'Permitted in Principle' Uses to Table 18.4 : Zoning Objective

DÚN LAOGHAIRE-RATHDOWN COUNTY DEVELOPMENT PLAN, 2010-2016 PROPOSED VARIATION NO. 9

Addition of New ‘Permitted in Principle’ Uses to Table 18.4 : Zoning Objective ‘B’ - Relating Solely and Exclusively to the Site of Specific Local Objective No. 97 (Map 5) – Proposed Retirement Village at Ticknock

MANAGER’S REPORT ON PUBLIC CONSULTATION

November 2012

Dún Laoghaire-Rathdown County Council

Table of Contents

Part Page No.

1. Introduction 4

2(A) Summary of Submissions from Prescribed and other Public Bodies 7

2(B) Summary of Submissions from General Public, Residents Associations and Other Organisations 11

3. Key Issues Arising and Manager’s Response and Recommendation 36

4. Appendix A – List of Submissions (Nos. 1-100)

Online link to submissions: -

PART 1

INTRODUCTION

1. Introduction

Statutory Background to the Manager’s Report This Manager’s Report has been prepared in accordance with the provisions of Section 13(4) of the Planning and Development Acts 2000, as amended.

In summary, this section of the Act (as amended) requires the Manager to prepare a report on any submissions or observations received – including any submissions from the Minister and Regional Authority – to summarise the issues raised on foot of the submissions and to then give the response of the Manager to the issues raised. (For information, no submission was received from the Minister while the submission received by the Dublin and Mid-East Regional Authority simply advised that they had no comment to make in respect of Variation No. 9).

The Manager’s Report is set out as follows:

(i) List of the persons or bodies who made submissions or observations during the public consultation period (See Appendix A), (ii) Summarises the content of the submissions/ observations made under this section: (a) from prescribed and other public bodies (See Part 2A) (b) from the general public, residents associations and other organizations (See Part 2B) (iii) Outlines the key issues raised on foot of the submissions and gives the Manager’s response and a recommendation to each of the issues raised, taking account of 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 for the time being of the Government or of any Minister or the Government (See Part 3).

This report is submitted to the Members of Dún Laoghaire-Rathdown County Council for their consideration as part of the process relating to proposed Variation No. 9 to the County Development Plan 2010-2016. Members have a period of up to 6 weeks from the date of submission of the Manager’s Report to consider the Manager’s Report. Following consideration of proposed Variation No. 9 and the Manager’s Report, the Members may, by resolution, accept or amend the proposed Variation or, alternatively, refuse to make it. If any amendments made are considered material, a further period of public consultation will be necessary.

Public Consultation Variation No. 9 to the County Development Plan 2010-2016, was put on public display on Friday 14 September 2012. Written submissions and/or observations were invited for a 4 week period ending Friday 12 October 2012. During this public consultation period the Council sought to raise awareness of the proposed Variation No. 9 among the citizens of the County and other stakeholders employing the following:

• A public notice placed in the Irish Times (14 September 2012) advising of the consultation period, where the Variation to the Development Plan could be accessed, advising of Public Open Day dates and times and inviting submissions up to and including the closing date.

• Two Public Open Days were held where Planning Officers were in attendance at the static displays in Dún Laoghaire and Dundrum to assist the public and others in their consideration of the Variation. The dates were as follows:

• County Hall Concourse Thursday 27 September (16.00-20.00)

• Dundrum Council Office Wednesday 3 October (16.00-20.00)

• The proposed Variation to the County Development Plan was on continuous public display for the duration of the consultation period at the following locations:

o The Concourse, County Hall, Dún Laoghaire (9.00-17.00)

o Council Offices, Dundrum Office Park (9.30-12.30 and 13.30-16.30)

• The proposed Variation to the Development Plan was available to view or download from the Council’s website, www.dlrcoco.ie .

• Copies of the Variation were made available at the County Council’s network of libraries both in hard copy and through the free web access facilities available at each library branch.

• Submissions/observations in respect of the proposed Variation to the County Development Plan were accommodated through two mediums – hard copy and e-mail.

Submissions Received The County Manager would like to take this opportunity to thank everyone who took the time to make a submission to the proposed Variation No. 9 - and to particularly thank those who attended the public information sessions.

During the 4-week consultation period a total of 100 no. submissions were received by the Planning Authority.

Of the submissions made, 67 no. opposed the Variation, 24 no. supported the Variation and the remaining 9 no. were ‘neutral’ in tenor/ content.

PART 2A

SUMMARY OF SUBMISSIONS FROM PRESCRIBED AND OTHER PUBLIC BODIES

Ref. Organisation Key Issue No. 9V002 Programme & • The requirements of S.I. No. 140 of 2006 Environmental Noise Regulations should be addressed. Regulatory Unit, National Roads • The NRA will require any planning applications to identify and implement noise mitigation measures Authority (NRA) within influence of existing or planned national roads.

• Need to provide adequate setback between the M50 and proposed development.

9V003 Environmental • Adhere to Environmental Noise Directive and Noise Action Plan for Dublin. Health Service, Health Service • The development must be in compliance with the Planning and Development Act and should not be Executive (HSE), prejudicial to public health. Dublin Mid- Leinster • Flood risk or potential flood risk of the proposed development requires to be identified, and, if identified, mechanisms for management to be put in place using the Flood Risk Management Guidelines from the DoEHLG and OPW.

9V005 SEA Section, • Planning Authority’s position with regard to SEA is noted. Office of Environmental • In proposing any Variations to the Plan, need to ensure that adequate and appropriate infrastructure is Assessment, in place, to service any development proposed. Environmental Protection • Variations need to take account of SEA Regulations 2A (SI No.436 of 2004). Agency (EPA), Regional • Council to ensure compliance with National/ EU environmental legislation. Inspectorate • Updated SEA Regulations and July 2011 Circular amending 2004 Regulations to be used in SEA process.

• Planning Authority is referred to EC (Birds and Natural Habitats) Regulations 2011.

• Copy of Council decision to be made available to the public and the Environmental Authorities consulted.

Ref. Organisation Key Issue No. 9V006 Regional • The content of Variation No.9 has been noted. The RPG Office has no comment to make on this Planning Variation. Guidelines (RPG) Officer, Dublin and Mid East Regional Authorities

9V011 Dublin Airport • The DAA has no comment at this time. Authority (DAA)

9V018 name withheld • Concern that the purpose of the Variation is to facilitate SLO 97. • Note that on sites Zoned ‘B’ retirement villages are neither ‘Permitted in Principle’ nor ‘Open for Consideration’. • The potential scale of the ‘retirement village’ is hinted at by the references to ‘retail’, ‘restaurant’ and unspecified ‘village centre’ uses. • Concerns that the promoters of the project are seeking to develop a new residential area on this open rural site in the foothills of the Dublin Mountains. • Council policy on housing is overriding in its authority, and any proposal contrary to its principles should not be permitted. • This site is not within any existing residential area, but is totally isolated and separated from residential areas by the M50, which - at this point - represents a natural ‘stop line’ to further southwards development • Footpath networks, if any, would be internal to the site and have no relation or connectivity to the general community. • Local shops, if at all commercially viable, would be ‘internal’, serving the elderly community in isolation, and not permitting interaction with the wider community. • There is no public transport. The nearest bus stop is over half a kilometre away across the very busy Blackglen Road. • Bus services are infrequent, and do not connect with the natural shopping focus in Dundrum. • Only vehicular access is via Ticknock Road, which is narrow and winding, and has a dangerous junction with the busy Blackglen Road. • Additional traffic from the development would only add to the traffic hazard and would be unacceptable. • The M50 Corridor is the natural stop line to the city’s development southwards at this point. No

Ref. Organisation Key Issue No. substantial development southward into the Ticknock Hills should be contemplated. • Danger of precedent. If a substantial development is permitted, it will be used to justify other adjacent development - further eroding the agricultural and high amenity quality of the area.

9V045 Transport • The documents of Variation No. 9 have been reviewed. The RPA Office has no objection to the proposed Planning amendment to the Development Plan. Manager, Railway Procurement Agency (RPA)

PART 2B

SUMMARY OF SUBMISSIONS FROM GENERAL PUBLIC, RESIDENTS ASSOCIATIONS AND OTHER ORGANISATIONS

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. 9V001 Councillor Labour Party • Strongly object to the current Variation. Richard Councillor for the • No merit in terms of proper planning and sustainable development has been Humphreys Stillorgan Ward demonstrated to make this Variation appropriate. • Fully supports Manager’s opposition to proposal for the reasons as set out in report Item No. 14 of September 2012 County Council Meeting.

9V004 name N/A • Opposed to the proposed SLO for a retirement village in Ticknock. withheld • Significant quantum of zoned residential land in the County. No requirement to build on unzoned lands. • Any development for Retirement Living needs to be central to community and should be close to public transport, shops, community facilities, churches, etc. The site in question satisfies none of these criteria.

9V007 name N/A • Reject proposed development of land in the foothills of the Dublin Mountains. withheld • M50 Corridor has to be the limit to development. • Precedent set if this Variation is allowed. • Proposed development would have adverse negative impacts on the foothills and should be rejected.

