reinforcing locally distinctive patterns of development.
The Draft Plan should strengthen policy on the public realm and public realm initiatives and support its development and implementation of schemes on a county wide basis. This should include enhancements in existing areas and incorporation into new schemes.
Community Facilities
The need for community facilities and the important role of community groups is recognised by the Council and a fully integrated approach to developing sustainable communities should be a key facet of the Draft Plan. Social infrastructure is recognised as being of as much importance as physical infrastructure. Strong interactions exist between the Council and existing community groups, and these relationships should continue to be fostered and strengthened.
The Draft Plan, aided by the Local Area Plan and Development Management processes, should ensure, where possible, the timely and accessible provision of community services and resources, including schools, religious, and community and health facilities. The Draft Plan should have regard to the Local Employment and Community Plan when that process has been finalised.
The Council has a good record in the provision and support of recreational and open space facilities. High quality accessible multifunctional active and passive recreational and open spaces and facilities are essential to the provision of sustainable communities. The current Development Plan sets out a hierarchy of open space and a similar approach should be adopted in the Draft Plan. The Council is seeking to develop active ‘Recreational Hubs’ at various locations throughout Fingal. These hubs should be provided by or facilitated by the Council and should allow clubs from different sporting codes to share facilities such as changing/meeting rooms, car-parking, all-weather pitches, and other ancillary facilities. The Recreational Hubs concept has been developed to encourage multi-use and sustainable community sporting facilities. The purpose of the hub is to locate sport in an area where it doesn’t conflict with adjoining residential use. It should create intensive recreational areas. The Council should endeavour to locate these hubs adjacent to school buildings or other municipal facilities to increase the use of same.
The Council should continue to implement the Development Contribution scheme as it relates to the improvement of existing recreation and leisure facilities and the funding of new recreational and leisure facilities.
The development of lands at Thornton Hall will be subject to the Development Management process.
A policy for the provision of additional lands for cemeteries should be considered. The existing Development Plan supports the development of crematoria through Objective
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CI44. The retention of this objective should be considered. The Fingal Allotment Strategy 2012 outlines the Councils’ approach to the development of allotments. A policy to support this Strategy should be considered in the Draft Plan. Design & Standards
The Draft Plan should continue to support the provision of a mix of developments in order to create sustainable communities. The Council should seek to enhance the environment of the town and village centres. The Draft Plan should focus on the urban design and aesthetic quality of our urban places.
The policies and objectives in the current Development Plan relating to issues such as design, density, location, height and open space should be reviewed during the preparation of the Draft Plan. Government Guidelines, including the Sustainable Residential Development in Urban Areas and the companion Urban Design Manual should be followed. Development should take place into the future on the basis of sustainability. The Development Management process has a key role to play to ensure that development will respect the character of an area.
It is essential that access in all communities is of the highest quality and allows access to all. The Draft Plan should aim to provide for development that is properly planned, managed and serviced with private amenity areas, drainage and water supplies as well as the provision of social infrastructure.
The provision of new residential development should be on the basis of best practice in terms of layout and design. Similarly the provision of services and open space should be provided according to best principles. Standards and quantities and areas should be reviewed in the preparation of the Draft Plan. Access to and permeability within housing areas will be required. New residential development should be guided by the various guidelines outlined in the Strategic Context section. Improvements and upgrades to existing dwellings are encouraged.
New dwellings are required to be constructed in accordance with the relevant building standards. Consideration should be given to the requirement to provide additional energy saving measures. However, it is recognised that there is a need to achieve a balance between the initial cost of construction of homes and the ultimate running costs, such that affordability or supply of homes is not unduly effected.
As part of the preparation of the Draft Plan the Council should review the success or otherwise regarding the implementation of existing Urban Centre Strategies and requirement for any amendments to existing or new Strategies to be undertaken in future.
Appropriate standards for non-traditional residential units, i.e. student accommodation, seasonal workers accommodation & sheltered housing, should be considered in the drafting of the Draft Plan. Open Space
The Council has a good record in the provision and support of recreational and open space facilities. A substantial network of parks and open spaces exist within the County, amounting to approximately 2,000 hectares. There is a hierarchy of managed parks from regional scale parks to smaller open spaces within residential areas all with a range of resources (sports pitches, play grounds, running tracks, adult exercise equipment etc.) and natural amenities
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(flora, fauna, watercourses etc.).
The Draft Plan should review the role and function of parks and recreational areas within the County and consider policies to strengthen the network of parks and recreational areas
The current Development Plan requires the provision of playground facilities as part of new residential developments. It is now a requirement that playground facilities be provided at a rate of 4 sq. m per residential unit and that all residential schemes in excess of 50 units incorporate playground facilities.
The Council should continue to develop active ‘Recreational Hubs’ at various locations throughout Fingal.
The Council should continue to liaise and consult with adjoining local authorities, particularly with regard to areas where parks and open space adjoin neighbouring authorities.
A Draft Open Space Strategy will be published shortly by the Council. This will outline the Council’s approach to the maintenance and management of existing and proposed open space. The current Development Plan outlines a quantitative approach to the provision of open space. This policy should be reviewed and supplemented if necessary. This document also encourages more community involvement in open spaces.
In the current Development Plan it is a requirement to provide a minimum of 10% of a proposed residential development site for use as open space. This requirement ensures that future residents of the development have sufficient amenities centrally located and close to their dwellings (Objectives OS01 and OS02). The Council in certain circumstances has discretion to accept a financial contributions in lieu of this requirement to be used solely for the purpose of the acquisition or upgrading of small parks, local parks and urban neighbourhood parks and/or recreational/amenity facilities subject to meeting ‘accessibility from home standards’ or in exceptional circumstances to contribute to the provision or upgrade of Regional Parks where more local provision is not achievable.
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6. INFRASTRUCTURE & MOVEMENT This Section of the Report deals with issues concerning Infrastructure and Movement. Under these broad headings the overall Strategic Context is first given before considering Infrastructure, under the headings of Waste Management, Energy, Telecommunications, and Water Related Issues. Aspects of Movement including public transport, roads, walking, cycling, Dublin Airport, and harbours are then considered. At the end of each sub theme the Chief Executive’s opinion is given.
Strategic Context National Spatial Strategy 2002-2020 (NSS)
The NSS recognises the importance of the Greater Dublin Area (GDA) in the overall economic well-being of the country. The strategy envisages the consolidation of the growth of the Metropolitan Area, i.e. Dublin City and suburbs whilst ensuring that development in the hinterland, e.g. parts of Fingal is concentrated in strategically placed, strong urban centres. This strategy provides aims to focus infrastructural investments at key locations in the county and to provide for an efficient and sustainable transport system linking these urban centres.
Regional Planning Guidelines 2010-2022
The RPG’s set out the infrastructure needs of the Greater Dublin Area to support the delivery of the RPG settlement policy.
The objectives of the NSS are dependent on prioritising infrastructure to identified towns and cities to ensure that these areas can develop the appropriate critical mass to sustain services.
Smarter Travel – A Sustainable Transport Future – A New Transport Policy for Ireland 2009-2020
This document aims to deliver a sustainable transport system as an important dimension of the climate change agenda with the Government reaffirming its vision for sustainability in transport. Five key goals are set out:
(i) to reduce overall travel demand
(ii) to maximise the efficiency of the transport network
(iii) to reduce reliance on fossil fuel,
(iv) to reduce transport emissions; and
(v) to improve accessibility to transport and improve our quality of life
The Smarter Travel document is one of the key policy documents informing the Development Plan. It promotes the integration of land use and transport planning and is a key facilitator in reducing urban sprawl, and delivering on the policy contained in the National Spatial Strategy and the Regional Planning Guidelines to consolidate existing urban areas.
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Greater Dublin Area Draft Transport Strategy 2011-2030, 2030 Vision
Produced by the NTA, this document is a draft strategic plan for transport in the GDA up to 2030. The purpose of the strategy was to establish appropriate policies and transport measures that would support the GDA in meeting its potential as a competitive, sustainable city region with a good quality of life.
The strategy was not intended as a standalone document but as the top level in a hierarchy of transport plans which included an Implementation Plan and Traffic Management Plan. The Strategy would have replaced A Platform for Change, its predecessor outlining transport policies to create a sustainable city region. Transport 21 translated the Platform for Change vision set out in the previous Strategy into more concrete objectives. However, given the significant changes that have occurred since the Strategy’s publication in 2011, the NTA has commenced the preparation of a new transport strategy for the GDA to cover the period 2015 to 2035. It is intended that the revised draft transport strategy will be available for public consultation in mid-2015.
Transport 21
This document was informed by A Platform for Change 2000-2016 and formed part of the National Development Plan (NDP). For the GDA, Transport 21 was to play a significant role in delivering high quality public transport and identified which projects were to be developed under the NDP and the timelines for the completion of those projects. Projects identified for the Fingal area included: Light Rail Metro
● Stephens Green to Belinstown (Metro North) ● Tallaght to Dardistown (Metro West)
DART Expansion Programme
● Electrification of the line to Balbriggan and Hazelhatch ● Interconnector (DART Underground) – improved capacity and connectivity NTA Integrated Implementation Plan 2013-2018
The Integrated Implementation Plan, informed by the draft 2030 Vision, sets out the NTA’s programme of investment and development in the Greater Dublin Area. It is statutorily approved and provides the framework for a capital and operational investment of almost €900 million. Funding up to 2016 is included as part of the Government’s overall capital plan and funding for the remaining years of 2017 and 2018 is to be addressed in the next national capital investment plan.
Planning and Development of Large Scale, Rail Focussed Residential Areas in Dublin, NTA May 2013 (Non Statutory)
The purpose of this study is to assess the future delivery of rail based large and medium scale residential development areas in Dublin, given the current economic and funding conditions prevailing in Ireland and the current lack of new residential development delivery of any scale. The purpose of this study is to inform policy in this area.
One of the key conclusions of the study is the prioritisation of strategic residential locations.
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In order to ensure delivery of housing areas where significant public investment has been made, there is a requirement for active public sector coordination to ensure the continued prioritisation of these areas for housing development. This requires:
(a) Coordinated government / public meetings (i.e. direct action and investment) with departments cooperating to deliver required interventions to support the delivery of the strategic residential development areas; and
(b) Prioritisation of locations that are considered most appropriate for development delivery in the short term.
Fingal / North Dublin Transport Study
Travel across the Fingal/North Dublin region is predicted to increase in the medium term, as a result of population and employment growth. This increased travel cannot be catered for by car; extra public transport capacity will be required, supplemented by cycling and walking for shorter journeys. Car travel is currently the dominant mode of travel within the Study area, although urban centres such as Ballymun and Swords have a higher uptake of sustainable modes of transport, particularly the bus. In Fingal, it is envisaged that Swords will grow significantly, in line with its designation as a Metropolitan Consolidation Town in the Regional Planning Guidelines. In January 2014, as part of the Fingal/North Dublin Transport Study, the NTA put their Stage 1 Appraisal Report out to public consultation with a shortlist of 6 options put forward for the optimum long term public transport solution to connect Dublin City Centre, Dublin Airport and Swords. The options included heavy rail, light rail, bus rapid transit and a combination option. It is expected that the preferred solution will be known by mid-2015. The outcome of the Study will have a significant influence on the Draft Plan. National Cycle Policy Framework (NCPF) (2009)
This document seeks to deliver a new culture of cycling in Ireland by 2020, with the aim of achieving 10% of all trips by bicycle within the next twelve years. The NCPF requires that cycle friendly planning principles be incorporated into all national, regional, local and sub local plans.
Greater Dublin Area Cycle Network Plan
This Plan sets out a ten year cycling strategy for Dublin, Kildare, Meath and Wicklow and was published by the NTA in 2014. The plan is to increase the region’s cycle network 5-fold in length to 2,840 kilometres. It includes a trebling of the existing network in urban areas from 500 kilometres to 1,485 kilometres in length, and over 1,300 kilometres of new connections between towns in rural areas. The routes will include greenways, cycle paths, cycle lanes and roads with low levels of traffic and will inform the next decade of investment in cycling.
Water Services Strategic Plan (WSSP)
Irish Water must produce a Water Services Strategic Plan (WSSP) which outlines the strategic direction for water services over the short to long term up to 2040. This strategic framework will identify and prioritise the key objectives required to ensure the public water system can meet the challenges of the future. Irish Water has published a draft of the first integrated plan for the delivery of water services in Ireland
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National Wastewater Sludge Management Plan
Wastewater treatment generates sludge products which require safe disposal or re-use where possible. Currently, wastewater sludge can be treated and re-used as a fertiliser, soil conditioner and also to generate renewable energy. Irish Water aims to retain and develop these sludge re-use strategies and will continue to maintain the high quality process management in place to ensure protection of the environment.
Irish Water is currently developing a National Wastewater Sludge Management Plan (NWSMP) which will set out Irish Waters strategies for wastewater sludge management over the next 25 years. When complete, the recommendations of the National Wastewater Sludge Management Plan will be used to inform future capital and operational activities in relation to sludge management. The principle conditions which must be met by the NWSMP is that it must provide a secure, sustainable and cost effective solution to the management of wastewater sludges over the life of the plans.
Irish Water indicates that by June/July they will be preparing the Draft NWSMP including the SEA Environmental Report and Appropriate Assessment.
The EU Water Framework Directive (WFD)
The Water Framework Directive (WFD) was developed in response to the increasing threat of pollution and the increasing demand from the public for cleaner rivers, lakes and beaches. This Directive is unique in that for the first time, it established a framework for the protection of all waters including rivers, lakes, estuaries, coastal waters and groundwater and their dependent wildlife/habitats under one piece of environmental legislation. Specifically the WFD aims to: • Protect / enhance all waters (surface, ground and coastal waters)
• Achieve “good status” for all waters by December 2015
• Manage water bodies based on river basins (or catchments)
• Involve the public
• Streamline legislation
Eastern River Basin District Management Plan 2009-2015
The first Eastern River Basin District Management Plan was published in 2009, covering the period up to 2015. All of Fingal lies within the Eastern River Basin District, along with eleven other local authorities. River Basin Management Plans are the end result of a process that starts with identifying the waters and key water management issues within a river basin district. Following changes to the governance structures by the Department of Environment, Community and Local Government in 2014 there will be a national River Basin Management Plan.
EU Floods Directive 2007/60/EC
The EU Floods Directive 2007/60/EC deals with the assessment and management of flood risks. It came into force in 2007 and was transposed into Irish law by the European Communities (Assessment and Management of Flood Risks) Regulations 2010 (SI 122/2010). The aim of the Directive is to reduce and manage the risks that floods pose to human health, the environment, cultural heritage and economic activity. The Directive requires a catchment- based approach to assessing and managing flood risk. Member States were required to carry
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out a preliminary assessment by 2011 to identify the river basins and associated coastal areas at risk of flooding. Following such assessment, flood risk maps were to be produced by 2013 followed by flood risk management plans focused on prevention, protection and preparedness by 2015. The Directive applies to all inland waters as well as all coastal waters across the whole EU.
FEMFRAMS & ECFRAMS
Arising from the Directive, flood risk pilot studies were undertaken and completed in different areas of the country. One of these was the Fingal East Meath Flood Risk Assessment and Management otherwise known as FEMFRAMS. This study was completed in 2012 and was the basis for the flood risk maps on the current Development Plan.
The Office of Public Works began a national programme of river catchment based Flood Risk Assessment and Management with the Eastern Catchment Flood Risk Assessment and Management (ECRFAM) Study commenced in June 2011
The Planning System and Flood Risk Management
In 2009 the Department of Environment, Heritage and Local Government published ‘The Planning System and Flood Risk Management’ in conjunction with the OPW. These guidelines require the planning system to take account of potential flooding and avoid development in areas that are at risk from flooding. While avoidance is preferable, this may not always be possible and the Guidelines indicate the types of development that might be suitable in certain areas based on the risk of flooding
Telecommunications Antennae and Support Structure Guidelines 1996
Guidance in respect of telecommunications has been largely contained within the document ‘Telecommunications Antennae & Support Structure Guidelines’, 1996. In October 2012 the Department of the Environment, Community, & Local Government issued a Circular advising of changes to the Guidelines. Revisions relate to temporary permissions, separation distances, bonds, health and safety and development contributions,
National Broadband Plan
Telecommunication facilities are largely provided on a private basis. Under the National Broadband Plan, the Government have committed to provide the services in areas not covered by existing private providers.
A Resource Opportunity
A Resource Opportunity was published by the Department of the Environment, Community and Local Government (DOECLG) in July 2012. It is based on the EU waste hierarchy and recognises the importance of waste as a resource opportunity. It covers the period up to 2020 but indicates that there will be a mid-term review in 2016.
Eastern Midlands Region Waste Management Plan 2015-2021
In order to manage wastes in a safe and compliant manner, clear strategies, policies and actions are required. The Waste Management Plan for the Eastern Midlands Region is the framework for the prevention and management of wastes in a safe and sustainable manner. The scope of the waste plan is broad and ultimately it needs to provide policy direction, setting out what we want to achieve and a roadmap of actions to get us there. The
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Eastern Midlands Region Waste Management Plan was adopted in May 2015 and is a statutory document prepared by the local authorities of the region. This Plan covers the period from 2015-2021 and is required to be revised or replaced every six years.
The strategic approach of the Plan places a stronger emphasis on preventing wastes and material reuse activities. It contains a comprehensive list of policies to achieve the overarching strategy and targets of the Plan.
Grid 25
Grid 25 is the Transmission Strategy of Eirgrid. The Strategy recognises the need to strike up a sustainable balance between cost, reliability, security and environmental impact. €800 million has been pinpointed for the GDA and it will be spent on upgrading 450km of the existing network and building new circuits. These upgrades are expected to cater for increases in populations and the resulting demands.
Energy Efficiency Directive (2012/27/EU) & Renewable Energy Directive (2009/28/EC)
The two main EU directives which seek to meet the targets of the European Union are the Energy Efficiency Directive which establishes a set of binding measures to help the EU reach its 20% energy efficiency target by 2020 and the Renewable Energy Directive which sets out rules for the EU to achieve its 20% renewables target by 2020.
Since the publication of the 2009 Renewable Energy Directive (2009/28/EC) the following are the European Mandatory targets: • 20% of all energy to come from renewable energy sources by 2020 (12% by 2010). Each member state is given different targets in order to achieve an overall target for Europe. Ireland’s target is 16% of gross final consumption to come from renewables by 2020.
• 10% of all transport energy to come from renewable sources by 2020.
The Dublin Agglomeration Environmental Noise Action Plan 2013-2018
The Dublin Agglomeration Environmental Noise Action Plan 2013-2018 was prepared jointly by the four local authorities in the Dublin Region. The key objectives of the plan are to avoid, prevent and reduce, where necessary, on a prioritised basis the harmful effects, including annoyance, caused by long term exposure to environmental noise from road traffic, rail and aircraft.
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SUMMARY OF ISSUES RAISED Submissions Received During the Consultation Process
P00001, P00002, P00004, P00005, P00008, P00009, P00011, P00016, P00018, P00020, P00022, P00026, P00028, P00029, P00031, P00034, P00040, P00042, P00044, P00046, P00047, P00048, P00050, P00053, P00058, P00059, P00060, P00061, P00062, P00064, P00065, P00072, P00073, P00076, P00077, P00079, P00080, P00082, P00083, P00084, P00085, P00086, P00087, P00088, P00090, P00092, P00093, P00097, P00100, P00102, P00104, P00106, P00107, P00108, P00109, P00110, P00111, P00114, P00116, P00118, P00119, P00120, P00121, P00122, P00124, P00126, P00127, P00128, P00129, P00131, P00132, P00133, P00134, P00135, P00136, P00137, P00138, P00140, P00141, P00143, P00144, P00147, P00148, P00149, P00151, P00153, P00154, P00156, P00157, P00159, P00160, P00161, P00163, P00164, P00169, P00170, P00174, P00175, P00177, P00180, P00181, P00184, P00185, P00186, P00187, P00190, P00191, P00192, P00193, P00194, P00197, P00198, P00200, P00203, P00204, P00206, P00207, P00209, P00211, P00215, P00217, P00219, P00220, P00222, P00223, P00224, P00225, P00226, P00228, P00229, P00230, P00233, P00234, P00239, P00240, P00242, P00243, P00247, P00248, P00250, P00251, P00253, P00254, P00256, P00257, P00260, P00261, P00265, P00268, P00280, P00286, P00294, P00300, P00302, P00306, P00309, P00311, P00312, P00313, P00315, P00316, P00317, P00321, P00323, P00327
For clarity the issues have been under separate headings, with the Chief Executive’s Opinion relating to these issues given immediately thereafter.
Waste Management The provision of recycling centres and ultimately their accessibility is an important issue that has arisen throughout the County. Proposals were put forward for the extension of opening hours at existing recycling centres which may alleviate potential illegal dumping in certain areas while suggestions were made for the reopening of previously closed centres such as the one in Balbriggan. These centres are recognised as great assets to the people of Fingal.
Waste management plans should include incentives to recycle plastics, drinks cans and materials.
There is a need to make recycling everyday materials easier with the suggested installation of recycling facilities that are not intrusive on the community like the massive bins that are currently in use.
There is a lack of litter bins including those for dog waste and litter enforcement was raised an issue that requires more attention.
Emphasis was put on the need for better policies to be put in place for the prosecution of illegal dumping.
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CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - WASTE MANAGEMENT Since the making of the current Development Plan there have been significant changes in the area of waste management. Previously local authorities were involved in the delivery of waste collection and treatment infrastructure but this is no longer the case. The local authority’s role is now focused on education, prevention and resource efficiency activities as well as regulating householders, businesses and waste operators and enforcing waste legislation.
