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Senior Executive Officer, Planning and Strategic Infrastructure Department, County Council, County Hall, Swords, Co. Dublin K67 X8Y2. Date: 29th April 2016

Dear Sir / Madam,

RE: SUBMISSION ON THE FINGAL DRAFT DEVELOPMENT PLAN 2017-2023 IN RELATION TO LANDS AT KINSEALY CO. DUBLIN

1.0 INTRODUCTION

1.1 On behalf of our clients, Alhans Limited (in receivership) over which Declan McDonald and William O' Riordan of PWC, One Spencer Dock, North Wall Quay, Dublin 1 were appointed (on 25 April 2012) as joint receivers of the assets, we wish to make a submission on the Draft Fingal County Development Plan 2017 – 2023, which is currently inviting submissions until 29th April 2016. This submission relates to a significant development parcel located in the core of Kinsealy Village, 4.09 ha of which are zoned RV Rural Village and 2.42 ha of which are unzoned. This submission seeks the zoning of the entire parcel of lands for RV purposes and the extension of the settlement boundary of the village in the interests of consolidation and to promote the orderly development of the village.

1.2 The RV Rural Village zoning seeks to:

“Protect and promote the character of the Rural Village and promote a vibrant community in accordance with an approved Local Area Plan, and the availability of physical and community infrastructure.”

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1.3 It is outlined in the draft plan that a Local Area Plan will be prepared for Kinsealy which will set out the detail regarding the future growth and development of Kinsealy Village.

1.4 However, it is important that the County Plan provides the strategic planning framework within which the LAP will be prepared. In this submission we will set out the rationale for amending the development boundary of Kinsealy Village and extending the RV zoning on our client’s lands in the draft County Plan to ensure that a sustainable pattern of development can be progressed there over the plan period. It is submitted that the development boundary as indicated in Map 9 of the draft plan should be amended to include further lands to the west. These lands should also be zoned RV. The inclusion of this land would allow a preferable consolidated form of development in Kinsealy.

Balance of Alhans Ltd. lands

Proposed extension to settlement boundary and RV zoning

Fig. 1: Extract from Zoning Map – Draft Fingal County Development Plan 2017-2023 indicating proposed extension to settlement boundary and RV zoning.

1.5 We also set out the objectives of our clients for the future of these lands and the key role that they will play in the future development and consolidation of Kinsealy Village. It will be detailed in this submission that sequentially these lands are best placed to ensure the appropriate and sustainable development of Kinsealy Village and in this regard should be prioritised for development. In this context the settlement boundary of Kinsealy Village should be amended in the review of the County Plan and the subject land zoned RV to ensure consistency with the future LAP for the settlement.

2.0 SITE LOCATION AND DESCRIPTION

2.1 The subject lands measure 6.51 ha and are located on the western side of the Road at the junction with Chapel Lane. Baskin Lane travels along the southern boundary of the site.

2.2 The site is bound to the south and north by a dense hedgerow with trees, and to the east by a low limestone wall, trees and hedgerow. The Sluice River runs to the north of the site. The grounds of the large Abbeville estate are located to the north which is identified as an Architectural Conservation Area. The landholding borders

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but does not encroach on this Conservation Area. The site is currently in agricultural use and there are agriculture gates on the eastern and southern boundaries.

2.3 The lands are located opposite the St. Olave development which comprises a residential development and a modest neighbourhood centre accommodating retail and commercial units. Also opposite the site is St. Nicholas Catholic Church and associated school building.

2.4 The lands are served by a public foothpath both along the Malahide Road and Baskin Lane. Further west on Baskin Lane there are a number of detached dwellings. At the junction of Baskin Lane and the Malahide Road, opposite the subject site is the Kinsealy Garden Centre. The Teagasc Research Centre is located further to the south.

2.5 The lands are served by a Route and are strategically located within the core of the village centre. In this regard they provide an obvious opportunity to consolidate development within the village core and create more of a defined village streetscape.