9V008 name N/A • Fundamentally opposed to the retirement village. withheld • Older people should be able to walk to amenities and community facilities. • There is no shortage of zoned residential land in Dublin. • The hillside is an amenity that should be preserved for recreational purposes. • Urban spread should be halted.

9V009 name N/A • Object to concept of category of ‘Permitted in Principle’ as it is not realistic. withheld • An unambiguous description of zoning needed. • Uses apparently allowed in zoning descriptions are not fact, and are subject to constraints.

9V010 name N/A • Opposed to Variation No. 9. withheld • Currently more than enough zoned residential land in the County.

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. • Supportive of retirement living concept but strongly believe any such facility should be central to community living, close to public transport, libraries, places of worship and shopping centres. • This mountain side location is not appropriate for any retirement village.

9V012 name N/A • The location of the proposed retirement village on Ticknock Hill is entirely wrong. withheld • Notable lack of amenities in this area for a development of this nature – no footpaths, public transport, shops or community facilities. • Extremely concerned that development of this nature will only isolate and marginalise those who find life most difficult. • Proposed development would be at a relatively high altitude and in an area prone to severe frost and ice. Residents would be house bound through the winter months. • Would welcome a retirement village in the County, but it should be integrated into the community with relevant amenities, rather than sited in a very peripheral location. • The proposed development would be located in a very high-value recreational area. • Incremental development should not be allowed in this valuable natural area.

9V013 name N/A • Object to proposed Variation. withheld • No development should take place in the Dublin Mountains foothills. • Variation could allow any manner of development. • Object to the change in the strongest possible terms. • Proposal would set a dangerous precedent for further development in the foothills.

9V014 name Blackglen • Impact of continuous noise from M50. withheld Residents’ • Hard to understand how a development for elderly people on such a site could be Association considered. • Concerns regarding safety given the topography of the site and the lack of footpaths. • Concern regarding the isolation of elderly people. • Very severe climatic conditions – the site could not be less suitable for the proposed development. • Residents of any retirement village would certainly be isolated within the scheme. • Proposed development should be in a well established residential area – not on an isolated site such as this. • County Manager was not in favour of this proposal. Why have the County Councillors

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. decided to progress this? • Have discussions with local Senior Citizens been considered?

9V015 name N/A • Object to Variation. withheld • No change to the use of this site should be permitted. • Any development in this area of beauty on the Dublin Mountain foothills – apart from farming and agriculture – would be inappropriate. • Expanding potential uses as proposed would make this site vulnerable to totally unsuitable development. • Any development ‘outside’ M50 corridor should be sensitive to the natural landscape.

9V016 name Sandyford • Object to the proposed Variation in the strongest possible terms. withheld Environmental • Site is totally unsuitable. Protection and • No footpaths on access roads to the site – safety hazard for elderly people walking to/ Road Safety Group from proposed development. • No public transport facilities proximate to the site. • No shops in proximity to this site. • No possibility of using public road on a motorised buggy. • Residents completely cut off and visitor access difficult. • M50 noise renders site completely unsuitable. • No justifiable reason to develop this part of the mountainside. • The proposed development would set a precedent for further development. • Scale of any proposed retirement village would not be in keeping with the mountainside environment.

9V017 name N/A • Object to the proposed Variation in the strongest possible terms. withheld • Site is totally unsuitable. • No footpaths on access roads to the site – safety hazard for elderly people walking to/ from proposed development. • No public transport facilities proximate to the site. • No shops in proximity to this site. • No possibility of using public road on a motorised buggy. • Residents completely cut off and visitor access difficult. • M50 noise renders site completely unsuitable.

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. • No justifiable reason to develop this part of the mountainside • The proposed development would set a precedent for further inappropriate development. • Scale of any proposed retirement village would not be in keeping with the mountainside environment.

9V019 name N/A • Oppose the principle of any retirement village at this location. withheld • Opposed to any inappropriate development on the foothills of the mountain. • This would a set precedent for other developments, and in time eventually erode the valuable amenity of the Dublin Mountains.

9V020 name N/A • Totally opposed to proposed ‘Permission in Principle’ for a retirement village at this withheld location. • Need to protect the landscape and mountains, but this proposal would open the floodgates for development in the foothills in the Ticknock area. • Proposal represents poor planning - retirement accommodation needs to be in centres of population with easy access to amenities. Proposal to include on-site amenities is not logical as such facilities are already available within established residential areas.

9V021 name N/A • Object to the Variation. withheld • Variation preamble states that it is being advanced to regularise inconsistencies from an earlier decision to locate a retirement village on a site in a zone that makes no provision for this use. Reaction to this would be that the original zoning was correct - it protected the environment, and properly utilised the M50 corridor as a boundary to further expansion of suburban development. • The Variation, if approved, will virtually convey to the site the equivalent of an outline planning permission for the uses as set out (with no opportunity for the public to appeal to An Bord Pleanala at this stage). • Variation No. 9 seeks to establish a palette of particular uses but with no planning study or justification of demand. • There will undoubtedly be appeals against any permission on this site and the public will rely on An Bord Pleanala to refuse – having regard to the Board’s recently articulated concerns relating to the promotion of nursing homes in isolated greenfield locations. • Variation 9 is clearly contradictory to proper planning and sustainable development, and

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. compounds the error of the earlier decision by the County Councillors to locate a retirement home in this isolated location. • The potential development on foot of this Variation prior to the building of the retirement home could be considerable. • Abundantly clear that the area has a lack of services and infrastructure to support the proposed development. • Access is very poor and Ticknock Road is not capable of accommodating increased traffic volumes. The junction with Blackglen Road has substandard sightlines, and no footpaths exist on the Ticknock Road. • The correct solution to remove the inconsistencies referred to in the Variation preamble is to rescind the earlier decision by the elected representatives to promote SLO 97.

9V022 name N/A • Proposed retirement village too remote from shops, churches and transport. withheld • It breaches the physical barrier provided by the M50 corridor. • Proposal sets a precedent for further development. Area to west will immediately become a target for further development. • Already ample residential zoned land for development in the County. This proposed change is totally unnecessary. • No sewage facilities in the area.

9V023 name N/A • Totally opposed to the proposed retirement village. withheld • Proposal is on a site with several unsuccessful and conflicting previous applications. Noted that the County Manager is opposed to the proposal. • Would effectively rezone an area, where current zoning imperatives are rural amenity and/ or agriculture. • Would breach the green belt. The Ticknock area represents a hugely popular and unspoilt greenbelt. • Precedent for similar development and additional future building. • Road infrastructure inadequate and unsafe. Ticknock Road/ Blackglen Road junction is already dangerous. • Further development as proposed will only increase the problems. • Developer is vague about provision of retail and the other services, with no information on size or scale of development being proposed. • Unconvincing scheme designed solely to serve developer interests.

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. • Inadequate public transport provision.

9V024 name N/A • Strongly object to proposal to rezone land from its current agricultural usage, to allow withheld the building of a retirement village. • This particular location is not suited for a retirement village.

9V025 name N/A • Agrees with County Manager’s recommendation that the proposed change of zoning at withheld Ticknock site should not be allowed. • The mountain area is an important recreational amenity and should be protected from inappropriate development.

9V026 name N/A • Completely opposed to the change of use this Variation will permit - for the reasons as withheld set out by the County Manager at the September 2012 County Council meeting. • Essential that this area of countryside be preserved for its recreational value. • The Dublin Mountains should be preserved for future generations. • Building ‘retirement’ housing in such a place ignores European best practice. • Integration into and with local communities is vital. • Dismayed that a propos al of this nature can be promoted by County Councillors in 2012. • When the proposal is further considered by the Council, trust that good sense and the need to cater for the common good, will prevail.

9V027 name N/A • Object to the proposed Variation. withheld • More than adequate zoned residential land already in the County. • Green spaces are important for future and present generations, and for the health and recreation of the wider community. • Too much development in area in last 15 years - some areas should remain unspoilt. • Retirement living should be central to community – near to public transport, libraries, shopping, etc. – not located on a isolated mountain site.

9V028 name N/A • Object to proposal. withheld • This area should be preserved as an amenity area. • Any development on the mountain foothills should be rejected.

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. 9V029 name Tudor Lawns • Concerns in relation to the ‘permitted in principle’ proposals. withheld Residents • Every effort should be made to protect the mountains as an amenity for the present and Association future generations. • Totally opposed to any development. • Introducing the ‘Permitted in Principle’ proposals will set a very unfortunate precedent for further development.

9V030 name N/A • Object to proposed Variation. withheld • No requirement to develop on mountain foothills when adequate zoned residential land and many vacant properties already in the County. • Site is isolated and unsuitable with no access to local community and facilities.

9V031 name N/A • Object to building a retirement home at Ticknock. withheld • No logic in housing elderly people on an isolated mountain site, remote from any public transport or amenities such as shops, libraries, churches, and, more importantly, from other people. • Cannot think of a less suitable site for a retirement village. • Should not be developing in a green-field area of natural beauty. • Development should be located in brown field areas with ease of access to local services.