For the purposes of waste management, Ireland is now divided into three regions, with the Council being in the Eastern-Midlands Region. In May 2015, the Eastern Midlands Waste Management Plan 2015-2021 was adopted. It must be noted that in preparation of the new Development Plan, by virtue of Section 22(10A) of the Waste Management Acts 1996-2008 the objectives of a Waste Management Plan are deemed to be included in county development plans. In the event that objectives of a county development plan and a waste management plan are in conflict, the objectives of the waste management plan prevail.
The waste infrastructure that will be provided by the Council will mainly include bring banks and civic amenities. In relation to issues raised concerning opening hours and their extension this should be considered in the context of available resources.
In respect of littering, the Council offers a free phone number for people to contact its Litter Management Unit to report any such offences. 918 litter fines were issued in 2014 and the Council successfully prosecuted 30 cases in 2014 for breaches of the Litter Pollution Acts. The Council is proactive in preventing and minimising litter. The Operations Department of the Council is responsible for the installation of litter bins throughout the County. Dog foul waste can be disposed of in all litter bins.
The Draft Plan should ensure through design standards that new residential developments are designed appropriately to accommodate the provision of a three bin service for food and bio-waste, dry recyclables and residual waste from a storage and access point of view.
Energy (including Renewable) There is a massive reliance on fossil fuels and coal to meet energy needs both in Ireland in general but also within Fingal. It is recommended that renewables should be at the forefront of future planning. Renewable energy technologies should be included in all new builds both residential and commercial.
It was indicated however that the renewable energy mix lacks diversity and Ireland has limited itself to wind, biofuels and hydro-electric.
All forms of renewables need to be considered in the Draft Plan along with support for innovation in the transition to achieving sustainable energy. Notwithstanding the foregoing, concern was also raised regarding the avoidance of excessively prescriptive policy provisions in relation to renewable energy technologies.
Innovations such as the potential that can be achieved from county production of carbon neutral willow biofuel are among the suggestions received that should be considered as part of the new Development Plan. Additionally the benefits of solar photovoltaics (PV) are noted as an unexploited option for meeting energy demands in Ireland and can assist in achieving the targets for Ireland. The issue was also raised regarding the importance of
embodied CO2 and embedded energy. It was suggested that the Council should consider what steps it can most effectively take through the Draft Plan to encourage construction projects which embody low carbon and energy. Such promotion would make a significant
contribution to the reduction of CO2 and energy consumption in Ireland. By reducing the
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levels of embodied CO2 and embedded energy, the Council could go beyond ‘adaptation’ to the effects of climate change and take the advanced step of actually ‘mitigating’ against
these effects. Additionally cognisance is made regarding the importance that Electric Vehicles (EV) can make to achieving sustainable energy, deployment of infrastructure for EV’s acts an enabler for larger scale wind energy projects in Ireland.
While strong emphasis has been put on the need to focus on renewable energy, the Draft Plan also needs to plan to accommodate the existing electricity networks serving Fingal which requires liaising with bodies such Eirgrid as the national electricity Transmission System Operator. Also, ESB Networks whose objective is to ensure that there is adequate network capacity to provide a reliable supply and to cater for new commercial, industrial and residential development. It is requested that the Draft Plan facilitate the extension and reinforcement of the electricity network, including the overhead lines which are the preferred means of distributing electricity.
Requests were made to have overhead wires in certain areas placed underground and supporting poles removed. Those that are needed should be placed in more convenient and less obtrusive or restrictive places.
Concern was raised over the state of disrepair of a number of utility units within Fingal and it is requested that the Council should insist on the full and proper reinstatement of areas when works have been carried out.
CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - ENERGY (INCLUDING RENEWABLE) The Council recognises the need for cost effective and reliable sources of power that are capable of accommodating the future growth and development of Fingal both for residential and commercial purposes.
The Regional Planning Guidelines indicate that 5,500 MW of renewable generation by 2020 is required to meet the government’s target of 40% total consumption from renewable energy. It is recommended that development plans support policies and plans that target renewable generation so that renewable energy targets for 2020 and beyond are met and that Energy Action Plans are developed.
The Draft Plan should include objectives that promote innovation regarding alternative energy sources while also promoting and exploring the use of solar energy, which at present is an unexploited option in Ireland. The Draft Plan should also consider suggestions
regarding the importance of embodied CO2 and embedded energy. The Draft Plan should continue to support the reinforcement and upgrading of the existing electricity supply to the County but should also place a strong emphasis on the importance of renewable energy.
While promoting and welcoming innovation for the development of sustainable energy technologies the protection of the environment should also be considered.
Telecommunications Telecommunication infrastructure plays a vital role in both the economic development of Fingal but also in the development of the County socially to avoid isolation and social exclusion.
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A strong emphasis was placed on the need to upgrade the telecommunications network which is considered to be quite poor with specific reference to high speed broadband both in the urban and rural areas. It is widely accepted that the need to upgrade the broadband services will facilitate local web based employment seeking to compete in a worldwide market.
Suggestions to entice people back to towns and villages to shop and socialise would be to include WiFi being made publicly available.
In respect of mobile telecommunications structures it was suggested that such infrastructure should be limited to non-residential areas and only permitted where the applicant has demonstrated documentary evidence that other site locations have been considered although the issue was conversely raised regarding the change in policy in respect of separation distances and allowing for flexibility on a case by case basis.
Concern was raised regarding multiple telecommunications poles located within the public footpaths and obstructing ease of use particularly for people with wheelchairs or buggys. The suggestion was made for better coordination of pole location and sharing of such infrastructure where appropriate and available.
CHIEF EXECUTIVE’S OPINION ON THE MAIN ISSUES - TELECOMMUNICATIONS The provision of a good quality high speed broadband and telecommunications service is essential for supporting and attracting business development and socially for the prevention of isolation and social exclusion. It is considered that Fingal has good broadband coverage generally. However it is acknowledged that there are parts of the County, both in urban and rural areas that are deficient in such services. The Draft Plan should promote the upgrade of such services by means of appropriate objectives and balance the need to remain flexible in terms of facilitating and adapting to advances in technology while ensuring that the environment and visual amenities of the County are not impacted upon.
When preparing the Draft Plan, cognisance should be taken of the Circular issued by the Department of the Environment, Community and Local Government (DOECLG) regarding changes to the 1996 Guidelines Telecommunications Antennae and Support Structure Guidelines and amendments to objectives within the Draft Plan shall be incorporated as necessary.
In so far as is possible the Draft Plan should promote the sharing of telecom poles in order to prevent any undue obstruction to footpaths.
Water Issues A number of submissions received noted the lack of sufficient waste water treatment plants in some of the towns and villages throughout Fingal which is preventing certain residential lands from being released for development.
Conversely it was noted in one submission that the village of Rowlestown is connected to a public foul drainage network which connects into the Swords Waste Water Treatment Plant and is currently underused and has the potential to facilitate higher densities.
Suggestions were made that all properties within proximity of sensitive areas like the River Tolka be connected to main foul drainage to prevent environmental impacts.
Issues were raised regarding implications that the proposed sewage outfall for much of the Dublin area 1km NE of Irelands Eye would have on local amenities of towns.
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Additionally concern was raised regarding the regulation and appropriate management of private on site waste water treatment systems.
In terms of the quality of water supply to homes reference was made to poor water quality in some parts of the county with an example of Rush and this has subsequent impacts on Skerries.
Water Pressure was indicated to be low in some areas of the County.
Appropriate regulation and monitoring of private wells should be done to ensure there is no adverse impact to ground water quality.
A strong emphasis was placed on the need to recycle surface water and ensure that water harvesting proposals are required as part of planning proposals in both homes and businesses. It was suggested that there is a lack of the sufficient integration of Sustainable Urban Drainage Systems (SuDs) and green infrastructure into developments, practice is rare and this should be driven through the Draft Plan.
Appropriate regulation and monitoring of private wells should be done to ensure there is no adverse impact to ground water quality.
Many submissions received raised issues of flooding throughout Fingal in various areas. Recommendations within submissions include the application of strict drainage conditions to development proposals. Submissions also highlighted that flood management plans need to be considered more robustly.
CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - WATER ISSUES It is important to note that since the adoption of the current Development Plan, the water sector in Ireland has undergone major transformation and reform. As of January 2014 Irish Water replaces local authorities as a single provider of water and waste water services. It is responsible for the operation of public water services including management of national water assets, maintenance of the system, investment, planning and management of capital projects.
The issues facing the County in terms of capacity constraints and that sufficient drainage and water supply are required to accommodate the anticipated future growth of Fingal are acknowledged. As such Council has and will continue to work closely with Irish Water to inform and influence the timely provision of infrastructure within the County in line with Fingal’s Settlement Strategy. The Draft Plan should consider this as a strategic issue to be addressed.
In respect of the control and regulation of private on site waste water treatment systems it is noted that the DOECLG published the Water Services (Amendment) Act 2012 to regulate wastewater discharges from all homes that are not connected to the public sewer network. This has the effect that all on site treatment systems must be registered on the central online registration system. The provisions of the Act should be reflected in the Draft Plan.
In respect of water supply and water quality, it is noted that there are two water treatment plants, at Leixlip and at Bog of the Ring. Output of water from the Bog of the Ring is in the region of up to 3.15 million litres daily. This plant treats extracted groundwater and supplements the water supply to the northern part of the County. At the time of adoption in respect of the current Development Plan in 2011, output from the Leixlip plant was operating at full capacity in the region of 168ML per day. The expansion to the plant was completed in the summer of 2014, bringing the overall production of water to 215ML daily
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which is approximately 30% of the Dublin Regions drinking water requirements. Irish Water published the Project Need Report in March 2015 which sets out the pressing need for a new water supply source for the Eastern and Midlands Region of the country. It is expected that the projected demand for water in Dublin alone will increase by over 50% by 2050, this far exceeds the capacity of the existing sources which currently serve the region. This report was on public display until 5th May 2015 and Irish Water indicated that following analysis and consideration of all issues raised from this consultation they will form part of the next phase of the process which will see the publication of an Options Working Paper (new supply options) Q2 2015.
Regarding the regulation and monitoring of private wells, when water supply is extracted from a private well the individual is responsible for monitoring the quality of the water. The Health Service Executive recommends that wells should be tested at least once a year for microbial contamination and every 3 years for chemical contamination.
Drainage is accommodated under the Greater Dublin Drainage Study (GDDS) which now falls within the remit of Irish Water. The Greater Dublin Drainage project is a strategic analysis of the existing and future foul and surface water systems requirement in the Greater Dublin Area. It sets out a number of major infrastructural requirements of the region including a new Regional Waste Water Plant and Orbital Sewer, and the upgrade to the existing regional plant at Ringsend Plant.
The GDD project was established in 2012 tasked with identifying the optimum location for the new Waste Water Treatment Plant (WWTP). Following detailed analysis and public consultation, a preferred option for the project was identified in 2013 comprising:
An underground orbital sewer and two pumping stations
A wastewater treatment plant on a 23 hectare site at Clonshaugh
An outfall pipe from the wastewater treatment plant discharging 6km out to sea from Baldoyle.
The GDD project had been led by Fingal on behalf of the other planning authorities in the Dublin region, and Kildare and Meath County Councils. Irish Water took over responsibility of this project from 2014.
Flooding is becoming an increasingly common issue in Ireland in general and although flooding in Fingal is relatively low there are areas which are particularly prone to flooding. The most proactive step the Council can take is the avoidance of development in floodplains and coastal areas. The Draft Plan must undergo a Strategic Flood Risk Assessment (SFRA) and this should help to ensure that zoning is not inappropriately located in floodplains.
In respect of surface water and flooding, where development is acceptable one of the key ways in managing surface water to reduce flooding potential and decrease the risk of pollution is through a design approach, known as SuDS (Sustainable Urban Drainage Systems). SuDS can best be summarised as offering a “total” solution to rainwater management while traditional drainage can be considered as only providing a “collection and disposal” approach. By using SuDS techniques, water is either infiltrated or conveyed more slowly to the drainage system and ultimately to water courses via permeable paving, swales, green roofs, rain water harvesting, detention basins, ponds and wetlands. This closely mimics natural catchment behaviour where rainfall either infiltrates through the soil or runs off slowly over the ground surface to the nearest water course, otherwise known as the treatment train approach. In assessing applications for new developments, the disposal of surface water is an integral part of the assessment.
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In respect of rain water harvesting, it is considered that such systems generally work best for commercial developments rather than residential developments given their ongoing maintenance requirements etc. The Draft Plan should reflect this by promoting the implementation of rainwater harvesting particularly in commercial developments. However, consideration of these issues for residential development should be given in the Draft Plan, and for example, encouragement of the use of water butts may provide a more adaptable approach for domestic properties.
The EU Water Framework Directive together with the Eastern River Basin Management Plan outlines a programme of measures that will facilitate the delivery of surface and groundwater quality targets in the County. A new three tier governance structure has been established under the European Union (Water Policy) Regulations 2014 reassigning functional responsibility for the Water Framework Directive (WFD). In July 2014, revisions to Ireland’s on-going implementation of the WFD were announced by Government. A consultation document setting out revised governance arrangements was published for the development of the 2nd cycle of River Basin Management Plans which will be adopted in 2017 and will run until 2021. This document stated that the Eastern, South Eastern, South Western, Western and Shannon River Basin Districts will be merged to form one national River Basin District. In June 2015 the DECLG initiated a second round of public consultation in respect of the development of the 2nd cycle of River Basin Management Plans. A consultation document entitled Significant Water Management Issues in Ireland (SWMI) is now available at www. environ.ie Submissions on the consultation document are invited up to December 2015.
The Council is responsible for the management of surface water at a local level and the Office of Public Works (OPW) has the responsibility of flood risk management at a strategic level. The OPW began a national programme of river catchment based Flood Risk Assessment and Management with the Eastern Catchment Flood Risk Assessment and Management (ECRFAM) Study which commenced in June 2011. This study will review the areas previously examined under FEMFRAMS such as the Turvey River and Ballyboghil River and the Tolka Flood Study. As of June 2015, the OPW have produced draft flood maps for the Areas of Further Assessment in the Eastern District. The draft flood maps show areas that are potentially at risk of flooding under a range of different scenarios, e.g. following periods of heavy rainfall or during times of high tide or time when wave overtopping may occur. The Study and draft flood maps should be used to inform the Draft Plan.
Movement Under Movement, issues surrounding public transport, roads, parking, walking/cycling, air transport and harbours are considered in turn.
Public Transport
Having regard to Fingal’s location in proximity to the City Centre, the County has an abundance of public transport service providers yet the reliance on the private car remains high. From a number of submissions received this is a concern that the Draft Plan needs to put an emphasis on a modal shift to more sustainable options.
The National Transport Authority (NTA) states that in preparing the Draft Plan, the Council be cognisant of the transport proposals, emanating from the NTA Strategy and in particular the Draft Plan should clearly state that any significant future employment developments in the vicinity of strategic road network will be dependent of the ability to provide an appropriate level of non-car based transport options. These strategic public transport options will be outlined in the draft NTA Transport Strategy.
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Submissions received overwhelmingly indicate that there are many gaps in the services being offered to the users and there is a need for a fully integrated public transport service. Better links are required serving the large towns and the city centre. Internally within the County movement by public transport is difficult in some locations and better local services are required. It is recognised that the rural areas are deficient in accessible public transport.
It was suggested that there should be better coordination between bus and train lines as examples provided suggest that at some stations, the bus pulls off just as the train is arriving into the station. A number of submissions note the need for shuttle buses to be provided to and from rail links to improve their connectivity. The importance of Mobility Management Plans for employees working within business parks need to be recognised as it appears to be a difficult issue for employers getting people to and from work with relative ease, especially those that are working outside the ‘core’ hours.
Better use of the existing Quality Bus Corridors (QBC’s) should be assessed. A strong emphasis was placed on the need to extend the Real Time Passenger Information (RTPI) to other areas of the County.
Consideration should be given to age friendly and accessible public transport.
It is recognised that higher densities should be promoted along transport corridors however a number of submissions suggest that a phased approach should be adopted in respect of the provision of higher densities in advance of the delivery of infrastructure.
The lack of certainty regarding what type of high capacity public transport will be provided to connect Swords with Dublin Airport and the City Centre is key to the future development of Swords. While BRT has a moderately positive acceptance it is clear that a light rail / Metro North is ultimately the preferred option of new public transport that should be provided. The submission received from the Dublin Airport Authority (DAA) notes their support for the current study on public transport options being assessed for North Dublin by the NTA.
The coastal towns are very well served by the northern train line. Suggestions were made for improvements to the service, like the addition of another set of tracks and an extension of the DART out to Balbriggan.
The frequency of trains especially on the Maynooth line together with issues regarding unmanned stations and length of time level crossings are closed are all considered factors that need to be addressed in order to provide a more streamlined service. Suggestions were made for better public transport links to Beaumont Hospital from Swords are required.
Roads
Fingal has an extensive road network with motorways passing through the County down to local level roads, including the M50, M1, M2 and M/N3. These roads consist of the most heavily trafficked roads in the Country. It is noted from the National Roads Authority that the M50 experiences in excess of 130,000 vehicles per day. The Draft Plan should ensure the protection of the strategic road network and outline how development takes place in and around important roads so that their integrity is not undermined. The submission received from the National Roads Authority suggests that it is of particular importance that policies and objectives in the next Development Plan are drafted which allow the network of national roads to continue to play the intended strategic role in catering for inter urban and inter regional transport requirements that will serve Irelands return to economic competitiveness by providing faster, more efficient and safer access to and from our major ports, airports, cities and large towns. Inappropriate planning can lead to the premature obsolescence of the national road network in contravention of the official policy objectives as outlined in
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Spatial Planning and National Roads Guidelines for Planning Authorities (DoECLG, 2012) and the objectives of the National Spatial Strategy. It is requested that the development objectives that maybe included in the Draft Plan would reflect the provisions of the DoECLG’s above mentioned document.
In 2012 the NRA convened a steering group with a view to undertaking a study to identify a scheme of indicative Demand Management Measures for the M50. The M50 Demand Management Report proposed traffic control measures and fiscal measures. In order to maintain the M50’s regional function, it is recommended that measures set out in the M50 Demand Management study, published in April 2014 by the four relevant local authorities and the NRA should be implemented. In the absence of the introduction of demand management, it is forecast that by 2023 nearly 40% of sections of the M50 will experience traffic flows in the busiest lanes that exceed the safe operating capacity, primarily during peak times but also at other times of the day/week. In February 2015, the NRA estimated that total cost of congestion on the M50 and its junctions currently results in a loss of between €48 and €65 million to the economy per annum due to the increased travel times at peak periods. Therefore there is a critical need to manage the road space on the M50 and to protect the capacity provided by the M50 Motorway Upgrade Scheme.
Suggestions were made in a number of submissions that the Council and Dublin City Council should work closer together on roads shared along their respective boundary.
There are a significant number of roads within the County that are in need of repair and upgrading. A number of potentially dangerous roads have been highlighted through the submissions with suggestions of ways to improve their safety such as the installation of traffic lights, reduction of speed limits and the placing of roundabouts at certain junctions. The issue of traffic within residential areas was also raised.
Arising from a number of submissions is a clear issue in relation to traffic management within a number of towns and the associated bottle necks that result on a daily basis. Many examples of such instances have been provided and it appears to be an issue that is county wide. Some recommendations on how to overcome such issues include making certain streets within towns one way e.g. Main Street Balbriggan.
A number of road proposals and widening / realigning of roads have also been proposed.
A number of submissions raised specific issues in relation to existing local objectives indicated in the current Development Plan for road proposals and it is requested that such objectives be revisited to ensure they remain realistic and do not limit development potential, e.g. Local Objective 496. Lands should not be developed until appropriate road infrastructure is in place.
Additional issues raised in relation to traffic appear to be rat runs through established residential areas, specifically in and around the M50 where cars seek to avoid congestion. More attention needs to be given to appropriate link roads to prevent the creation of rat runs.
Better road signage is needed in many areas.
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Parking
The need for more car parking was raised in a number of submissions, in many of the towns in Fingal and also at local amenities such as the beaches. Although conversely, it was also suggested that should car parking be limited within towns this would essentially force people to use public transport.
Suggestions were made to provide additional parking at some of the train stations such as Hansfield Train Station and the provision of more park and ride facilities throughout the County.
Issues were raised regarding the parking and set down areas at the local schools with an example provided of Scoil Choilm, Diswellstown.
More parking for tourist coaches is also required.
Car parking standards in general require reviewing and to facilitate the inclusion of fully functional Electric Vehicle (EV) charging points.
There were some suggestions for incentivised car parking in the towns, for example the Council could provide the first 2 hours free.
Walking / Cycling
Through the Draft Plan the Council needs to promote walking and cycling as a healthy way of moving around. It is clear that a lot of pedestrian and cycle paths require either upgrading or to be constructed in the first place.
Cycling is not only for recreational purposes and it is considered by a number of submissions that more intensive cycle paths need to be installed for faster travelling. In addition more dedicated cycle lanes for children cycling to school are required.
Many routes have been indicated in the submissions for the provision of linked cycle paths e.g. along the coast and between Fingal and the City Centre. It has also been suggested that playing parks should be accessible on foot, by bicycle and public transport.
It is acknowledged that better facilities are required for cyclists such a better parking / lock up facilities and also the lack of seating along the Sli na Slainte routes with reference to Malahide. In addition to cycling better pedestrian access /footpaths and the promotion of ‘walk n stride’ is also highlighted as an issue within the County. Expansion of the Sli na Slainte route was also suggested along Skerries Beach.
The provision of paths through parks should be maintained and upgraded where needed to make them safe and more accessible.
Connectivity together with permeability play a vital role in the quality and usability of cycle / walking paths for residential developments and communities in general and it is important for the Draft Plan to recognise this issue and aim to achieve paths that are continuous.
