I have objected to the proposed high-density development of part of the Santa Sabina lands.
Councillor David Healy
Green Party/Comhaontas Glas
Howth ward / Dublin North East
 
www.davidhealy.com
01 8324087
54, Páirc Éabhóra, Beann Éadair
54, Evora Park, Howth
 
5th September 2006

Planning Department,
Fingal County Council

Re: planning application F06A/1099

A chairde,

I wish to object to this application on the following grounds.

1. Excessive density in an area poorly served by public transport.  

Density guidelines both at national and local level are based on the potential for serving higher density developments by public transport.  This area is on the 31B bus route which has 16 buses a day on a weekday, 6 on a Saturday and 3 on a Sunday.    It is well outside walking distance from Sutton Dart Station.  The overall area is mostly low to medium density housing and amenity, high amenity, special amenity area and other protected lands.  The creation a pockets of high-density development within this area, which will not be served by quality public transport is car-dependent residential development and therefore is entirely contrary to proper planning and development.

2. Visual impact  and height

The development would have a negative visual impact on protected views, marked for preservation in the Development Plan from Dublin Road and Strand Road.  This is primarily due to the height of the developments.

3. Impact on neighbouring residential amenity.

The development would have a severe negative impact on adjacent houses.  I know many of these residents are rightly objecting on their own behalf.

4. Flooding risk

The development could by displacing groundwater and interfering with drainage increase flooding risks in the area.  I note that ground floor levels are elevated in the plans.  Underneath some of these ground floors basement car parking is proposed.  Is it considered that car parking with a high risk of flooding is proper planning?

Allegations of irregularities in the planning process

Mr. Bannon’s letter of 24th August makes an important allegation that alterations were made to documents in the planning file.  If this allegation is correct it would be an  offence under the planning acts. I request that this matter be fully investigated.

Is mise, le meas,

David Healy

The Agenda for the next Area Cttee A (Water Services, Environment and Transportation) is out. The meeting is on Wednesday the 6th September at 3pm in Baldoyle Library and is open to the public.
COMHAIRLE CONTAE FHINE GALL

FINGAL COUNTY COUNCIL

Phone:  8905000                              P.O. Box 174,
Fax:      8905809                             County Hall,
                                    Swords,
                                    Fingal,    
                                    Co. Dublin.
                                                                                 30th August, 2006

         OTE CHANGE OF DATE OF MEETING
       

To each Member of the Malahide/Howth
Area Committee:

Dear Councillor,

A meeting of the Malahide/Howth Area Committee (Services A – Transportation, Environment and Water Services) will be held in the Baldoyle Library and Offices, Baldoyle, Fingal Dublin 13, at 3.00 p.m. on Wednesday 6th September 2006 to consider the following Agenda.

Yours faithfully,

 S. Peppard
Meetings Administrator
Corporate Services Division

****************************************************

A  G  E  N  D  A

1.    Confirmation and Re-affirmation of Minutes.

(a)    Minutes of Malahide/Howth Area Committee (Services A) held on Thursday 8th June 2006.
           (already circulated)

(b)     Minutes of Special Meeting of Malahide/Howth Area Committee (Services A) held on Thursday 29th June 2006.                        
        
               (to be circulated)
WATER SERVICES QUESTIONS

2.    Councillor R. Kelly
"To ask the Manager to report on recent large sewage spill on Old Portmarnock Road area (possibly linked to Seabrooke,Links and Kilns apartments)which is flowing into the Sluice Marsh?"

3.    Councillor D. Healy
"To ask the Manager for a report on sewage discharges into the Santry River and whether the loss of the Blue Flag at Dollymount might be linked to this?"

4.    Councillor D. Healy
"To ask the Manager what the anticipated time scales are for installation of the sewage pipe between the outfall at the Nose of Howth and the pumping station at Sutton?"

5.    Councillor D. Healy
"To ask the Manager what the arrangements are for the cleaning and caretaking of the public toilets at the East Pier in Howth?"

6.    Councillor D. Healy
"To ask the Manager to report on the water quality at Burrow Beach Sutton in 2005 and 2006 and to report on the known or likely sources of contamination?"

7.    Councillor R. Kelly
"To ask the Manager to report on the illegal dumping of road rubble at the
mouth of Sluice River which has not been removed over one year after it was
reported?"

ENVIRONMENT QUESTIONS

8.    Councillor R. Kelly
"To ask the Manager what policy has Fingal got in relation to both monitoring and removal of graffiti in the Malahide Ward?"

9.    Councillor R. Kelly
"To ask the Manager what powers do the Council have in relation to
enforcement of environment law in relation to Sluice Marsh?"

10.    Councillor R. Kelly
    "To ask the Manager could the Council get a break down on the cost the
Council pay Dublin City Council for Malahide Fire Station?"

11.    Councillor R. Kelly
    "To ask the Manager the to report back on Fingal County Council running
Malahide Fire Station independent of Dublin City Council?"

12.    Councillor R. Kelly
"To ask the Manager to comment on the recent news that Malahide Fire Station is closing down?"

TRANSPORTATION QUESTIONS

13.    Councillor D. O’Brien
"To ask the Manager to have a name plate erected on Holy Well Drive Kinsealy?"

14.    Councillor D. O’Brien
"To ask the Manager to provide the time scale and schedule of remaining works for the traffic management plan for Seabury, Old Yellow Walls Road, Millview and the Swords Road?"

15.    Councillor D. O’Brien
"To once again ask the Manager for an update in the progress with the ESB in relation to putting the ESB cables underground in Gainsborough Estate, Malahide."

16.    Councillor D. O’Brien
"To ask the Manager to arrange for the steps leading onto Bissetts Strand Malahide, at the Railway bridge to be fixed as they are broken and in a dangerous condition?"

17.    Councillor D. O’Brien
"To once again ask the Manager when the ESB poles will be removed at Barrack Bridge and to carry out this work as a matter of extreme urgency?"

18.    Councillor P. Coyle
"To ask the Manager if the footpath outside 81-83 and 107 Carrick Court, Portmarnock, could be examined and remedial works carried out for pedestrian safety?"

19.    Councillor D. Healy
"To ask the Manager to arrange for the repair of the wall at the junction of Windgate Road and the track leading up the ben of Howth which was damaged by a fire engine 2 years ago?"(grid location 53˚22’07.39N, 6˚04’08.31W)

20.    Councillor R. Kelly
"To ask the Manager to place double yellow lines at both side of the entrance
to the driveway at 20 Yellow Walls Road due to problems caused by cars
parking and blocking the visibility?"

21.    Councillor R. Kelly
"To ask the Manager is the any current plans to put in place traffic calming
measures on Yellow Walls Road?"
22.    Councillor A. Farrell
"To ask the Manager to improve the surface drainage at The Walk, Kinsealy Melrose?"

