Author Archives: david

Appeal in relation to Deer Park Hotel

I have made a planning appeal in relation to the application to demolish and replace the Deer Park Hotel. I agree with the appropriateness of the existing hotel use and with the renovation of the hotel. The appeal focuses on three issues:

  • Sustainability assessment of demolition and reuse
  • Access and permeability by foot
  • Support for FIngal’s decision to refuse a large new access road
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Information on sewage overflows

I have been campaigning for some years for Irish Water and Fingal County Council, who are their agents, to make information on all sewage overflows publicly available as soon as they happen. I was particularly concerned when a number of years ago we were told by Irish Water that there had been no sewage discharge at a particular location only to find out some months later that there had.

I believe the ongoing failure to make this information easily and immediately available to the public is a breach of the obligation of active dissemination in the Aarhus Convention and the Access to Information on the Environment (AIE) Regulations.

I have made an AIE request for information about the sewer network and locations of discharges and overflows, as well as details of the overflows over recent years. Here’s the response:

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Submission to Dart+ North Consultation

My submission to Iarnród Éireann’s consultation on Dart+ North

It follows my previous observations.

Observations on Deer Park Hotel application additional information

I have made an observation on the additional information received for application F22A/0372, subsequent to my previous observation. The main points are:

  • The proposed new road should be refused.
  • There should be an analysis of the sustainability of the proposal comparing demolition, reuse etc, as required by the new Fingal Development Plan.
  • The application should provide for pedestrian links from the hotel to Howth and neighbouring residential areas.

Abolishing car parking requirements and developing car-free neighbourhoods – Green Councillors’ submission to consultation on sustainable settlements

The Green councillors on Fingal County Council have a made a submission to the consultation on Sustainable and Compact Settlements Guidelines run by the Department of Housing, Local Government and Heritage.

Our submission focusses on car parking issues, pointing to good policies adopted in the Fingal Development Plan 2023-2029.

Two aspects of the Fingal Plan are worth copying. First we advocate that minimum parking standards should be abolished from the planning system. The Fingal Plan does this for areas near public transport (which are effectively the entire developed area of Fingal.)

This is not abolishing parking entirely, it is that the planners will no longer require developers to provide more car parking than they want to, i.e. than they think the market is looking for. Our recommendations as regards car parking are informed by the work of planners like Donald Shoup and campaigns such as the Parking Reform Network. We are very conscious that minimum parking requirements have two significant negative effects. Minimum parking requirements reduce housing affordability, and it has been found again and again that removing the parking requirements enables the building of more housing. The cost minimum parking requirements imposes on housing becomes a subsidy which builds in an incentive to car use, contrary to our climate, health and quality of life goals for transport.

Secondly, we recommend that urban areas be designed primarily for walking, cycling and public transport, and that car parking be clustered rather than spread through out residential or mixed use areas as is often the case. We point to the provision of the Fingal plan providing for car-free neighbourhoods as a good example to be followed nationally. These recommendations are informed by positive experiences in pedestrianising existing areas and by the development of new car-free neighbourhoods in cities and towns across Europe and the world.

Our observation on proposed draft direction to delete noise insulation objective from Fingal Development Plan; make your observation by Tuesday 2nd May!

Following advice from the Planning Regulator, the Minister of State for Local Government and Planning has drafted a Direction to Fingal County Council to delete a provision about noise insulation included in the Plan. The Draft Direction is open to public consultation until Tuesday 2nd May 2023 at 11.59pm.

The 5 Green Councillors on Fingal County Council have made an observation pointing out that there is no legal basis for the draft direction and that the provisions were included to protect human health.

The objective, agreed by unanimous vote of the Council, specifies that insulation for homes affected by aircraft noise should achieve 40 dB Lnight, which is the standard recommended by the World Health Organisation to protect people from the impact on health caused by sleep disruption.

Anyone affected by aircraft noise should make their views known before the deadline.

Observation on Howth Castle planning appeal

I have submitted an observation on the appeal by Tetrarch against conditions imposed by Fingal County Council as follows:

  • I welcome the Council’s approval of the hospitality use of Howth Castle subject to architectural protection conditions.
  • I agree with the Council’s conditions removing the proposed new road access parallel to the existing avenue and reducing the area of car parking.
  • I disagree with the Council’s condition to widen a proposed footpath to a greenway and propose that Tetrarch’s own greenway proposal be added to the project instead.

Observation on Irish Water pumping stations to end Doldrum Bay sewage discharge

I have made an observation on Irish Water’s application to divert sewage currently running into the sea at Doldrum Bay in Howth into the system leading to the Ringsend sewage treatment plant. This application is late as is to comply with a condition of the EPA licence which should have been met 11 years ago. It is very welcome, but unfortunately Irish Water has failed to take on feedback about the impact on the local environment. The main issues raised in the observation are

  • impact on views protected in the Howth Special Amenity Area Order (SAAO) and fencing in breach of the requirements of the SAAO;
  • discharge of surface water should be to a soakaway not to the sea.