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CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - PUBLIC TRANSPORT, ROADS, PARKING, WALKING/CYCLING Public Transport
Although the Council is not a public transport provider, it has an important role to play in accommodating public transport within the County, through liaising with bodies such as the NTA and public transport service providers to identify future transport routes and ensure their reservation for future protection.
The Draft Plan should provide for an integrated approach to land use and ground transportation, aimed at securing a modal shift to more sustainable modes of transport, i.e. cycling, walking and public transport. This should include promoting land use patterns which reduce the need to travel and support public transport including, where appropriate, higher densities at public transport corridors and nodes.
The Draft Plan should prioritise public transport by safeguarding future rail and bus routes, promoting the provision and improvements of QBC’s, BRTs and bus priority measures on existing and planned road infrastructure, requiring mobility management plans for new developments both residential and commercial, implementing traffic management measures and controlling the supply of parking , where appropriate.
In particular the Draft Plan should continue to promote and facilitate the development of a high frequency light rail link connecting Swords to Dublin Airport and onto the City Centre. In addition the Draft Plan should promote and safeguard the line for the development of a high frequency light rail link connecting Blanchardstown with Dardistown and the proposed link between Swords, Dublin Airport and Dublin City Centre.
In the absence of the delivery of a new public transport service, buses still remain the major method of travel and the Council should continue to promote and facilitate the upgrades to the services, QBC’s and BRT’s.
In recent times there appears to be a significant shift in preferences in the residential market since the adoption of the existing Development Plan. Pressures are being put on local authorities to reduce densities in nearly all locations in favour of own door, own plot, houses. This creates urban sprawl and from an infrastructure investment it will become increasingly difficult to provide viable public transport to serve these lesser densely populated areas.
One of the key policies of the Draft Plan should be the integration of land use patterns with transportation seeking to ensure that lands are developed in tandem with the provision of a good public transport system to provide sustainable neighbourhoods where travel requirements are reduced. Roads
Improvements to the roads across the County in terms of upgrades, realignments, repairs, traffic management measures, traffic calming and improvements to road signage should be assessed and implemented as deemed necessary and as resources allow. The upgrade and development of the County’s national, regional and local road infrastructure should continue to be supported.
The Draft Plan should place an emphasis on demand management with particular reference to the M50 and the associated M50 Demand Management Report.
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Parking
The Draft Plan should consider the provision of park and ride facilities at appropriate locations within the County in conjunction with the NTA and relevant public transport providers.
Car parking standards in general should be reviewed and amended where necessary based on the needs of the area such as the availability of public transport.
Having regard to the importance of reducing the carbon footprint, cognisance should be given to the inclusion of dedicated fully functional Electrical Vehicle (EV) charging points through appropriate objectives within the draft Plan. Walking / Cycling
The Council should continue to promote and encourage walking and cycling as a healthy mode of transport and should endeavour to provide safe, accessible and quality cycling / walking paths. The objectives of the National Cycle Policy Framework (NCPF) (2009) and the Greater Dublin Area Cycle Network Plan should be incorporated into the Draft Plan.
The Draft Plan should continue to promote walking and cycling by the providing, upgrading and maintaining of cycleways and footpaths as resources allow; and ensure that connectivity is provided in new developments with the provision of good pedestrian and cycle network and facilities.
Design standards should ensure that new residential and commercial proposals should adequately accommodate safe and secure bicycle parking, particularly at stations and other public transport interchanges.
Air Transport: Dublin Airport Dublin Airport processed 21.7 million passengers in 2014 which represented an 8% increase in passenger numbers on the previous year. As per the submission received from the Dublin Airport Authority, It is critical that any planning policy be consistent with the draft National Aviation Policy and permits the airport to develop in accordance with the operational requirements of the industry. The new development plan must continue to support aviation growth; in this regard it must continue to support a northern parallel runway of 3775m paved length as currently outlined in the Dublin Airport Local Area Plan.
Strategic issues for the Draft Plan would include giving priority to surface access surrounding the Airport; this should include a light rail system to serve the Airport and Swords. It should also prioritise road infrastructure around the airport to facilitate other public and private transport modes in an efficient manner. The existing car park at Dublin Airport requires to be re-visited having regard to the passage of time, deferral of Metro North and changing profile of passengers, particularly for the first departure wave from 6am onwards.
The NTA notes that in particular substantial development at the airport should not proceed until it can be clearly demonstrated that it will not have a significant impact on the carrying capacity of the M1 or M50 and that any development would not impact on national accessibility to Dublin International Airport.
The submission received from the Irish Airline Pilots Association (IALPA) states that the IALPA maintain that the state owned daa should clearly refocus on passenger related activity / development. As the economy accelerates and passenger numbers increase the IALPA are concerned that the daa lacks capacity on the eastern campus to expand whilst further
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refurbishing / replacing existing 1970’s piers. IALPA concurs with the Irish Aviation Authority stating that the Dublin Airport airside infrastructure is deficient.
It is acknowledged that Fingal has a vital role in safeguarding the current and future operational, safety and technical requirements of the Airport and also facilitating its expansion.
The existing Dublin Airport Local Area Plan has been extended until June 2015 and an interim masterplan is being prepared in advance of the preparation of the new LAP. One submission requested that the current LAP be carried forward, and specifically gives reasons for the continued need for additional facilities at the Airport and in particular the development of the Western Campus.
It has been noted that consideration should be given to modern advances in aviation technology and how planes are now getting quieter, suggestions have been made for the review and consideration of the inner and outer noise zones which if contracted would essential free up strategically located greenfield land and allowing further consolidation of urban centres within the County.
Support has been indicated for both the protection and the extension of the Dublin Airport boundary.
Issues have been raised through submissions from residents of Portmarnock and local residents group such as St. Margarets Concerned Residents Group regarding the overall relationship between the communities re the development of the airport and lack of consultation.
CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - AIR TRANSPORT: DUBLIN AIRPORT Dublin Airport is the primary and most important gateway into Ireland both for business and tourism and recreational purposes. It is one of the most significant economic influences in Fingal and the Dublin Region. At the time of preparation of the current Development Plan it was noted that passenger numbers had fallen due to the global recession. However recent figures for 2014 indicate an 8% increase on the previous year. The airport supports directly and indirectly approximately 100,000 jobs in the Irish economy. The importance of ecomonic development and employment is recognised in High Technology (HT) zoning and the recently prepared Masterplan which promotes commercial office development at this location.
Given the rise in passenger numbers and the potential emergence from recession, the preparation of the Draft Plan together with a new Dublin Airport LAP will be critical to the future development of the area both in terms of infrastructure and economically. The Draft Plan should safeguard the current and future operational, safety, technical and developmental requirements of the airport. This should include the protection and enhancement of surface access to and from the Airport. Subject to this, commercial development should continue to be supported at appropriate locations.
The Draft Plan should also promote appropriate land use patterns in the vicinity of the designated flight paths serving the airport, having regard to the existing and anticipated environmental impacts of aircraft movements. This should also include the continued implementation of the Public Safety Zones for the Airport (as outlined in the draft ERM report on this issue).
The Draft Plan should continue to support and facilitate the development of the second parallel runway.
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Harbours
A number of submissions raised the issues regarding the use, maintenance and upgrade of the existing harbours throughout the County. It is also noted that a number of submissions relate to potential recreational and tourist potential at the existing harbours throughout the County. CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - HARBOURS These issues have primarily been dealt with under Economic Development, where the potential for tourism should be balanced with maintaining and promoting the operational requirements and activity in working harbours such as Howth, Balbriggan and Skerries.
Air, Noise and Light Noise issues in relation to Dublin Airport, including the suggestions that the Council should review the inner and outer airport noise zones for the proposed second runway, have been covered earlier in this Section.
Light pollution of residential properties was raised as being an issue of concern particularly where dwellings are within proximity to industrial parks.
CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - AIR, NOISE AND LIGHT The current Development Plan deals with issues concerning air, noise and light, and these should be brought forward into the Draft Plan taking account of the matters raised above as appropriate, in order to protect the residential amenities of the County.
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7. ECONOMIC DEVELOPMENT Strategic Context The strategic context for the economic development section of the Draft Plan is determined at national, regional and local levels by a diverse range of economic, enterprise and planning frameworks. A number of these influencing key frameworks are outlined below.
Investing for Growth and Jobs – Infrastructure Investment Priorities 2010- 2016 and Infrastructure and Capital Investment 2012-2016 Medium Term Exchequer Framework
At national level, key funding programmes arising from the National Development Plan 2007- 2013 are Investing for Growth and Jobs – Infrastructure Investment Priorities 2010-2016 and Infrastructure and Capital Investment 2012-2016 Medium Term Exchequer Framework. These programmes set out the Government’s funding priorities for these years and commitments are given for continued improvements to the road and public transport networks, developments in energy and communications infrastructure, capital supports to the commercial and enterprise sectors, expanding the country’s tourism offer, and investment in educational and health facilities. The funding allocations for these core sectors will contribute to the continued economic recovery that is increasingly apparent.
Action Plan for Jobs, 2015
Other relevant national frameworks include those relating to employment creation, the tourism sector, and enterprise development. In relation to the former, the Government’s most recent Action Plan for Jobs, 2015 identifies five strategic ambitions including creating an additional 100,000 jobs by 2016, increasing competiveness, stimulating the domestic economy, building up indigenous growth in the exports market, and creating enterprise and business clusters of opportunity. A “Regional Action Plan for Jobs” is due to be published this autumn in respect of the Dublin Region. The Grow Dublin Task Force, established by the Minister will also be finalised this year, which will set out a strategy for Tourism for the Dublin Region. Fingal exhibits a number of key strengths in these areas, for instance in the strength of the county’s agri-food industry, the potential for aviation-related clustering in Swords/ Dublin Airport and pharmaceutical/ biopharma enterprise clustering in the Dublin 15 area.
Pathways to Work, 2015
An associated programme is the Government’s most recent Pathways to Work, 2015, within which the continuing challenge of unemployment for younger adults is identified as a significant issue that the Government will target through supports and funding measures. The Government identifies a number of measures including increased training, skills and educational opportunities and for maximum effectiveness the programme should operate in conjunction with the funding and measures identified in theAction Plan for Jobs, 2015.
People, Place and Policy: Growing Tourism to 2025, 2015
In relation to the tourism sector, in March 2015 the Government published People, Place and Policy: Growing Tourism to 2025. This national framework on the tourism sector specifically identifies the key role for local authorities in the development of the tourism industry of their areas (such as the funding, organisation and promotion of events, protecting their natural and built heritage, and the provision of supporting tourist facilities and infrastructure),
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and the contribution that communities make to the local tourism offer in their areas. The national framework highlights that tourism is a key area in which local authorities can promote economic development in conjunction with community efforts.
Energising Ireland’s Rural Economy, 2014
The economic benefits that can be associated with the tourism industry for rural locations in the country are a key component of Energising Ireland’s Rural Economy prepared by the Commission for the Economic Development of Rural Areas (CEDRA) for the Government in 2014. This framework highlights that national economic recovery is dependent on all sectors of the economy in all parts of Ireland performing and contributing. In addition to the tourism sector, the framework outlines recommendations in relation to governance of rural economic development, coordination of efforts at regional and local level, local enterprise support, mobilising community capacity, infrastructural improvements to roads, transport, water services, energy, and broadband, specific sector development of the food and drinks industry, and creative industries such as crafts, film industry and the arts.
Putting People First Action Programme for Effective Local Government, 2012
In relation to Government policy influencing the local enterprise environment, the new structures and enhanced powers for economic matters envisaged for local government in Putting People First Action Programme for Effective Local Government (2012) and policy frameworks such as Local Government Sectoral Strategy to Promote Employment and Support Local Enterprise 2012 are coming to fruition in Fingal. In addition to the establishment of the Economic and Enterprise Strategic Policy Committee (SPC) and the Local Enterprise Office (LEO) in the Council, the establishment of the Local Community Development Committee (LCDC) that is joint-preparing the Local Economic and Community Plan (LECP) for Fingal, which is anticipated to be completed in the third quarter of 2015.
National Spatial Strategy 2002-2020 (NSS) and the Regional Planning Guidelines for the Greater Dublin Area 2010-2022
Guidance on spatial development and establishing hierarchies of scale of development on a locational basis are the National Spatial Strategy 2002-2020 (NSS) and the Regional Planning Guidelines for the Greater Dublin Area 2010-2022 (RPGs). Both frameworks are due to be revised, and should updated versions become available within the plan-preparation period, these frameworks will likely be replaced with new versions (National Planning Framework (NPF) and the Regional Spatial and Economic Strategy (RSES).
The RPGs vision in relation to economic development seeks to develop Dublin Gateway as an international driver of enterprise within the GDA to be supported by regionally designated strategic employment centres that serve the urban and rural hinterlands. These strategic employment centres will be promoted to facilitate new employment opportunities as appropriate. The settlement hierarchy for Fingal includes lands to the south of the County adjacent to the north of Dublin City within the Gateway Core, identifies Swords and Blanchardstown as Metropolitan Consolidation towns, and classifies Balbriggan as a Large Growth Town II and Donabate, Lusk and Rush as Moderate Sustainable Growth Towns. Planning authorities are required to have regard to the strategic policies and the settlement hierarchies identified in the NSS and the RPGs in their Development Plans.
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Guidelines for Planning Authorities: Retail Planning, 2012
A major component of the economic development of the County is its retail sector. Retail planning policy for the Draft Plan is required to accord with retail guidance documents existing at the national and regional levels. Respectively, these include Guidelines for Planning Authorities: Retail Planning and an accompanying Retail Design Manual were published by the DOECLG in April 2012; and the Retail Strategy for the Greater Dublin Area, 2008-2016 published in 2008 on behalf of the Dublin and Mid East Regional Authorities.
The Retail Planning Guidelines require that the County Retail Strategy in the Draft Plan includes guidance on the location, quantum and type of retail provision across the urban centres in Fingal. This retail hierarchy is required to appropriately accord with the settlement hierarchies identified for Fingal in the NSS and RPGs.
The Guidelines have five policy objectives that form the basis for guidance to planning authorities on how planning can support retailing as an important part of the country’s economy, the type of retailing objectives to include in their statutory plans and how planning applications for retail developments should be assessed. These objectives include: ensuring retail development is plan-led; use of the sequential approach to retail development to promote town centre vitality; securing competitiveness in the retailing sector through quality designed and suitably located projects; increasing access to retailing opportunities through more sustainable forms of transport than the private car; and delivering quality urban design outcomes.
Retail Strategy for the Greater Dublin Area, 2008-2016
The Retail Strategy for the GDA performs two important roles for devising and determining retail planning policy for the Draft Plan. The Retail Strategy provides projected floorspace totals for each of the seven planning authorities, including Fingal, for convenience and comparison retailing up until 2016. Additionally, the Retail Strategy also defines the retail hierarchy within the GDA, including Fingal, with locations identified and recommendations made on the appropriate type and scale of retail provision at these various locations. In similarity with the NSS and RPGs, the Retail Strategy needs for the GDA needs to be updated. However, pending this, the current Strategy remains applicable for the preparation of the Draft Plan.
Local Economic and Community Plan for Fingal
Arising from the national policy context outlined above, are some key local frameworks that exist at the local level. First of these is Fingal’s Local Economic and Community Plan (LECP). The LECP is being prepared by consultants on behalf of the LCDC, the Economic Department and the Economic and Enterprise SPC of the Council, and it is anticipated to be completed in the third quarter of 2015. The DOEHLG issued Guidelines on Local Economic and Community Plans, 2015 state that the LECP shall for a six-year period, identify the objectives and actions needed to promote and support the economic development and the local and community development of the relevant local authority area, both by itself directly and in partnership with other economic and community development stakeholders.
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Fingal Tourism Strategy 2015-2018
Another important local framework is the Fingal Tourism Strategy 2015-2018, which the Council adopted in May 2015. The Strategy is a detailed framework identifying Fingal’s key strengths, defining a vision for the tourism industry in Fingal and its role in a regional context, and measures for translating strategy into deliverables. It has been informed by the Grow Dublin Task Force. Local Authority Retail Support: Improving Our Cities and Towns, 2015 The Local Authority Retail Support: Improving Our Cities and Towns, 2015 was prepared in June 2015 by the City and County Managers Association (CCMA) and the Association of Irish Local Government (AILG). This framework outlines ways in which local authorities can support the retail sector in its area and investigates measures to improve business conditions, create a welcoming environment and improve the public realm, enhance the retailing experience and improve safety and viability. SUMMARY OF ISSUES RAISED Submissions Received During the Consultation Process
P00001, P00005, P00006, P00009, P00011, P00013, P00015, P00023, P00026, P00031, P00034, P00037, P00038, P00039, P00044, P00048, P00061, P00067, P00072, P00077, P00079, P00083, P00084, P00088, P00093, P00104, P00106, P00110, P00117, P00121, P00123, P00127, P00133, P00135, P00137, P00142, P00147, P00148, P00150, P00151, P00157, P00158, P00161, P00162, P00164, P00166, P00171, P00172, P00173, P00174, P00181, P00183, P00185, P00187, P00189, P00191, P00192, P00194, P00198, P00199, P00206, P00212, P00217, P00218, P00219, P00224, P00225, P00230, P00231, P00233, P00252, P00256, P00266, P00267, P00268, P00270, P00278, P00282, P00287, P00289, P00290, P00299, P00318, P00322, P00324, P00325. Location of Employment
A significant number of the submissions received in relation to the economic development of the County refer to the issue of location of employment. These submissions can be grouped into comments regarding the general appropriateness of locations for such uses, and then more specific comments on locations, in particular Dublin Airport, lands to the south of Dublin Airport (Southern Fringe and Dardistown areas), Metro Economic Corridor (ME) zoned lands located proximate to Swords and Santry Demesne, Blanchardstown and Balbriggan.
In relation to general comments on optimum locations for future employment, many of the submissions highlight the importance of siting employment creating uses in locations that maximise existing and planned infrastructure such as adjacent to Dublin Airport, at rail and other public transport connection points, as well as in proximity to strategic road networks such as the M1. Additionally, the opportunity to create and enhance economic clusters should be achieved through directing additional employment lands around existing business activities which feature strongly in Fingal such as horticulture, distribution, and logistics. Other submissions recommend that consideration should be given to locating high quality employment uses adjacent to residential development due to the benefits associated with shorter distances to travel to work.
In relation to Dublin Airport, a number of submissions refer to its importance as a location of employment based on its operational and functional uses as an airport, and other
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submissions refer to its employment generating potential associated with commercial uses such as offices and hotels. In particular, the DAA submission seeks recognition in the Draft Plan of Dublin Airport as being the key economic driver and highlights the potential to broaden the employment base associated with the airport. However, some submissions are critical of the planned commercial development at or adjacent to the airport and state that the focus of development at and around Dublin Airport should be on the functional activities of the airport and growing numbers of passengers, and that there are infrastructural deficits at the airport that will be worsened by other commercial development. Submissions also highlight the requirement for a new LAP for Dublin Airport and comment on issues that should be considered in a new LAP or in the Draft Plan such as the extent of the development boundaries of any such LAP or (Dublin Airport) DA zoned lands, the road network serving and surrounding the airport lands, the arrangement and provision of the runways and terminal facilities, and consideration of the uses within the lands.
A number of submissions are made in relation to lands generally to the south of the airport, principally the South Fringe and Dardistown areas. The South Fringe is identified as a key location driving Fingal’s economic growth and efforts should be made to ensure it does not stagnate. A submission identifies it as an ideal location for FDI companies, and states that there is market demand for smaller units in medium size plots and that a ‘Metropolitan Business Park’ should be developed. Similarly, another submission identifies the area north of the R139/ N32 as suitable for high value, hi-technology businesses at the Fingal Manufacturing and Industrial Park. Another submission states that employment lands south of the airport, proximate to the M1/N2/M50 corridor, should be consolidated. A submission requests that consideration be given to the Green Belt (GB) zoned lands south of the airport being zoned for employment uses such as General Employment (GE) and Warehouse and Distribution (WD) land uses. In relation to the Dardistown area, a submission requests continued support for employment uses in lands to the south of the airport as currently exist in the Development Plan.
A number of submissions refer to the Metro Economic Corridor (ME) zoned lands located at Swords and Santry Demesne. Due to the uncertainty surrounding the ME zoning, one submission requests that the ME corridor vision remains intact in the Draft Plan as the lands located at Santry Demesne continue to be an appropriate location for new employment, residential and leisure opportunities in close proximity to transportation hubs. Another submission also refers to the ME zoning and the appropriateness of this zoning objective as the Metro North has been deferred, and that an amended zoning be considered allowing for the release of strategic ME lands for development in the short time. A zoning that removes the requirement for the preparation of LAPs should also be considered on such strategic employment lands.
Some of the submissions raise more specific locational issues and recommendations to be considered in the Draft Plan.
Business Promotion
Submissions relating to business promotion typically focus on highlighting and promoting Fingal’s unique strengths and advantages. A number of submissions refer to the location of Dublin Airport and the good road network within Fingal, including the M1, M50 and N3, and that these strengths should be used in promoting Fingal as an excellent business location for FDI and indigenous small and medium enterprise (SME) investment. However, a number of submissions were critical of the Council’s focus on FDI and stated that more focus should be on indigenous SME’s. In particular, major towns of Balbriggan and Blanchardstown are identified as being promotable as business locations. A submission also requested that an enterprise officer be specifically employed for Balbriggan with a key responsibility for promoting the town.
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A submission refers to the successful promotion of Dublin 15 with major national and multinational employers having a presence there, and requests that the Council continue with this promotional strategy that targets high quality, high skilled jobs, achieved through appropriate High Technology (HT) zoning and developing links with IT Blanchardstown, and utilising all available national upskilling and training schemes.