23.    Councillor R. Kelly
    "To ask the Manager to investigate reports that recent work carried out by
Fingal or on behalf of Fingal on the path surface on Old Street Malahide
has blocked gutter drains?"

24.    Councillor R. Kelly
    "To ask the Manager to report on lack of footpath from Rob’s Wall to
Malahide Village?"

25.    Councillor R. Kelly
"To ask the Manager what are the current plans for access at Melrose Drive
and Melrose Park?"

26.    Councillor D. Healy
"To ask the Manager why the repairs to the road outside the Methodist Church, Sutton referred to at the January 2006 meeting of this Committee have not been carried out?"

27.    Councillor D. Healy
"To ask the Manager to report on the design of the junction at Grange Road and the reasons for the Council’s failure to respond to correspondence in relation to the junction and report on whether there has been a safety audit of the design and whether the design complies with the National Manual for Urban Areas on the Provision of Cycle Facilities?"

28.    Councillor D. Healy
"To ask the Manager why the sign hasn’t gone up on the infill opposite St. Fintan’s High School as agreed at the meeting of this Area committee on 30th March 2006?"

29.    Councillor D. Healy
"To ask the Manager whether the design of the roundabout at the junction of the Coast Road and the access to the new residential area complies with the National Manual for Urban Areas on the Provision of Cycle Facilities and whether there has been a safety audit of the design?"

30.    Councillor P. Coyle
"To ask the Manager to include The Bawn Grove for resurfacing in the 2007 Programme of Works?"

31.    Councillor P. Coyle
"To ask the Manager if a new street light could be installed near the entrance of Suncroft Avenue, Portmarnock?"

32.    Councillor P. Coyle
"To ask the Manager if the footpaths in Chalfont Estate, Malahide, could be examined and a major programme of remedial works be carried out under the 2007 Programme of Works?"

33.    Councillor P. Coyle
"To ask the Manager to provide better notice at the entrance to The Bawn Grove, Malahide, indicating that there is no through road?"

WATER SERVICES BUSINESS

34.    New Works, Acceptance of Tenders etc.
(if any, to be circulated)

35.    Correspondence.
   (if any, to be circulated)

WATER SERVICES MOTIONS

36.    Councillor R. Kelly
"That this Committee recomends repair work on foul sewage drain effecting
111,112,113,114,and 116 Seapark Coast Road Malahide which was promised seven months ago after intial work discovered possible root damage blocking drain."

37.    Councillor J. Maher
"That the pumping station on Racecourse Lands, Baldoyle be further secured and the area cleaned up."

38.    Councillor P. Coyle
"That the Manager report on who is responsible for the sewerage spills on Old Road, in Old Portmarnock, and to state what measures are being taken to prevent the regular re-occurrence and associated pollution to the local streams."

ENVIRONMENT BUSINESS  

39.    New Works, Acceptance of Tenders etc.
(if any, to be circulated)

40.    Area Chairperson’s Business: Councillor D. Healy    
"That the Manager report on the dumping in the ditch along Grace O’Malley Drive and take the following steps:
a)    erection of a no dumping sign;
b)    erection of a fence;
c)    operation of a video camera focussed on the ditch."

41.    Correspondence.
                               (if any, to be circulated)              
ENVIRONMENT MOTIONS

42.    Councillor D. Healy
"That the Manager produce a detailed report on what is known by this Council and Dublin City Council and/or consultants answerable to the Council on the illegal hazardous waste dump at Clonshaugh/Belcamp and report on what steps are being taken to investigate the dump and bring those involved in dumping the waste to justice."

TRANSPORTATION BUSINESS

43.    New Works, Acceptance of Tenders etc.
(if any, to be circulated)

44.    Correspondence
(if any to be circulated)

TRANSPORTATION MOTIONS

45.    Councillor R. Kelly
"That the Manager reports on and does repair work on pot holes on Station
Road."

46.    Councillor A. Farrell
"That Fingal County Council constructs steps leading to the road opposite the entrance to Robswall Estate, Coast Road Malahide to increase pedestrian safety in the area"

47.    Councillor D. O’Brien
"That in the interest of safety, this committee strongly recommends that traffic calming measures are introduced on Kinsealy Lane to reduce dangerous speeding in the area."

48.    Councillor D. Healy
"That this Area Committee recommends that the Council direct the Manager to carry out a multi-modal transport study in relation to transport in the North Fringe/South Fringe area (Stapolin, Donaghmede, Balgriffin, Belcamp, Clonshaugh) with Dublin City Council’s co-operation if possible, to include consideration of the possibilities for a light rail link between the Dublin-Belfast railway line at Stapolin and the Metro in the vicinity of Ballymun/Dublin Airport and other possible rail links and to include consideration of roads, bus routes, cycling routes and walking routes in the area."

49.    Councillor P. Coyle
"That the Manager report on proposed road improvements for Station Road, Portmarnock, for the current year, and on plans for improving the junction with Drumnigh Road."

50.    Councillor R. Kelly
"That this Committee recomends repair work on surface drain effecting
111,112,113,114,and 116 Seapark Coast Road Malahide which is blocked by
leaves and other material and may need high pressure jetting to resolve the
situation."

51.    Councillor D. O’Brien
"That the Manager report on the progress of installing pedestrian lights on the Swords Road Malahide to facilitate the safe crossing of school children and pedestrians on this very busy road and furthermore that this Committee recommends that this work takes place as a matter of priority."

52.    Councillor D. Healy
"That given the close connection between traffic and urban design, the consultancy study in relation to traffic and parking management in Howth be carried out in tandem with the preparation of an Urban Centre Strategy for Howth as specified in Objective Howth 1 in the Development Plan."

53.    Councillor P. Coyle
"This Committee recommends that safe pedestrian facilities be provided for residents of Robswall to enable them to use the coastal footpath to and from Malahide Village."

**************************************

Just to update that I got a prompt and positive response from Jimmy Kinahan of Engineers Ireland to my last email.  He is recommending to the CPD committee that the incorporate a session on designing for cyclists.

Press release issued today.
Dublin Airport expansion is bad news for climate change – Healy

Green Party General Election candidate for Dublin North East Cllr David Healy reacted to the plans unveiled for a new €395m terminal at Dublin airport, saying:

"The planned doubling of traffic through Dublin Airport is inconsistent with Ireland’s international commitment to prevent climate change and with the reality of rising oil prices. This massive investment – within one or two decades – is in danger of becoming a stranded asset.

"Aviation is the fastest growing source of greenhouse gas emissions in the EU and if there are twice as many flights coming in and out of Dublin in three or four years time, then the impact of reducing emissions in other sectors will be vastly reduced in terms of our overall Kyoto commitments. The expansion would also create significant additional noise pollution from more flights coming into the city.

"Airlines have for too long dodged the polluter pays principle and should be brought into a carbon emissions trading scheme as well as subjected to levies – that currently apply to other forms of transport – on the vast amounts of kerosene fuel that they consume."