9V032 name N/A • Location of site completely inappropriate for a retirement village. withheld • Proposed development should be located near, or in, a town/village centre. • Already more than adequate zoned residential land in the County. • Any retirement village should have ready access to a village centre with shops, services, public transport and other community amenities. • Integration with local community is very important for independent living. • The proposed retirement village will be wholly car dependant. • Ticknock Road substandard and unsafe. • Ticknock Road/ Blackglen Road junction is very dangerous. • Local roads and footpaths have steep slopes. • Accessibility issues for elderly and wheelchair users. • The proposed site is very exposed and prone to severe winter weather conditions. • Retirement village is not a real village, only in name.

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. • Proposed development will not have the critical mass to support village shops and services. • Not a community facility as it does not connect with any local community. • Much better sites available all over metropolitan Dublin for a development of this nature.

9V033 name N/A • Object to proposed Variation. withheld • Supports principle of retirement villages but only in appropriate locations. Proposed site is on the mountain foothills, accessed via a substandard road and largely isolated from the wider community. • Proposed development will adversely impact on the amenity of the area. • Visual impact from the M50 and other locations. • Illogical to rezone agricultural land when there is already adequate zoned residential land and many empty construction sites in the County.

9V034 name N/A • Object to proposed development on mountain foothills. withheld • Introducing ‘Permitted in Principle’ uses will set precedent for further undesirable development in the area which is not in the interests of the local or wider community.

9V035 name N/A • Object to proposed development. withheld • Proposed development would impact adversely on Ticknock and surrounding areas. • No need to rezone more development land on the foothills of the Dublin Mountains. • Mountainside location completely unsuitable as a location for a retirement centre.

9V036 name N/A • Strongly opposed to proposed retirement village. withheld • Development of proposed retirement village - along with the other ancillary commercial developments – effectively introduces a new village into Ticknock Valley (a sensitive and isolated area on the Dublin Mountain foothills). • Retirement accommodation should be located adjacent to established population centres where community facilities are available. • Very poor road access to the site, inadequate roads infrastructure and very limited public transport provision. • On the ‘wrong’ side of M50 Corridor – which represents a clear dividing line between the

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. developed part of the County and the high amenity areas of the Dublin Mountains. • Proposal is inconsistent with Council housing policy as set out in the County Development Plan.

9V037 name N/A • Object to the proposed development. withheld • Ticknock area is unique in the context of Dublin. It is relatively remote, yet provides a high quality natural environment for many recreational activities - walking, cycling, horse riding. • Ticknock Road is a steep, substandard narrow road along its entire length. The road has no footpaths, and many bends, raising obvious concerns in relation to pedestrian safety. • Site is zoned ‘B’. That zoning should provide protection to this environment. • M50 represents a clear demarcation line – further development south of the motorway corridor should not be permitted.

9V038 name N/A • Strongly object to the proposed Variation to ‘permit in principle’ building a retirement withheld village. • This location is completely inappropriate. • A retirement village located on the foothills of the Dublin Mountains, isolated from local village centres and community, transport, churches, shops, etc. represents bad planning. • Many local businesses and village centres in the local area are struggling to survive. Constructing further retail units is completely unnecessary and inappropriate. • Developing stand-alone services specifically for elderly people will be expensive and stretch resources. • The proposed development on lands at Ticknock zoned, “ To protect and improve rural amenity and to provide for the development of agriculture ” would be completely contrary to the zoning provisions. • Access road narrow and substandard - unsafe for pedestrians. • The proposed development would impact adversely on the foothills of the Dublin Mountains both in terms of visual impact and consequences for tourism. • The Ticknock area represents a valued recreational amenity both for local residents and wider City area.

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. 9V039 name N/A • Object to proposed development. withheld • Access to development is via Ticknock Road which is narrow and without footpaths. • Ticknock Road/ Blackglen Road junction is dangerous. • Site experiences severe climatic conditions in winter months. • Any further increase in traffic would generate greater risks to cyclists and pedestrians. • Foul drainage may be problematic due to location south of M50. • Site e njoys agricultural status. The consequences of implementing Variation No. 9 would be detrimental to this elevated, prominent site. • Developer in this instance driven solely by commercial interests - showing scant consideration or respect for Ticknock residents. • Proposed development completely contrary to the zone ‘B’ zoning provisions.

9V040 name N/A • Oppose any Variation to the County Development Plan which would facilitate this withheld proposed development violating the integrity of the Dublin Mountain foothills. • The Ticknock area represents an important amenity for all citizens in Dún Laoghaire- Rathdown and beyond.

9V041 name N/A • Object strongly to proposed Variation for a retirement village at Ticknock. withheld • Inappropriate site for such a proposal, as it is a rural area close to a large city. • Land is zoned agricultural and should remain agricultural. • Ticknock is an important amenity area used by many city dwellers for walking and cycling, etc. • Many empty development sites available elsewhere in the County for retirement complexes. • The site is very elevated - any development would have a significant visual impact. • The proposed retirement village in Ticknock simply represents bad planning. • Local Councillors should take cognisance of opposition of local residents to the proposal. • Site is isolated and inappropriate. Such developments should be located within established communities which have access to facilities.

9V042 name N/A • Object strenuously to proposed Variation. withheld • Ticknock area is rightly protected for amenity and agriculture uses in the County Development Plan. This protection represents proper planning. • Site for proposed development is in an isolated area. It is important for elderly citizens

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. that they are fully integrated within their community. • Proposal has been opposed by the County Manager. For the Elected Members to now attempt to vary the Development Plan in order to facilitate the proposed retirement village is appalling.

9V043 name N/A • Object strongly to this Variation. withheld • Should be no further development south of M50. • If Variation is approved and development takes place it sets a dangerous precedent in relation to further inappropriate development in the foothills of the Dublin Mountains. • No public transport provision in the area for residents, staff or visitors.

9V044 name N/A • Object strongly to this proposed Variation. withheld • Variation completely at odds with the zoning provisions set out in the County Development Plan. • Proposed location completely unsuitable for a retirement village. • Ticknock Road is narrow and substandard – not an appropriate access arrangement for development of the type proposed. • Aesthetically, the proposed development will have a huge adverse impact on the mountain vista. • Location too remote from mainstream facilities to provide for residents in a retirement village.

9V046 name N/A • Object to the proposed Variation. withheld • Unsuitable site – elevation, prominent nature of development, lack of adequate services, zoned agricultural. • Planning objectives – development appears to materially contravene and conflict with planning objectives for the area and County Development Plan in general. • Development proposed is contrary to the preservation of rural environment. • Ticknock Road is inadequate – it is narrow, and poorly aligned and completely substandard to serve a development of this type. • Entrance of proposed commercial retirement complex situated on an extremely bad bend with very poor sight lines. • Appeal to local elected representatives to reconsider their support for this development.

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO.

9V047 name N/A • Object to proposed Variation. withheld • Completely inappropriate to locate a large development of this nature half way up the Ticknock Road. • Very few open spaces left in Dublin Mountains. • Site highly visible from the rest of the city. • Development of the type proposed should not be located on agricultural land. • Appeal to the local Councillors to finally put an end to the repeated planning applications for this piece of land.

9V048 name N/A • Object to the proposed Variation. withheld • Dublin Mountains play an important role in the lives of people in area, further development of the type envisaged will damage this. • Retirement Living is important, but any such development should be centrally located close to the established community with public transport, libraries, shopping facilities,etc. • Mountain location inappropriate.

9V049 name N/A • Object to the proposed Variation. withheld • Sufficient residentially-zoned land already available in the County makes this rezoning unnecessary. • Many vacant buildings in the County that could be converted to retirement village-type accommodation. • Retirement villages should only be set in the context of community living, with ready access to public transport, libraries, places of worship, shops and other facilities. This proposed development does not meet any of these requirements. • The proposed development would be visually intrusive and inappropriate, located as it is on an elevated and prominent site in an agricultural area.

9V050 name N/A • Object to proposed Variation. withheld • Continuous noise generated from the M50. • Very steep topography across the proposed site. • Site inappropriate for a development focused on elderly population.

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. • Substandard road/footpath infrastructure compromises pedestrian safety and ability of retirement village residents to access other areas on foot. • Very exposed site that experiences severe winter weather conditions. Not appropriate for elderly population. • Retirement villages should be located in, or close to, fully developed residential areas - not on isolated sites such as Ticknock. • County Manager is opposed to the proposed development so unclear as to why County Councillors are so supportive of the proposal.

9V051 name N/A • Strongly object to the proposed development. withheld • Site is north facing and exposed to the prevailing westerly winds. It experiences severe winter weather conditions and is unsuitable for housing the elderly. • It is isolated from existing residential communities by the M50 corridor. • The site is exposed to serious noise pollution from the M50. • Access is by narrow, substandard roads which would be dangerous for elderly people. • There is no public transport in the area. • M50 serves as a natural boundary between the existing residential developments to the north and the undeveloped foothills of the Dublin Mountains to the south. • Essential to preserve Ticknock Valley’s natural scenery and to resist the creeping erosion of such green spaces.

