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Response to DLRCC's Issues Paper for the County

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Response to DLRCC's Issues Paper for the County HAVE YOUR SAY Dun laoghaire-Rathdown County Development Plan 2022TITLE-2028 PAGE Submission from Imagine Dundrum February 2020 Submission from: Imagine Dundrum Secretary: Dr Wendy Cox 30 Ailesbury Lawn Dublin 16 Mobile: 087 9087388 Landline: 01-2951054 2 Introduction Overview Imagine Dundrum welcomes the opportunity to make a submission to the pre-draft consultation for the revised County Development Plan 2022-2028. In this submission, our focus is on those aspects of the County Development Plan that are likely to have most relevance for Dundrum Village and its immediate surroundings : 1. People, Homes and Places (including Housing) 2. Sustainable Movement and Transport 3. Green County; Play and Recreation 4. Retailing and Major Town Centres 5. Built Heritage 6. Climate Action and Energy Efficiency We are at a key moment in the decisions and processes that will determine the future of Dundrum. The redevelopment of the Village offers an unparalleled opportunity to restore Dundrum’s original strong identity and focus, and renew it as a uniquely thriving and attractive place. The County Development Plan, along with the Dundrum Local Area Plan, will have a major influence on the outcome, not only for current local residents, workers and visitors, but for many years to come. It is vital that they support and enable the best possible future Dundrum. Dundrum in the County Development Plans The current and future County Development Plans will provide the crucial framework for the redevelopment of Dundrum Village, and hence will significantly determine the future quality of life of its rapidly expanding and changing population. At present, Dundrum’s situation is poor – while it has been designated the second major town within DLR County, it lacks almost all the facilities and services appropriate to this status, including a civic centre as the focus for community life. The Plan for 2022-28 has the potential to address these deficits. Imagine Dundrum urges in particular that the specific elements relating to Dundrum Village in the original Dundrum Urban Design Framework of 2003, which have already been incorporated into the current Development Plan, and the specific requirements of SLO 149 and 150, be retained in their entirety in the Plan for 2022-28. Guiding principles for the County Development Plan 2022-28 Imagine Dundrum welcomes the consultation document’s emphasis on sustainable communities and placemaking as key drivers of the revised County Development Plan. It is our view that wellbeing and quality of life should also be explicit values, underpinning all aspects of the Plan, and enabling the provisions of the Plan to be measured against them. A further guiding principle, now that DLR County Council has adopted its Climate Action Plan 2019- 2024, is that climate thinking becomes integral to all aspects of planning and decision-making under the auspices of the County Development Plan. 3 Placemaking and community engagement Imagine Dundrum understands placemaking to mean that local people and communities are fully involved and engaged in the design of their own place. We ask that this principle be endorsed by Dún Laoghaire Rathdown County Council for the future stages of local and County Plan-making. Planning focus: a village and a neighbourhood While recognising that the County Development Plan has overall a whole of county focus, Imagine Dundrum considers that high quality village and neighbourhood thinking is critical to the quality of life of residents and communities, and therefore that attention needs to be paid to specific localities and their unique characteristics. Currently, the development focus in relation to the critical area of housing is predominantly on individual Strategic Housing Developments and apartment buildings, and national guidelines take minimal account of neighbourhood considerations. However, sustainable communities cannot be achieved without a high standard of planning at the level of villages and neighbourhoods/localities. We therefore look to the County Development Plan to place a new emphasis on this level of planning, in order to protect and support local communities as they change and develop. Imagine Dundrum wishes to see the provisions of the Urban Design Manual: A Best Practice Manual1, with its strong focus on neighbourhood urban design e retained fully in the provisions of the County Development Plan. Lifecourse planning The distinct needs of differing segments of the population – children and young people, families, older people, people with disabilities – should be visible in all key aspects of the County Development Plan, in order to ensure a planning response that meets those needs. A “health-in-all” approach, with joined-up, inter-departmental and inter-professional working supporting genuinely citizen-centred planning could be a valuable feature of the next County Development Plan. * 1 Department of Housing, Environment and Local Government (2009) ://www.housing.gov.ie/sites/default/files/migrated- files/en/Publications/DevelopmentandHousing/Planning/FileDownLoad,19216,en.pdf 4 1. People, Homes and Places 1.1 General principles Imagine Dundrum welcomes the focus on sustainable communities and community wellbeing as the driver of all aspects of the County Development Plan, but particularly the provisions in relation to housing, public realm, community facilities and placemaking. This focus on community wellbeing needs to be explicit and visible across all aspects of the County Development Plan. The policy of promoting sustainable community-friendly development must translate into specific neighbourhood/locality development policy across a range of aspects including housing, public spaces, public realm and community facilities. The provisions of the Urban Design Manual: A Best Practice Manual2, which focuses strongly on neighbourhood urban design should be retained in the provisions of the County Development Plan. The development of a proactive and strategic housing policy over the next 6 years will mean concentrating on increased density (but not necessarily increased building heights) in areas of the County adjacent to public transport links, good pedestrian and cycling facilities and reducing the need for car use. Careful planning will be crucial to avoid increased pressure on housing costs over the next 6 years, when the population of the County is expected to increase by 23,000-27,000. It is also critical that all future development should adhere to a climate change strategy designed to substantially reduce the production of greenhouse gases (GHGs) in the County. 1.2 The County Development Plan anD housing provision Ensuring that housing provision is geared to the needs of the local population is a critical element of the County Development Plan. 1.2.1 Residential development in urban villages Imagine Dundrum strongly supports the provision in the current Development Plan (Policy RES 15,p45) regarding housing provision in urban villages, which provides for a variety of dwellings by type and size to accommodate families with different needs, and proposes a mix of apartments, terraced houses, and other house types. Managing this variety should be the role of the Local Area Plan, supported by the County Development Plan. Imagine Dundrum also strongly supports the provision (RES 15, p46) that the character of existing villages should be protected or enhanced by any new development. Imagine Dundrum does not support Departmental Guidelines which frustrate the fundamental concepts of local placemaking and neighbourhood development. 2 Department of Housing, Environment and Local Government (2009) ://www.housing.gov.ie/sites/default/files/migrated- files/en/Publications/DevelopmentandHousing/Planning/FileDownLoad,19216,en.pdf 5 Recommendation: That the County Development Plan 2022-28 retains and strengthens Policy RES 15 in the current CDP. 1.2.2 Brownfield development, density and building heights Imagine Dundrum recognises the policy objective of using brownfield/infill sites to promote compact development and higher densities, and to maximise land use in the area. However, these developments must positively contribute to and integrate with the existing built environment and respect the residential amenities of neighbouring properties. We welcome the recognition (p24??) that this type of development can raise legitimate concerns about the impact on the existing residents and amenities, and want to state clearly our serious concern that new planning guidelines for apartment developments, and particularly for Build to Rent developments, make this essential placemaking approach difficult if not impossible. Recommendation: The County Development Plan should require from developers and planners a neighbourhood-focused approach to the development of brownfield sites, to enable their successful integration into existing environments and communities. It cannot be an approach that addresses a single development in isolation from its neighbourhood context. We look to the County Development Plan to put in place policies that embed the neighbourhood/locality-based approach to brownfield development. In particular, the County Development Plan should set down the requirements for the way in which a brownfield development will interact with the public realm. Where the site sits alongside a Main Street, as in the case of Dundrum Village and the old Shopping Centre site, the alignment of the development and the Main Street must contribute fully to the enhancement of the public realm. In this regard,
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