A submission recommended that Fingal should be developed and promoted as a centre for the clean technology industry; other submissions refer to opportunities in medical research, the solar market, and the ‘purple flag’ concept (excellence in night-life events). Some submissions called for IDA supported initiatives associated with the Council and/ or with Fingal Chamber of Commerce to promote local towns as locations for business opportunities, as an industrial and/ or enterprise hub. A number of submissions also identify the food industry as a major and distinctive strength, and recommend that the sector should be used to develop a distinct ‘Fingal’ identity. Another submission highlighted the importance of forging better links with business communities in locations in Northern Ireland such as Newry, Portadown and Armagh.
There is a degree of overlap between business promotion and other submissions related to tourism and rural economy that highlight the promotion of tourism and rural related businesses and activities, which are outlined in the Tourism and Rural Economy sections below. Retail
A number of the submissions received in relation to the economic development of the county relate to the retailing sector. The submissions can be grouped into certain themes: criticisms of the current situation in Fingal’s towns and villages and of the existing retailing provision, identification of measures to address the problems and make improvements, and finally specific and detailed submissions from many of the main retailers on the retailing policy for the Draft Plan.
Criticisms made in the submissions relate to the increasing number of fast food outlets and betting offices, to the vacancy rates in a number of towns, and to the negative impact caused on the main streets of towns by ‘out-of-town’ and ‘edge-of-town’ retailing developments. Measures identified to address these perceived problems include refusing planning permission for certain forms of retailing (principally fast food outlets and betting offices), encouraging a greater diversity of businesses in the county’s towns, strengthen the main shopping streets, establish the vitality and viability of the towns and villages and devise appropriate actions, only permit retail developments that are appropriate to the size and population of that town or village, undertake public realm improvements to the main streets, do not permit out-of-town retail developments, do not permit 24 hour retail operations, take a new approach to the operation of local centres allowing a greater mix of uses such as community and cultural uses, and address vacancy rates through incentives such as the Council acting as a landlord, rent controls and reduced rates. A number of the negative issues outlined above and relevant measures to address same were made in relation to Balbriggan, Swords, Lusk, Donabate, Rush, Howth, Sutton, Ongar and Castleknock.
A number of detailed submissions have been made by main retailers which have identified issues such as: locations in the county where there may be under provision of certain types of retailing, requests for definitions of retailing formats to be included in the County Retail Strategy of the Draft Plan such as discount store and membership warehouse club, recognition of the operational requirements of modern retailers, consideration of certain car parking standards for convenience stores, and requests for flexible policies in relation to design, layout, formats and signage. Some submissions identify more specific
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considerations including the expansion of the town centre zonings in Blanchardstown and Swords in anticipation of growing populations over the Draft Plan period, the designation of Lusk as a Level 3 retail centre, the length of time to complete Local Area Plans (LAPs) and consequent issues relating to prematurity, continued recognition in the Draft Plan of the importance of Swords Pavilions Centre in the retail hierarchy of the County, and a review of retail related use classes (eg. retail warehousing and stores less than/ equal to 2,500 sqm) in certain land use zonings in the Draft Plan. Regeneration
A number of submissions have been made on the topic of regeneration. References are made to the vacancy and dereliction of properties within the County’s towns and villages, with Rush, Swords and Mulhuddart being highlighted. Recommendations for the regeneration of outdated local centres, commercial and employment areas are also made, the latter with reference to Howth and Sutton. A number of submissions requested that innovative methods be found to reuse vacant buildings such as for community uses, or pop- up shops. The content of some of these submissions overlap, to a certain extent, with the issue of vitality and viability of the County’s towns and villages that are referred to above in relation to the retailing sector. Rural Economy
A number of submissions relate to the rural economy in Fingal. These can be grouped into those seeking to strengthen and support the existing rural economy, add new forms of rural developments, identify opportunities for diversification, and to review the current zonings and use classes relating to the rural economy. In relation to the existing rural economy, some submissions request strengthening and supporting the horticultural industry, with Rush being highlighted. One submission from a horticultural operator raises the operational issues associated with the marked shortage of appropriate temporary accommodation to house seasonal workers and requests that the issue be addressed in the Draft Plan.
A number of submissions identify potential opportunities for new forms of rural economic activity including enhancing the natural heritage of rural areas and restoration projects of the county’s built heritage thereby creating employment, providing small scale IT related hubs in the greenbelt around Swords, opportunities associated with wind energy, the biomass industry, micro-breweries and cider makers, and the new concept of ‘rural tourism’ which is described as an extension to the agri-tourism offer that exists presently in the current Development Plan.
Additionally, a number of the submissions seek reviews of rural zonings and the use classes permitted within these. For instance, a submission requests review of Rural Business (RB) and Rural (RU) zonings in Rush, another seeks clarification on the westerly expansion of Swords in the Draft Plan towards lands being used for horticultural purposes. A submission requests a review of the RB zoning and associated uses classes, while another requests the broadening of the FP zoning and the use classes permitted thereafter.
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Tourism
Many of the submissions highlight the important link between the tourist industry and economic activity, stating that the local economy of many towns, villages, and rural areas depend on harnessing opportunities associated with the available tourism spend. A number of the submissions request that the tourist industry and offer in Fingal be strengthened and further developed because of the economic benefits that could arise. The benefits of improving the tourism offer to visitors, Fingal citizens, and the Council are highlighted, for instance in relation to economic generation, social and community benefits and increased rates.
The submissions can be organised into a number of groups as follows: identifying Fingal’s assets; highlighting activities to be developed; facilities that are required; and measures or actions to be undertaken to improve the tourist offer. In relation to the former, the assets and strengths identified in Fingal include the county’s natural surroundings, high quality landscapes, heritage sites, heritage towns, coastal routes, beaches, coastal cliffs, regional parks, proximity to Dublin Airport and Dublin City, the food industry, and historical richness such as ‘black tourism’ i.e. tourist offer associated with the risings in 1798 and 1916.
In relation to activities that may attract tourists, a number of submissions highlight that opportunities for water sports, wind surfing, sailing, cycling, fishing, canoeing, and golf should be supported and encouraged. In relation to facilities associated with tourism, submissions request increased numbers of facilities such as tourist information offices, hotels, heritage museums, picnic areas, public toilets in villages and beaches, craft markets, country and farmers’ markets, local workshops and display areas for craft workers.
Some submissions identify specific measures that could be undertaken to assist the tourist offer in Fingal including public realm improvements in the country’s towns and villages, renovate historic buildings, provide better signage, create new events, promotion of events and historical sites, providing historic information and information on local attractions and amenities, recommendations on places to eat and take leisure, develop a plan to encourage tourism into the county, improve accessibility to the county’s beaches and seafront, provide marinas and viewing points, creating connections to and between historic buildings, parks, playgrounds, beaches, harbours, walking and cycling paths. Submissions request such measures to be undertaken in towns and villages such as Balbriggan, Skerries, Rush, Lusk, Howth, Liffey Valley/ Dublin 15 area, Castleknock, and Mulhuddart.
Some submissions raised more specific issues relating to, for instance, harnessing the tourism potential associated with the ‘new Irish’ (immigrants that are Irish citizens who have settled in Fingal and who have quality contacts and networks in their home countries that may travel to Fingal); requesting that the agri-tourism use class be permitted under Food Park land use zoning; and that an Integrated Tourism and Leisure land use zoning is required.
Other
A number of submissions highlight the connection between a well-educated workforce and economic development, and recommend strengthening the links in Fingal between industry and higher educational institutions. Reference is made to the potential creation of a technological university in the County through the merger of IT Blanchardstown, IT Tallaght and Dublin Institute of Technology, which should be supported.
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A number of submissions highlight the importance of high speed broadband connections in both urban and rural locations in Fingal, as this would facilitate small businesses allowing them to compete in a modern economy.
A submission recommends that strategically located employment zoned lands should be protected from non-conforming uses to not detract from the development potential of employment lands proximate to the M50, and an example of those in the Dardistown area is given.
A submission refers to the Warehouse and Distribution (WD) zoning stating that the use classes are too restrictive and that in the Draft Plan the zoning should be widened to allow light manufacturing, general enterprise and employment creating uses.
A submission requests that GE zoning and permissible use classes in an Industrial Estate be reviewed having regard to the range of activities that currently operate therein.
A submission requests that consideration be given to reviewing the current amenity zoning at the Total Fitness site which has a permitted commercial history and where the surrounding area has undergone significant change making the continued zoning inappropriate.
A submission states that the commercial centres of towns at the Coast and Clongriffin have failed to develop and that there should be more integration between Fingal County Council and Dublin City Council to connect these areas thereby creating a well-connected commercial zone in the Southern Fringe area of the County.
A submission highlights that the local economy and local enterprise roles of local authorities such as Fingal need to integrate with a transition to a low carbon economy and opportunities in the green economy.
A submission refers to the existing text in Chapter 2 and Chapter 8 of the current Development Plan and recommendations are made to make text changes to and add policies and objectives as appropriate.
CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - ECONONMIC DEVELOPMENT Location of Employment
The range of issues raised in submissions on location of employment is noted and many require further consideration in the preparation of the Draft Plan. In devising policies and objectives in relation to the location of employment uses, focus should be placed on locating complimentary uses adjacent to each other such as quality employment and residential developments. Similarly, locating employment intensive land use zonings proximate to high capacity public transport networks should also be promoted. In determining the location of employment uses, consideration should be given ensuring appropriate forms of employment uses in accordance with the Settlement Strategy for the County and to the use of various sizes of land parcels for commercial, office, industrial uses in order to cater for a wide range of employment and enterprise formats.
There should be a strong focus in the economic section of the Draft Plan on harnessing, promoting and maximising the strengths and distinctive assets that Fingal has, such as
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its location in the Dublin Region, excellent access to the national road network and port, the well-connected and serviced major urban centres of Swords and Blanchardstown, key employment locations such as Dublin Airport and Dublin 15, and regionally strategic economic generators of the Metro North (or equivalent high capacity public transport route) and Dublin–Belfast Economic Corridors.
Specifically in relation to Dublin Airport the Draft Plan should support development of the Airport, and ensure a balance should be achieved between harnessing the unique potential of Dublin Airport as an economic generator and major employer in the County and protecting its core operational function as the country’s main international airport.
In relation to submissions that seek changes to zonings and/ or use classes, a review of all zonings and use classes should be undertaken as part of the preparation of the Draft Plan process. Business Promotion
The issues raised in the submissions in relation to business promotion are noted, and a degree of overlap with tourism and rural economy submissions in relation to business promotion in those sectors is also highlighted. In preparing the Draft Plan and appropriately addressing the issue of business promotion in the County, engagement should take place with the LEO, the Economic Development Section and other relevant stakeholders of Fingal. Additionally, through such engagement the policies and objectives in the Draft Plan should support the objectives, measures and actions included in the Fingal LECP, where appropriate. Additionally, submissions that raised the importance of IDA collaboration are concurred within and policies that seek opportunities for investment in and development of FDI and indigenous enterprises at appropriate locations in the County should be considered. Retail
The issues raised in the submissions relating to retailing have been noted, with many of them requiring further consideration in the preparation of the Draft Fingal Retail Strategy of the Draft Plan. As outlined in the Strategic Context above, there are number of planning guidance documents and frameworks that Fingal is required to have regard to in the preparation of its Draft Retail Strategy. In this regard, policies relating to the type, quantum and locations of new retail developments are required to be consistent with the requirements and recommendations of the relevant regional policy frameworks and national planning guidelines. For instance, the Retail Hierarchy that should be identified in the Draft Fingal Retail Strategy is required to align with the Settlement Hierarchy for the County and to be included in the Draft Plan. As such, decisions regarding the quantum and format of retail development in urban and rural located centres should to be in accordance with the Settlement Hierarchy.
Additionally, a number of the issues raised in the submissions, such as the vitality and viability of towns and undertaking public realm improvements, are included as measures and actions identified in the Local Authority Retail Support: Improving our Cities and Towns, June 2015 and policies and objectives in the Draft Plan should support the relevant measures identified in that framework.
Having regard to submissions received, the Draft Plan should consider the issues and potential impact as a result of proliferation of particular uses within town centres.
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Regeneration
The concerns regarding areas in need of renewal and regeneration are noted and policies should be developed in the Draft Plan to address this challenge. Measures and powers available to the Council should be explored to encourage and promote the regeneration of areas in need of renewal, for instance in underperforming or outdated commercial and/ or industrial areas. Rural Economy
The issues raised in the submissions relating to the rural economy have been noted, many of which should be explored in the Draft Plan. For Fingal’s rural economy, a balance is required to be reached that seeks to protect the landscape and natural heritage of rural Fingal while also promoting economic opportunities associated with rural life such as agricultural, horticultural and rural-related economic uses.
In relation to submissions that seek reviews of the rural related zonings and the use classes permitted therein, a review of all zonings and use classes should be undertaken as part of the preparation of the Draft Plan process. Tourism
The issues raised in the submissions in relation to tourism have been noted and many are very informative and insightful. The strong contribution that tourism can make to the local economy of Fingal is accepted and a vision should be developed in the Draft Plan to reflect this potential. Additionally, the Fingal Tourism Strategy 2015-2018 includes a number of actions and measures that could be useful in addressing the issues raised in the submissions. Therefore, policies and objectives in the Draft Plan should seek to facilitate and promote the development of tourism in the County and ensure that the policies, objectives and measures identified in theFingal Tourism Strategy 2015-2018 are aligned with and supported by policies and objectives in the Draft Plan, where appropriate. Other
In relation to the submissions highlighting the connection between education and economic development, these are noted and the Draft Plan should recognise the strong link between a well-educated workforce and economic prosperity and support continued educational investment in the county.
In relation to the requirement for high speed broadband, the Council should liaise and engage with all relevant public service providers to ensure that zoned lands are serviced in a timely fashion to facilitate opportunities for employment and enterprise creation.
In relation to submissions that seek changes to zonings, use classes, and wording of text included in the current Development Plan, a review of all zonings use classes and text should be undertaken as part of the preparation of the Draft Plan process.
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8. GREEN INFRASTRUCTURE STRATEGIC CONTEXT International Conventions and Agreements
Ireland has signed and ratified a number of international conventions and agreements in relation to biodiversity including the Convention on Biological Diversity (CBD), the Convention on the Conservation of European Wildlife and Natural Habitats (Bern), the Convention on the Conservation of Migratory Species of Wild Animals (Bonn) and the Convention on Wetlands of International Importance (Ramsar). These are implemented through both European and national legislation including the Birds and Habitats Directives and the Wildlife Acts 1976- 2000. Ireland has also signed and ratified the European Landscape Convention (ELC).
National Spatial Strategy 2002-2020 (NSS)
The NSS aims to ensure that all parts of the country will in future be able to sustain a better quality of life for people, a strong competitive economy and an environment of the highest quality. The conservation and management of our heritage plays a key role in achieving these objectives and is a benchmark for the achievement of sustainability.
National Biodiversity Plan 2011-2016
The National Biodiversity Plan (NBP) sets out the Government’s strategy in relation to the conservation and management of biodiversity. The NBP underlines the need to conserve biodiversity in light of its ongoing world-wide decline. It emphasizes the need to integrate biodiversity conservation measures into all sectorial policies. In so doing it requires all local authorities to prepare and implement a Local Biodiversity Action Plan.
National Landscape Strategy 2015-2025
The National Landscape Strategy provides a framework for the protection of the many cultural, social, economic and environmental values embedded in the landscape. The objectives of this Strategy are to establish and implement through a series of actions, policies aimed at understanding, protecting, managing and planning our landscape. It sets out specific measures to integrate and embed landscape considerations in all sectors which influence the landscape and improve and enhance the quality of decision-making by those who have an impact on it. The Government will work in co-operation with public authorities, stakeholders, communities and individuals to implement it.
Regional Planning Guidelines 2010-2022
The Regional Planning Guidelines for the Greater Dublin Area recognise the importance of protecting and managing our natural heritage including biodiversity, geological heritage and landscape and call on local authorities to include policies and objectives to address these issues comprehensively in their development plans.
Fingal Heritage Plan 2011-2017
The Fingal Heritage Plan was adopted by the Council in April 2012. It sets out 49 actions to be undertaken to care for and manage Fingal’s heritage in the period up to 2017.
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Fingal Biodiversity Plan 2010-2015
The Fingal Biodiversity Action Plan includes 100 actions to protect and enhance the key nature conservation areas in Fingal. The Plan focuses on the development of an ecological network that includes the international and nationally designated nature conservation sites and their buffer zones, nature development areas and ecological corridors.
SUMMARY OF ISSUES RAISED Submissions Received During the Consultation Process
P00034, P00048, P00083, P00093, P00110, P00121, P00131, P00133, P00137, P00147, P00148, P00155, P00164, P00169, P00174, P00187, P00192, P00195, P00197, P00198, P00218, P00235, P00245
Many submissions strongly support the Council’s green infrastructure policy approach including its focus on the five themes of biodiversity; parks, open space and recreation; landscape; sustainable water management; and archaeological and architectural heritage. A number of submissions sought a further strengthening of the policies in relation to green infrastructure and emphasise the need for the development management process to deliver a range of green infrastructure benefits. The link between public health and green infrastructure was raised, with a particular focus on the provision of walking and cycling infrastructure, including along waterways. One submission called for a “Healthy Fingal” to be a central goal of the Draft Plan and another called for the development of a food forest. The importance of green infrastructure in responding to the challenge of climate change was also highlighted with particular reference to its importance in dealing with increased coastal erosion and flooding. Several submissions raised the need to protect green belts and flood plains from inappropriate development. The importance of green infrastructure in underpinning the tourism industry was also raised.
CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - GREEN INFRASTRUCTURE There is strong support for the Council’s green infrastructure policy approach and recognition that Fingal is a leader in this area. The Draft Plan should continue to focus on the five themes of biodiversity; parks, open space and recreation; landscape; sustainable water management; and archaeological and architectural heritage and support for the integration of walking and cycling routes within the green infrastructure framework. There is recognition of the need to ensure that the development management process can deliver green infrastructure benefits in accordance with the requirements of the Draft Plan and Local Area Plans. In this regard consideration should be given to the development of decision-support tools based on existing models elsewhere such as the Seattle Green Factor, the Malmo Green Space factor and Green Points System. The importance of green infrastructure such as sand-dune systems in responding to the challenges presented by climate change is also recognised. It is vital that the Draft Plan provides a coastal policy framework which recognises the dynamic nature of coastal ecosystems and provides for their protection and maintenance into the future. Opportunities should be sought to increase investment in green infrastructure by raising awareness and understanding of the links between green infrastructure and public health. A continuation of the importance placed on green infrastructure should be advocated in the review of the Plan.
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9. NATURAL HERITAGE STRATEGIC CONTEXT International Conventions and Agreements
Ireland has signed and ratified a number of international conventions and agreements in relation to biodiversity including the Convention on Biological Diversity (CBD), the Convention on the Conservation of European Wildlife and Natural Habitats (Bern), the Convention on the Conservation of Migratory Species of Wild Animals (Bonn) and the Convention on Wetlands of International Importance (Ramsar). These are implemented through both European and national legislation including the Birds and Habitats Directives and the Wildlife Acts 1976- 2000. Ireland has also signed and ratified the European Landscape Convention (ELC).
National Spatial Strategy 2002-2020 (NSS)
The NSS aims to ensure that all parts of the country will in future be able to sustain a better quality of life for people, a strong competitive economy and an environment of the highest quality. The conservation and management of our heritage plays a key role in achieving these objectives and is a benchmark for the achievement of sustainability.
National Biodiversity Plan 2011-2016
The National Biodiversity Plan (NBP) sets out the Government’s strategy in relation to the conservation and management of biodiversity. The NBP underlines the need to conserve biodiversity in light of its ongoing world-wide decline. It emphasizes the need to integrate biodiversity conservation measures into all sectorial policies. In so doing it requires all local authorities to prepare and implement a Local Biodiversity Action Plan.
National Landscape Strategy 2015-2025
The National Landscape Strategy provides a framework for the protection of the many cultural, social, economic and environmental values embedded in the landscape. The objectives of this Strategy are to establish and implement, through a series of actions, policies aimed at understanding, protecting, managing and planning our landscape. It sets out specific measures to integrate and embed landscape considerations in all sectors which influence the landscape and improve and enhance the quality of decision-making by those who have an impact on it. The Government will work in co-operation with public authorities, stakeholders, communities and individuals to implement it.
Regional Planning Guidelines 2010-2022
The Regional Planning Guidelines for the Greater Dublin Area recognise the importance of protecting and managing our natural heritage including biodiversity, geological heritage and landscape. The Guidelines call on local authorities to include policies and objectives to address these issues comprehensively in their development plans.
Fingal Heritage Plan 2011-2017
The Fingal Heritage Plan was adopted by the Council in April 2012. It sets out 49 actions to be undertaken to care for and manage Fingal’s heritage in the period up to 2017.
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Fingal Biodiversity Plan 2010-2015
The Fingal Biodiversity Action Plan includes 100 actions to protect and enhance the key nature conservation areas in Fingal. The Plan focuses on the development of an ecological network that includes the international and nationally designated nature conservation sites and their buffer zones, nature development areas and ecological corridors.
SUMMARY OF ISSUES RAISED Submissions Received During the Consultation Process
P00009, P00029, P00034, P00048, P00058, P00061, P00062, P00071, P00072, P00076, P00077, P00087, P00092, P00093, P000106, P00108, P00109, P00110, P00115, P00121, P00127, P00133, P00135, P00137, P00147, P00148, P00155, P00164, P00169, P00174, P00182, P00185, P00187, P00192, P00195, P00197, P00198, P00205, P00225, P00233, P00245, P00322
Many submissions raised issues relating to natural heritage including biodiversity, landscape and geological heritage. The need to protect designated nature conservation sites was highlighted, as was the importance of biodiversity conservation generally, with particular emphasis on the need to protect trees, hedgerows, wetlands and rivers together with their corridors. Coastal erosion and the need to address it in a considered way was raised as was the issue of flooding - often in the context of the likely impacts of climate change. The need to protect floodplains from development was raised as was the need to protect green belts. The issues of bird nuisance and the proliferation of the Irish Hare at Dublin Airport were raised. The need to address untreated sewage discharges in Rush and Howth was raised due to its potential to impact designated sites. The need to manage the spread of invasive alien species was raised.