9V052 name N/A • Object to proposed Variation. withheld • Contravenes Council policy for housing. • Too remote for access to services, including shops and community facilities. • No public transport except a minimal bus service about 1km distance from site. • Substandard access roads with no footpaths. • Provision of shops and other on-site facilities will not be viable for a small catchment. • Breaches physical barrier of M50 – so setting a precedent for further development into an area of high amenity. • No sewage facilities in the area. • Adequate areas already zoned for residential development within the County that do not have the locational disadvantages of the Ticknock site.

9V053 name N/A • Support proposed retirement village.

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. withheld • Village will give stroke patients access to professional healthcare in their own home. • Site is not isolated, but is located close to a major apartment development. • The retirement village concept addresses older people’s concerns in relation to loneliness, cost of heating and security.

9V054 name N/A • Support proposed retirement village. withheld • Village will address concerns of older population in relation to loneliness, heating costs, security and accessibility to healthcare. • Relocating elderly people out of large family homes into new, purpose built homes will release family homes onto the market. These homes are currently in demand. • Proposed retirement village will have services on site so residents do not need to be close to established town/ village centres.

9V055 name N/A • Support proposed retirement village. withheld • A major apartment development is located close to the site. The Ticknock site is not isolated. • Village will provide stroke patients access to professional healthcare in their own home. • Proposed retirement village will provide services on site, so residents do not need to be close to established town/ village centres.

9V056 name N/A • Support proposed retirement village. withheld • This village will provide elderly community with a choice of living opportunities. • This facility will be a retirement village and not a nursing home. • The proposed Variation is only to facilitate what has already been agreed in relation to SLO No. 97.

9V057 name N/A • Support proposed retirement village. withheld • The on-site services will provide residents of the complex with excellent facilities and reduce any need to travel outside the proposed retirement village. • The village will provide badly needed job opportunities to the local community.

9V058 name N/A • Support proposed retirement village. withheld • Proposed retirement village will enable elderly people to live in a safe, secure

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. environment - less chance of isolation as surrounded by their peers. • On-site health services will reduce pressure on local public healthcare services. • Development has backing of HSE.

9V059 name N/A • Support proposed retirement village. withheld • Development will reduce demand on the local public healthcare services, as a wide range of on-site healthcare is to be provided. • Variation does not propose new zoning of land. • Uses referred to in the Variation relate only to SLO No. 97. There are no concerns over the site being used for any other purpose.

9V060 name N/A • Support proposed retirement village. withheld • On-site services proposed will provide residents with required services thereby reducing the need to travel outside the retirement village. • Proposed retirement village will create jobs in the local economy. • Existing facilities available in the County for stroke patients extremely limited. The on- site provision for stroke patients is much needed.

9V061 name N/A • Support proposed retirement village. withheld • The proposed complex would provide elderly people with companionship in a safe and secure environment. • It is recognised that such a facility would benefit the older population as the HSE have supported this proposal in writing. • Local pubic healthcare services will see their demand reduced as a wide range of on-site health services are to be provided.

9V062 name N/A • Object to proposed Variation. withheld • Proposed site is inappropriate because of its isolation and remove from public transport and community facilities.

9V063 name N/A • Oppose proposed retirement village. withheld • It is an agricultural site and is unsuitable for the elderly both in terms of socialisation and distance from community facilities.

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. • Other, more appropriate sites could be identified that would be more suited to ‘retirement living’. • The proposed development will destroy natural beauty of Dublin Mountains and surrounding areas. Insufficient consideration has been given to potential adverse impacts on the countryside. • Proposal will not protect and improve rural amenity as per the County Development Plan zoning provisions but will, rather, only serve to destroy it. • The elderly should be integrated into the community – not banished to an isolated, elevated site in the foothills of the Dublin Mountains.

9V064 name Vice President, An • Object to proposed Variation. withheld Oige. • The Ticknock area is where the Wicklow Way and the Dublin Mountain Way are located. • The Dublin Mountain Partnership (DMP) was established specifically to improve the recreational experience of the Dublin Mountains. The County Council is one of the Partnership Organisations of the DMP so it is surprising the Council is supporting this Variation. • The Dublin Mountains represent an enormous recreational asset due to their proximity to Dublin City and accessibility. • The Council should identify an alternative site for this retirement village - one that would not interfere with the recreational experience of the public utilising the Ticknock area for walking, orienteering, mountain biking and horse riding.

9V065 name N/A • Object to proposed retirement village. withheld • Ticknock is not a suitable location for a retirement village. Location is too isolated, with no social/ community infrastructure - public transport, shops, church/chapel. • There is a need for retirement housing, but it should be located in the community to foster interaction between elderly residents and the wider society. • The understanding in the Stepaside area is that the mountain side of Enniskerry Road/ M50 corridor would not be developed. • If the Variation is granted, there is no guarantee that it is a retirement village that will be built. The proposal smacks of the rampant opportunism of the recent past.

9V066 name N/A • Strongly objects to proposed Variation. withheld • While in favour of retirement villages, this location is inappropriate and ill considered.

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. • The proposed retirement village will greatly diminish and adversely impact on the outstanding recreational and tourism potential of the Dublin Mountains. • The proposed retirement village would occupy a prominent and elevated site overlooking the M50 - any building here will impede the view of the mountains. • No footpaths on Ticknock Road. Pedestrian safety would be seriously compromised. • Illogical to house elderly people on an isolated mountain site well removed from public transport and services - shops, libraries, churches and, more importantly, other people. Developments such as these can only isolate the elderly further. • No economic sense in re-zoning agricultural/ recreational land in the current economic climate. Substantial zoned residential land and many empty development sites in more appropriate locations in the County. • No benefit in proposal for the elderly, local area or the County. If Variation goes ahead, a precious asset will be destroyed.

9V067 name N/A • Object strongly to proposed Variation. withheld • Ticknock Road clearly substandard with no footpaths. • Ticknock Road is not capable of accommodating any further increase in traffic. The Mountain Bike Way has already greatly increased traffic using this road. • Ticknock Road/ Blackglen Road junction is dangerous. The dangers would only be exacerbated by the proposed development. • How big is it intended this retirement village will be? No details are provided. • This is an inappropriate site for the elderly. It is isolated, and not readily accessible by public transport. • Proposed site is not a residential area – it is an intrinsic part of the Dublin Mountains.

9V068 name N/A • Object to proposed Variation. withheld • Variation contravenes the Council’s own stated planning and zoning principles. • Visual impact on the broader Dublin region has not been considered in sufficient detail. • Inappropriate to locate elderly housing in such a remote location - without access to a community. • Exposed site with severe climatic conditions in the winter months • Would urge that good sense by the elected representatives should prevail.

9V069 name N/A • Oppose proposed Variation.

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. withheld • Site is on the ‘wrong’ side of the M50 corridor. • The Ticknock area has huge recreational potential and includes the Wicklow Way and the Dublin Mountain Way. The proposed development would compromise the amenity and recreational value of the area. • The area is zoned ‘to protect and improve rural amenity and to provide for the development of agriculture ’. • The County Manager in his report to the Elected Members stated that there was ‘ clearly something incompatible ’ between the proposal and the agricultural zoning on the site.

9V070 name N/A • Strongly object to the proposed Variation. withheld • Land is zoned agricultural and should remain for agriculture and recreational uses. • The proposed development would represent an extension of city into the mountains – regardless of past and present objections of locals and the wider community of south Dublin.

9V071 name N/A • Object to this proposed development of a retirement village at Ticknock. withheld • Location for the proposed development is completely inappropriate.

9V072 name N/A • Object to proposed Variation. withheld • Adverse impacts on natural landscape. • Proposal represents an isolated retirement ghetto bounded by the motorway corridor and with no access to public transport, shops, libraries and other social infrastructure. • Retirement complexes should be located in, and integrated with, the wider community – not in isolated locations such as the Ticknock area.

9V073 name N/A • Submission made on behalf of the promoter of proposed Retirement village – Mr. Rod withheld McGovern. • Rationale for the Variation is that SLO No. 97 cannot be fully implemented without a ‘local’ alteration to the zoning objective. Variation would not permit any development outside the terms of the SLO. • Variation cannot be contrary to the overarching zoning objectives as the purpose of the Variation is to amend the zoning objective itself. The Variation does not propose any ‘new zoning’ of land.

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. • Variation permits a ‘retirement village’ where all services required by elderly/ convalescent are provided on site. Consequently the ‘retirement village’ does not need to be located proximate to a town centre. • There is already a nursing home located on the southern side of the M50 – so a precedent has already been set. • Increasing demand and need for this type of facility across Dublin. • Proposed development will create circa 200 full and part-time positions post construction. • Having facilities that are not open to the general public is part of the attraction of such a retirement village.

