Beach management to protect and encourage dunes

At today’s Area Committee, I again raised the need to change our beach management on Burrow Beach to stop mechanically raking away the incipient dunes which grow on the beach, and to intervene to catch sand where the beach is badly eroded. I put before and after photographs in a powerpoint presentation. The Committee agreed to my motion

“That the Chief Executive bring forward proposals for alterations to the beach and
dune management practices on Burrow, Claremont and Portmarnock beaches in
order to protect dune vegetation and to encourage its growth and recovery in line
with the recommendations of “Leave No Trace”.”

The Executive will return soon to the Area Cttee with a headed item.

Proposed Amendments to Dunsink Urban Area Plan

I have submitted the following amendments to the draft Dunsink Urban Area Plan. Topics include

  • phasing of the Luas to ensure this is transport-oriented development and without which the area will not succeed;
  • reducing downstream flood risks along the Tolka
  • protecting water quality through choice of building materials
  • enabling mixed use beside Navan Road
  • dezoning wetland area along the railway
  • protection from motorway noise
  • adressing land contamination
  • protecting people from construction traffic impacts
  • achieving diversity of housing units despite the Apartment Guidelines which prevent local planners requiring it.
  • protecting Dunsink Observatory from light pollution.
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Observation on draft Beach Bye-laws

A public consultation was open recently in relation to revised Beach Bye-laws for Fingal. I made a submission raising a number of problems with the proposals.

I have since realised that the correct legal process hasn’t been followed, as the draft bye-laws should not have gone on public display without approval of the full Council exercising a reserved function under the Local Government Act. I have drawn the Council Executive’s attention to this legal requirement.

The text of my submission is below.

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Observation in relation to safety at St. Fintan’s National School

I have given the following feedback in relation to proposals online until midnight today.

A proposal like this should not be presented as solely drawings with no explanatory text. The reasons for and purposes of the specific changes proposed should be set out, as well as considerations as regards any changes considered but not currently proposed.

The proposal is to put bollards along the footpath beside the zigzagged area and the marked car parking/waiting areas. Is this intended to prevent footpath parking at these locations? If not, what are these bollards for? It’s my impression that there isn’t footpath parking at these locations. However, the zigzagged area is subject to illegal car parking/entry. Google maps show traffic cones placed to prevent this. Bollards on the footpath, of course, won’t address the problem of illegal parking on the carriageway.  This presumably results from the road layout providing an additional section of the carriageway off the (already wide) main westbound lane. It’s not surprising that the subsequent modification by road markings hasn’t eliminated this parking. Surely it would make more sense to widen the footpath here so there is no additional carriageway space off the main eastbound lane?

The visual narrowing of the road at this location would also help address the main concern identified in the road safety audit. The road widens significantly at the school, leading to increased vehicle speeds. This has to be addressed. Some tree planting, sited to maintain necessary sightlines, could help with this as well. 

Why is a zebra crossing or a controlled crossing not proposed here? 

Given work is to be done at this location, this is an appropriate time to consider the installation of bus shelters at the stops outside the school.

Observation in relation to safety at Scoil Mhuire, Howth Primary School

I have given the following feedback in relation to proposals online until midnight today.

I have been raising the unsatisfactory condition for people walking and wheeling on Tuckett’s Lane for some time. The footpath is only on one side of the road, which would be ok if it was adequate, but it isn’t adequate. It narrows to a pinch point too narrow for wheelchairs and most pushchairs just uphill from the park, with no ramped access. (See attached photo.) I asked for this to be addressed when the lane was dug up for surface water works. I raised the need to address the quality of the lane for people walking and cycling at the earliest possible opportunity, and pointed out that this was consistent with the direction agreed by the full Council in late 2022. (https://meetings.fingal.ie/ieIssueDetails.aspx?IId=58033&Opt=3&AIID=82573)  

The response was effectively that this was a different area of responsibility and that the opportunity to improve the lane while resurfacing after the water supply wouldn’t be taken. I was told that the issue would be referred to Active Travel. I have forwarded the relevant correspondence by email.

I’m concerned that the proposal on display is to address the situation immediately at the school but not the situation 100m away, despite the declared aim of Fingal Safer Schools to “Improve access routes to school by enhancing walking and cycling infrastructure.”

Downhill from the park, the footpath has steps due to its steepness, but there is no dishing to enable people using wheels to access the carriageway.

Without a doubt some of the motor vehicle delivery traffic to the school is a result of the inadequacy of the walking routes to the school. Therefore, the above issues with Tuckett’s Lane should be addressed to facilitate greater numbers walking rather than being driven, in accordance with the aim of the project.