Fig. 2: Approximate Site Location

Fig.3: Kinsealy Village Centre (Subject lands to left)

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Fig. 4: Baskin Lane (Subject Lands to right)

Fig. 5: St. Nicholas Church Fig. 6: St. Olave Neighbourhood Centre

2.6 The village therefore accommodates all of the key ingredients that make successful communities and the development of the subject site, including the proposed extended area for residential use, provides an opportunity to consolidate the role of the village in the settlement hierarchy of the County. Its location within the core of the village surrounded by land uses and services that support residential use, means its development as proposed accords with best planning practice.

2.7 Existing development in Kinsealy Village is generally low density and linear in nature. The route of the proposed Kinsealy Bypass runs along the western boundary of the site in part and traverses the northern part of the site.

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3.0 STATUTORY CONTEXT

FINGAL COUNTY DEVELOPMENT PLAN 2011-2017

3.1 The current statutory Development Plan for the lands is the Fingal County Development Plan 2011 – 2017. The subject lands are primarily zoned:

Zoning objective “RV” rural village:

Objective: Protect and promote the character of the Rural Village and promote a vibrant community in accordance with an approved local area plan, and the availability of physical and community infrastructure.

Vision: Protect and promote established villages within the rural landscape where people can settle and have access to community services. The villages are areas within the rural landscape where housing needs can be satisfied with minimal harm to the countryside and surrounding environment. The villages will serve their rural catchment, provide local services and smaller scale rural enterprises. Levels of growth will be managed through local area plans to ensure that a critical mass for local services is encouraged without providing for growth beyond local need and unsustainable commuting patterns.

3.2 The following specific objectives relate to villages:

“Develop each village in accordance with a Local Area Plan (LAP) which will provide the optimal development framework to ensure the protection and enhancement of the existing village, the strengthening and consolidation of the village core and the provision of a high quality living environment for the existing and future population of the village.”

3.3 Part of our clients the lands to the west are outside of the development boundary and are unzoned.

3.4 It is stated in the plan that there is 6.6ha of land zoned for residential use in Kinsealy providing sufficient land for 109 new housing units. It is submitted that this is a very modest allocation of residentially zoned land considering the strategic location of the village and its good public transport connections. It is considered that Kinsealy, given its proximity to existing facilities and amenities and its public transport connections has the capacity for further residential development. It is envisaged that the subject lands that are sought to be included within the settlement boundary which constitute 2.42 ha could accommodate further housing provision. This additional housing would ensure the sustainable development of Kinsealy Village whilst maintaining its position as a rural village within the overall settlement hierarchy.

3.5 The inclusion of the subject lands within the settlement boundary and their zoning as RV would also provide a greater spatial balance to the existing pattern of development in the village which to date has largely been concentrated to the east of the Malahide Road.

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Lands outside Plan Boundary

Fig. 6: Extract from Fingal County Plan 2011-2017 Zoning Map

Fig. 7: Location of Lands outside Development Boundary

Draft Fingal County Development Plan 2017 - 2023

3.6 Under the draft County Development Plan, part of our clients lands retain their RV zoning:

“Protect and promote the character of the Rural Village and promote a vibrant community in accordance with an approved Local Area Plan, and the availability of physical and community infrastructure.”

3.7 However, the western extremity of the lands remains outside the settlement boundary and are not zoned RV.

3.8 It is stated in the Plan:

“The future development of Fingal’s villages needs careful consideration. In the metropolitan area growth in villages such as Coolquay, Kinsealy, and Rowlestown will be managed to ensure these centres do not expand rapidly, putting pressure on services and the environment and creating the potential for unsustainable travel patterns.”

3.9 In terms of capacity over the plan period, the plan identifies that there is 94 ha of land available in the small towns and villages which has the potential to yield 877 residential units. However, the County Plan does not specify a specific allocation to each village. It is respectfully submitted that Kinsealy is more strategically located than Coolquay, Rivermeade and Rowlestown and has a better provision of public transport, local facilities, amenities, and social and community infrastructure. In this context it is well placed to absorb additional residential development.