The Fingal County Councillor concluded:

"Even if the Government chooses to deny the looming problems of climate change and oil prices, it would make far more sense to provide a quality rail access to Shannon airport where there is existing spare capacity. This link would make access to air travel quicker and easier for passengers from Galway, Cork and surrounding areas. They could thus avoid the inevitable and inefficient drive to Dublin Airport. Investing in rail is a much better bet than investing in aviation."

Below I attach the draft headings of Michael O’Neill’s submission for the Santa Sabina Action Group, as discussed at recent meetings.  I will replace it with the full objection when I receive it.

Re: Planning application for residential development of 130 no. dwelling units and a crèche on lands that formerly formed part of the curtilage of the Santa Sabina St. Dominic’s School and Convent complex at Greenfield Road, Sutton, Dublin 13, for Parsis Ltd., Sandyford, Dublin 18.  ( Reg. Ref  F06A/1099)
 
•    Fig 1: Aerial view of subject site – outlined in red.
1.1    CONTEXT
•    Suburban Lands
•    Institutional Lands
•    Surrounding Land Uses
•    Backland Site
•    Embedded Site – within Educational religious precinct
•    Shared Educational Use
•    Archaeological Impacts
1.2    PLANNING PARAMETERS GOVERNING DEVELOPMENT
•    Government Sustainable Development Policies 1997
•    National Spatial Strategy
•    Regional Guidelines for the Greater Dublin Region
•    Residential Density Guidelines
•    Dublin Transportation Office Policy Documents
•    Fingal County Development Plan 2005 – 2011
•    Special Amenity Area Order for the Howth Peninsula
1.3    PLANNING ASSESSMENT
•    Contextual constraints
•    Compliance with Planning Parameters
•    Residential Density Guidelines
•    National Spatial Strategy
•    Special Amenity Area Order
•    Compliance with Fingal County Plan 2005 – 2011
     Zoning Objectives
     Policy for Residential Areas
     Policies for Public Open Space
     Development Control Standards
1.4    IMPACTS OF DEVELOPMENT
     Residential amenity
     Character and pattern of development in the area
     Development Potential of adjoining lands
     Zoned Public Open Space Lands
     Institutional Setting
     Protected Trees
     Potential Protected Structures – Church and Convent
     Protected views and prospects
     Special Amenity Area Order for the Howth peninsula
     Environmental Quality of the area
     Impacts of Traffic – conflict with school traffic
     Drainage and Water supply

 
Fig 4: Potential impacts of proposed development on surrounding land uses.
Legend:
A.    Impact on the residential amenities presently enjoyed by residents in the vicinity
B.    Impact on the Educational Facility
C.    Impact on the Development Potential of Adjoining lands
D.    Impact on Protected Trees
E.    Impact on zoned Public Open Space  
F.    Impact on school recreational facilities.
G.                Specific overlooking
1.5    PARAMETERS GOVERNING DEVELOPMENT
1.5.1    Development Plan Policy
The subject lands are within the functional area of Fingal County Council and are therefore covered by the statutory Development Plan for the area.  The most recent Development Plan for the County is the Fingal County Development Plan 2005 – 2011, and in that Plan the subject lands, which in land use terms contain the school, convent and recreational areas, are split between two zoned areas, i.e. residential and Public Open Space.  The current zoning on the lands is shown in Fig. 2 below, and, as can be seen from this map, all of the lands in use as hockey pitch and basketball areas have been zoned for open space and recreational uses.   The other lands, which contain most of the subject site, all of the school buildings, convent, and surrounding areas are zoned for residential use.
 
•    Fig 2: Fingal County Development Plan 2005 – 2011 zoning objectives for subject lands.
At present, as can be seen from Fig. 2 below, approximately 27% of the site is zoned “OS”, i.e. “to preserve and provide for open space and recreational amenities”, while the rest (73%) of the site is zoned “RS”, i.e. “to provide for residential development and improve residential amenity”.
    
•    Fig 3:  Zoning Fingal County Development Plan 2005 – 2011(left), overlaid on site plan of proposed development (right).
•    Uses permitted in principle on the residentially zoned land include, inter alia, residential.  
•    Uses permitted in principle on the open space zoned land include, inter alia, community facilities, recreational facilities and sports club.  
•    The vision of the Planning Authority for public open space zoned lands states that:
       “Only community facilities and other recreational uses will be considered and encouraged.”  
The lands presently zoned for residential development are severed from the public road by zoned  Open Space lands.  The use of these lands for a residential road to serve an embedded  backland residential development – particularly of the size and scale proposed must constitute a material contravention of the statutory Development Plan for the area as the  zoning does not allow for residential developments.  Part of Block B is being built on the Open Space zoned lands. This is clearly a material contravention of the Plan.  
It would be our contention that the Public Open Space zoned lands make up a substantial part of the subject site – approximately 4200 sq.m. or twenty seven percent of the overall site, and are been used to facilitate the residential development to the rear.  On these grounds alone the proposed development should be refused planning permission.   
1.5.2    Development Control Standards
The critical Development Control Standards for the proposed development are set out in the statutory Development Plan for the area, and the following Standards are relevant in the present instance:-
    Density
    Car Parking
    Private open space
    Public Open Space .
 
1.5.3    Density
The area of the zoned residential lands at 1.128 hectares is well above the 0.5 hectares required to determine a separate density from the site.  The proposed density of 110 units per hectare (46 per acre) is well above the maximum permitted on sites which have all the necessary characteristics for maximising density. In the present instance a density of even fifty units per hectare would have to be predicated by the obvious constraints that the site offers, particularly the following:-
•    The zoning on the subject lands, and adjoining lands,
•    The transitional nature of the site – in both land use and zoning terms,
•    The institutional nature of the lands,
•    The surrounding type and scale of residential development in the area,
•    The educational and recreation use – for girls  – on two sides of the proposed development.
•    The distance from the DART station – above that recommended in the Dublin Transportation Office document Platform for Change,
•    The roads and traffic constraints, danger to road users particularly school going children,
•    The development potential of adjoining lands,
•    The tree protection policies of the Council,
•    The proximity to a pSAC, pNHA.
•    The location of the site within attendant lands subject to the Special Amenity Area Order.

