A very large urban development application has been made on the Belcamp lands, in advance of the Local Area Plan which the zoning provides for. I have made an observation to An Bord Pleanála (version with appendices) focussing on the need to develop around high-quality public transport.
It has been clear to me for over 15 years that the large development area planned between Clonshaugh and Clongriffin, of which this Belcamp application forms part, should be served by an orbital light rail or metro connection to the Dart in the east and the Metro in the west, a link which will also be of wider benefit to the public transport network.
The only additional recent element is that NTA, in its proposals for revising the Greater Dublin Area Transport Strategy, now recognises that there will be a need for a light rail service on the Malahide Road, so it’s proposing a further link in the network.
My observation to the public consultation which closes today focuses, in particular, on
- the need to ensure active travel is fully incorporated into the road and street maintenance process, and
- ensuring planning applications deliver quality environments for walking and cycling.
The first Strategic Housing Development planning application at Auburn SHD was turned down by An Bord Pleanála. (See my submission here.) A new application has come in with some minor changes, but still with no walking routes northward to connect up with Malahide and the Swords Road (and 102 bus route). So my observation again points to the accumulation of policy which commits to ensuring that new residential areas are walkable and asks An Bord Pleanála to follow national, regional, county and local policy.
My observation on the Strategic Housing Development planning application at Broomfield, Malahide is here. The main points are:
- The application is for a very car-dominated and child-hostile environment. It would be much better to group the car parking near the Back Road and provide for a pedestrian-oriented estate layout, with motor vehicle access for deliveries only.
- To minimise walking distances to the town of Malahide, public transport and local amenities, there should be a walking and cycling access from the north of the proposed housing area to Back Road.
- The applicant should be required to reserve a route to facilitate the active travel access route between the Back Road and Malahide Community School proposed in the draft Fingal Development Plan following recommendations from a report by Sustrans.
- The applicant here should be required to incorporate a school in their application or reserve and allocate a site for a primary school.
My submission is here, covering the following topics:
- Ecological restoration
- Water Framework Directive
- Assessment of climate impact of development proposals
- Fossil fuel infrastructure
- Solar energy
- Nature-based solutions and biodiversity co-benefits on the coast
- Baldoyle and Kilbarrack Industrial Estates
- Roadside signage
- Restriction of advertising
- Circular Economy
- Howth West Pier infill proposal
- Access to Balscadden Beach
- Car parking “norms”
- Actions towards filtered permeability
- Indicative Cycle/Pedestrian Routes
- Local Objectives and various policies and objectives
- Duty of active dissemination of environmental information
- Local objective to recognise Bathing Waters
- Public Rights of Way
- Sewage overflows and unplanned discharges
- South Fringe/North Fringe development area and orbital public transport
My comments on the draft design are here. The main points are:
- The proposal is very welcome and the design is greatly improved from the previous versions.
- However, there are a number of changes which I recommend, in particular full segregation between walking and cycling on the route, given how busy it will inevitably be with existing and new population and the many visitors which the route itself will help to attract.
My observation to ABP in relation to the latest application on this site is here. The development should be scaled back to respect the natural and architectural context of the site, in particular the Martello Tower on Tower Hill. The underground car parking should be removed from the application. My observations on previous applications are here and here.
My response to the public consultation on the Dart + North project focusses on
- the fact that the analysis doesn’t demonstrate how the proposal for a shuttle service between Howth and Howth Junction might be justified;
- the fact that an increase in frequency to Howth would not compensate for longer and more inconvenient journeys especially for those with mobility challenges;
- the design disaster of the illegally constructed Howth Junction station;
- the need to redevelop Howth Junction as part of a densification of the adjoining employment areas so well served by public transport; and
- the need to ensure coherence between the level crossing plan in this project and that in the Sutton to Malahide Cycle Route.
My observations on the draft River Basin Management Plan are based on the template from SWAN (Sustainable Water Action Network), with the addition of two issues:
My response to Fingal County Council’s public consultation on aircraft noise is here. In it, I point out that
- there should be a general ban on night-time flights given the known health impacts of sleep disturbance by aircraft noise;
- the noise reduction objective needs to be based on analysis not just picked from an EU-wide strategy;
- Strategic Environmental Assessment (SEA) requires that alternatives such as a general night-time ban be considered;
- SEA also requires that the climate impact of the proposal and alternatives be considered, especially as night time aviation is generally much worse for the climate than daytime;
- Fingal County Council, including when it acts as an Aircraft Noise Competent Authority, is required by Irish law to pursue climate objectives.