9V074 name N/A • Fully support the development. withheld 9V075 name N/A • Fully support the development. withheld 9V076 name N/A • No objection to the proposed Variation. withheld 9V077 name N/A • Fully support the development. withheld 9V078 name N/A • No objection to proposed Variation. withheld • This Variation will facilitate local employment, care for the elderly and provide facilities for stroke patients.

9V079 name N/A • No objection to proposed Variation. withheld 9V080 name N/A • Fully support the proposed Variation. withheld • The retirement village will benefit the local area. • The Variation will allow for the delivery of on-site facilities.

9V081 name N/A • No objections to proposed Variation. withheld

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. 9V082 name N/A • Fully Support proposed development. withheld • Will create employment. • Will provide care for the elderly.

9V083 name N/A • Fully support proposed rehabilitation village in Ticknock. withheld • Attractive location with views over Dublin. • Reassurance to residents of on-site medical services. • Establishes a secure environment for the elderly.

9V084 name N/A • Fully support the proposed development. withheld 9V085 name N/A • Fully support proposed Variation. withheld • Reassurance of on-site health services and care. • Retirement village will create a safe, friendly environment.

9V086 name N/A • Support proposed retirement village. withheld • Retirement village will create safe and caring environment for residents. • Demand exists for this type of integrated village for older people. • Proposed development will not adversely impact on the recreational facilities of Ticknock.

9V087 name N/A • Support the proposed retirement village in Ticknock. withheld 9V088 name N/A • Support the proposed retirement village. withheld • This facility will be of benefit to the local community and society in general.

9V089 name N/A • Object to the proposed Variation. withheld • Site is an isolated location. • Accessed via a substandard road - no improvements to this road could satisfy the traffic requirements of this development. • Ticknock Road is a narrow, substandard road with no footpaths, and it’s junction with Blackglen Road is dangerous. Increased traffic will only compound the problems.

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. • Site has no services. • Council is making provisions with this Variation for a major development to take place on land currently zoned for agriculture and high amenity. • The Ticknock Hill developments on the north side of Blackglen Road have adequate facilities at present, including a bus service. It is unclear therefore, why this proposal on the Ticknock foothills is necessary. • Original zoning provision on this site should be maintained.

9V090 name N/A • Object to proposed Variation. withheld • Proposed development would adversely impact on an attractive natural area that has an important recreational function. • Strongly object to any further rezoning in the area. • The purpose of this re-zoning is not in the best interests of elderly people. • Elderly people should not be isolated or segregated from the wider local community but should be fully integrated into same. • The isolated nature of the site and the non-existent footpath network will make it extremely difficult for residents in the retirement village to venture beyond it’s confines. • No apparent rationale to allow this rezoning. Should be rejected outright.

9V091 name N/A • Object to proposed Variation. withheld • Note that certain Councillors are promoting the proposal to re-zone land in the Ticknock area of the Dublin Mountains. • Site is isolated and wholly inappropriate for the purpose intended. • No public transport services nearby – how are residents of the retirement village expected to travel beyond the confines of the village itself? • Proposed development would have adverse visual impact in terms of views from the M50 and the wider city. • The recreational and tourist potential of the Dublin Mountains would be compromised by this proposed development.

9V092 name N/A • Object to proposed Variation. withheld • Bad planning to situate a retirement village right beside the M50. • Residents will suffer significant noise pollution from M50 traffic – anathema to the peace and tranquillity to be expected at a retirement village.

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. • Ticknock is very removed from all services – no facilities within ready walking distance for elderly people. • No public transport services for residents, employees or visitors. • Will set a dangerous precedent for further inappropriate development in the Ticknock and Kellystown areas. • Proposed development will severely compromise the landscape and amenity of the Dublin Mountains around Ticknock and Tibradden. • Retirement villages should be located within established residential communities where access to services and facilities – including public transport – are readily available.

9V093 name N/A • Strong objection to Variation. withheld • Unsuitable site – elevation, prominent nature of development, lack of local services, zoned agricultural. • Proposal appears to materially contravene and conflict with fundamental planning objectives for the area and County Development Plan in general. • Development compromises the protection of the rural environment and is contrary to proper planning and future development of the area. • Ticknock Road is substandard, narrow and poorly aligned, while entrance to proposed commercial retirement complex is situated on an extremely bad bend with poor sight lines. • Retirement home in an isolated location where residents cannot go to church, local shops or do anything else – as a consequence of substandard roads and footpath infrastructure. • Essential that elderly residents are not isolated or segregated from the wider community and services. • Appeal to local Councillors to reconsider their support for this development. • County Manager’s opposition to this proposal should be given credence.

9V094 name N/A • Object to proposed Variation. withheld • Important that the Dublin Mountains be protected from further inappropriate development.

9V095 name N/A • Object to proposed Variation. withheld • Proximity of proposed development to Motorway is inappropriate.

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. • Questionable whether local foul and surface water infrastructure has capacity to support such a development. • No indication of size, scale or height of the proposed development. • The site is elevated and steeply sloping – not suitable for an elderly population. • Ticknock Road is substandard. No footpaths on Ticknock Road or Blackglen Road. How are elderly residents expected to walk anywhere? • Detrimental impacts on local wildlife - deer and foxes. • No public transport to service the proposed development. • Proposed development will compromise and adversely impact on the Ticknock area and the wider Dublin Mountains.

9V096 name Pine Valley • Object to proposed Variation. withheld Residents • The term “Village” raises concerns about potential additional future developments - Association what else could be “bolted on” to the site. • Development should not be allowed on south side of M50 corridor. • Unclear what implications of proposed development will have on surface water run-off. • Development is wholly inconsistent with the current zoning. • Completely reliant on private cars as no public transport services in the area. • Constant noise from M50 not consistent with a ‘peaceful’ and ‘tranquil’ retirement environment. • Proposal totally contradictory to the established rural/ agricultural context of the Ticknock area. • Dublin Mountains are an amenity for citizens of Dublin - must be preserved and protected from encroaching development. • A glut of vacant and unfinished developments elsewhere in the County that could be converted to retirement village uses. • Transport links and infrastructure already in place in more convenient and suitable locations elsewhere in the County. • Inadequate local foul and surface water drainage infrastructure. Proposed development will only compound existing difficulties. • Local roads network substandard, narrow, poorly aligned and with limited footpath provision. • Exposed and elevated nature of the site is subject to secure climatic conditions – particularly during winter months.

REF NAME ORGANISATION ISSUES/OBSERVATIONS NO. 9V097 name N/A • Object to proposed Variation. withheld • Inconceivable that Council would even countenance locating a retirement village on Ticknock Road. • Proposed development would compromise the landscape and natural beauty of the area that is a focus for recreational facilities. • Exposed and elevated site is subject to severe winter weather conditions.

9V098 name N/A • Object to proposed Variation. withheld • Incredulous that a retirement village is being built in Ticknock. • Inconceivable that Council would even countenance locating a retirement village on Ticknock Road. • Proposed development would compromise the landscape and natural beauty of the area that is a focus for recreational facilities.

9V099 name N/A • Object to Variation. withheld • Preserve the Dublin Mountains and Ticknock as a green zone.

9V100 name N/A • Objection to Variation. withheld • Is a ‘ crazy place’ for a retirement home. • Proposed development will be an eyesore and highly visible from M50 and wider city. • Foothills of Dublin Mountains should be protected and preserved for future generations.

PART 3

KEY ISSUES ARISING AND MANAGER’S RESPONSE AND RECOMMENDATIONS

Key Issue Ref. Manager’s Response & Recommendation No. 3.1 Inappropriate Location • Numerous concerns raised (9V)004, 008, The Manager agrees with those submissions objecting to the Variation on that retirement villages of this 010, 012, 016, the basis that any retirement village at this particular location would be type should properly be 017, 018, 022, remote from any existing community node and without ready access to located with in established 027, 030, 031, established social/ community facilities – public transport links, shops, residential nodes where they 032, 036, 038, places of worship and other local services. would be integrated with, and 041, 042, 044, into, the wider community and 046, 048, 049, where access to a wide range 050, 051, 052, Recommendation : of social and community 063, 065, 066, Do not proceed with the proposed Variation. infrastructure – shops, places 067, 068, 072, of worship, libraries, public 089, 090, 091, transport and other local 092, 093, 095, services would be readily 096 available. The proposed location on the foothills of the Dublin Mountains at Ticknock satisfies none of these parameters.

3.2 Land Use Zoning Principles • Many submissions raised (9V)009, 018, The Manager concurs fully with those submissions that highlight the concerns that the proposed 019, 020, 021, contradiction between the package of uses and activities the Variation Variation would, in effect, 023, 024, 025, seeks to introduce at Ticknock with the generally restrictive provisions set allow for a wide range of 032, 033, 034, by the overarching Zoning Objective ‘B’ on the subject site. The Manager ‘Permitted in Principle’ uses 035, 037, 038, has clearly stated on a number of occasions in the past that there is an and activities on the site which 039, 040, 041, obvious incompatibility between the proposal and the rural amenity/ are fundamentally 042, 046, 049, agricultural zoning of the subject site. contradictory to, and in 064, 066, 067, conflict with, the provisions of 068, 069, 070, the overarching Zone 090, 091, 093, Recommendation : Objective ‘B’ which is ‘ To 096 Do not proceed with the proposed Variation. protect and improve rural amenity and to provide for the development of agriculture’ .