All of the above have to be considered before any decision can be made on an appropriate density for the site.  
The proposed density of 110 units per hectare is over seven times the existing general density in the area, – which is roughly fifteen units per hectare.  
1.5.4    Car Parking
The 2005 – 2011 Fingal County Development Plan Parking Standards identify the following parking requirements in relation to the proposed use for the site.
CAR PARKING STANDARDS IN FINGAL
Land Use    Maximum Permissible
Dwelling     1-2 spaces per dwelling
Source: Fingal County Development Plan 2005 – 2011
Based on the above, the proposed development would require between 130 and 260 car parking spaces for the proposed development.  A total of 195 car parking spaces are to be provided to cater for the overall development – including the crèche.  This number of car parking spaces is deficient in terms of numbers – none allocated for crèche or visitors.  A further twenty spaces need to be provided for these uses, reducing the number available to the future residents to 175 spaces.  The result of all this is that there will be an overflow of car parking unto the surrounding roads, which is already deficient in width and alignment.  Car parking near the entrance to the proposed development would create a traffic hazard and affect the safety of other road users.   
On these grounds alone the proposed development constitutes overdevelopment and contrary to the proper planning and sustainable development of the area.
1.5.5    Open Space
The lack of private and communal open space in both quantitative and qualitative terms must be mentioned, and in this regard the proposed development has not been adequately addressed in terms of its institutional land use and Public Open Space zoning.  
In apartment developments private open space may be in the form of balconies, terraces, roof gardens or communal landscaped areas exclusive of surface car parking. Balconies or terraces shall be usable and be a minimum of 5 sq.m. in area and should be integrated or recessed into the main structure of the building with a view to providing shelter, privacy and where possible to avoid overlooking.  The minimum private open space requirement for apartments in the general area, as per the statutory Development Plan for the area, should be as follows:
Suburbs     12 – 15 sq.m. per bedspace
In the present instance there are approximately four hundred and forty one bedspaces in the proposed development.  This represents a requirement for a total of between 5292 – 6615 sq.m. of private open space on the site.  Private open space at this level has not been provided and the communal open space available is only 2085 sq.m.     
In the Fingal County Development Plan 2005 – 2011 the policy is to retain in open space use institutional lands and similar properties with established recreational or amenity uses, as far as practicable.  Open space provision in excess of the normal standards is required to maintain the open character of such parts of the land as are considered necessary by the Council for this purpose.  The quantity of land required for this purpose is not stated, but in the Dublin City Development Plan 2005-2011, the policy is that, where residential development occurs on former institutional lands public open space should be located in such a way as to be accessible to the general public.  They require that 25% of the site shall be set aside for accessible public open space and/or community facilities.  We would be of the opinion that this standard of Public Open Space is appropriate, and in the present instance this level of Public Open Space should be provided within the residentially zoned lands.   Therefore a minimum of 4800 sq.m.  of Public Open Space should be provided to cater for the proposed development.  Only 2085 sq.m.  is provided to cater for the proposed development, less than half that required.
1.6    PLANNING PARAMETERS GOVERNING DEVELOPMENT ON THE SITE
1.6.1    National Spatial Strategy
In terms of the location of housing in urban areas, the NSS states that this must involve:-
Concentration of development in locations where is it possible to integrate employment, community services, retailing and public transport;
Mixed use and well designed higher density development particularly near town centres and public transport nodes like railway stations;
The efficient use of land by consolidating existing settlements, focusing in particular on development capacity within central urban areas through re-use of under-utilised land and buildings as priority, rather than extending greenfield development.
We would submit that the subject development is not in compliance with the basic  requirements as set out in Table 4.1 of the National Spatial Strategy, and does not adequately match the character, community, or integration tests listed.
1.6.2    Strategic Planning Guidelines  2000 – 2004
The principal objective of these guidelines is to establish a broad planning framework for the area which comprises Dublin City, Dun-Laoighre Rathdown, Fingal, Kildare, Meath, south Dublin and Wicklow all of which are experiencing unprecedented growth driven by the recent buoyant economy. This planning framework will provide an overall strategic context for the formulation of Development Plans at local authority level.
In line with the overall vision, the strategy for the Metropolitan Area is to follow a development path that will:
    Consolidate development within the area.
    Increase overall densities of development.
    Thereby facilitate the provision of a considerably enhanced public transport system and facilitate and encourage a shift to public transport.
1.6.3    Residential Density Guidelines 1999
The Department of the Environment published guidelines on residential density in 1999, following circular letter PD 4/98.  Briefly, the guidelines seek to promote higher densities in new residential schemes.  They have emerged against a background of rising demand, falling household sizes and government policy on sustainability.  The guidelines set out policies and standards but are not intended as a design guide.
In general terms, the guidelines discourage densities less than 20 dwellings per hectare (8 dwellings per acre), and they suggest that a range of 35-50 dwellings per hectare (14-20 per acre) would result in more efficient land usage.
The guidelines recommend the following for residential densities in towns and villages:
    In the case of residential development on serviced lands in towns and villages located in existing or planned quality public transport corridors, particularly those which have spare capacity in existing facilities such as schools, shops, libraries, health centres, childcare facilities etc., increased densities would be appropriate in order to maximise such social and infrastructural investment (Section 3.6.1).

Of import in the present instance is Section 3.3.1 of the Guidelines, which deals with “Infill Residential Development”, where it is stated that,
“….In residential areas whose character is established by their density or architectural form, a balance has to be struck between the reasonable protection of the amenities and privacy of adjoining dwellings, the protection of established character and the need to provide residential infill.  The design approach should be based on a recognition of the need to protect the amenities of directly adjoining neighbours and the general character of the area and its amenities…..”
In the present instance the subject site does not meet all of the above criteria and the design of the apartments are such that it would not blend into either the character or the pattern of residential developments in the area.  Indeed it is submitted that the proposed development would maximise the disamenity by virtue of the location of the development proposed, its three/four/five storey design – with windows and  balconies directly overlooking neighbours, i.e.  residential, educational, and recreational properties.
Section 5.1, of the Residential Density Guidelines deals with the General Approach – Criteria for Higher Densities. The following are deemed important in arriving at suitable sites for the development of higher densities.
•    Size of site
•    Proximity to town / city centre facilities and to existing or planned public transport systems
•    Quality of proposed layout and elevational design
•    Quality of proposed open space and general landscaping
•    Levels of privacy and amenity
In section 5.7.4 Recommended Qualitative Standards suggest that the following criteria, inter alia, should be utilised when assessing the appropriateness and impact of any development.  
•    Quality of design and layout.
•    Standard of residential environment.
•    Protection of privacy.
•    Issues in respect to adjoining property;
•    Overlooking.
•    Overshadowing of habitable rooms (daylight and shadow projections may be required to be submitted as part of a proposal)
•    Height (In general low rise buildings which respect the scale and character are appropriate if adjoining existing development is low rise).
It will be our contention that the proposed development does not properly address the issues raised in the Guidelines for Planning Authorities on Residential Density , nor does it particularly address the issue of set backs, overlooking and overshadowing.  We would suggest that the proposed development contravenes both the government’s and the Planning Authority’s policies with regard to the protection of residential amenity of adjoining properties.
 Zoning Objectives
Land Use Zoning Objective RS: To protect, provide and improve residential amenities.
The general objectives for primarily residential areas are to provide a measure of protection from unsuitable new development or certain ‘bad neighbour’ developments that would either threaten or be incompatible with the overall residential function of the area. It is not intended to rule out development other than housing development but simply to apply a test that the new development should be compatible with or reinforce the residential function of the area as a whole.
General Site Development Standards
The creation of attractive environments with a genuine sense of place is a prerequisite to achieving sustainability. The quality of where we live, work and visit depends not just on the design of buildings, but on their layout and landscaping, the arrangements made for access, and in particular, how they relate to their surroundings…..
Development proposals will be assessed in terms of how they contribute to the achievement of the objectives above, and having regard to various qualitative and quantitative standards. Of foremost importance will be the encouragement of development of the highest possible architectural and urban quality.
Density  
Density should achieve optimum use of urban land appropriate to its location and context.
In implementing the Department of Environment, Heritage and Local Government guidelines on residential development and to encourage sustainable residential communities, consideration must be given to the qualitative and quantitative standards outlined above and to the following elements:
• Density: High densities should be provided in appropriate locations. Site configuration and area will have an impact on the density levels achievable.
• Quality of the proposed layout and elevations: The quality of the residential environment will be paramount in the acceptability of planning applications. Layouts, elevations, and design must be designed to emphasize a sense of place and community. Residential complexes including social and affordable housing shall be built to designs, which do not articulate social difference and will be laid out in a way that makes no sharp territorial boundaries between different housing origins.
• Quality of proposed open space and general landscaping:
Detailed landscape proposals, including specifications, must be submitted with all planning applications. The detail of these proposals will form an integral part of the assessment of the quality of the proposed layout….
• Levels of privacy and amenity: The relationship of buildings to one another, potential overlooking, sunlight/daylight standards and the use of screening devices and landscape elements will form the basis of assessment……
We would submit that the proposed development neither complies with nor supports these reasonable objectives.  It is clear that the proposed development would represent a material contravention of the said policies and objectives of the current plan.
Daylight and Sunlight
• The Planning Authority considers that all buildings should receive adequate daylight and sunlight. Careful design of residential buildings, where the amount of incoming light is important, can ensure that sufficient sunlight can enter habitable rooms to provide comfort and also reduce the need for artificial lighting.
The proposed development does not comply with the reasonable objectives of the Planning Authority in this regard.