As part of that, the four arms of the Tuckett’s Lane/ St. Lawrence’s Terrace/ St. Nessan’s Terrace junction should be marked with zebra crossings.

The footpath on Tuckett’s Lane between the above junction and the school is also substandard and should also be widened.

The drawing is hard to understand, being marked in yellow on a faded photographic background.  Am I correct that bollards are proposed to prevent cars parking on or accessing the footpath? There are no indications on the map that there is an intention to restrict car parking on the carriageway at these locations, yet a number of the submissions seem to understand that this is proposed. If this is a misunderstanding it should be clarified to those who made submissions.

The crossing point in front of the school should be made into a zebra crossing.

One of the submissions correctly points out that the footpath across from the school on the west side of St. Peter’s Terrace ends at a height blocked off with railings. This should be redesigned to facilitate people walking.

The opportunity should be taken for locating additional trees/rain gardens in this area.

Observation on proposed Dunsink Local Area Plan

I have made an observation on the draft Dunsink Local Area Plan. It’s main points:

  • Luas should be delivered along with housing, not after.
  • The proposal to delay the light rail line until long after extensive housing is provided is contrary to the principles of Transport-oriented Development and inconsistent with the Regional Spatial and Economic Strategy.
  • The assessment of alternatives in the Strategic Environmental Assessment is not meaningful and does not comply with the requirements of the SEA Directive.
  • The proposals in the draft LAP as regards car parking present opportunities for significant economic savings for residents and for major improvements in welfare and the public realm.
  • The proposed combined light rail and cycle/pedestrian bridge over the M50, consistent with the relevant provisions of the Fingal Development Plan, is very welcome.
  • The alteration of River Road to a quietway with no through motor traffic requires minimal initial investment and should be implemented as part of, or before, phase 1 of the LAP.
  • The land to the west of the Navan Road train station is ideally suited for transport-oriented development and the zoning shoul be changed to the mixed use Metro Rail Economic Corridor to provide housing as well as employment.
  • The land to the east of the station includes a large area of wetland. The wetland area should have the development zoning removed from it.

Full details here.

An Coimisiún Pleanála decision on Deer Park Hotel replacement

ACP has granted permission for a replacement Deer Park Hotel, following appeals.

The first-party (Tetrarch) appeal against Fingal’s permission was about the refusal of permission for a new road and the extent of car parking.

My (third-party) appeal was about

  • the need to do a sustainability analysis of the demolition proposal
  • a request for pedestrian permeability conditions in the decision and
  • support for the refusal of the road.
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Don’t exempt car parks from the Residential Zoned Land Tax

At Monday’s meeting the Council agreed to my motion to write to the Minister for Housing to ask that sites with housing planning permissions but which are currently used as car parks no longer be exempted from the Residential Zoned Land Tax.

I became aware of this exemption in the context of the recent Variation to the County Development Plan, where we rezoned green belt and rural land despite the availability of well-located, fully serviced residential land with planning permissions. In the Variation process, I asked for details of the undeveloped sites with planning permission and found that these sites included two on car parking at Blanchardstown Shopping Centre for 1319 apartments, and one on car parking in Santry for 192 apartments.

The owner of the Blanchardstown sites has gone on public record that they are deferring their development of these apartments: “In respect of the permitted Site A and Site B/C permissions, due to current viability challenges, these developments are expected to come forward in the medium term…”

A majority of the Council supported my motion, with one FG councillor voting against and eight councillors abstaining.

More details are in the Dublin Inquirer’s article.

Abbey Park and District Residents again stand up for proper planning in Baldoyle

Congratulations are due to Abbey Park and District Residents Association for yet again standing up for proper planning and sustainable development in their area. Their Judicial Review challenge to a permission for an 11 storey residential tower beside Stapolin Educate Together National School has been successful. The application was refused by Fingal County Council but that refusal was overturned by An Bord Pleánala (ABP, now An Coimisiún Pleanála, ACP) on appeal.

In the High Court, Holland J ruled that ABP had failed to address the inadequate playground provision, which was a material contravention of the Fingal Development Plan. The file has been remitted to ACP for decision, with the assistance of the Judge’s observations on a number of the other grounds in the judicial review challenge, on which he did not make findings.

The judgement will be of particular general value in reminding planning authorities of something surprisingly contested by ACP in the hearing, i.e. that they have “a duty to seek to protect the residential conditions and amenities…of those, usually as yet unidentified or unidentifiable, who will live in the dwellings proposed” and in reminding them that [w]hile opposed planning applications are in practice considerably adversarial, they are primarily inquisitorial processes.”