There was support for the protection of geological heritage sites already included in the Development Plan together with a call for greater awareness raising efforts to highlight these sites.
Many submissions highlighted the need to manage the landscape, to protect special landscapes and to protect special views and vistas where appropriate. Areas highlighted included the coast, Howth, the Liffey Valley and the Tolka Valley. Submissions sought the implementation of the Special Amenity Area Orders (SAAO) in Howth and the Liffey Valley and the implementation of the Operational Plan 2015-2020 for the Howth SAAO. The expansion of the Liffey Valley SAAO was called for, as was its designation as a Special Area of Conservation.
The tourism and recreational potential of Fingal’s natural heritage was raised. Submissions indicated the need to develop walking and cycling routes along our coast and inland waterways. The potential to develop water-based recreational pursuits along the coast, including marinas in Skerries and Rush, was raised as was the general potential of the countryside to facilitate active recreation and tourism. There was recognition that development of tourism infrastructure is required in Fingal but that this must take place in a manner which takes full account of the need to protect the county’s rich natural and cultural heritage.
Many submissions highlighted the importance of natural heritage as part of the County’s wider green infrastructure network which needs to be protected, managed, and created to sustain a high quality of life in the county. The development of Balleally and Dunsink landfill sites as public amenity spaces was called for.
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CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - NATURAL HERITAGE There is strong support in Fingal for the protection of our natural heritage including biodiversity, landscape and geological heritage. It is recognized as a key asset for the County because it is vital for sustaining a high quality of life and it is important in attracting visitors to the County. It is clear that the proactive approach by the Council in protecting and managing of our natural heritage should be continued into the future.
There are a number of nationally and internationally important nature conservation areas in Fingal. The majority of these areas are designated under the EU Habitats and Bird Directives and are subject to strict protection, both in relation to activities occurring within the sites and in relation to any activities beyond the sites that could threaten their ecological integrity. Nearly all these designated areas occur along the coast and the Council is required by law to incorporate objectives in the Draft Plan for their protection. The coastal area is also the focus for increasing economic activity including residential and recreational development. The Draft Plan needs to integrate strong protection of our natural heritage, and designated nature conservation areas in particular, with other economic and recreational activities along the coast. The preparation of integrated masterplans for the estuaries and their buffer zones, that will address issues such as nature conservation, recreation, erosion and flooding, is an important objective to ensure that these key nature conservation sites are protected. These plans should be developed together with local landowners, community groups and other relevant stakeholders, to ensure broad community input and support.
There is also a need to protect biodiversity outside the designated nature conservation sites. The existing policies for the protection of habitats, and plant and animal species outside the designated nature conservation sites, including the development and protection of the ecological network, should be continued and strengthened in the Draft Plan. This includes the need to protect trees and hedgerows. The need to monitor and manage invasive species in Fingal should also be recognised and should be addressed in the Draft Plan. Opportunities for the development of Balleally and Dunsink landfill sites as major natural amenity areas should be explored.
The protection of geological heritage sites in the county should be maintained and more emphasis should be given to the provision of information in relation to geological heritage sites especially along the coast where there is public access.
The need to plan for climate change adaptation in the coastal zone is vital. This requires a long-term management view of this dynamic environment to be taken rather than relying on ad-hoc responses to crises. Existing policies to prohibit new development near high-risk coastal areas should be maintained in the Draft Plan. Policy should be developed to address issues arising from existing properties and infrastructure at risk from coastal erosion. Policy approaches which seek to facilitate adaptive coastal zone management or managed retreat should be explored.
The harbours at Balbriggan, Skerries, Loughshinny, Howth, Rush and Malahide provide major opportunities for improvement of the inshore fishing industry and the development of active and passive leisure, tourism and service enterprises: although the costs associated with maintaining and developing these harbours for fishing and other amenity purposes are very high. The Draft Plan should aim to undertake a strategic appraisal of the harbours to establish what opportunities exist for the development of recreational and tourism pursuits including marinas within existing harbours and how the harbours can be improved for the inshore fishing industry.
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The policy framework needed to manage the landscape in a sustainable manner should be maintained and further developed in the Draft Plan including the need to address the requirements of the recently published National Landscape Strategy 2015-2025. This may include a requirement to undertake Landscape Character Assessment and Historic Landscape Characterisation for Fingal within a standardised national framework yet to be developed and a requirement to undertake or participate in periodic ‘State of the Landscape’ reports which will seek to track landscape change. The Draft Plan should also continue to protect special landscapes including areas designated as Special Amenity Areas. The focus of the Draft Plan should be on the implementation and of the SAAO management and/or operational plans in Howth and the Liffey Valley.
The recently designated UNESCO Dublin Bay Biosphere seeks to conserve the Bay and its immediate surroundings. Managed by Dublin Bay Partnership, a group of organisations of which the Council is a part, the Partnership seeks to help conserve the Bay, by promoting the protection of landscapes, habitats, wildlife and cultural values; while providing an important learning resource, and assisting in the fostering of a sustainable economy and society for people living and working in the area. The Biosphere designation and the wider role it can also play in for example providing an attraction to the area should be reflected in the Draft Plan.
The Draft Plan should also promote the integration of key natural heritage assets into the wider green infrastructure framework for the County. The potential for Fingal’s natural heritage to underpin sustainable tourism in the county should also be reflected in the Draft Plan. A key aim should be to deliver the Fingal Coastal Way while ensuring the protection of sites designated for nature conservation at national and EU level.
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10. CULTURAL HERITAGE STRATEGIC CONTEXT
European Conventions and Agreements
Ireland has signed and ratified a number of Conventions and Agreements in relation to our cultural, archaeological and architectural heritage and also to our natural and designed landscapes. These include the European Cultural Convention, the European Convention on the Protection of the Archaeological Heritage (Valletta Convention), the European Convention on the Protection of the Architectural Heritage of Europe (Granada Convention) and the European Landscape Convention (Florence Convention). These Conventions place legal obligations on Ireland in relation to the conservation and management of our national culture and heritage which are given effect through the National Monuments Acts 1930- 2004, the Heritage Act 1995, and the Planning and Development Acts 2000 to 2014.
National Spatial Strategy 2002-2020 (NSS)
The NSS aims to ensure that all parts of the country will in future be able to sustain a better quality of life for people, a strong competitive economy and an environment of the highest quality. The conservation and management of our heritage will play a key role in achieving these objectives and is a benchmark for the achievement of sustainability.
National Landscape Strategy for Ireland 2015-2025
The National Landscape Strategy seeks to establish principles for protecting and enhancing Ireland’s natural and cultural heritage landscapes while positively managing change. These landscapes include natural, urban, peri-urban and rural areas, and so incorporate historic designed landscapes, urban parks and spaces, inland water systems, coastal and marine areas as well as open countryside and wilderness areas.
National Heritage Plan, 2002
The National Heritage Plan sets out the Government’s strategy in relation to the conservation and management of our heritage. The Plan recognises that heritage conservation and management is an essential part of sustainable development and the delivery of a high quality of life for all. A key element of this Plan is an enhanced role for local authorities in heritage awareness and management, to be given effect through the preparation and implementation of Local Heritage Plans.
Government Policy on Architecture 2009-2015
The Policy on Architecture sought to raise awareness and understanding of the contribution of high quality and sustainable design within the built environment. The document set out key policy statements on architecture both new build and the conservation and re-use of the existing historic building stock. A list of actions was identified to achieve the objectives of the policy which have delivered a number of projects and publications through the lifetime of the policy.
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Architectural Heritage Protection Guidelines for Planning Authorities, 2011
These Guidelines provide detailed direction to Planning Authorities on the designation, protection and management of development of Protected Structures and Architectural Conservation Areas to ensure architectural heritage, which is a finite and often irreplaceable inheritance, is conserved and appropriately managed to pass on to future generations.
Framework and Principles for the Protection of the Archaeological Heritage, 1999
This document sets out the role of the different bodies and entities tasked with the protection and safeguarding the archaeological heritage of the country and the principles to achieve this, in particular where development is being approved or carried out. These include the principles of preservation in-situ, preservation by record, archaeological assessment and archaeological monitoring.
Our Sustainable Future: A Framework for Sustainable Development for Ireland, 2012
This national framework sets out a range of environmental, economic and social measures to support the Green economy and sustainable development. The better integration and re- use of architectural heritage and the existing building stock is seen as a significant element in the creation of sustainable communities.
Regional Planning Guidelines for the Greater Dublin Area 2010-2022
At regional level the Regional Planning Guidelines for the Greater Dublin Area acknowledges that heritage is an important environmental and economic resource that needs to be cared for and managed properly and so sets out priority areas that include the continued protection, management and enhancement of natural heritage, built heritage and environmental resources.
Fingal Heritage Plan 2011-2017
The heritage of Fingal encompasses the archaeological, architectural, natural heritage and culture of the County. The current Fingal Heritage Plan sets out a range of objectives to protect, manage and promote Fingal’s Heritage under four themes: communicating our heritage to a wider audience; caring for our heritage; increasing the level of community activity for heritage; and supporting the local community.
Local Economic and Community Plan (LECP)
Through the Local Government Reform Act 2014 local authorities have a more enhanced role in the development and support of local communities and local enterprise. Local Economic and Community Plans will identify and implement actions to strengthen economic and community development with the local authority area. The Council is in the process of drafting a LECP. One of the principal goals identified for this plan to help stimulate growth is the encouragement of a sense of place and capitalisation of natural and built heritage and culture.
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SUMMARY OF ISSUES RAISED Submissions Received During the Consultation Process
P00005, P00006, P00019, P00030, P00034, P00048, P00072, P00077, P00083, P00084, P00093, P00108, P00110, P00111, P00114, P00115, P00127, P00131, P00187, P00197, P00203, P00204, P00217, P00226, P00231, P00233, P00241, P00243, P00254, P00287
In general the submissions were supportive of the protection of the heritage of Fingal.
A recurring issue raised in a number of the submissions related to the need to utilize both the archaeological and architectural heritage resource better through the development of their tourism potential and better promotion, marketing and branding of sites. Specific sites were identified both in public and in private ownership but it was also proposed that the focus should not just be limited to major heritage sites but that awareness of sites of local interest or importance should also be raised. The branding of historic towns was put forward and the utilization of the term “heritage town” encouraged. Different mediums for promotion of heritage sites were mentioned including maps, pamphlets, apps, events, websites and improved interpretative and directional signage. The provision of a county or maritime museum was put forward a number of times. The creation of heritage trails or routes was identified as a mechanism to promote local heritage in specific towns and villages. It was also suggested that cycling trails and a bus service serving the major heritage sites should be used to link these together. Heritage trails could also link into adjoining counties/jurisdictions. Awareness of Fingal as a place to visit should be raised outside of Fingal itself, in particular through Dublin Airport and within Dublin City Centre.
The quality of facilities such as parking and cafes at some heritage properties was highlighted and suggestions made in relation to establishing partnerships with known café brands to increase the profile and draw of a site. However, concerns about heritage sites drawing customers away from businesses in adjoining town centres were also expressed in some submissions. Demands to open up or provide more access to certain sites was also identified as an issue. Opening up Swords Castle, in particular, was a significant issue flagged at the public consultation meetings.
The importance of the coastal heritage of Fingal was raised on a few occasions in submissions and that it is not marketed enough. Coastal archaeology, historic harbours, lighthouses and Martello Towers were all identified as potential heritage sites that should be used to promote the coast.
Concern was expressed in some submissions in relation to the condition of specific structures or sites and the need to better monitor works being undertaken and that greater time should be given for public submissions to be made on applications relating to Protected Structures. Requests were made that the Council acquire Protected Structures identified as being at risk. Potential uses for specific Protected Structures were suggested. Other submissions sought the restoration of specific sites. Development within the setting of Protected Structures or demesnes should be sympathetic and the phasing of development should ensure that works to Protected Structures are carried out first. Development with the centre of historic villages needed to be appropriate in scale and in keeping with the character of the area. Although one submission sought a more pragmatic approach to development within the curtilage of Protected Structures.
Suggestions for individual additions to the Record of Protected Structures (RPS) were outlined and that the Council should provide a list of all protected structures and historic structures in Fingal. A list of the principal archaeological sites was also requested. The need to retain certain existing Architectural Conservation Areas (ACAs) was stated and potential
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new ACAs proposed. The identification of protected views within ACAs was raised.
One very detailed submission was made that went into great depth in relation to the current section of the Fingal Development Plan on archaeological heritage, suggesting changes to the wording of objections and proposals for new objectives.
CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - CULTURAL HERITAGE There is clearly a great deal of support from residents of the County for the conservation and protection and promotion of the tangible cultural heritage and this should be reflected in the policies of the Draft Plan.
The need to promote and develop the tourism of Fingal’s heritage has already been identified and acknowledged in the Fingal Tourism Strategy 2015-2018 and objectives to support this strategy should be incorporated into the new Development Plan. Some of the actions of the Fingal Tourism Strategy should address issues raised in the submissions. Any tourism development of Fingal’s heritage should be carefully considered and carried out in a sensitive and sympathetic manner so that it is does not negatively impact on the heritage asset.
In relation to an assessment of the Record of Protected Structures (RPS), the Council is currently carrying out a review identifying potential new additions, some deletions and amendments of descriptions or addresses to help clarify extent of existing Protected Structures. The RPS review is due to be completed prior to the next stage of the review of the Development Plan. The RPS is already included as an Appendix of the Development Plan and should continue to be incorporated as such. Any recommendations received for additions to the RPS should be included in the ongoing review.
There are currently twenty-nine Architectural Conservation Areas (ACAs) designated under the existing Development Plan. Most of the areas suggested in the submissions are already ACAs. Any proposed new areas should be considered. The production of (non-statutory) guidance documents on all the ACAs should assist in directing development within these areas. Documents such as the Swords Cultural Quarter Masterplan have the potential to provide an exemplar or template regarding non statutory guidance documents which balance cultural protection while optimising their economic and tourist value.
Consideration should be given to improvements concerning the interpretation of heritage generally and in particular the treatment of archaeological monuments within open space in order to raise awareness of their presence and to ensure their protection. Incorporating heritage features into infrastructure design at an early stage in the development planning and management process would help to protect and promote the cultural heritage resource.
The Council should investigate the inclusion of a list of the Recorded Monuments within Fingal within the Draft Plan to raise awareness of the archaeological sites and monuments within the area.
The wording of existing objectives and inclusion of new objectives for the archaeological heritage of Fingal should form part of the review of this section of the Plan.
The Council should consider the inclusion of objectives in relation to the treatment of archaeological monuments within open space in order to raise awareness of their presence and to ensure their protection.
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11. IMPACTS ON THE ENVIRONMENT STRATEGIC CONTEXT EU Strategic Environmental Directive 2001/42/EC (SEA Directive)
The SEA Directive was transposed into Irish Law under the ‘Planning and Development (Strategic Environmental Assessment) Regulations 2004-2011’. SEA is a statutory process involving the systematic evaluation of the likely significant environmental effects of implementing the Draft Plan before a decision is made to adopt. It is being carried out as a parallel process to the Development Plan Review. The objective of the SEA process is to provide for a high level of protection of the environment and to promote sustainable development integrating environmental considerations into the preparation of the specified plans and programmes. It is concerned with the effects of the Plan on matters such as population, soil, biodiversity, water, human health, climatic factors, flora/fauna, material assets, and cultural heritage including architecture, archaeology, landscape and the interrelationship between each of these factors.
The SEA process, with regard to preparation of a Development Plan, involves a number of steps from Screening, Scoping, the preparation of and Environmental Report, undertaking consultations, the integration of environmental considerations into the Plan, before the publication of information on the decision i.e. the SEA Statement.
Habitats Directive (92/43/EEC) and Appropriate Assessment (AA)
The Draft Plan will be subject to AA, as required by the Habitats Directive. The Directive aims to create a network of protected wildlife sites in Europe through the designation of Special areas of Conservation (SACs) and Special Protection Areas (SPAs) collectively known as Natura 2000 sites. It is a requirement of the Directive and legislation to carry out an AA (Natura Impact Report) on any plan or project, including the Draft Plan that is likely to have a significant effect on the conservation status of a protected site. AA is a focussed and detailed impact assessment of the implications of the Plan, alone and in combination with other plans and projects, on the integrity of Natura 2000 sites in view of the conservation objectives of the sites
SACs, relate to habitats and wildlife while SPAs are largely concerned with protecting bird species. There are 8 SACs and 9 SPAs in Fingal, with a number of areas enjoying protection under both designations due to their qualifying features. Some SPAs have also been designated under the Ramsar Convention (an international treaty on the conservation and sustainable utilisation of wetlands).
Flood Risk Assessment
The EU Floods Directive (FD) 2007/60/EC on the ‘Assessment and Management of Flood Risks’ requires Member States to assess and manage flood risks. The Office of Public Works (OPW) is the lead agency is implementing this process. A national Preliminary Flood Risk Assessment (PFRA) was completed to identify where significant flood risk exists. Areas of further assessment were identified throughout the country and were subject to more detailed analysis. These steps are being carried out as part of the National Catchment Flood Risk Assessment and Management (CFRAM) Studies, which were to be completed by 2015. These CFRAM Studies will contain objectives and actions and remedial measures to be taken for managing floods.
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The Department of the Environment, Community and Local Government (DECLG) and Office of Public Works (OPW) prepared the ‘Planning System and Flood Risk Management – Guidelines for Planning Authorities’ (DECLG & OPW, 2009) in order to integrate the assessment and management of flood risk into the planning process. The Guidelines indicate that Flood Risk Assessment (FRA) should be integrated into the SEA process. Planning authorities are required to introduce flood risk assessment as an integral and leading element of their development planning functions under the Planning Code. The FRA will be aligned with the existing SEA process. Scoping of SEA will normally include flood risk as an environmental criterion.
As a Development Plan is a strategic Plan a Strategic Flood Risk Assessment (SFRA) will be prepared alongside the Draft Plan.
SUMMARY OF ISSUES RAISED Submissions Received During the Consultation Process
P00034, P00076, P00077, P00087, P00192
The submissions received generally draw attention to the requirements for the Council to undertake an SEA, AA and SFRA; and also suggest where baseline data can be accessed.
One submission suggests that a health impact assessment be included as part of the SEA is noted.
A submission from the Geological Survey of Ireland (GSI) notes that it should be consulted as a prescribed body under the aegis of the Department of Communications, Energy and Natural Resources at the planning stage and in the preparation of an SEA, Environmental Impact Assessment (EIA) or Environmental Impact Statement (EIS) for any proposed development as appropriate.
In terms of flood risk the continual monitoring of the Delvin, Ward and Mayne Rivers was raised in one submission.
CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - IMPACTS ON THE ENVIRONMENT As part of the Development Plan review process the Council is required to carry out a number of environmental assessments of the Draft Plan. These include a SEA, AA, and SFRA. The Council is aware of its statutory obligations and to this end is undertaking an SEA, AA and SFRA, in accordance with EU Directives, legislative requirements and having regard to Government Guidance.
In terms of SEA, when the Draft Development Plan is published, an Environmental Report, Appropriate Assessment and Flood Risk Assessment will also be published. The Environmental Report should set out details of the environmental baseline, trends and environmental objectives. It should show how the Draft Plan has been assessed against the environmental objectives during its preparation and seek opinions from interested parties. Where conflict occurs, it should demonstrate what alternatives were considered and informed decision-making on these issues. The Council should invite submissions on the Environmental Report, as well as the Draft Plan early next year. The GSI should be consulted as part of this process.
The effect of the Draft Plan on human health is one of the issues that the SEA is concerned with and should be considered during the SEA process and inform the Draft Plan accordingly.
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The Draft Plan should be screened to ascertain whether it has any significant impact on any Natura 2000 site. Whilst the AA process is a separate process to the SEA, it runs in parallel with the SEA and the outcomes will feed into, and inform the SEA. A Natural Impact Report outlining any potential impact of the Draft Plan on Natura 2000 sites should be available with the Draft Plan, the SEA and the SFRA.
While the review of the Development Plan should be informed by national planning policy such as the Guidelines on Flood Risk Management and also RPGs, all practical steps to ensure the identification of any areas at risk of flooding and flood zones must be taken. The Council has commenced the SFRA process and a copy of the SFRA will be available alongside the Draft Plan, SEA and the AA.
Recording of flooding events along rivers such as the Delvin, Ward and Mayne Riversis made by the Council when such events occur. This and any other relevant data should be used to inform the SFRA.
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12. MISCELLANEOUS This Section of the Report deals with a range of issues. Under these broad headings the overall Strategic or Statutory Context is first given before considering issues raised under the various headings of Development Plan Issues, Other Planning Related Matters and Other; before addressing those submissions primarily concerned with Zoning. At the end of Section (or subsection, where applicable) the Chief Executive’s Opinion is given.
STRATEGIC CONTEXT The Statutory and policy context which relates to the Plan review process has been outlined in detail in respect of the specific themes in previous Sections in the Chief Executive’s Report, and therefore to avoid undue duplication they are not outlined specifically again hereunder, but it should be noted that they have informed the assessment of the submissions under the Section Heading ‘Miscellaneous’.
SUMMARY OF ISSUES RAISED Submissions Received During the Consultation Process
P00002, P00005, P00032, P00034, P00042, P00045, P00050, P00058, P00076, P00083, P00087, P00093, P00098, P00108, P00110, P00120, P00131, P00132, P00145, P00164, P00169, P00181, P00187, P00192, P00203, P00204, P00217, P00226, P00233, P00252, P00287, P00294, P00295, P00316 Development Plan Issues
It is contended based on the first page of the consultation booklet that the focus of the new Plan will be economic considerations rather than building sustainable communities.