 
Aerial photograph of subject site showing trees on site and densities around site.
 
Such a diversion from the densities of adjacent buildings and indeed from the densities of the surrounding area must be seen as both unreasonable and excessive, and contrary to the Density Guidelines and statutory Development Plan for the area  which states that; ‘The density of new residential development will generally be influenced by the density of the surrounding area’
Indeed the Planning Authority, and An Bord Pleanála, have refused planning permission for less dense apartment developments in similar  areas for the reason of its density being excessive in relation to the low to medium densities which characterize the particular area and therefore,
 ‘would injure the special amenities of the area and would set an undesirable precedent for further such developments in the area and would be contrary to the proper planning and development of the area’
We would contend that the density of the proposed development is a much more serious breach of this reasonable reason for refusal given previously.
This view is fully consistent with the Guidelines for Planning Authorities on Residential Density.  Although the Residential Density Guidelines targets infill residential in Inner Suburban locations for higher residential densities it qualifies it by stating that,
‘the design approach should be based on recognition of the need to protect amenities of directly adjoining neighbours and the general character of the area and its amenities i.e. views, architectural quality civic design etc.’
We would submit that the proposed development does not protect the general character of the area, i.e. medium density single family dwellings set in small gardens
1.6.4    Building Form & Size
Dwellings in the immediate vicinity of the proposed development site are two-storey.  It is therefore suggested that the form, size and height of proposed development does not relate to that of the surrounding dwellings and therefore is contrary to the statutory development plan.  Again it is the policy of the Planning Authority that housing development should relate to the surrounding urban form and land use. Protection and respect of the existing amenities and the character of the area are important and should be regarded as a feature of good design.
Lack of Open Space
The level of Private and Communal Open Space on the site is, given the nature of the lands, seriously deficient.  The deficiencies can partially be met by reducing the number of residential units on the site, but this requires a major revision to the current plans.  It would be our contention that the deficiency is of a scale to require the Planning Authority to refuse planning permission on grounds of material contravention of the statutory Development Plan for the area.  
1.6.5    Overshadowing
Given the proximity of the proposed development to adjoining properties, and its orientation, the potential for overshadowing is significant.  The proposed development, by virtue of its size, proximity and height will significantly diminish the amount of sunlight into many of our clients’ properties, thereby affecting the residential amenity and the value of the property.
1.6.6    Concluding Remarks
On the basis of the above analysis we would ask the Planning Authority to refuse planning permission for the subject development for the following reasons:-
1.  “The proposed development due to its density, height, bulk and scale, would overall represent an unsatisfactory standard of development in terms of design and layout.  The proposed development would contravene materially the current statutory Development Plan for the area and would also conflict with the Department of Environment and Local Government Residential Density Guidelines, Section 5.1, 5.2 and Section 5.5 and would therefore be contrary to the proper planning and development of the area”.
Due to its unsatisfactory design and layout the proposed development is considered to be out of character with the pattern of adjoining residential development and would seriously injure the amenities and depreciate the value of property in the vicinity. The proposed development would therefore contravene materially an objective of the County Council, as expressed in the Development Plan “To protect and / or improve residential amenity”.
It is clear from the proposal that the proposed development is totally reliant on the removal of attractive mature specimen trees which are designated in the Statutory Development Plan for the area.  Access to the site is also inappropriate, given the existing access from the regional route, which is more than adequate to serve the existing development.  
In Table 2 below we have set out the key development control standards – as per the statutory Development Plan for the area and the Guidelines for Planning Authorities on Residential Density – applicable to this site, and as can be seen from this Table the proposed development is significantly in breach of most of the development standards – both quantitative and qualitative – applicable to ones assessment of the subject application.
TABLE 2: SUMMARY OF DEVELOPMENT CONTROL STANDARDS.
Development Control Standard    Proposed Development    Development Plan requirement    Development Control Standard Met
Residential density    110 per ha.      30-50    r
Open Space /bedspace    9 sq.m.     12 – 15 sq.m.     r
Car Parking    195     130-260     r
Consultant’s Estimate
Our clients’ private residential amenity will be significantly affected by the proposed development.  As already stated one of the key recommendations emanating from all of the reports is that higher densities can only be countenanced in situations where the size, and location, of the site is adequate to create its own density and design without significantly damaging neighbouring properties or the neighbourhood.   The test for higher densities is therefore two fold, but both have to be achieved.  In the present instance none of the criteria for higher densities are present.  Therefore, as is clearly stated in the guidelines, but very often ignored by Planning Authorities, the type of development must be consistent with the character and pattern of residential development in the area.  Only in this way can the residential amenities presently enjoyed by our clients be protected as outlined in the statutory Development Plan for the area.  
It is clear from a perusal of the statutory Development Plan for the area that the proposed development is a contravention of the objectives, policy, and Development Control Standards therein.  Given the size, type and location of the subject lands and the impacts of the proposed development on adjoining residential, community, and educational amenity, including the environmental quality of the access road through Public Open Space zoned lands, the subject development materially contravenes the statutory Development Plan for the area.
In conclusion we would respectfully submit that the subject development is a material contravention of the statutory Development Plan for the area; and is therefore contrary to the proper planning and sustainable development of the area; would seriously injure the residential amenities of our clients’ properties, and would destroy the residential character of this area.
Michael A. O’ Neill, MIPI

Following correspondence earlier in the year on road design and "cycle facilities" I realised that the lack of proper training for roads engineers must be a significant part of the problem.  So I wrote to "Engineers Ireland."  I’m sending the second reminder today. I wasn’t originally going to put this online, but as it’s waited a few months for a reply I’m putting it up, partly in the hope that individual engineers might take this up with their professional organisation.