Key Issue Ref. Manager’s Response & Recommendation No.

• The proposal materially contravenes the Council’s own stated policy and zoning principles – as set out in the 2010-2016 County Development Plan – as retirement villages are neither ‘Permitted in Principle’ nor ‘Open for Consideration’ on lands zoned Objective ‘B’.

3.3 Issue of Precedent • Concerns that proposal could (9V)007, 012, The Manager concurs with those submissions expressing concern that the set an undesirable precedent 013, 015, 016, proposed Variation could set a precedent for further development in the for further inappropriate 017, 018, 019, foothills of the Dublin Mountains generally but particularly in the immediate development in the future in 020, 022, 023, locality of the subject site. the high amenity areas of the 029, 037, 043, Dublin Mountain foothills. If a 052, 092 With regard to the existing nursing home referred to by the promoter of the substantial development is Ticknock retirement village, the Manager does not consider that poor permitted at Ticknock it could planning decisions of the past should in any way be used to set a template be used to justify further or benchmark for the future proper planning and sustainable development development on adjacent sites of the County. – further eroding the agricultural and high amenity quality of the area. Recommendation : Do not proceed with the proposed Variation. • The promoter of the Ticknock (9V)073 retirement village asserts that a nursing home is already located on the southern side of the M50 corridor and so sets a precedent for development.

Key Issue Ref. Manager’s Response & Recommendation No.

3.4 Adequacy of Zoned Residential Land in the County • Comment that there is (9V)004, 008, The Manager concurs fully with the comments in relation to the supply of currently more than an 010, 022, 027, residentially zoned lands throughout the County. The 2012 Housing Land adequate supply of serviced, 032, 049, 052 Availability return produced for the Department of Environment, well located and appropriate Community and Local Government advised there were circa 640 hectares of residentially zoned land in Dún zoned residential land in the Dún Laoghaire-Rathdown administrative area. Laoghaire-Rathdown to satisfy housing development There is, patently, an abundance of land already available in the County for demands for the foreseeable any and all residential-type development for the next 10-12 years. There future. No rational need or is, therefore, no objective planning imperative at this time to open up ‘non- reasoned justification for the zoned’ lands for residential development of the type being promoted by the proposed Variation on proposed Variation. agricultural zoned lands on the foothills of the Dublin Mountains at Ticknock when Recommendation : there is already a surfeit of Do not proceed with the proposed Variation. undeveloped residential development land elsewhere in the County.

3.5 Current Availability of Appropriate Well Located Housing Stock • Submissions highlighted the (9V)007, 033, The Manager notes the submissions. A number of unfinished housing ready availability of various 038, 041, 049, estates and vacant developments within the County are well located partially-constructed but 063, 066, 070, proximate to established residential communities with access to existing unfinished housing 092, 096, social infrastructure. While these represent a potential housing asset, their developments and the well capacity for conversion to complexes for retirement living is, however, documented ‘overhang’ of unknown without further detailed technical assessment and analysis. vacant housing stock in established residential parts of the County. Potential to Recommendation : utilise/ convert certain Do not proceed with the proposed Variation.

Key Issue Ref. Manager’s Response & Recommendation No. unfinished housing developments for retirement living.

3.6 Intrusive Impact on Foothills of Dublin Mountains/ Compromising the Recreational and Amenity Value of Area • The proposed development (9V)007, 008, The Manager agrees with the sentiments of these submissions. The that would be facilitated by 012, 013, 015, proposed Variation, if agreed, would facilitate a development for which no the proposed Variation would 016, 017, 018, objective or valid planning rationale has been offered. impact adversely on the 019, 020, 023, amenity of the Dublin 025, 026, 027, The attractiveness of, and sensitivities associated with, the landscape of the Mountain foothills and would 028, 029, 030, Dublin Mountains and its foothills are acknowledged. There should be a compromise the recreational 031, 033, 034, presumption to protect these areas from development that is inappropriate and tourism value of the area. 035, 036, 037, or would compromise its integrity and natural amenity. The Ticknock area represents 038, 040, 041, a valued recreational asset 042, 046, 047, both for local residents and 048, 051, 052, Recommendation : the wider conurbation given its 063, 065, 066, Do not proceed with the proposed Variation. relationship and proximity to 067, 069, 070, both the Wicklow Way and the 072, 091, 092, Dublin Mountain Way. 094, 096, 097, 098, 099

• The Dublin Mountain (9V)064 Partnership (DMP) was established specifically to improve the recreational experience of the Dublin Mountains. As one of the Partnership Organisations of the DMP there are concerns that the County Council is seen to be supporting this

Key Issue Ref. Manager’s Response & Recommendation No. Variation.

3.7 Exposed And Elevated Site Subject to Severe Climatic Conditions • Major concerns in relation to (9V)012, 014, The Manager agrees with the content of the submissions. The Ticknock site the very exposed and elevated 032, 039, 050, is unquestionably exposed and elevated, located as it is at an altitude of nature of the site of the 051, 068, 096, between circa 135-170m (440-550ft.). The adverse impacts associated retirement village that would 097 with the severe climatic winter weather conditions experienced in 2010 and be facilitated by the proposed 2011 were most pronounced in the more elevated parts of the County – Variation and the severe including the Ticknock area. When combined also with the relatively steep climatic conditions topography across the proposal site (circa 1:8) it does cast considerable experienced in the Ticknock doubt as to the environmental suitability of the site for the purpose area generally but particularly intended - particularly in light of the age cohort of the intended client during winter months. The group. severe winter weather conditions of recent years, and the accessibility difficulties Recommendation : associated with same, have Do not proceed with the proposed Variation. been particularly pronounced and problematic in the Dublin Mountain foothills.

3.8 Remote and Isolated Nature of the Site And Associated Negative Social Impact on Future Residents • Concerns in relation to the (9V)008, 012, The Manager agrees with the concerns expressed in relation to the isolated isolated location and nature of 014, 018, 033, location and context of the proposed development site and the extremely the development that would 035, 036, 038, limited physical infrastructure available in the area to facilitate interaction be facilitated by the proposed 042, 044, 050, between, and integration with, the retirement village and the wider Variation and the potential 051, 052, 063, community. problems of isolation for 065, 066, 067, elderly residents within the 068, 072, 089, The apartment scheme at Ticknock Hill referred to is c.750 metres distant complex. The site is relatively 090, 091, 092, from the proposed retirement village. There is significant severance remote, and segregated from, 093, 096 between the proposed retirement village and the apartment scheme at

Key Issue Ref. Manager’s Response & Recommendation No. existing established Ticknock Hill as a consequence of the heavily trafficked but geometrically communities, public transport substandard Blackglen Road. The relatively steep topography of the area provision is virtually non- further compounds the problem. The lack of any meaningful local footpath existent and the pedestrian/ infrastructure is another major impediment to facilitating meaningful footpath infrastructure in the interaction and integration between the retirement village and the wider area is patently substandard locale. and unsafe. All these factors would combine to limit interaction between the Recommendation : residents of the retirement Do not proceed with the proposed Variation. village and the wider community.

• A number of submissions in (9V)053, 055, support of the proposed 073 Variation argue that the site is not isolated but is close by a major apartment scheme at Ticknock Hill.

3.9 Substandard Roads/Footpath Infrastructure and Traffic Safety Issues • A significant number of (9V)008, 012, The Manager agrees and shares the serious concerns expressed regarding concerns articulated related to 014, 016, 017, traffic/pedestrian safety issues associated with the inadequate roads and the wholly inadequate and 018, 021, 023, footpath infrastructure in the Ticknock area. Any increase in traffic volumes substandard nature of the 032, 033, 036, arising from the proposed development would only exacerbate matters. Put local roads/ footpath 037, 038, 039, simply, the local roads/ footpath infrastructure is not of a standard capable infrastructure in the vicinity of 044, 046, 050, of accommodating the volumes of traffic likely to be generated by the the Ticknock site. Ticknock 051, 052, 066, proposed retirement village witho ut compromising traffic/ pedestrian safety. Road itself is narrow, steeply 067, 089, 093, Navigation of the wider Ticknock/ Blackglen Road area on foot is extremely sloping, poorly aligned and 095, 096 dangerous. This hostility of the pedestrian environment is likely to impose lacking any footpath provision significant limitations on the ability of elderly residents from the retirement whatsoever. The junction of village to interact with the wider community. Ticknock Road with Blackglen Road is dangerous with very Recommendation :

Key Issue Ref. Manager’s Response & Recommendation No. poor sightline provision. Any Do not proceed with the proposed Variation. increase in traffic volumes on Ticknock Road would further compromise pedestrian safety and the ability of retirement village residents to access other areas on foot. Blackglen Road likewise is substandard with only very intermittent sections of footpath along its length. Despite its inadequate geometry it carries significant traffic volumes making any navigation of the area on foot extremely dangerous.