The Draft Plan should have a section on natural heritage. All designated sites should be listed and mapped. The Draft Plan should also have regard to the Biodiversity Convention, the Ramsar Convention, the EC Habitats Directive, the EC Birds Directive, the Wildlife Act and the European Community Regulations and its amendments.
It is suggested that a number of proposed Local Area Plans are replaced with Masterplans which would be more time efficient and effective.
A policy in relation to derelict sites and deserted buildings and sites should be developed. This should include legal sanctions. One submission suggested specific derelict building in a locality should be removed.
The Council should have a policy which indicates social performance indicators which must be met by all developments.
In relation to the physical format of the Draft Plan, it is suggested to track changes in the interest of clarity. The layout could also be improved by sub-numbering or sub-lettering the sections. The existing layout has difficulties in this regard.
Clarity is requested regarding the terms used within the Development Plan. Ambiguous terms should be avoided and unusual terms defined. Clarity is also sought in relation to the term “open for consideration”. It is considered a list of use classes which are “open for
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consideration” should be included in the zoning matrix.
The existing online mapping tools are considered user-friendly.
The following mapped Local Objectives should be retained 126, 127, 129, 135, 143, 170, 172, 176, 177, 184, 186, 190, 204, 205, 206, 208, 209, 210, 211, 212, 213, 216, 217 and 221. These all relate to the Rush area. Objective Castleknock 1 should be removed. One submission contends that all Local Objectives should be reviewed and any redundant objectives omitted from the Draft Plan.
It is suggested where development already exists on site, compatible or complementary uses should be permitted on the remainder of the site, regardless of the zoning.
The use and promotion of the Irish language is encouraged.
A number of submissions advocate that the Council work with Dublin City Council and other neighbouring counties to support the policy objectives of the Development Plan.
One submission considered the online consultation website difficult to use. It is unclear why submissions could not be accepted by email or at the Blanchardstown office.
A number of Community Associations (in the Castleknock-Mulhuddard area) note their dissatisfaction with the existing Development Plan objectives as they relate to their communities and in particular the failure of the Council to enforce these objectives. Other Planning Related Matters
A number of submissions raise issues which relate to planning matters but not the Development Plan or the drafting of a new Development Plan. These issues included:
• Refusing planning permission in certain circumstances.
• Publication of a policy in relation to Section 35 of the Planning & Development Act.
• Request for flexibility regarding the phasing of development contributions and Part V obligations.
• Enforcement concerns.
• Lack of consultation regarding planning applications. In this regard a number of community groups/residents associations requested active consultation for developments in their areas.
• Unfinished housing estates and their issues.
• A review of publications acceptable for planning applications is required.
• Publication of pre-planning discussions.
• Restrictive unnecessarily complex conditions should be avoided.
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Other Issues
The GSI note County Geological Survey Audit, carried out in 2007, should be made available on the Council website.
A strategy to acknowledge Fingal’s history in the 1916 Rising and War of Independence should be developed.
The Fingal website can be difficult to navigate.
Pyrite was listed as a problem in one submission.
The issue of anti-social behaviour in Balbriggan is raised. It is suggested that better policing and the setting up of youth projects would alleviate this issue.
There is a need for a Risk Assessment Policy for applications to look at the risk of commercial failure and mitigate this risk. Developments should be commercially sustainable.
There is a perceived imbalance in Council’s spend and development between East and West Fingal.
CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - MISCELLANEOUS Development Plan
The Draft Plan should be underpinned by the cross cutting themes of sustainable development, climate change adaptation, social inclusion and high quality design. Issues raised relating to these four key overarching strands permeates the policies and objectives of all Draft Plan topics.
The current Development Plan has a section on Natural Heritage and has regard to all relevant legislation as it relates to issues of Natural Heritage. The Draft Plan should be similarly informed.
The consideration of any Local Area Plan or Masterplan forms part of the review process of the Draft Plan.
The issue of derelict sites is not a matter that can be dealt with in the context of the Draft Plan under the current legislation. However, in view of the Planning Bill No.1, this matter should begin to inform future Development Plans.
This Draft Plan is separate, standalone document, albeit informed by the Housing Strategy, LECP and Tourism Strategies, etc. The design and layout of the Draft Plan should be examined to ensure ease of use and reference to other relevant documents, without being unduly lengthy so as to duplicate Council policies or strategies.
A Glossary of Terms should be provided to assist in ease of understanding of the Plan.
The land use zoning ‘matrix’ of permissible uses should be reviewed as part of the Development Plan Review.
All Local Objectives should be re-examined and where relevant retained and or/amended.
The current Development Plan includes objectives which allow for a reasonable intensification of, extension to or improvement of non-conforming uses. It is considered that a similar objective should form part of the Draft Plan.
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The Council remains mindful of its requirements under the Official Languages Act. The Council is committed to the promotion of Irish within the Council and the Draft Plan should reflect the importance and promotion of the Irish Language in its policies and objectives.
The Council recognises that political/administrative boundaries do not coincide with geographical, hydrological and other boundaries. Liaison with adjoining Counties/City forms part of the Development Plan Review process. The Regional Assembly and other bodies such as the National Transport Authority also have a role in ensuring coordination between adjoining areas.
A comprehensive Pre-Draft consultation process in accordance with Section 11 of the Planning and Development Act 2000 2010 (as amended) has been undertaken by the Council, as detailed in Part 1 of the report. As part of this pre-draft consultation process Planning Officials were available in person to demonstrate the online submission process & receive written submissions. Other Planning Related Matters
Issues raised can only be considered where they relate to developing (a) the objectives and policies to deliver an overall strategy for the proper planning and sustainable development of the area of the Draft Plan and (b) the Core Strategy in the context of the preparation of the Draft Plan. The issues listed are outside the Plan context or are non-strategic in nature and do not come within the scope of the current process. Other Issues
The purpose of this Report is to set an overall strategy for the development of the County and a broad policy structure for the Draft Plan. Many of the issues raised are more appropriately addressed by other plans and programmes prepared or being prepared by the Council or of other Public Bodies, and as such should continue to be considered in the most appropriate planning context.
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ZONING STATUTORY CONTEXT The Statutory provisions and procedures regarding the Making of a Development Plan are set out in the Planning & Development Act, 2000-2014 (as amended). Pursuant to Section 11(2) (bc) of the Planning & Development Act, 2000 (as amended), requests or proposals for zoning of particular land for any purpose cannot be considered at this stage of the process. SUMMARY OF ISSUES RAISED Submissions Received During the Consultation Process
P00012, P00075, P00078, P00099, P00146, P00176, P00232, P00255, P00259, P00271, P00273, P00274, P00276, P00277, P00303, P00307, P00320 Seventeen submissions received related to rezoning proposals. These submissions related to the rezoning of a specific site or sites, mainly from the rural zonings to residential, mixed use or tourism zoning or for employment and economic uses.
CHIEF EXECUTIVE’S OPINION ON MAIN ISSUES - ZONING Pursuant to Section 11(2)(bc) of the Planning & Development Act, 2000 (as amended), requests or proposals for zoning of particular land for any purpose cannot be considered at this stage of the process. The proper planning and sustainable development of the area requires that such a framework be agreed and that the re-zoning of land should only be considered in the context of this framework and of the overall land use zoning of the County. It would therefore be premature at this early stage of the process to make determinations on each individual re-zoning proposal. The Council intends to review the zoning of the area of the Development Plan at the next stage of the process.
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100 Chief Executive’s Report Pre-Draft Consulation July 2015 Fingal Development Plan 2017-2023 PART THREE
CHIEF EXECUTIVE’S POLICY RECOMMENDATIONS
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 2017-2023
PART THREE
CHIEF EXECUTIVE’S POLICY RECOMMENDATIONS BY TOPIC INTRODUCTION This part of the report sets out the Chief Executive’s Policy Recommendations on the broad policies to be included in the Draft Development Plan. It is presented mainly as a response to the issues raised in the public submissions. The statutory requirements of the Planning and Development Acts 2000 – 2014 must also be followed. The Draft Plan will have regard to the National Spatial Strategy 2002-2020 and other Government policies, and to the Regional Planning Guidelines for the Greater Dublin Area which are currently under review.
CHIEF EXECUTIVE’S POLICY RECOMMENDATIONS
1. MAIN AIMS OF THE DEVELOPMENT PLAN The Draft Fingal Development Plan 2017-2023 aims to:
1.1 Plan for and support the sustainable development of Fingal as an integrated network of vibrant socially and economically successful urban settlements and rural communities, strategic green belts and open countryside, supporting and contributing to the economic development of the County and of the Dublin City Region.
1.2 Provide for the future well being of the residents of the County by:
• Supporting economic activity and increasing employment opportunities
• Protecting and improving the quality of the built and natural environments
• Ensuring the provision of necessary infrastructure and community facilities
• Promoting and improving quality of life
1.3 Incorporate sustainable development, climate change adaptation, social inclusion and high quality design as fundamental values, cross cutting and underpinning the Draft Plan.
1.4 Promote an appropriate balance of development across the County, by developing a hierarchy of high quality, vibrant urban centres and clearly delineated areas of growth.
1.5 Ensure an adequate supply of zoned lands to meet forecasted and anticipated economic and social needs, while avoiding an oversupply which would lead to fragmented development, dissipated infrastructural provision and urban sprawl.
1.6 Foster the development of socially and economically balanced sustainable communities.
1.7 Facilitate the actions and implementation of the Local Economic and Community Plan, as appropriate.
1.8 Facilitate the potential for growth in tourism by implementing the Fingal Tourism Strategy 2015-2018, as appropriate.
1.9 Continue to influence regional and national planning and development policies in the interest of the County.
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2.0 Co-operate with the Eastern and Midland Regional Assembly, local authorities and other stakeholders in meeting the needs and development requirements of the County and the Greater Dublin Area in accordance with the National Spatial Strategy and the Regional Planning Guidelines for the Greater Dublin Area and any successor policy documents.
2. STRATEGIC POLICY The Strategic Policy will deliver on the Main Aims by seeking to:
2.1 Promote sustainable development by providing for the integration of economic, environmental, social and cultural issues into Development Plan policies and objectives, utilising to that end the Strategic Environmental Assessment (SEA) and Appropriate Assessment (AA) processes.
2.2 Minimise the impact of the County’s contribution to climate change, and adapt to the effects of climate change, with particular reference to the areas of land use, energy, transport, water resources, flooding, waste management and biodiversity.
2.3 Contribute to the creation of a more socially inclusive society by providing for appropriate community infrastructure and improving access to information and resources. Seek new innovative ways of enhancing social inclusion and ensure the Plan can facilitate initiatives arising from the Social Inclusion and Community Activation Programme (SICAP), where appropriate.
2.4 Add quality to the places where Fingal’s people live, work and recreate by integrating high quality design into every aspect of the Plan promoting adaptable residential buildings and ensuring developments contribute to a positive sense of place and local distinctiveness of an area.
2.5 Promote and facilitate the long-term consolidation and growth of the County town of Swords generally as provided for in the Swords Strategic Vision 2035.
2.6 Consolidate the growth of the major centres of Blanchardstown and Balbriggan largely within their previously identified limits by encouraging infill rather than greenfield development and by intensification at appropriately identified locations.
2.7 Consolidate the development and protect the unique identities of the settlement of Howth, Sutton, Baldoyle, Portmarnock, Malahide, Donabate, Lusk, Rush and Skerries.
2.8 Develop an enhanced identity and link with Fingal for the wider communities of Santry, Ballymun, Meakstown/Charlestown, Finglas, and Lanesborough and define them beyond a South Fingal Fringe Settlement.
2.9 Promote the vibrancy of town centres by providing for a mix of uses within these areas, including cultural and community uses and upper floor residential, as appropriate.
2.10 Safeguard the current and future operational, safety, and technical requirements of Dublin Airport and provide for its ongoing development (incl. the second runway and potential commercial opportunities) within a sustainable development framework.
2.11 Promote enterprise and employment throughout the County, including the Metro North Economic Corridor and Blanchardstown, and work with the other Dublin Local authorities to promote the Dublin City Region as an engine for economic growth for the Region and the country.
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2.12 Protect, maintain and enhance the natural and built heritage of the County.
2.13 Safeguard the ‘green agricultural’ identity of North Fingal, promoting the rural character of the County and supporting the agricultural/horticultural production sector.
2.14 Provide viable options for the rural community through the promotion of controlled growth of the rural villages and clusters balanced with careful restriction of residential development in the countryside.
2.15 Strengthen and consolidate greenbelts around key settlements.
2.16 Seek the development of a high quality public transport system throughout and adjoining the County, including the development of modern light rail systems integrated into the existing rail network like Metro North and Metro West, improvements to the railway infrastructure incl. the DART Expansion Programme DEP, the facilitation of QBC’s and BRT systems, together with enhanced facilities for walking and cycling.
2.17 Promote, improve and develop a modern national, regional and local roads infrastructure geared to the needs of the County and Region.
2.18 Work with Irish Water to secure the timely provision of the water supply and drainage infrastructure necessary to facilitate the sustainable development of the County and the Region.
2.19 Secure the timely provision of other infrastructure essential to the sustainable development of the County, in particular in areas of waste disposal, energy supply, renewable energy generation and ICT.
2.20 Ensure the timely provision of community infrastructure including schools, recreational and sport facilities, roads, waste water treatment facilities and emergency services, commensurate with the number of housing units proposed for construction on lands zoned for residential development.
2.21 Ensure new developments have regard to the recommendations of the Flood Risk Assessment, generally avoiding development on areas liable to flooding or which would be liable to exacerbate flooding. 3. SETTLEMENT STRATEGY The new plan must detail a settlement strategy that make adequate provision for the housing and ancillary facilities needed to accommodate the anticipated population throughout the County. Towards this end the Plan policies must:
3.1 Support and comply with Regional Planning Guidance or its successor Settlement Strategy and associated population and employment targets.
3.2 Ensure there is sufficient land zoned to accommodate the anticipated population, providing for changing household sizes and housing needs, while avoiding an oversupply which would lead to fragmented development, dissipated infrastructure provision and urban sprawl.
3.3 Promote the provision of affordable and social housing and specialised housing including sheltered housing and housing for people with disabilities.
3.4 Identify opportunities for infill development and consolidation of existing towns to reduce the need to zone additional greenfield lands.
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3.5 Ensure the timely provision of community services and resources, including open space, schools, community facilities and local retail facilities, required for the creation of sustainable communities.
3.6 Develop an appropriate mix of house types and different densities having regard to public transport infrastructure and Government guidelines on sustainable residential development.
3.7 Provide good quality well designed housing units and residential areas.
3.8 Provide for a mix of housing and employment opportunities to reduce travel needs.
3.9 Revise the Council’s Housing Strategy to cover the Plan period 2017-2023.
3.10 Secure the implementation of the Council’s Traveller Accommodation Programme.
3.11 Actively preserve and promote the landscape, natural life, economy and lifestyles of rural Fingal, protecting the area from inappropriate development and land uses.
3.12 Respond to rural-generated housing need by means of a rural settlement strategy which will direct the demand where possible to rural villages and clusters, and permit housing development within the countryside only for those people who have a genuine rural- generated housing need in accordance with the Council’s Rural Housing Policy and where sustainable drainage solutions are feasible.
3.13 Support and protect rural villages by appropriate sustainable development to preserve the character and viability of the villages and to support local services.
3.14 Encourage re-use and rehabilitation of existing housing stock in rural areas in preference to new build, and actively promote the protection of traditional rural buildings.
3.15 Strengthen and consolidate greenbelt lands around key settlements.
4. PLACEMAKING & COMMUNITIES Through placemaking, which encompasses a multi-faceted approach to planning, design and management, the Council will continue to ensure the development of attractive places to live, work and recreate by supporting the development of sustainable communities, quality public realm, community facilities, design and standards and open space throughout the County. Sustainable Communities: Recognising the importance of creating vibrant and viable communities which will seek to improve prosperity and quality of life in the County, the Council will:
4.1 Seek to enhance the vitality and viability of existing urban, town and village centres in the County, with a particular focus on the major centres of Swords, Blanchardstown and Balbriggan.
4.2 Foster the development of socially and economically balanced sustainable communities.
4.3 Encourage appropriate residential, social and community uses in centres in order to enhance their vitality and viability and recognising diversity of communities.
4.4 Enhance and develop the fabric of existing and developing centres in accordance with the principles of good urban design.
4.5 Secure the regeneration of areas in need of renewal.
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Public Realm: The importance of the public realm, i.e. the open spaces, parks, streets and places accessible to and enjoyed by the public, is acknowledged. The Council will seek to: 4.6 Consolidate and protect the unique identities of existing urban, town and village centres.
4.7 Develop, promote and implement policies and initiatives that shape and deliver quality public realm throughout the County. Community Infrastructure, Facilities and Services: The Council will support and facilitate the development and expansion of community infrastructure, facilities and services by working with the relevant agencies as appropriate. The Council will: 4.8 Ensure the timely provision of community services and resources, including schools, community, religious, and health facilities, required for the creation of sustainable communities. Design & Standards: High quality design and design standards of individual buildings, developments and wider areas are critical to achieving more cohesive and integrated local communities. In this regard the Council will seek to: 4.9 Add quality to the places where Fingal’s people live, work and recreate by integrating high quality design into every aspect of the Draft Plan.
4.10 Support and require the provision of well-designed development having regard to Government guidance and in particular the publications Sustainable Residential Development in Urban Areas (2009) and the accompanying Urban Design Manual (2009), Sustainable Urban Housing: Design Standards for Apartments (2007) and Delivering Homes, Sustaining Communities – Statement on Housing Policy (2007).
4.11 Ensure that any proposals to increase residential building and development standards above national regulation and guidance are balanced against any potential negative impacts on supply and affordability.
4.12 Develop an appropriate mix of house types, meeting different user needs, and different densities having regard to public transport infrastructure and Government guidelines on sustainable residential development.
4.13 Continue to implement the Development Contribution Scheme, which forms a basis for the improvement of existing community facilities and the funding of new community facilities. Open Space: The provision and management of open space is important to quality of life. The Council will: 4.14 Continue the development of a hierarchy of multifunctional active and passive recreational open spaces and facilities to serve all age cohorts.
4.15 Promote the sustainable use for recreational purposes of the County’s green belts.
4.16 Implement the Council’s Development Contribution Scheme as it relates to the improvement of existing recreation and leisure facilities and the funding of new recreation and leisure facilities.
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5. INFRASTRUCTURE & MOVEMENT Infrastructure Recognising the vital role of an efficient modern infrastructure in enabling the County to reach its full potential, the Council will: 5.1 Facilitate the provision of the necessary physical infrastructure required to promote the sustainable development of the County and the Region.
5.2 Facilitate the provision of high quality water supply and waste water infrastructure adequate to serve the short, medium and long term needs of the County working in conjunction with Irish Water and other local authorities, where appropriate.
5.3 Facilitate the provision of a new Regional Wastewater Treatment Plant and the implementation of other recommendations of the Greater Dublin Strategic Drainage Study, in conjunction with Irish Water to facilitate development in the County and Region.
5.4 Facilitate the provision of a new regional water supply of high quality to serve the future needs of the County and Region in conjunction with Irish Water.
5.5 Develop a long term strategy of identifying and managing flood risk in an integrated and sustainable manner.
5.6 Promote the sustainable use of water and water conservation measures in new development within the County.
5.7 Strive to achieve ‘good status’ in all waterbodies in compliance with the Water Framework Directive, the ERBD River Basin Management Plan and the associated Programme of Measures (1st cycle) and to cooperate with the development and implementation of the 2nd cycle national River Basin Management Plan 2017-2021.
5.8 Ensure compliance with EU, national and regional policy in relation to the protection of the environment and the pursuance of sustainable development.
5.9 Ensure the objectives of the East Midlands Region Waste Management Plan 2015-2021 are incorporated into the Development Plan.
5.10 Promote the development of additional ICT infrastructure so as to provide for the further physical and economic development of Fingal.
5.11 Encourage and facilitate the development of renewable energy sources. Continue to implement the Development Contribution Scheme to provide funding for infrastructure to serve new development in accordance with the Planning and Development Acts 2000-2014 in conjunction with other sources of funding.
Movement The implementation of a safe, effective, universally accessible and sustainable transport system is essential to the future economic, social and physical development of Fingal.
The Council will continue to provide those elements of the transport system in so far as within its remit and to facilitate those provided by others and will:
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5.12 Provide for an integrated approach to land use and ground transportation, aimed at securing a modal shift to more sustainable modes of transport, i.e. cycling walking and public transport.
5.13 Promote land use patterns which reduce the need to travel and support public transport including higher densities at public transport corridors and nodes.
5.14 Prioritise public transport by safeguarding future rail and bus routes, promoting the provision and improvement of QBC’s, BRT’s and bus priority measures on existing and planned road infrastructure, requiring mobility management plans for new developments both residential and commercial, implementing traffic management measures and controlling the supply of parking, where appropriate.
5.15 Promote and facilitate the development of a high frequency light rail link connecting Swords to the Airport and on to the City Centre.
5.16 Promote and safeguard the line for the development of a high frequency light rail link connecting Blanchardstown with Dardistown and a proposed high capacity link between Swords, Dublin airport and Dublin City Centre.
5.17 Promote and facilitate the development of the DART Expansion Programme (DEP).
5.18 Promote good connectivity between key urban settlements and destinations within the County.
5.19 Implement where necessary Section 49 Development Levy Schemes required to facilitate new high frequency rail links directly benefitting the County.
5.20 Support demand management to reduce car travel.
5.21 Ensure that new developments are laid out in a manner that is capable of being serviced by local buses.
5.22 Promote walking and cycling by providing, upgrading and maintaining of cycle ways and footpaths.
5.23 Require connectivity and good pedestrian and cycle facilities through new developments.
5.24 Promote the provision of secure cycle parking facilities at appropriate locations including stations and other public transport interchanges.