——————————————————————————–

From: David Healy / Daithí Ó hÉalaithe [mailto:verdire@eircom.net]
Sent: 29 May 2006 21:46
To: ’emchugh@engineersireland.ie’
Cc: ‘info@dto.ie’
Subject: Modular Roads Course 2006/2007

Dear Mr. McHugh,

I note the programme for your Modular Roads Course.  I have been concerned for some time at the lack of understanding road engineers have of the design needs of cyclists and the safety implications for cyclists of their designs. This unfortunately applies not only to engineers who are designing for a general traffic flow including cyclists but also to those who are trying to design specifically for cyclists.    The attached correspondence relating to a junction in my constituency reflects such a lack of understanding, if I may refer you to it as an example.

In relation to responses 1 and 2, Mr. Deegan is entirely wrong in his suggestion of how a cyclist should safely use the road.  I would refer to Cyclecraft by John Franklin published by the Stationery Office in the UK and recommended reading for the National Cyclist Training Standard in UK. (http://www.tsoshop.co.uk/bookstore.asp?FO=1159966&Action=Book&ProductID=0117020516&From=SearchResults) or alternatively to Oregon Department of Transportation’s Bicyclist Manual 2006 at pages 6 and 7 (http://www.oregon.gov/ODOT/HWY/BIKEPED/docs/bike_manual_06.pdf )

An understanding of the sources of risk for cyclists and of how cyclists can use the road to best reduce the risk of collision is essential if road design is to cater for safe use by cyclists.  Nobody should be designing roads which cyclists use and especially not designing specifically for cyclists without this understanding.  Many of the flaws in road design for cyclists in Dublin probably come from such basic misunderstanding.

If this was a single instance, I would not refer to it.  However, from travelling around Dublin, I know that when it comes to designing for cyclists,  bad design is the rule rather than the exception.  

The poor quality of these designs must in part reflect an inadequacy in training or at least could be remedied by better training, which is why I’m writing to you.  I would be interested to know if you have or could incorporate sessions on road design as it affects cyclists in your training course.  It seems to me that this would be appropriate to both Modules 2 and 4.

I’m copying this to the DTO for information.  As funders of much of the cycle-specific infrastructure, they have an interest in having good design applied, and may be able to work with you in relation to CPD issues.  I’m sure that the Dublin Cycling Campaign (http://home.connect.ie/dcc/) would also be interested in helping you include these elements in your training course.

Is mise, le meas,

David Healy

Councillor David Healy

Green Party/Comhaontas Glas

Howth ward / Dublin North East

www.davidhealy.com

01 8324087

54, Páirc Éabhóra, Beann Éadair

54, Evora Park, Howth

——————————————————————————–

From: Sean McGrath [mailto:Sean.McGrath@fingalcoco.ie]
Sent: 19 May 2006 16:36
To: verdire@eircom.net
Subject: FW: RE: design of grange road/industrial estate junction.

Dear Cllr Healy

I forward the consultants response FYI.

We are considering changing the layout of the junction to have only two general traffic lanes on the approach from the M50 direction. This will give additional space to allow for full width traffic and cycle lanes in both directions without compromise. There may be some loss in capacity of the junction, but, given the improved comfort for all, it may be worthwhile.

Regards

Sean

—–Original Message—–
From: Martin Deegan [mailto:mdeegan@jbbarry.ie]
Sent: 11 May 2006 13:52
To: Sean McGrath
Subject: [Possible Spam] RE: design of grange road/industrial estate junction.

Dear Sean,

Thank you for the attached.  As a regular cyclist and traffic engineer, I have pleasure in responding to Cllr Healy’s points in order as following.

Providing formal cycle facilities highlights the presence and needs of cyclists to motorized road users.  The left turning conflict is apparent in this situation at every junction with or without cycle tracks, and is dependent on a measure of good judgment and courtesy between vulnerable road users and motorists.  The safest place for the cyclist in this situation is to stay within the appointed cycle track, and not in the middle of the traffic lane where the risk rear end shunt type conflict with fast moving vehicles would undoubtedly be greater.
 

Referencing point 1 above, the safest place for cyclists is within the allocated cycle lane.  This risk is apparent within all urban road environments which have cycle tracks retrofitted.
 

The traffic lanes have been widened to a minimum of 3.25 metres. This is sufficient for a HGV to pass a cyclist without entering the cycle lane or the adjacent right turning traffic lane.
 

With reference to the Cllr’s final paragraph:

In the event of an emergency or breakdown, a motorist can pull into the hard shoulder to get out of the flow of traffic and obtain an element of safety. It is not a traffic lane; nor was it designed as a cycle lane, although it serves the purpose well in this instance.  Thought must be given to the safety of all road users, in this instance 1.5 metres has been allocated for the cycle lane, and 4.0 metres for the adjacent traffic lane, both dimensions provide a good level of service for both motorists and cyclists, and are well above minimum industry standards.

Best regards,

Martin Deegan

J.B.Barry & Partners Ltd

Consulting Engineers

Dolcain House

Monastery Road

Clondalkin

Dublin 22

Ireland

_______________________________________________________

Tel:              +353 (0)1 403 3600

Fax :            +353 (0)1 459 4357

Email: mdeegan@jbbarry.ie

_______________________________________________________

The information contained within this e-mail including any attachments is

intended for the sole use of the individual to whom it is addressed and may

contain confidential and/or privileged information. If you receive this e-mail

in error please contact the sender by return and delete this e-mail including

any attachments.

—–Original Message—–
From: Sean McGrath [mailto:Sean.McGrath@fingalcoco.ie]
Sent: 08 May 2006 10:49
To: Martin Deegan
Subject: FW: design of grange road/industrial estate junction.

Martin

Comments from Cllr Healy FYI.

Regards

Sean

—–Original Message—–
From: Mary McPhillips
Sent: 08 May 2006 10:30
To: Sean McGrath
Subject: FW: [Possible Spam] design of grange road/industrial estate junction.