3.10 With regard to Kinsealy, it is further detailed in the draft plan:

“Kinsealy is a small village settlement within the Metropolitan Area with a strong visual identity and landscape quality formed by the Sluice River, running east-west through the village, and by the stone walls and mature trees associated with the nearby Abbeville Demesne. The busy Malahide Road (R107) runs north-south to the west of the existing village. Chapel Road which splits the village runs east-west

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and forms a junction with the R107 at the Parish Church of St. Nicholas of Myra, a protected structure. The village is about mid-way between Malahide to the north and to the south and is surrounded by greenbelt. The village core is centred on the parish church, some cottages and the relatively recently developed lands at St. Olave’s local centre and residential development. Functionally, the village can be described as a commuter village under development pressure. Lands within the village boundary are subject to new residential planning permissions with one such development at Cooper’s Wood to the east of Kinsealy Lane which is nearing completion.

Local employment exists in the form of Kinsealy Business Park, comprising light industrial units and offices built in the late 80’s and accessed off Kinsealy Lane. Until recently, the Teagasc site to the south of the village offered significant rural based employment but this has ceased since consolidation into the Teagasc Centre in . Other employment uses are focused on existing retail services along the Malahide Road, many of which are non-conforming in the context of their greenbelt location. Kinsealy has a current population of circa 340 persons.”

3.11 With regard to future development in Rural Villages, the draft plan contains the following statement of policy:

 Promote attractive and vibrant villages.  Ensure sustainable expansion and development at a level appropriate to and integrated with the existing village.  Meet the socio-economic and civic aspirations of the community, whilst at the same time affording maximum environmental protection.  Preserve the villages' distinctive character, heritage, amenity and local identity.

3.12 With regard to these objectives it is considered that the proposed modest extension of the settlement boundary and RV zoning as it relates to the subject lands would comply with these criteria. The subject lands represent a sustainable extension to the village core and would help rebalance the spatial pattern of development in the village. The extent of land proposed for rezoning is modest and would ensure the sustainable delivery of much needed housing to this area of the County. Their inclusion within the settlement boundary would have no adverse impact on the character of the village and indeed would help consolidate the existing pattern of development. Therefore the subject lands represent an appropriate extension to the existing urban envelope.

3.13 The draft plan notes:

“In the course of preparation of LAPs for each of the Rural Villages, consideration may be given to the extent of the RV zoning objective. This may result in a reduction or small scale extension of the existing zoning. Changes to the RV zoning will be considered only where it can be clearly shown that this contributes significantly to the development objectives for the village, and that there is a clear evidence base for such a proposed change.”

3.14 It is submitted however, that to ensure consistency, that the development boundary of Kinsealy as indicated in Map 9 of the Draft Plan should be amended at this stage to ensure consistency with the future LAP for the village. There is a clear evidence base for the amendment of the village boundary as will be set out in detail in section 4 below.

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4.0 VILLAGE GROWTH AND DEVELOPMENT

4.1 The core of Kinsealy Village is centered around St. Nicholas Church and the adjacent neighbourhood centre. The subject lands are pivotally located to form a natural extension to the village centre, to consolidate the urban form and provide for a more appropriate traffic calmed pedestrian orientated thoroughfare through the village centre. In this regard the future growth and development of Kinsealy should be focused around the village core and the subject lands in order to create a compact village centre.

4.2 Our client envisages the development of the subject lands will be a sustainable village extension, with the development of high quality, low density residential development that will complement and enhance the village structure. Future growth should be directed towards the subject site as these lands represent the most opportune lands to create a natural and sustainable extension to the village. The lands are sequentially preferable to other land zoned RV within the settlement boundary and in this context the extension of the current settlement boundary should be considered.

4.3 It is important that the lands that are the most appropriately located to allow for the consolidation of the village core and create a compact and walkable neighbourhood are priortised for development. The subject lands are the most appropriate location in this regard.

4.4 It is evident that the core of Kinsealy Village needs to be consolidated and developed. At the moment, development is dispersed in a linear fashion and is predominantly located on the eastern side of the Malahide Road.