5.25 Promote road safety as a high priority.
5.26 Promote the design of streets so as to provide for the safety of road users, including pedestrians, cyclists and car users.
5.27 Implement a programme of new roads and road improvement scheme.
5.28 Encourage when appropriate the provision of park and ride facilities at suitable locations.
5.29 Control on street parking in urban centres in order to protect their viability, vitality and amenity.
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5.30 Safeguard the current and future operational, safety, technical and developmental requirements of Dublin Airport. Protect and enhance surface access to and from the Airport.
5.31 Promote appropriate land use patterns in the vicinity of the designated flight paths serving the Airport, having regard to the existing and anticipated environmental impacts of aircraft movements.
5.32 Support and facilitate the second runway at Dublin Airport.
5.33 Implement the policies to be determined by Government in relation to Public Safety Zones for Dublin Airport.
5.34 Continue to implement the Development Contribution Scheme to provide funding for infrastructure to serve new development in accordance with the Planning and Development Acts 2000-2014 in conjunction with other sources of funding. 6. ECONOMIC DEVELOPMENT The Council will continue its proactive support of employment creation and enterprise development in Fingal in order to promote economic recovery and secure and augment the prosperity of the County, and to that end will:
6.1 Support economic growth within the County through strengthening and promoting the strategic importance of major urban centres of Swords, Blanchardstown and Balbriggan and of key employment locations such as Dublin Airport and Dublin 15.
6.2 Maximise the economic potential of Fingal’s unique strengths and advantageous position within the Eastern and Midlands region.
6.3 Actively seek and facilitate continued opportunities for investment in and development of FDI and indigenous enterprises at appropriate locations in the County.
6.4 Ensure there are sufficient quantums and appropriate types of lands zoned for commercial, enterprise and/ or industrial uses in urban and rural located centres in accordance with the Settlement Hierarchy.
6.5 Prioritise locating quality employment and residential developments in proximity to each other in order to reduce the need to travel, and ensure that suitable local accommodation is available to meet the needs of workers in the County.
6.6 Ensure locating employment intensive land use zonings proximate to high capacity public transport networks and links thereby reducing reliance on private car transport.
6.7 Consider the allocation of various sizes of land parcels for commercial, office, industrial uses in order to cater for a wide range of employment and enterprise formats.
6.8 Liaise and engage with all relevant public service providers to ensure that zoned lands are serviced in a timely fashion to facilitate opportunities for employment and enterprise creation.
6.9 Utilise the measures and powers available to Fingal to encourage and promote the regeneration of areas in need of renewal, for instance in underperforming or outdated commercial and/ or industrial areas.
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6.10 Ensure that Fingal plays has a pivotal role in the promotion of Dublin as the primary Gateway in the Eastern and Midland Region through the engaging and collaborating with the other Dublin local authorities and Eastern and Midland Regional Assembly.
6.11 Engage and collaborate with adjoining local authorities and regional assemblies, as appropriate, to promote the continued economic development of the Metro North and Dublin–Belfast Economic Corridors.
6.12 Liaise and coordinate with Fingal’s Local Community Development Committee, Local Enterprise Office and the Economic Development and Enterprise SPC to ensure that the appropriate objectives, measures and actions included in the Local Economic Community Plan are supported by policies and objectives in the Draft Plan.
6.13 Ensure an appropriate balance is achieved between developing the unique potential of Dublin Airport as an economic generator and major employer in the County and protecting its core operational function as the country’s main international airport.
6.14 Maximise opportunities relating to Fingal’s strategic location within the Dublin Region including proximity to motorways, the Port Tunnel, Dublin Airport and the City.
6.15 Facilitate and promote the development of tourism in the County and ensure that the appropriate policies, objectives and measures identified in the Fingal Tourism Strategy 2015-2018 are aligned with and supported by policies and objectives in the Draft Plan.
6.16 Balance protecting the landscape and natural heritage of rural Fingal with the need to harness and promote economic opportunities associated with rural life such as agricultural, horticultural, tourism and rural-related economic uses.
6.17 Support the maximum number of existing viable farms in Fingal and facilitate part time farming.
6.18 Encourage and provide for industry specifically linked to food, agriculture and the development of added value opportunities in these areas.
6.19 Support alternative rural enterprises and farm diversification, and promote appropriate enterprise in villages.
6.20 Ensure that policies in relation to type, quantum and locations of retail floorspace provision are consistent with the requirements and recommendations of the relevant regional policy frameworks and national planning guidelines.
6.21 Identify measures for maintaining and strengthening the vitality, viability and regeneration of the County’s town, district, village and local centres by providing for cultural and tourism attractions while ensuring that retailing remains a core function of these centres.
6.22 Ensure that policies and objectives in the Draft Plan support the measures and actions identified in the Local Authority Retail Support: Improving our Cities and Towns, June 2015.
6.23 Recognise the strong link between a well-educated workforce and economic prosperity and support continued educational investment in the County.
6.24 Identify all Major Accidents Directive operations in the Draft Plan and include policies in relation to issues such as location, clustering of facilities, and minimising associated impacts on surrounding areas.
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7. GREEN INFRASTRUCTURE Fingal’s green infrastructure is vitally important in providing for a high quality of life for our growing population. It needs to be proactively protected, planned, enhanced and created to provide a full range benefits across the county. Green infrastructure policy also needs to be further developed and integrated into all Council policy, plans and strategy. The Council will: 7.1 Create an integrated and coherent green infrastructure for the County which will protect and enhance biodiversity, provide for accessible parks and open space, maintain and enhance landscape character including historic landscape character.
7.2 Protect and enhance architectural and archaeological heritage.
7.3 Provide for sustainable water management by requiring the retention of substantial net works of green space in urban, urban fringe and adjacent countryside areas to serve the needs of communities now and in the future including the need to adapt to climate change.
7.4 Work to increase awareness of the importance of green infrastructure in providing multiple benefits to communities and engage with key stakeholders including the development sector, agriculture and tourism with a view to increasing investment in green infrastructure projects and places.
7.5 Facilitate the integration of walking and cycling routes with green infrastructure provision, as appropriate, taking the need to protect biodiversity, including the Natura 2000 network, and other landscape resources into account at all times.
7.6 Develop decision-support tools to assist in the provision of green infrastructure benefits as part of the development management process.
7.7 Protect and manage coastal green infrastructure, because of its importance in addressing the challenges posed by climate change, by ensuring policy, plans and strategies recognise and take account of its dynamic nature.
7.8 Set targets for the provision of green infrastructure, such as increasing the number of trees in urban areas, ensuring minimum areas of open space, ecological corridors and green roofs in new urban developments, during the Plan period. 8. NATURAL HERITAGE Fingal’s biodiversity, geological heritage and landscape are important resources which need to be managed, protected and enhanced as appropriate. They underpin the quality of life of the people of Fingal and are important in sustaining the tourism and recreation sectors. The Council will:
8.1 Proactively conserve and manage the County’s natural heritage which enhances our quality of life.
8.2 Take opportunities to utilise Fingal’s natural heritage to develop sustainable tourism and recreation in the county including the development of walking and cycling routes.
8.3 Examine options to utilise existing harbours for leisure and recreational uses while recognising the need to maintain and enhance our harbours for fishing.
8.4 Protect sites designated under national and EU law for biodiversity conservation.
8.5 Conserve and manage biodiversity outside designated sites by strengthening and developing the Fingal Ecological Network and by adopting policies which protect
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habitats and species of conservation concern including rivers and other waterways, wetlands, trees, hedgerows and woodlands.
8.6 Adopt a strategic and long-term approach to planning for new development and infrastructure in coastal areas taking into account the dynamic nature of our coastline, the need to plan for climate change adaptation, including the need to facilitate adaptive management and managed retreat where appropriate, and the need to protect the natural heritage of the coast including its biodiversity, geology and landscape. 8.7 Protect county geological heritage sites and raise awareness in relation to them as appropriate.
8.8 Implement the requirements of the Water Framework Directive as set out in the Eastern River Basin District River Basin Management Plan 2009-2015 [and any subsequent Plans adopted thereafter] while ensuring the conservation and enhancement of natural heritage.
8.9 Review and strengthen landscape policies in the development plan to take account of the new requirements of the planning code as reflected in the National Landscape Strategy 2015-2015.
8.10 Protect and manage the Special Amenity Areas in Howth and the Liffey Valley by implementing the SAAO management and/or operational plans.
8.11 Support and promote the Dublin Bay Biosphere, in particular as it relates to Fingal.
8.12 Utilise Strategic Environmental Assessment and Appropriate Assessment to promote harmonisation of policies in other areas with policies in relation to the conservation and management of the natural heritage.
8.13 Continue to raise public awareness in relation to Fingal’s natural heritage and provide access to it as appropriate.
8.14 Continue to implement the Fingal Biodiversity Action Plan 2010-2015 and the Fingal Heritage Plan 2011-2017, and review as required.
9. CULTURAL HERITAGE Fingal’s rich archaeological and architectural heritage is a key asset in improving the quality of life for the people living and working in the area and is also important in attracting visitors. The Council will: 9.1 Proactively conserve and manage the County’s archaeological and architectural heritage.
9.2 Review and strengthen the Council’s policy and objectives for the protection of the archaeological and architectural heritage of the County; including updating the Record of Protected Structures for the County.
9.3 Raise awareness and understanding of the archaeological heritage of the County especially sites where there is no physical remains above ground. Include a list in the Development Plan of the County’s Recorded Monuments i.e. a list of the protected archaeological sites in Fingal.
9.4 Examine measures to encourage the retention and re-use of the historic building stock of the County, in particular where no statutory protection has been assigned.
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9.5 Continue to update the Record of Protected Structures as appropriate; and review existing or examine potential new Architectural Conservation Areas.
9.6 Utilise new and existing mechanisms to increase knowledge of the heritage of Fingal and the appropriate methods to conserve it.
9.7 Integrate cultural heritage into the design of infrastructure at an early stage of development planning and management process.
9.8 Consider new ways of interpreting and incorporating archaeological monuments within open space.
9.9 Continue to implement the Fingal Heritage Plan 2011-2017 and review as required.
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APPENDIX A TO D
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 2017-2023
APPENDICES
APPENDIX A M K H G E D C B A L F J I DEVELOPMENT PLAN TIMELINE AMCHLÁR AN PHLEAN FORBARTHA Visit/Féach: www.fingal.ie/devplan Tuarascáil an phríomhfheidhmeannaigh ar aighneachtaí dréacht Week/ Tuarascáil an phríomhfheidhmeannaigh ar aighneachtaí Dara Comhairliúchán Poiblí ar Leasuithe Councillors consider Chief Executive’s Report Chief Executive’s Report on Submissions Prepare Draft For Public Consultation Prepare Amended Draft Development Plan Dréachtphlean Forbartha Leasaithe a Úllmhú Chief Executive’s Report on Submissions Breithníonn Comhairleoirí Tuarascáil an Bhainisteora Weeks/ Councillors Consider Managers Report Tuarascáil an phríomhfheidhmeannaigh ar aighneachtaí Weeks/ Weeks/ An Dréachtphlean Forbartha a Ullmhú Initial Public Consultation An Chéad Bhreithniúchán Poiblí ar an Dréachtphlean Forbartha Réamhchomhairliúchán Poiblí Second Public Consultation on Amendments Councillors Consider Draft Development Plan Breithníonn Comhairleoirí ar an Dréachtphlean Forbartha Preparation of Draft Development Plan Breithníonn Comhairleoirí tuarascáil an príomhfheidhmeannach Dréachtphlean Forbartha a Ullmhú ionas go mBreithneoidh an Pobal é Councillors Adopt Plan - Into effect in 4 Weeks Chief Executive’s Report on Submissions to Draft Glacann Comhairleoirí leis an bPlean – I bhfeidhm i 4 seachtaine Weeks/ Weeks/ Weeks/ Weeks/ Weeks/ First Public Consultation of Draft Development Plan Weeks/ Weeks/ Weeks/ Weeks/ Tréimhse Comhairliúcháin Consultation Period Seachtain Seachtain Seachtain Seachtain Seachtain Seachtain Seachtain Seachtain Seachtain Seachtain Seachtain Seachtain Seachtain 99 70 - 82 48 - 58 16 - 38 93 - 99 38 - 46 46 - 48 82 - 85 89 - 93 85 - 89 1 - 8 8 - 16 58 - 70 Tuarascáil ar Aighneachtaí Report on Submissions WE ARE HERE F F M M A A A M B B M J 2015 J I A L C M S Tréimhse Ullmhúcháin an Phlean Plan Preparation Period O D N S N D D E J E F F F M M A A M B G M J 2016 I J H A L M S Breithnithe na gComhairleoirí Councillors Considerations O D I N S J K D N L E J F F M 2017 M M A A M B
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APPENDIX B LIST OF SUBMISSIONS RECEIVED BY NUMBER AND NAME / ORGANISATION
Submission First Name Last Name Company Name Body/Organisation Reference (Submitter) (Submitter) (Submitter) Represented
P00001 J Lee P00002 Darren S. Mac an Phríora P00004 Ivo Brett P00005 Martin Naughton P00006 Owen Gerard O’Kane P00007 Holly McGowan P00008 Jonathan Hartshorn P00009 Ciara Feeney P00011 Aneta Laska P00012 Chloe Cooney P00013 William O’Connor P00014 Ann McNamee P00015 Annieta Jordan P00016 Annieta Jordan P00017 Ronan O Malley P00018 Mick Guildea P00019 Vincent JP Farry Vincent JP Farry & Co. Mr.S Mullen, Mr. P Ltd Grimes P00020 Aidan Maher P00021 Aidan Maher P00022 Aidan Maher P00023 Adaku Ezeudo i-Smile International P00024 Chloe Cooney P00025 Kieran Rush Kieran Rush Consult Sherman Oaks Ltd Ltd P00026 Joe McPeake P00027 Colm Moore P00028 Patrick Crowley ESB Networks P00029 Lorraine Bull Irish Wildlife Trust P00030 Ann Charleton P00031 Jason Fitzharris P00032 John Fitzgerald
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Submission First Name Last Name Company Name Body/Organisation Reference (Submitter) (Submitter) (Submitter) Represented
P00033 Tricia Ni Coitir P00034 Malachy Bradley Eastern & Midland Regional Assembly P00035 Vincent JP Farry Vincent JP Farry & Co. Chanel Homes Ltd P00036 Stephen Foley SFA P00037 Seán Barry Balbriggan Commu- nity Council P00038 Seán Barry Balbriggan Commu- nity Council P00039 Mark Brindley The Planning Partner- LIDL Ireland GmbH ship P00040 Seán Barry Balbriggan Commu- nity Council P00041 Seán Barry Balbriggan Commu- nity Council P00042 Seán Barry Balbriggan Commu- nity Council P00043 Seán Barry Balbriggan Commu- nity Council P00044 Seán Barry Balbriggan Commu- nity Council P00045 Seán Barry Balbriggan Commu- nity Council P00046 Seán Barry Balbriggan Commu- nity Council P00047 Brian Wylie Iarnrod Eireann / Irish Rail P00048 Cllr Justin Sinnott P00049 David Conway National Sports Campus P00050 Jamie Rohan Rohan Holdings P00051 Jamie Rohan Rohan Holdings P00052 Declan McCluskey Verona Sports & Lei- sure Club P00053 Tara Spain National Roads Au- thority P00054 Michael Jones P00055 David Byrne P00056 Joanna Jones
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Submission First Name Last Name Company Name Body/Organisation Reference (Submitter) (Submitter) (Submitter) Represented
P00057 Sylvia Jones P00058 David Holmes P00059 Joseph Behan P00060 Aidan Maher P00061 David Maguire Irish Solar Energy Association P00062 Dr. Raymond A Ryan Skerries Cycling Ini- tiative P00063 Shyam Sundar Chellamani Ireland Vinayaka Tem- ple Limited P00064 Eoin Farrell National Transport Authority P00065 Gael Gibson Eirgrid P00066 Veronica Kelly Dept. of Education and Skills P00067 Tara Buckley Retail Grocery Dairy & Allied Trades Assoc P00068 Gerry McDonagh Dept. of Justice and Law Reform P00069 Brian Arnold Lusk Community Lusk Community Council 2020 Sports Plan Committee P00070 Carolyne Lindsay Pobal Gaeilge Cúig Déag P00071 Andrew Craigie P00072 Brian Arnold Lusk Community Council P00073 Tony Brennan Woodland Park Resi- dents Association P00074 Jonathan Keogh Declan Brassil & Co. The Keogh Farming Ltd Partnership P00075 Jong Kim AKM Consultants Brierley Develop- ments P00076 Mary Brady Geological Survey of Ireland P00077 Malachy Quinn P00078 Hendrik van der Kamp Hendrik W van der Mike Woods Kamp - Town Planner P00079 Neil Cramer Skerries Sailing Club P00080 John Lee Mulhuddart Business Association
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Submission First Name Last Name Company Name Body/Organisation Reference (Submitter) (Submitter) (Submitter) Represented
P00081 Tom Winters P00082 Loretta Jennings Jennings P00083 Paul Donnelly P00084 Bob Kerr Castleknock Park Residents Association P00085 Aidan McGoey P00086 Aidan McGoey P00087 Patricia O’Leary Department of Arts Heritage and the Gaeltacht P00088 Edward McGuire P00089 Paul Gormley Fingallians GAA Club P00090 Eamonn Flanagan P00091 Philip Cleere
P00092 Holly Westwood Malahide Community Forum P00093 Roger Garland P00094 John Fynes P00095 Gerry Riordan
P00096 David Reilly DR Consultants Shuhada Foundation of Ireland P00097 Thomas Freeman Douglas Hyde & Asso- Menolly Homes ciates P00098 Ken Swaby ILTP Consulting Sainfoin Property Company P00099 Seán Barry Balbriggan Commu- nity Council P00100 Seán Barry Balbriggan Commu- nity Council P00102 Suzanne Dempsey Irish Water P00103 Deirdre O’Connor NAMA P00104 Simon McGreevy DAA (Dublin Airport) P00105 Jana Stefanova
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 v 2017-2023 APPENDICES
Submission First Name Last Name Company Name Body/Organisation Reference (Submitter) (Submitter) (Submitter) Represented
P00106 Evan Cullen Irish Airline Pilots Association (IALPA) P00107 Gerardine McGuinness P00108 Anne Sheridan Kirkpatrick Rockfield Coolmine Residents Association (KRCRA) P00109 Michael Mcloughlin P00110 Leonard Skelly Strawberry Beds Res- idents Association P00111 Philip Lynam P00112 Tom Crowley P00113 Sylvia Guy P00114 Helena Merriman St. Margaret’s Con- cerned Residents Group P00115 Andrea Patterson Saint Columba’s Church Restoration Committee P00116 Colm Mythen P00117 Maura Murtagh P00118 Ann McLoone P00119 Seán Barry Balbriggan Commu- nity Council P00120 Paul Johnson P00121 Kieran O Neill Dublin 15 Communi- ty Council P00122 Brian Dennehy P00123 Martin Davis ISKCON IRELAND P00124 Peter Monks P00125 Peter Monks P00126 Peter Monks P00127 John Roche P00128 Brian Dennehy P00129 Niall Power P00130 Brian Dennehy P00131 Roderic O’Gorman P00132 Nora Shortall JFOC Design and Plan- ning
vi Chief Executive’s Report Pre-Draft Consulation July 2015 Fingal Development Plan 2017-2023 APPENDICES
Submission First Name Last Name Company Name Body/Organisation Reference (Submitter) (Submitter) (Submitter) Represented
P00133 Venerina Legname P00134 Niall Power P00135 Mary Hamilton P00136 Peadair O Monacahain P00137 Mary Hamilton P00138 Maria Gallagher P00139 Paddy Dooly P00140 Ray Donnellan Dublin Bus P00141 Conor Daly P00142 Hennie Kallmeyer Declan Brassil and Co. Station Construction Ltd Ltd. P00143 Alison Quinn P00144 Michael Hanaway P00145 Helen Foley P00146 Tom Winters P00147 Thomas P. Broughan T.D. Dublin Bay North Constituents P00148 James H P00149 Michael Leahy P00150 Paul Turley John Spain & Associ- Glasnevin Trust ates P00151 Ken Swaby ILTP Consulting Byrne Lands at Dun- soughly P00152 Nora Shortall JFOC Design and Plan- Sneem Properties ning Ltd. P00153 Thomas Larkin P00154 Darren Brady