3.10 Unknown Size/ Scale of the Retirement Village and Nature/ Extent of Activities on Site • Serious concerns expressed (9V)016, 017, The Manager agrees and shares the concerns of the submissions in relation about the size and scale of 018, 023, 032, to the paucity of available information regarding the overall size and scale development and the nature 036, 038, 047, of the development envisaged, the potential range of activities proposed for and extent of the associated 065, 067, 072, the site and the possibility of a ‘creeping’ introduction of other uses beyond activities that would be 095, 096 those notionally set in the Variation. The somewhat ‘open ended’ nature of facilitated by the proposed both the SLO No. 97 and the potential range of uses provided for in the Variation. A complete lack of current proposed Variation is a major concern. detail available to the general public renders meaningful Fundamentally however, any proposal to introduce a residential village plus comment almost impossible. associated commercial uses onto the site in question would permanently and irrevocably alter the rural characteristics of this site – irrespective of • While any development on the the eventual scale of the end product. On a steeply sloping hillside site proposed site would be such as this – significant site excavations, levelling and retention measures contradictory to the will be necessary over and above the ‘normal’ panoply of construction overarching agricultural/ activities associated with any development site. amenity zoning provisions,

Key Issue Ref. Manager’s Response & Recommendation No. and patently inappropriate and In relation to the questionable commercial viability of some of the uses unwarranted from the envisaged in the proposed development the Manager also would query perspective of the proper whether the retirement village will have the necessary ‘critical mass’ to planning and sustainable sustain such uses – particularly so when the promoter of the proposed development of the area, a retirement village states that “ Having facilities that are not open to the particularly large development general public is part of the attraction of such a retirement village ” type and of the scale that is (emphasis). being hinted at would be a complete anathema to the rural mountain foothills Recommendation : environment at Ticknock. Do not proceed with the proposed Variation.

• A small number of submissions have queried the commercial viability of some of the palette of uses being promoted by the proposed Variation.

3.11 M50 Corridor as ‘Stop Line’ to Development • The M50 Motorway corridor (9V)001, 007, The Manager agrees with the content of the submissions and concurs that, should represent a very clear 015, 018, 021, in this part of the County, the M50 corridor does represent a discrete and and definitive ‘stop line’ to 022, 036, 037, clearly defined demarcation line between the built-up conurbation to the development in this part of the 043, 044, 046, north and the undeveloped foothills of the Dublin Mountains to the south. County. The M50 establishes 051, 052, 067, The very obvious demarcation it provides should be maintained. a very obvious demarcation 068, 069, 072, between the built-up area of 093, 095, 096 the conurbation and the Recommendation : foothills of the Dublin Do not proceed with the proposed Variation Mountains. No substantial development southwards into the Ticknock Hills is warranted or should be contemplated.

Key Issue Ref. Manager’s Response & Recommendation No.

3.12 Inadequate Water and Drainage Infrastructure • Foul drainage/ sewage (9V)022, 039, There is a paucity of mains drainage and certain difficulties with water services at the proposed site 052, 089, 095, supply in the Ticknock area generally. The capacity of water and waste are non-existent, or 096 physical infrastructure to satisfy any demands placed on it by the proposed problematic at best, and there retirement village are not known as there is a complete lack of is inadequate water supply transparency in relation to the size and scale of development that is to be infrastructure to address the facilitated on foot of the proposed Variation. Further detailed assessment potential demands posed by of the local water and drainage infrastructure will be necessary before any the proposed. determination of its adequacy, or otherwise, can be commented upon with any conviction. • Sewage and mains drainage infrastructure in the general area already experiences Recommendation : capacity difficulties while Do not proceed with the proposed Variation. surface water run-off following construction of the South Eastern Motorway has exacerbated flooding issues in certain gardens in Pine Valley. Concern that development of the proposed retirement village will only exacerbate existing issues.

• The HSE comments that the (9V)003 development must be in compliance with the Planning and Development Act and should not be prejudicial to public health.

• The HSE comments that flood (9V)003 risk or potential flood risk of

Key Issue Ref. Manager’s Response & Recommendation No. the proposed development requires to be identified, and, if identified, mechanisms for management be put in place using the Flood Risk Management Guidelines from the DoEHLG and OPW.

• The EPA comments that in (9V)005 proposing any Variations to the Plan, need to ensure that adequate and appropriate infrastructure is in place to service any development proposed.

3.13 Adverse Visual Impact • The retirement village (9V)033, 038, While the overall size, scale and bulk of the proposed development to be development that would be 041, 044, 046, facilitated by the Variation is not known – given the paucity of information facilitated by the proposed 047, 049, 066, and detail provided in respect of same – the Manager agrees that, given the Variation would be visually 068, 091, 093, elevated nature of the site and its essentially agricultural/ amenity context, intrusive and inappropriate, 098, 100 any substantial built form at this location will be visually intrusive and located as it is on an elevated highly visible from the M50, from areas proximate to Ticknock and from and prominent greenfield site parts of the wider Dublin conurbation. on the ‘wrong’ side of the M50 corridor. Any proposed development on the site is almost certain to compromise the Preserved Views from Kellystown Road and Ticknock Road. • The proposed development would be visible from many parts of the Dublin Recommendation : conurbation and particularly so Do not proceed with the proposed Variation. from the M50 corridor and from various vantage points surrounding the proposed site.

• One submission in support of

Key Issue Ref. Manager’s Response & Recommendation No. the proposed retirement (9V)083 village states that the most appealing aspect of the proposed facility is the views over the city.

3.14 M50 Noise Impacts • Concerns raised regarding (9V)014, 016, The Manager agrees that the M50 in undoubtedly a source of traffic noise – traffic noise levels generated 017, 050, 092, as confirmed by the data inputs to the Noise Action Plan for Dublin. by M50 and proximity of the 095 However, the potential adverse impacts of noise intrusion on the proposed retirement village to development that would be facilitated by the proposed Variation cannot be this noise source. Constant quantified at this time without further detailed assessment and clarity in noise likely to have a respect of the proposed scale, height and layout of the retirement village detrimental and negative scheme. impact on the elderly residents of the proposed retirement Likewise the potential implications of the noise mitigation and set-back village. requirements of the National Road Authority on any proposed development on the site cannot be quantified or determined at this time given the • Submission by National Roads (9V)002 information vacuum relating to the retirement village. Authority states that any planning application would require to identify and Recommendation : implement noise mitigation Do not proceed with the proposed Variation. measures for sites within influence of existing national roads and that there is a need to provide [unquantified] adequate set-back between the M50 and the proposed retirement village.

• The submission by the (9V)003 Environmental Health Service states that any proposed development facilitated on foot of the proposed Variation

Key Issue Ref. Manager’s Response & Recommendation No. would be required to adhere to the provisions of the Environmental Noise Directive and the Noise Action Plan for Dublin.

3.15 Lack of Public Transport Provision • Concerns expressed about the (9V)004, 010, The Manager agrees with the sentiments expressed in the submissions almost complete lack of public 012, 016, 018, regarding the paucity of public transport provision serving both the transport serving the wider 027, 031, 032, proposed development site and the wider Ticknock area. Ticknock area. The nearest 036, 038, 043, bus stop to the proposed 048, 051, 052, The only bus route currently serving the wider area is the 114 – Ticknock/ retirement village site is in 062, 065, 066, Sandyford/ Blackrock. Its terminus at Ticknock Hill/ Simons Ridge is more Ticknock Hill – more than 067, 072, 091, than 700 metres distant from the proposed retirement village site. The 700m away. The combination 092, 095, 096 frequency of service is also very limited – on average only one bus every 40 of non-existent public minutes. transport services, combined with the extremely hostile The alignment, topography and geometry of Ticknock Road is completely pedestrian environment in the unsuitable for buses. Ticknock/ Blackglen Road area can only compound issues of isolation and segregation Recommendation : between the proposed Do not proceed with the proposed Variation. retirement village and the wider community.

3.16 Demand for Retirement Living Provision and On-site Facilities • Submissions advise of the (9V)053, 054, The Manager is fully aware of the ageing profile – both of the State and the increasing demand and need 055, 056, 057, County – and is supportive of the principle of specific provision being made for retirement living provision 058, 059, 060, for retirement/ elderly living. However, the Manager disagrees – given the ageing profile both 061, 073, 077, fundamentally with the proposition that the site in question is a suitable nationally and locally – and 078, 080, 082, location for such a development that would be facilitated by the proposed that the development that 083, 084, 085, Variation. There are already over 600 hectares of existing residentially

Key Issue Ref. Manager’s Response & Recommendation No. would be facilitated by the 086, 087, 088 zoned lands in Dún Laoghaire-Rathdown. There are many far better proposed Variation would locations and opportunities – proximate to established communities and provide a safe and secure centres well served by infrastructure and amenities and which are zoned environment for elderly appropriately - than the site in question. The demand/ need for retirement residents with on-site health living facilities in the County should not conflict with the overarching care services. The additional principles of proper planning and sustainable development. supplementary on-site facilities to be provided – commensurate with the scale Recommendation : of the proposed scheme - Do not proceed with the proposed Variation. obviates the need for such a complex to be located proximate to established town/ village centres. Having facilities that are not open to the general public is part of the attraction of retirement village living.