4.5 The inclusion of the subject lands within the settlement boundary and their zoning as RV would provide for additional residential development and improve this situation immeasurably. It would create a more balanced pattern of development and create a more defined village centre and streetscape.

4.6 The development of the subject lands would create the opportunity to provide for the traffic calming of the village centre and enhance connectivity and permeability along the Malahide Road and Baskin Lane. It would create opportunities for better pedestrian links and connections between these development lands and existing residential development along Baskin Lane to the village core.

4.7 The development of the subject lands would create the critical mass to enable the development of new urban spaces within the village core. The primary open space for the new residential development could form a new square, opening up the site opposite St. Nicholas Church and the existing neighbourhood centre. The inclusion of the lands would facilitate the development of pedestrian and cycle connections to the west. In this context, consideration should be given to adjusting the settlement boundary of the village.

4.8 It is also noted that the draft Development Plan includes the proposed route of the Kinsealy Bypass. It is noted that this runs along the western boundary of the existing zoned lands and traverses the site to the north. The existing alignment of the Bypass impact on parts of the site and limits the development potential of these remnant land parcels. Although there is no definitive timescale for the development of the Kinsealy Bypass, it is envisaged that the forthcoming LAP will have regard to the preferred alignment of this route.

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4.9 In order to fully optimise the lands which are the most appropriate location for the sustainable extension of Kinsealy, it is submitted that a compensatory piece of land should be zoned in lieu of these severed land parcels. In this regard, the lands to the immediate west of the existing development plan boundary, should be included within the development boundary of Kinsealy Village and designated as zone RV.

4.10 It is submitted that the LAP settlement boundary should be consistent with the Fingal County Development Plan in terms of zoning, and in this context the adjustment to the settlement boundary of the LAP and extent of RV zoning should be incorporated.

4.11 The inclusion of these additional lands would allow for the sustainable extension of the village centre on the most optimal sequentially located lands within Kinsealy.

Lands impacted by By Pass

Revised Settlement Boundary

Land to be zoned RV and included within development boundary Fig: 7: Proposed Rezoning Strategy

Fig. 8: Proposed Amendments to Settlement Boundary

5.0 CONCLUSION

5.1 In conclusion, the optimal location for future residential development in Kinsealy is the subject lands. They will play an important role in consolidating the village centre and provide the opportunity to enhance cycling and pedestrian connections to existing development along Baskin Lane.

5.2 It is set out in detail in this submission that the subject lands are sequentially the most appropriate location for such development. The development of the lands has the potential to create a compact village core, defined streetscape and would create the critical mass of development to facilitate the introduction of appropriate public realm and traffic calming measures at the centre of the village. The development of these lands would also rebalance the form of development in Kinsealy and provide a better spatial pattern in the village.

5.3 The existing County Plan provides for a relatively modest extension of development in Kinsealy of just 109 houses. It is considered that given the strategic location of Kinsealy, its good public transport connections and proximity to existing social and community infrastructure, that it has the capacity to absorb

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additional residential development without adversely affecting the character or integrity of the village.

5.4 In this context, the lands are the most appropriate and sustainable location for future residential development. In sequential terms they are optimally located and in this context, consideration should be given to the amendment of the settlement boundary and the extent of the RV zoning to include all of our client’s lands.

5.5 It has also been identified in this submission that the route of the proposed Kinsealy Bypass severs some of the land within our clients ownership that is zoned RV in the current draft County Plan. If the Bypass is developed, this land may limited development potential. In this regard, it is respectfully submitted that compensatory land should be zoned.

5.6 Whilst it is acknowledged that a detailed LAP will be prepared for Kinsealy following the adoption of the County Plan, it is submitted that it is important that the settlement boundary of the village and extent of RV zoning as set out in the County Plan is consistent with the future LAP. In this regard it is respectfully submitted that the settlement boundary and extent of RV zoning as currently indicated in Map 9 of the draft plan be amended to include all of our clients lands. This will ensure the coherent and integrated development of the village under the future LAP.

5.7 We would be very grateful if this submission could be considered in the preparation of the Fingal County Development Plan 2017-2023.

Yours sincerely,

______John Spain Associates

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