P00155 Ciara Ní Laoi Friends of Balscad- den Bay P00156 Sarah Miley P00157 Stephen M. Purcell Future Analytics Con- Omega Air sulting Ltd. P00159 Neil Higginbotham P00160 Owen McGinty P00161 Conor Byrne Green REIT Horizon Ltd P00162 Alan Whelan O’Connor Whelan Aldi Stores (Irl) Ltd
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 vii 2017-2023 APPENDICES
Submission First Name Last Name Company Name Body/Organisation Reference (Submitter) (Submitter) (Submitter) Represented
P00163 Simon Clear Simon Clear & Asso- Vincentian Order ciates P00164 Cathal Boland P00165 Kevin Hughes Hughes Planning & Patricia Lord Development Consul- tants P00166 Martin Hoban Cunnane Stratton H2Blake Ltd. Reynolds P00167 Nicola Rutledge P00168 Kevin Hughes Hughes Planning & Kieran Kiernan Development Consul- tants P00169 Bryan Maher Rathborne Commu- nity Association P00170 Owen McGinty P00171 Pauline Byrne Brady Shipman Martin Keelings P00172 Pauline Byrne Brady Shipman Martin Keelings P00173 Kevin Hughes Hughes Planning & Toyoko Inn Interna- Development Consul- tional Ltd. tants P00174 John Walsh Dublin West Labour Party P00175 Dan Egan The Big Space Carley Propoerties Ltd. P00176 Ann Mulcrone Reid Associates A & L Goodbody P00177 Nikki O’Dea P00178 Patrick Rutledge P00179 Gerry Foley P00180 JG Consulting JG Consulting Marron Agricultural Company P00181 Margie McLoone P00182 Conor Crotty Artisan Army P00183 JG Consulting JG Consulting Genvest Ltd. P00184 Gerry Foley P00185 Fintan Price Rush Community Council P00186 JG Consulting JG Consulting Danhill P00187 George Mongey Swords Tidy Town P00188 Robert MccLoughlin GVA Educena Foundation P00189 Kieran Kennedy RPS Planning & Costco Wholesale Ltd Environment
viii Chief Executive’s Report Pre-Draft Consulation July 2015 Fingal Development Plan 2017-2023 APPENDICES
Submission First Name Last Name Company Name Body/Organisation Reference (Submitter) (Submitter) (Submitter) Represented
P00190 Donal Shanahan P00191 Muirenn Duffy GVA Tesco Ireland Ltd P00192 David Healy P00193 Leo McKittrick P00194 Mary McCann P00195 Justin Byrne Liffey Valley Park Alliance P00196 Peter Boyd P00197 Attracta Uí Bhroin An Taisce P00198 Geoff McEvoy Skerries Community Association P00199 Edward Mac Manus P00200 John Raeside P00201 Paul Turley John Spain Associates Park Developments Group P00202 Noelle Corcoran Donabate Portrane Dramatic Society P00203 Sinead Owens Navan Road Commu- nity Council P00204 Emma Gosnell New Generation Homes Ltd. P00205 Helen Lahert Howth Special Amen- ity Order Committee P00206 Mary McCann P00207 Canice Reade P00209 Kate Fitzgerald P00210 Martina Wogan P00211 Anthony Heijenga GIA Consultancy P00212 Eleanor MacPartlin Stephen Little & Asso- Killeen Properties ciates Ltd. P00213 Andrew McGrane Ecocem P00214 Joe O’Brien Green Party P00215 Colm Cummins ESB P00216 M Sharif Nayyar Muslim Community of North Dublin P00217 Charles Monks Rush Community Development Com- mittee P00218 John Spain John Spain Associates Castleknock Golf Club
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 ix 2017-2023 APPENDICES
Submission First Name Last Name Company Name Body/Organisation Reference (Submitter) (Submitter) (Submitter) Represented
P00219 Eleanor MacPartlin Stephen Litte & Asso- TEBA, Irish Life Assur- ciates ance plc & IPUT P00220 John Austin P00221 Clare Burke Conroy Crowe Kelly McGarrell Reilly Group
P00222 Paul McVeigh Conroy Crowe Kelly Hansfield Invest- ments Ltd P00223 Siobhan O’Neill P00224 Maria Stanley P00225 Daire Ni Laoi P00226 Rory Scannell P00227 Josh Maguire The House Architects Tom Leonard P00228 James Leonard Castlethorn Construc- tion P00229 Josh Maguire The House Architects Patrick Leonard P00230 Roy Harford P00231 Edward Stevenson P00232 Josh Maguire The House Architects Tom Leonard P00234 Josh Maguire The House Architects Patrick Leonard P00235 John Downey Downey Planning Noel McAllister P00236 John Downey Downey Planning Gannon Properties P00237 Eamon McBride P00238 Kevin Tolan KT Designs Ray & Lynda Murphy P00239 Gerry Roarty Mary O’Dea P00240 Máire Kelly P00241 Eilish McDermott P00242 Mick O’Brien P00243 Anna Churcher P00244 Jim Egan Hughes Planning & Pat White Development Consul- tants P00245 Anne Thornton Howth Pathways P00246 Madeline Mangan P00247 Mary & Anthony Fitzpatrick P00248 Keith Finn
x Chief Executive’s Report Pre-Draft Consulation July 2015 Fingal Development Plan 2017-2023 APPENDICES
Submission First Name Last Name Company Name Body/Organisation Reference (Submitter) (Submitter) (Submitter) Represented
P00249 Michael Grimes P00250 Dr. Dee Duffy P00251 Glenda Maddy P00252 John Murphy BMA Planning Lidl Ireland GmbH P00253 Martin Duffy P00254 Elizabeth McDonnell Woodland Park Res- idents P00255 John Murphy BMA Planning Noel O’Flaherty P00256 John Murphy BMA Planning Musgrave Group P00257 Joseph Corr Corr & Associates P00258 Joseph Corr Corr & Associates P00259 Joseph Corr Corr & Associates P00260 Susan Quinn P00261 Patrick J Hurley Archer Nurseries P00262 John F O’Connor JFOC Design & Plan- Leonie Gallagher ning P00263 John Murphy BMA Planning Flynn & O’Flaherty (Dublin) Ltd. P00265 Susan Doorley P00266 Helena Gavin RPS Planning & Envi- Cosgrave Develop- ronment ments P00267 Kieran Kennedy RPS Planning & Envi- Costco Wholesale ronment Ltd. P00268 Breda Dockrell P00269 Theresa O’Donoghue P00270 Patrena Slowey RPS Planning Environ- Elmslope Ltd.(Hollyst- ment won Golf Club) P00271 Michael Halligan P00272 Kevin Hughes Hughes Planning & Balmoral Land Rath- Development Consul- beale Ltd. tant P00273 Michael Halligan Hamilton Care Facil- ity P00274 Michael Halligan Sinead O’Hanrahan P00275 Kevin Hughes Hughes Planning & John Smith & John Development Consul- Paul McNeese tant P00276 Michael Halligan Brendan & Catherine Barden
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 xi 2017-2023 APPENDICES
Submission First Name Last Name Company Name Body/Organisation Reference (Submitter) (Submitter) (Submitter) Represented
P00277 Bridget Doyle P00278 Kevin Hughes Hughes Planning Crescent Park & Development Properties Consultant P00279 Kevin Hughes Hughes Planning Crescent Park Prop- & Development erties Consultant P00280 Jonathan Quinn BGM Consulting John & Rosemary Tevera P00281 John Downey Downey Planning David Campion P00282 John Downey Downey Planning Hollywood Lakes Golf Club P00283 John Downey Downey Planning Mssrs. O’Connor, Byrne & Halligan P00285 John Downey Downey Planning MKN Property Group P00286 Owen McGinty P00287 Martin Sweeney Balbriggan Commu- nity Liaison Commit- tee P00288 John Downey Downey Planning Audrey Leonard P00289 John Downey Downey Planning Gerry Tallon P00290 Brian O’Leary Dublin Meat Company P00291 John Downey Downey Planning The National Council of Urban Land Insti- tute (Ireland)
P00292 Kevin Hughes Hughes Planning & Liam Thorn Development Consul- tant P00293 Kevin Hughes Hughes Planning & Pegasus Life Development Consul- tant P00294 Jim O’Donoghoe P00295 Ben Waite ILTP Consulting Frank Grant Garages Ltd. P00296 Kevin Hughes Hughes Planning & Ross Kiernan Development Consul- tant P00297 Christopher Brady
xii Chief Executive’s Report Pre-Draft Consulation July 2015 Fingal Development Plan 2017-2023 APPENDICES
Submission First Name Last Name Company Name Body/Organisation Reference (Submitter) (Submitter) (Submitter) Represented
P00298 Kevin Hughes Hughes Planning & Debbie Kiernan Development Consul- tant P00299 Kevin Hughes Hughes Planning & JC Supermarket Ltd Development Consul- tant P00300 Kevin Hughes Hughes Planning & Stephen Bannon Development Consul- tant P00301 Geraldine John Dockrell Whelan, P00303 Hubert Madigan P00304 Michael James Sutton O’Connor, P00305 Rory Flynn P00306 Liam Lumley P00307 John Downey Downey Planning Brian McDonnell, St. Margarets Recycling & Transfer Centre Ltd. P00308 John Downey Downey Planning Bernard Watsom P00309 Sean Lyons P00310 John Downey Downey Planning Noel McAllister P00311 John Downey Downey Planning St. Margaret Re- cycling & Transfer Centre P00312 John Downey Downey Planning Mary & Norma Ho- gan P00313 John & Anna Daly P00314 John Downey Downey Planning Jennifer Kealy (nee Dwyer) P00315 Colm McDonald P00316 Anonymous Garristown Commu- nity P00317 Peadar O’Kelly P00318 Kieran O’Malley Kieran O’Malley & Co. Mardown Ltd. Ltd P00319 Jim Brogan Jim Brogan Planning & Cumann Luthcleas Development Consul- Gael Coiste Atha tant Cliath (Dublin GAA County Board)
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 xiii 2017-2023 APPENDICES
Submission First Name Last Name Company Name Body/Organisation Reference (Submitter) (Submitter) (Submitter) Represented
P00320 Kieran O’Malley & Co. Kieran O’Malley & Co. Padraig & Geraldine Ltd Ltd Scanaill P00321 Jim Brogan Jim Brogan Planning & Dublin GAA County Development Consul- Board tant P00322 Cllr Malachy Quinn P00324 John Downey Downey Planning MKN Property Group & Balmoral Land Swords P00325 John Downey Downey Planning Rolat Ltd. & Rohan Holdings Ltd. P00326 John Downey Downey Planning Ian McGuinness & Other Landowners P00327 Andrew McGrane Ecocem
In total 327 Submissions were initially recorded however, Submission Nos. P0003 and P00010 refer to submissions lodged in error, which are not related to the Development Plan review process. In addition Submissions P00189 & P00267; P00213 & P00327; and P00227 & P00232 are duplicates of each other.
xiv Chief Executive’s Report Pre-Draft Consulation July 2015 Fingal Development Plan 2017-2023 APPENDICES
APPENDIX C List of prescribed bodies who were informed of the Review of the Development Plan under the statutory process. Minister for Food, Marine and Defence
Minister for Defence
Minister for Education & Skills
Minister for Transport, Tourism & Sport
Department of Communications, Energy & Natural Resources
Minister for Communications, Energy & Natural Resources
Minister for Justice & Equality
Minister for Jobs, Enterprise & Innovation
An Bord Pleanala
Dublin Airport Authority
Failte Ireland
Central Fisheries Board
An Colmhairle Ealaoin
Office of Public Works
National Transport Authority
ESB
Local Health Office
Heritage Council
National Authority of Occupational Safety & Health
National Roads Authority
Eastern Regional Fisheries Board
An Taisce
UCD
Meath County Council
South Dublin County Council
Dublin City Council
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 xv 2017-2023 APPENDICES
Eastern & Midland Regional Assembly
Department of the Environment, Community and Local Government
Department for the Arts, Heritage & the Gaeltacht
Environmental Protection Agency
Irish Aviation Authority
Kildare County Council
Rail Procurement Agency
Minister for Children & Youth Affairs
Irish Water
Eirgrid
Wicklow County Council
Meath County Council
Louth County Council
Dun Laoghaire - Rathdown County Council
Fingal Development Board
xvi Chief Executive’s Report Pre-Draft Consulation July 2015 Fingal Development Plan 2017-2023 APPENDICES
Appendix D List of organisations invited to the Stakeholder meetings.
4th Bayside Village Environment Group 13+ Transition Youth Club/NYP 181st Castaheaney/Ongar Scout Group Abbey Park & District Residents Association Aldemere Residents Association Applewood Community Centre Artisan Army Ireland Artists Rest Workshop Ashleigh Residents Association Avondale Park Committee Group Badminton Ireland Balbriggan Cancer Support Group Balbriggan Chamber of Commerce Balbriggan Community Council Balbriggan & District Historical Society Balbriggan Golf Club Balbriggan Maritime Museum Committee Balbriggan Tidy Towns Balbriggan Town Decoration Committee Balbriggan Youth Service Baldoyle and District Men’s Shed Baldoyle Family Resources Centre Baldoyle Forum Limited Baldoyle Parish Council Balgriffin T.T.C. Ballyboughal Community Council Ballyboughal Foroige Youth Club Ballyboughal Hedgerow Society Ballyboughal Pitch & Putt Club Balrothery Community Council Balrothery Heritage Committee Balrothery Tidy Towns Balscadden District Community Council Bayside Youth Club Biscayne/Lambay Residents Association Blakestown Mountain View Educational Programme Blakestown & Mountain View Youth Initiative
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Blakestown Community Resource Centre Ltd Blanch Blitzer’s, Special Olympic Bowling Club Blanchardstown Castleknock History Society Blanchardstown Centre for Independent living Blanchardstown Centre for the Unemployed Blanchardstown Citizen Information Centre Blanchardstown Community Training Centre Blanchardstown Methodist Centre Blathanna Beaga Teoanto trading as Lifestart Bramley Wood Residents Association Briarswood Huntstown Lawn & Woodlands Residents Association CCE Port Mearnog Caden Academy Cairde Balbriggan Cameroonian & Irish Association Castaheany Community Centre Ltd Castlefield Court Residents Association Castleknock Community Centre Association Limited Castleknock Localise Youth Group Cianlea Residents Association Cityside Phase 1 Residents Committee Cloghran Historical Society Clonee United Cois Inbhir Residents Association Coolmine Community School Corduff Sports Centre Corduff Womens Group Crosscare D15 Mens Shed Diswellstown Community & Recreational Centre Ltd Domville Woods Residents Association Donabate Historical Society Donabate & Portrane Community Centre Donabate Portrane Community Council Donabate Portrane Swimming Pool Association Donabate Sea Scouts – 63rd Dublin Drynam Avenue-Russells Terrace Residents Association Dublin 15 Community Council Dublin 15 Womens Group Dublin Simon Community
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Duo Chagall Early School leavers Program Blanchardstown Youth Service Family Mirror Fancourt Residents Association Fingal Bereaved by Suicide Support Service Fingal Counselling Service Fingal County Childcare Fingal Environmental Network Fingal Ethnic Network Fingal Ireland/Poland Inter-cultural Association Fingal Horticultural Society Fingal Triathlon Club Fingal Volunteer Centre Flemington Community Centre Foroige Friends of Balscadden Bay Friends of East Mountain Friends of Lusk Community Unit Garristown Community Council Garristown Historical Society Global Movement for Change and Project Colourful Grow in Ireland Hamilton Residents Association Hampton Cove Residents Association Haven Residents Association Heathfield Residents Association Holywell Community Centre Housing Association for Integrated Living (HAIL) Howth Brownie Guides Howth Sutton Horticultural Society Huntstown Family Resource Centre Ltd Iiyo Taekwondo Club Irish Red Cross Dublin 15 Branch Holywell Residents Association Homeleigh & Portertown Residents Association Howth pathways Howth Peninsula Heritage Society Howth/Sutton Community Council Howth, Sutton and District Community Centre Ltd Huntstown Community Youth project
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Ireland Tehuhu Association Irish Kennel Club Irish Wheelchair Association Jigsaw Dublin 15 Kirkpatrick Rockfield Coolmine Residents Association Lusk Athletic Club Lusk Heritage Group Lusk Tidy Towns Association Lusk Village Residents Association Malahide Community Forum Malahide Historical Society Malahide Lions Club Malahide Rugby Club Malahide Tidy Towns Malahide United Mid Sutton Community Centre Millview residents Association Mulhuddart Community Centre Mulhuddart Senior Citizens Club nanBaenda Networking Dublin 15 New Communities Partnership North Fingal Community Transport Old Yellow Walls Residents association Ongar Community Centre Ongar Tidy Towns Osun Descendants Union Ireland Parents Association Gaelscoil ROS ED Phoenix writers Group Pinewood Residents Association Pop Up Artists Portersgate Residents Association Portertown Scout Group Portmarnock Beach Clean Coast Portmarnock Integrated Arch Clun Portmarnock Sub Aqua Club Pride in Bayside Prosper Fingal RCCG Remember Us
xx Chief Executive’s Report Pre-Draft Consulation July 2015 Fingal Development Plan 2017-2023 APPENDICES
Revival Active Retired Group River Valley Active Retirement Group River Valley Community Club River Valley & Rathingle Residents Association Rivermeade Community Centre Rolestown Oldtown Historical Association Romanian Community of Ireland Rowlinstown Community Centre Royal Friends Club Ireland Rush Community Council Rush GIY Rush Mens Shed Rush Multi-purpose Youth Facility Rush Playground Group Rush senior Citizens Rush Tidy Towns Rush Youth Cafe St Bridgets Castleknock Community College St Cronans Residents Association St Johns Ambulance Ireland St Margarets Concerned Residents Group St Patrick Hall, Ballyboughal St Patricks Brass Band Saddlers Residents Association Santry Community Garden Seabury Tidy District Group Sheepmoorians 35 Skerries Community Association Skerries Community College Skerries Cycling Initiative Skerries Guerrilla Gardeners Skerries Historical Society Skerries Reaching Out Skerries Town FC Skerries Womens Volleyball Club Slovak Centre - Ireland Snowflakes Autism Support Spinal Injuries Ireland Sports Club 15 Strand Street Residents Association
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 xxi 2017-2023 APPENDICES
Student Support Tyrrelstown Sustainable Skerries Sutton Dinghy Club Swords Baldoyle Youth Service Swords Celtic FC Swords Historical Society Swords Mens Sheds Swords Pride of Place Committee Swords Tidy Towns Tayleurs Point Residents Association The Bleeding Pig Cultural Festival The Burrow Residents Association The Transport Museum Society of Ireland Ltd The Tuesday Club Thormanby Lawns Residents Association Thornleigh Residents Association Tyrellstown Community Centre University of the 3rd Age U3A Visit Howth Peninsula Limited Westbrook Phase One Residents Association Wisdom Learning Centre Woodland Park Residents Association Youth Reach Balbriggan The Society of Chartered Surveyors Irish Planning Institute Construction Federation of Ireland Fingal Business Forum Institute of Engineers in Ireland Chambers of Commerce Ireland Irish Farmers Association Irish Organic Farmers and Growers Assoc Solas Dept. of Jobs. Enterprise and Inovation Irish Council for Science, Technology and Innovation The Royal Institute of Architects of Ireland Irish Business and Employers Federation Tourism Ireland Irish Hotels Federation Enterprise Ireland Irish Fisherman’s Organisation
xxii Chief Executive’s Report Pre-Draft Consulation July 2015 Fingal Development Plan 2017-2023 APPENDICES
Irish Landscape Institute Rural Dublin LEADER Co. Ltd Irish Small and Medium Enterprise Assoc. Blanchardstown Area Partnership Fingal Enterprise Board BEA Orpan Building Co-operation Fingal IDA Ireland Irish Homebuilders Association Meteor Eircom Vodafone Ireland Ltd NTL Communications 02 Small Firms Association Malahide Chamber of Commerce Balbriggan Chamber of Commece Keelings Retail Excellence Ireland Irish Road Haulage Association Irish National Organisation of the Unemployed Congress Centres for the Unemployed Age Action Ireland Community Action Network European anti-poverty Network Gay and Lesbian Equality Network Irish Penal Reform Trust Irish Refugee Council Irish Traveller Movement National Adult Literacy National Network of Women Refuges & Support Service National Traveller Women’s Forum Pavee Point Traveller Centre Rape Crises Centre Simon Communities Ireland Threshold Voluntary Drug Treatment Network Vincentian Partnership for Justice Women’s Aid Conference of Religious in Ireland (CORI)
Fingal Development Plan Chief Executive’s Report Pre-Draft Consulation July 2015 xxiii 2017-2023 APPENDICES
National Womens Council of Ireland National Youth Council of Ireland Society of St. Vincent de Paul Protestant Aid New Communities Partnership National Association of Tenant’s Associations National Association of Building C0-Operatives (NABCO) Fingal Awareness of Disability & Equality Disabled Federation of Ireland Irish Society of Prevention of Cruelty to Animals Association of Combined Residents Association Association for Refugees & Asylum Seekers in Ireland GAA Dublin Trades Council Comhairle na nOg Irish Council for Social Housing Fingal Leader Partnership Blanchardstown Traveller Development Group FAI Community Workers Co-Operative Irish Commission for Prisoners Overseas Irish Rural Link Forum of People with Disabilities Age Friendly Alliance European Anti-poverty Network Irish Association of Older People National Travellers Womens Forum Carers Association The Wheel Irish Senior Citizens Parliment Children’s Rights Alliance Bat Conservation Ireland Bird Watch Ireland CELT – Centre for Ecological Living Coomhola Salmon Trust Conservation Volunteers Ireland Crann Eco Unesco Feasta Forest Friends Friends of the Earth
xxiv Chief Executive’s Report Pre-Draft Consulation July 2015 Fingal Development Plan 2017-2023 APPENDICES
Friends of the Irish Environment Gluaiseacht for Global Justice Grian Hedge Laying Association of Ireland Irish Doctors Environmental Association Irish Natural Forestry Foundation Irish Peatland Conservation Council Irish Seal Sanctuary Irish Seed Savers Association St. Michaels House North Prosper Fingal Irish Countrywomen’s Association Irish Teachers Organisation RESPOND (Housing Association) Rail Users Ireland The Organic Centre Irish Whale and Dolphin Group Irish Wildlife Trust Irish Congress of Trade Unions National Council for the Blind Irish Wheelchair Association Down Syndrome Ireland Irish Football Association Irish Rugby Foottball Club Blanchardstown Area Partnership FAI Swords Irish Red Cross Comholtas Eireann Blanchardstown Centre for Independent Living Crosscare Irish Hockey Association Irish Sailing Association Pitch and Put Ireland Triathlan Ireland Fingal Hedgegrow Society Base Enterprise Centre Plato Fingal Enterprise Board Blanchardstown Institute of Technology Fingal Chamber of Commerce
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xxvi Chief Executive’s Report Pre-Draft Consulation July 2015 Fingal Development Plan 2017-2023