Inspector’s Report 06S.JA0040. Development Dublin Mountain Visitor Centre and all associated works. Location Townlands of Montpelier, Killakee and Jamestown, South Dublin. Planning Authority South Dublin County Council. Applicant South Dublin County Council. Type of Application Section 175(3), Planning and Development Act 2000 (as amended). Submissions/Observations See Appendices. Date of Site Inspection 26th August 2017, 6th January 2018, 25th January 2018, 6th November 2018, 18th November 2018. Inspector Ciara Kellett. 06S.JA0040 Inspector’s Report Page 1 of 141 Contents 1.0 Introduction .......................................................................................................... 3 2.0 Site Location and Description .............................................................................. 3 3.0 Proposed Development ....................................................................................... 6 4.0 Planning History ................................................................................................. 10 5.0 Policy Context .................................................................................................... 12 6.0 Submissions following initial lodgement ............................................................. 23 7.0 Request for Further Information ......................................................................... 33 8.0 Oral Hearing ...................................................................................................... 49 9.0 Assessment ....................................................................................................... 52 10.0 Planning Assessment .................................................................................. 53 11.0 Environmental Impact Assessment ............................................................. 73 12.0 Appropriate Assessment ........................................................................... 120 13.0 Conclusion ................................................................................................ 131 14.0 Recommendation ...................................................................................... 132 15.0 Reasons and Considerations .................................................................... 132 Appendix 1 ............................................................................................................. 138 Appendix 2 ............................................................................................................. 140 06S.JA0040 Inspector’s Report Page 2 of 141 1.0 Introduction This is an application for development approval submitted to An Bord Pleanála (the Board) under Section 175(3) of the Planning and Development Act 2000, as amended. Applications under Section 175(3) are made by Local Authorities when the authority proposes to carry out development within its functional area, in respect of which an Environmental Impact Assessment Report (EIAR) has been prepared. Under the provisions of Article 120(3)(b) of the Planning and Development Regulations 2001, as amended, South Dublin County Council sought a determination from the Board as to whether or not the proposal would be likely to give rise to significant effects on the environment and thereby require the preparation of an Environmental Impact Statement (EIS)1. The Board decided on 8th May 2017 to direct the Council to prepare an EIS. An Environmental Impact Assessment Report (EIAR) accompanies this application. 2.0 Site Location and Description The application site is stated as being c.152Ha within the foothills of the Dublin Mountains on Coillte owned land. The site is bisected by the R115 Road in a north- south direction (known as the Killakee Road at this location). To the west of the R115 Road lies Montpelier Hill and the area known as the Hellfire Forest, and the land to the east of the road is known as Massy’s Wood2. The R115 Road links Rathfarnham with Killakee, Glencree and Sally Gap in County Wicklow running south through the Dublin and Wicklow Mountains and climbing steadily uphill from Rathfarnham. The R115 meets the R113 Road at a junction north of the site. The R113 runs north-west of the site towards the Ballycullen Road and is known as Gunny Hill. The 60kph speed limit applies in this area and there are no public footpaths or cycle lanes. The area is not served by public transport and the R115 is particularly steep where it bisects the subject site. 1 This application was submitted after 16th May 2017, the date for transposition of Directive 2014/52/EU amending the 2011 EIA Directive. The Directive was transposed into Irish Legislation on 1st September 2018. An EIAR was submitted with the application. 2 Various spellings of the names of the areas (Montpelier, Killakee, Massy’s) are used throughout the documentation submitted, as well as on maps. 06S.JA0040 Inspector’s Report Page 3 of 141 Hellfire Forest 2.3.1. The Hellfire forest to the west of the R115 is stated as being 105Ha in extent and is an actively managed commercial coniferous forest. It is located on Montpelier Hill which is one of the northern hills of the Dublin Mountains. There is one entrance to the forest from the R115 via a barrier-controlled access. It has restricted opening hours between 08.00 – 17.00 October to March, and 07.00 – 21.00 April to September. 2.3.2. There is an existing car park to the north of the entrance which is stated as holding 75-80 cars. The parking spaces are not clearly marked out resulting in haphazard parking. On busy days parking can overspill onto the R115 on the west side of the road. This overspill parking can lead to difficulty for two cars to pass. It is stated that the over-mature conifer plantation at the car park will be subject to wind throw and is not sustainable and is therefore due to be felled. 2.3.3. From the entrance to the car park which is at a level of 250m AOD, the site rises steeply to the summit of Montpelier Hill at 383m AOD. There are a number of forest tracks (both pedestrian and vehicular) which lead up to the summit where the ruins of the hunting lodge known as the Hellfire Club lie. 2.3.4. On the most direct pedestrian route up to the Hellfire Club, there is a large boulder in the centre of the track which is indicated as a ‘standing stone’. It is noted as having been knocked over onto its side in recent years, making it somewhat indistinguishable. 2.3.5. From the top of the hill and on the tracks up, there are long distance panoramic views to the north and east of Dublin City and Bay. There has been recent clear felling of the forest to the east. There are still large mostly conifer plantations on the hill which limit views to the south and west. 2.3.6. The Hellfire Club ruin is located in a clearing at the top of the hill. The building is a Protected Structure (RPS Ref. 388) and listed in the National Inventory of Architectural Heritage (NIAH Ref. 11220022). It is noted as being constructed in 1725 (although this date differs from the description provided by the NIAH). The NIAH describes it as ‘Detached five-bay single-storey-over-basement former hunting lodge on hill summit, built c.1740, burnt soon after, with vaulted stone roof repair, now derelict. Projecting porch / gallery with arched window to front, between plain 06S.JA0040 Inspector’s Report Page 4 of 141 openings in main elevation. Two wings with small rooms and sloping stone roofs, and projecting shelter walls. Projecting wing to rear with small semi-circular window. Internal rooms with fireplaces, arched doorways and niches, and connecting gallery. Robbed megalithic tomb and triangulation survey pillar nearby’. 2.3.7. The NIAH further notes the infamous history of the building and states that the building ‘has an undeniably foreboding presence, and the later stone vaulted roof repair is outstanding in its coarseness’. 2.3.8. The original staircase is missing and has been replaced in the recent past with a concrete staircase with welded metal balustrade. 2.3.9. There are clear signs of anti-social behaviour which is damaging the building. There is graffiti on the walls, debris and litter left lying around and evidence of fires having been lit in the interior. 2.3.10. To the south of the Hellfire Club are the remains of two passage tombs (Neolithic/Megalithic) which are recorded in the Record of Monuments and Places. Massy’s Wood 2.4.1. To the east of the R115 lies Massy’s wood which is stated as being 47Ha. The principle entrance to the woods lies to the north of the entrance to the Hellfire forest. There is no parking provided in the woods at this point and it is likely that people park in the Hellfire car park and walk across the road, or park on the R115 outside. There are two other access points to Massy’s wood at Rockbrook to the north-east and Cruagh to the south-east where the Dublin Mountains Way passes the site. Neither access point has car park facilities but there is a parking spot near the Rockbrook entrance. 2.4.2. Pedestrian access from the R115 is via a gate which leads into the woods and is along the last remaining unpaved section of the Old Military Road (Protected Structure Ref. 385). Massy’s wood is part of the demesne of the former Killakee House which was demolished in 1941. The woodlands are now managed as a mixed woodland predominantly for recreational purposes. There are a number of older specimen trees from the original demesne, such as Giant Sequoia, Monkey Puzzle and West Himalayan Spruce trees. 06S.JA0040 Inspector’s Report Page 5 of 141 2.4.3.