3.17 Councillor Support for Proposed Variation • Submissions advocate that (9V)010, 014, The Manager agrees with the sentiments of these submissions. The local elected members 021, 023, 025, Manager continues to uphold the position that the proposed site is a wholly reconsider their support for 026, 039, 041, inappropriate and unsustainable location for a retirement village complex of the proposed retirement 042, 046, 047, the type envisaged. village development. Noted 050, 064, 065, that Councillor support for 068, 089, 091, proposed retirement village 093, 097, 098, Recommendation : and Variation No. 9 at odds 099 Do not proceed with the proposed Variation. with Manager’s stated opposition to the proposed development.

Key Issue Ref. Manager’s Response & Recommendation No. 3.18 Complying with National/ EU Environmental Legislation and Updated SEA Regulations • Environmental Protection (9V)002, 003, Updated Regulations are noted. The relevant Environmental Bodies were Agency, National Roads 005 properly consulted during the initial stages of the process associated with Authority and Environmental the proposed Variation. Health Service simply flag that this (and future) Variations require to ensure compliance Recommendation : with various National and EU Do not proceed with the proposed Variation. environmental legislation - including recently updated SEA Regulations.

3.19 Other (i) • Submissions state ‘ Fully (9V)074, 075, Manager notes the submissions but is unclear on what basis or rationale the support the development’ 077 development is being supported.

Recommendation : Do not proceed with the proposed Variation.

3.20 Other (ii) • Submissions state ‘ No (9V)045, 076, Submissions are noted. Objection’ . 079, 081

Recommendation : Do not proceed with the proposed Variation.

APPENDIX A

REF NO ORGANISATION ADDRESS EMAIL 9V001 richard.humphreys@votelab our.ie 9V002 National Roads Authority St Martin's House Waterloo Road Dublin 4 9V003 Health Service Executive Enviornmental Health Service HSE Dublin Mid-Leinster 8 Corrig Avenue Dun Laoghaire 9V004 [email protected] 9V005 Environmental Protection Office of Environmental Assessment Agency Regional Inspectorate Inniscarra Co Cork 9V006 Dublin & Mid-East Regional Mainscourt 23 Main Street Swords Co [email protected] Authority Dublin 9V007 41 Cedar Court Dublin 6W 9V008 7 Kingston Crescent Ballinteer Dublin 16 9V009 41 Upper Leeson Street Dublin 4 9V010 21 Delbrook Park Ballinteer Dublin 16 [email protected] 9V011 Dublin Airport Authority Asset Management & Development Level 2 [email protected] Cloghran House Dublin Airport 9V012 3 Ticknock Way Ticknock Hill Co Dublin [email protected] 9V013 Violet Hill Kilgobbin Road Co Dublin [email protected] 9V014 Blackglen Residents 2 Blackglen Court Sandyford Dublin 18 [email protected] Association 9V015 44 Marlay View Ballinteer Dublin 16 [email protected] 9V016 Sandyford Environmental 2 Blackglen Court Sandyford Dublin 18 [email protected] Protection & Road Safety G 9V017 2 Blackglen Road Sandyford Dublin 18 [email protected] 9V018 South County Dublin An Planning Sub-Committee Glenfarn [email protected] Taisce Woodside Road Sandyford Dublin 18 9V019 [email protected] 9V020 Kilgobbin House Kilgobbin Road Stepaside [email protected] Dublin 18 9V021 Hawthorns Ticknock Sandyford Dublin 18 9V022 Derryclare Ballycorus Road Dublin 18 9V023 Ticknock House Ticknock Sandyford Dublin

REF NO ORGANISATION ADDRESS EMAIL 18 9V024 [email protected] 9V025 Holywell Dundrum Dublin 14 [email protected] 9V026 30 Ailesbury Lawn Dublin 16 [email protected] 9V027 28 The view Woodpark Ballinteer Dublin 16 [email protected] om 9V028 7 Tudor Lawns Foxrock Dublin 18 [email protected] 9V029 Tudor Lawns Residents [email protected] Association 9V030 [email protected] 9V031 Kimmage Dublin 12 [email protected] 9V032 37 Mount Eagle Green Leopardstown [email protected] Heights Dublin 18 9V033 muireannbernadino@gmail. com 9V034 58 Stepaside Park Stepaside Dublin 18 [email protected] 9V035 Dublin 16 9V036 Cloughran Gordon Avenue Foxrock Dublin [email protected] 18 9V037 Ticknock Lodge Ticknock Road Sandyford [email protected] Dublin 18 9V038 57 Marley Avenue Rathfarnham Dublin 16 [email protected] 9V039 Valley Lodge Ticknock Road Ticknock Dublin [email protected] 18 9V040 Liscahane Ballycorus Road Kilternan Co [email protected] Dublin 9V041 [email protected] 9V042 [email protected] 9V043 1 Edmondstown Park Dublin 16 [email protected] 9V044 16 Brehons Chair Kellystown Road [email protected] Rathfarnham Dublin 16 9V045 Railway Procurement Parkgate Business Centre Parkgate Street [email protected] Agency Dublin 8 9V046 [email protected] 9V047 [email protected] 9V048 [email protected]

REF NO ORGANISATION ADDRESS EMAIL m 9V049 4 The Glen Woodpark Ballinteer Dublin 16 [email protected] 9V050 2 Blackglen Court Sandyford Dublin 18 [email protected] 9V051 Pinecroft Kilternan Dublin 18 [email protected] 9V052 [email protected] 9V053 Grange Hill Harolds Grange Road Sandyford Dublin 18 9V054 Deerfield Harolds Grange Road Rathfarnham Dublin 16 9V055 50 Ticknock Way Ticknock Hill Sandyford Dublin 18 9V056 Shalan Cottage Harolds Grange Road Sandyford Dublin 18 9V057 Grange Hill Harolds Grange Road Sandyford Dublin 18 9V058 No 1 Sorrell Hall Ticknock Hill Sandyford Dublin 18 9V059 No 8 Sorrell Hall Ticknock Hill Sandyford Dublin 18 9V060 No 2 Sweetmount Avenue Dundrum Dublin 14 9V061 38 Ticknock Way Ticknock Hill Sandyford Dublin 18 9V062 553 Grange Cottages Rathfarnham Dublin 16 9V063 [email protected] 9V064 An Oige muireannbernadino@gmail. com 9V065 [email protected] 9V066 24 The Avenue Woodpark Ballinteer Dublin [email protected] 16 9V067 Woodbine Cottage Ticknock Sandyford Dublin 18 9V068 26 Ailesbury Lawn Dundrum Dublin 16 [email protected] 9V069 elizabethcandon7@hotmail. com

REF NO ORGANISATION ADDRESS EMAIL 9V070 [email protected] 9V071 1 Ailesbury Grove Dundrum Dublin 16 [email protected] m 9V072 Togherbeg Roundwood Co Wicklow 9V073 GVA Planning on behalf of 2nd Floor Seagrave House 19-20 Earlsfort Mr Rod McGovern Terrace Dublin 2 9V074 Jamestown Cottage Enniskerry road Kilternan Dublin 18 9V075 86 Clonbrugh Aikens Village Sandyford Dublin 18 9V076 2 Meadowlfields Sandyford Dublin 18 9V077 84 Clon Brugh Aikens Village Sandyford Dublin 18 9V078 28 Stepaside Park Stepaside Dublin 18 9V079 47 Glenbourne Road Leopardstown Valley Co Dublin 9V080 Apt 4 The Cedar Parkview Stepaside Dublin 18 9V081 19 Stepaside Park Stepaside Dublin 18 9V082 Carrickglen Glenamuck Road Carrickmines Dublin 18 9V083 Algoa Westminster Road Foxrock Dublin 18 9V084 Darone Slate Cabin Lane Sandyford Dublin 18 9V085 Briarwood Ticknock Kellystown Road Dublin 18 9V086 20 Woodside Hall Ticknock Hill Sandyford Dublin 18 9V087 20 Woodside Hall Ticknock Hill Sandyford Dublin 18 9V088 60 Llewellyn Grove Ballinteer Dublin 16 9V089 Hanlon's Lane [email protected] 9V090 8 Ballinteer Drive Dublin 16 [email protected] 9V091 39 Mountain View Road Ranelagh Dublin 6 9V092 [email protected] .uk

REF NO ORGANISATION ADDRESS EMAIL 9V093 [email protected] 9V094 14 Ontario Terrace Dublin 6 9V095 273 Harolds Grange Road Ratharnham Dublin 16 9V096 Pine Valley Residents c/0 64 Pine Valley Park Rathfarnham Dublin Association 16 9V097 Ticknock Road Ticknock [email protected] 9V098 Blackglen Road [email protected] 9V099 18 The View Woodpark Dundrum Dublin 16 9V100 Pine Valley Avenue Rathfarnham