Sean,

Did you get this already

Mary

—–Original Message—–
From: David Healy / Daithí Ó hÉalaithe [mailto:verdire@eircom.net]
Sent: 02 May 2006 14:09
To: Peter Caulfield; Mary McPhillips
Subject: [Possible Spam] design of grange road/industrial estate junction.

Dear Peter,

Thank you for showing us the proposed redesign of the junction last week.

In relation to the design, I have the following comments.

I welcome the removal of one of the 3 eastbound lanes coming into the junction, to give more room for westbound traffic.

I am concerned at the design including cycle lanes within an existing lane. By the design shown, it is not possible for a car or truck to use this lane without travelling in the cycle lane.  This seems to be the case northbound entering the junction on the industrial estate road and eastbound entering the junction on grange road.  It seems to me that these could have 3 undesirable effects

1.       They are likely to encourage cyclists to stay left at the junction.  In fact, safe cycling requires that a cyclist travelling straight on should not stay to the left of the lane as to do so would risk a car or truck turning left across them.  Safe cyclists will occupy the centre of the straight ahead lane.

2.       They may encourage cyclists to travel up on the inside of trucks, which puts cyclists in a particularly dangerous position.

3.       They may encourage motor vehicles to pass cyclists without moving fully into the adjacent lane.

If there is a good reason for this design I would like to hear of it.

I am also concerned at the width of the cycle lane over the bridge.  The previous situation was a good wide hard shoulder.  The new situation should not lead to any reduction in safety for cyclists.  There is a tendency for a motor vehicle user to assume that it is safe to pass a cyclist on a cycle lane as long as each road user remains in their lane.  This, of course, is not the case, but it is a consequence of cycle lane design.  Narrow cycle lanes (especially if associated with other narrow lanes and markings such as central hatching) can encourage motor vehicle users to pass closer than they would otherwise have done.   In this case, we are talking about a road with high levels of HGVs, making safe passing even more important for cyclists’ safety and cyclists’ perceptions of safety. The width of the lane was not marked on the plan.  However, there is a tendency for road engineers to incorrectly assume that a width of 1.5m is standard.  In this case, a width of at least 2m would be appropriate

Is mise, le meas,

David Healy

Councillor David Healy

Green Party/Comhaontas Glas

Howth ward / Dublin North East

www.davidhealy.com

01 8324087

54, Páirc Éabhóra, Beann Éadair

54, Evora Park, Howth

{mosimage}

The Development Plan contains an objective to do an Urban Centre Strategy for Howth.  The Transportation Department has separately advertised for consultants to work on traffic and parking in Howth. I am trying to ensure that the Urban Centre Strategy is done in tandem with the traffic work.

To: Planning Department, Transportation Department
by email: 21st August

A chairde

The Development Plan contains a number of objectives specifically related to Howth (attached as Annex 1)

In particular the first objective is

“Objective HOWTH 1

“To prepare an Urban Centre Strategy for the village core to include
detailed urban design guidelines and actions for the harbour (extending
to Claremont Strand) and village area and which will have regard for
the special historic and architectural character of the area.”

Arising initially from a proposal by the Department of the Marine to
introduce parking charges, the Transportation Department is seeking to
employ consultants to work on traffic and parking management in Howth. 
See http://www.e-tenders.gov.ie/search/search_show.aspx?ID=JUL064318 

It seems to me that it would be best for the Urban Centre Strategy work
to be connected to the Traffic and Parking Management Plan.  Indeed it
would make so sense at all to do the Traffic and Parking Management
Plan with all its impacts on the design and use of the area and then
come back to do an Urban Centre Strategy.  Additionally, the Traffic
and Parking Management Plan if implemented is likely to give rise to
some income which could be used to fund work such as burying
electricity cables in the historic core of Howth.
 

Therefore I would like to recommend that the two pieces of work be
carried out in tandem. I will raise this at the area cttee. in
September but I am aware that tenders will be coming in in relation to
the traffic work and I wanted to give you my views as soon as possible.
 

Regards,
 

David
  
 

Annex 1 Extract from County Development Plan pp. 177 to 178
 

HOWTH

Howth is a distinctive settlement located within a unique natural and built environment. It fulfils a predominately

leisure role for visitors with restaurants, cafes, bars and some niche shopping such as arts and crafts.

DEVELOPMENT STRATEGY

It is envisaged that Howth village will develop in a manner that will protect the character of the town, strengthen

and promote the provision and range of facilities especially the retention and promotion of retail convenience

shopping and community services to support the existing populations and tourists. Future development shall be

strictly related to the indicated use zones including the infilling of existing developed areas rather than further

extension of these areas. Development shall be encouraged which utilises the recreational and educational

potential of the area and other nearby natural environments of high quality.

The strategy for Howth Peninsula is to ensure the conservation and preservation of the areas of outstanding

natural beauty and the sustainable tourist and recreational use of natural assets. The main basis for this

strategy will be the Howth Special Amenity Area Order.

DEVELOPMENT OBJECTIVES

Objective HOWTH 1

To prepare an Urban Centre Strategy for the village core to include detailed urban design guidelines and

actions for the harbour (extending to Claremont Strand) and village area and which will have regard for the

special historic and architectural character of the area.

Objective HOWTH 2

To encourage the retention and development of ground floor commercial uses within the core of the village.

178

Y o u r F i n g a l – W r i t t e n S t a t e m e n t

New development in the core of Howth shall ensure the provision of commercial/retail uses on the ground

floor. Such uses should be of a convenience and comparison retail mix with emphasis on the latter. Office

provision should also be encouraged to ensure a vibrant village core with both indigenous day and evening

populations.

Objective HOWTH 3

To implement the Howth Special Amenity Area Order, the associated management plan and objectives for the

buffer zone.

Objective HOWTH 4

To continue to encourage the development of the harbour area for fishing and marine related industry and

tourism.

Objective HOWTH 5

To provide traffic calming in Howth Village taking account of its environment as a residential, tourist and local

shopping area, and in particular the protection of the residential amenity of Main Street from the effects of

motor traffic.

Objective HOWTH 6

To restrict the number of advertising structures in Howth peninsula and village.

Objective HOWTH 7

To reduce the number of masts on the West Mountain to the minimum necessary.

I have commented on a road proposal in Dublin 15 because of the proposed use of multiple roundabouts which severely impact on the safety of pedestrians, (especially the mobility impaired and visually impaired) cyclists and motorcyclists.

Councillor David Healy
Green Party/Comhaontas Glas
Howth ward / Dublin North East
www.davidhealy.com
01 8324087
54, Páirc Éabhóra, Beann Éadair
54, Evora Park, Howth

20th July 2006

Mr James V Cleary, BE CEng MIEI,
Senior Engineer,
Transportation Dept.,
Fingal County Council,
Grove Road,
Blanchardstown,
Dublin 15

By email: james.cleary@fingalcoco.ie

Re: Tyrrelstown to N2 Link Road

James, a chara,

Unfortunately, only a poor copy of a leaflet is on the Council’s website and I have not had an opportunity to visit Swords or Blanchardstown to look at whatever is on display there.

My concerns in relation to the proposed road design as shown have to do with the provision of roundabout junctions.  This road serves a residential area and  ST1 zoned employment areas.  Roundabouts provide a significant hazard to pedestrians and act a major barriers to pedestrian movement. This is already widely visible in Dublin 15.  The lack of any control of traffic at roundabouts leaves pedestrians trying to guess where traffic circulating on a roundabout is going and running across between what they hope are gaps in the traffic.  Crossing the side of the carriageway coming onto the roundabout the pedestrians have to cope with traffic which will be either decelerating or accelerating and will often have to weave between stationary cars and trucks. Where there are two lanes of traffic coming onto the roundabout this is particularly dangerous as the drivers are looking at traffic on the roundabout and not at pedestrians approaching from the sides.

This impact is particularly severe for mobility impaired pedestrians, those with buggies and small children etc.  Access for visually impaired pedestrians is pretty much completely blocked.

Roundabouts also pose significant risks to cyclists.  This is widely recognised and documented.  The difficulties arise from the varied speeds between cyclists and motor vehicles using the roundabout.  One response to this is often to provide for cyclists to cross the roundabout effectively as pedestrians. This leads to the same conflicts as pedestrians experience and considerable delays to cyclists in getting through the junction.  Additionally, cyclists often do not use this facility and remain on the carriageway.

Roundabouts also cause increased accident risk for motorcyclists.  They cannot legally use any off-carriageway cycle facility which may be provided.

In addition, roundabouts require a substantially increased land take and have a major negative impact on the urban design potential of the area.

Junctions controlled by traffic lights would be better in every respect.

In carrying out consultation in relation to this road scheme direct contact should be made with organisations representing the visually impaired, mobility impaired, pedestrians, cyclists and motorcyclists.

I attach two information sheets from the Galway Cycling Campaign which are highly relevant.

Is mise, le meas,

Cllr. David Healy

Information sheets from
http://www.galwaycycling.org/roundabout/roundabout01.html and
http://www.eirbyte.com/gcc/info/roundabouts.html

I have commented on the new road proposals in the Balgriffin/Belcamp/Clonshaugh areas.  The core of my comment is that a study should be done on all transport modes not just road proposals.

I believe there is an excellent case for a light rail link through this area from the new Dart Station to be built at Stapolin across to join the Metro south of Dublin Airport.

I am concerned that this work was put out to consultants without the terms of reference being agreed by the Councillors.  (If we had been involved I believe that a wider study would have been required.)  I will be putting down a motion at the September Council meeting to require that all terms of reference are agreed by Councilors.

Councillor David Healy
Green Party/Comhaontas Glas
Howth ward / Dublin North East
 
www.davidhealy.com
verdire@eircom.net
01 8324087
54, Páirc Éabhóra, Beann Éadair
54, Evora Park, Howth

Ms. Ursula O’Sullivan,
Atkins Consulting Engineers,
Atkins House,
150 – 155 Airside Business Park,
Swords,
County Dublin

By email to dublin@atkinsglobal.com

Re: Comments on display of potential roads in Balgriffin, Belcamp and Clonshaugh areas

A chairde,

Objectives of the Study

The leaflet includes the following

“The prime objectives of the Study are:

• To identify feasible route options for the new routes to provide an integrated transport network to cater for new development and to have minimal impact on the built, human and natural environment of the area and;

• To select the emerging preferred routes on the basis of environmental, traffic and cost criteria.

The new routes are proposed as the Transportation Framework necessary to accommodate extensive urban development in the North Fringe Area. It is envisaged that some 17,000 residential units will be developed within the North Fringe Area to provide for an approximate population increase of 42,000 residents.

There are a number of worrying features of this.  

Firstly it is shocking that with the massive development in the area, it is only at this stage that the transport issues are being considered.

Secondly it is striking that reference is made to an “integrated transport network” and a “Transportation Framework” when what is being studied is a road network and a road transport framework.  I would have thought that the mistakes of mono-modal transport planning had been learnt by now.

Thirdly, the study is being done with no reference to the urban design implications for the new residential areas.  The results are obvious and if allowed to proceed would be disastrous:  in the middle of an area zoned for housing two flyover junctions are proposed to be constructed.

Rationale behind the design – provide for increased traffic

The specific rationale for the design is not given in the public consultation.  This is unfortunate, as it leaves many people speculating as to the intentions behind the design.  
 
However, from discussions I have had with both local authority engineers and consultants, it appears that the reasoning behind the proposed roads, aside from the obvious of giving access to zoned land, is as follows:

•    To provide a duplicate route to the M50 to reduce congestion on the motorway
•    To facilitate car traffic going from the new residential areas onto the M50, or the new parallel route to access the Airport, Blanchardstown etc.

This is very worrying.  The policy of facilitating increases in car traffic has already been abandoned in the existing urban area of Dublin city for some years now.  Yet the same mistakes are to be repeated in a new high-density suburban area.  The entire justification for new high-density suburbs has been that they will support good public transport networks. Yet in planning the transport infrastructure for the area, the area’s obvious potential for light rail is not even being considered.

Instead a predict and provide exercise is being carried out.

If built, this route would facilitate further increases in traffic in the “edge city” pattern.  It would represent a massive further investment in motor traffic in the area.  The reality of course is that the road network in the existing urban area immediately to the south cannot cope with increases in traffic and will become further congested, with negative impacts on both bus and car traffic.

Multi-modal integrated study should be carried out.

We suggest the current study be dropped in favour of a multi-modal transportation study, obtaining the necessary expertise to carry out an effective analysis of the rail options for this area.  We suggest that the east-west route could be used for a surface metro/light rail.  

This route would go along the proposed new distributor road to join up with the Metro North and Metro West proposals.  It would start from the new Dart Station at Stapolin (Baldoyle), with stops at Hole in the Wall Road, Balgriffin, Belcamp, Clonshaugh and joining the Metro north alignment south of the Airport.  

Trams/metro trains could share the Metro North alignment until Ballymun and then either
a)    continue on the Metro West route,  with interchage to the Metro North Route, or
b)    travel south on the Metro North alignment into the city centre, with interchange to the Metro West Route.

Note that this integration with Metro North means it will be possible to build and operate the route together with the Metro North route.  

The link across the M1 motorway should be available only to public transport, bicycles and pedestrians.  The motorway is already available to facilitate private cars.  Facilitating long-distance east-west traffic on this east-west distributor road will ruin the possibilities of creating a decent residential area around it.

The diversion of the Malahide Road has been explained as primarily to facilitate the east-west traffic predicted. Instead of providing for this traffic by road, we should provide public transport links in the area.  This element should be dropped.

Because of the severe implications of these road proposals for plannng and urban design in the areas, I am copying these comments to the relevant planning officials as well.

Is mise, le meas,

Cllr. David Healy

                I