I have made an observation on the additional information received for application F22A/0372, subsequent to my previous observation. The main points are:
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.
I have submitted an observation on the appeal by Tetrarch against conditions imposed by Fingal County Council as follows:
Two Strategic Housing Development applications have been made to An Bord Pleanála (Clongriffin SHD 1 and Clongriffin SHD 2). They say they will be accompanied by an application to Dublin City Council for a more mixed use development. The applications represent a completely unacceptable abandonment of the original plan for a high-density mixed use development, remaining high density but being almost entirely residential. The Howth/ Malahide Area Cttee. today agreed to my proposal to make the following submission to these applications:
1. The applications for almost exclusively residential development are contrary to the long-established goal of a mixed-use development at Clongriffin with significant employment uses. We strongly support the original plan of a mixed-use quarter.
2. The very low levels of community facilities proposed are not in keeping with the development of a sustainable community and the needs of current and future residents.
3. The reservation of a school site for Clongriffin should be respected.
4. The proposed towers should not be included due to their negative impact on views from and across the Baldoyle – Portmarnock Green Belt and public parkland protected in the Fingal County Development Plan.
The submission from Clongriffin Community Association goes into considerable detail on these applications, demonstrating how they go directly against the original vision for the area.
Update: the permissions were granted contravening the City Development Plan and Local Area Plan despite the submissions received.
A South Fingal Transport Study has been carried out for the Council. (This is in fulfilment of an objective in the County Development Plan which specified the Study would include public consultation; unfortunately the public consultation hasn’t happened.)
The Study contains strong recommendations about prioritising walking, cycling and public transport in the area, and will be discussed at a Planning and Strategic Infrastructure Policy Committee meeting on Monday 28th.
As a member of the Eastern and Midland Regional Assembly, I was involved in drafting the Green Party submission to the consultation on the draft Regional Spatial and Economic Strategy. The submission is quite brief and contains recommendations in the following areas:
Strategic Housing Development Section
An Bord Pleanála
64 Marlborough St.
Dublin D01 V902
Re: Case reference: PL06F.300879
A chairde,
I refer to the above development and would like to make the following observations:
1. SHD process is not compliant with the Aarhus Convention
The decision-making process in the Strategic Housing Development
category is contrary to the Aarhus Convention, in particular as it
fails to meet the requirement of Article 6(4) to “provide for early
public participation, when all options are open and effective public
participation can take place.”
The process established for Strategic Housing Developments ends up,
as in this instance, pre-determining and pre-deciding choices and
decisions about many elements of the development before any public
participation happens. That this is so is evident from the record in
the planning file of pre-application discussions with both Fingal
County Council and An Bord Pleanála. The fact that there is no appeal
from this decision makes this failing considerably more significant
from the point of view of the public’s ability to have an impact on
the final decision and the quality of the decision-making process.
I have made observations on two linked planning applications in Holywell. The proposal for a petrol station and takeaway is not in keeping with the objective of maintaining residential amenity and providing quality sustainable neighbourhoods. The road design is confused and inadequate for pedestrians and cyclists like other road designs in the Holywell area.
The observation on the road proposal F17/A0392 also includes a copy of the observation on the petrol station/ takeaway F17A/0393.
The Council today confirmed the following amendment I proposed to the Draft Development Plan:
“At locations where higher density development is being provided, encourage the development of car-free neighbourhoods, where non-motorised transport is allowed and motorised vehicles have access only for deliveries but must park outside the neighbourhood, creating a much better quality public realm with green infrastructure, public health, economic and community benefits.”
It reflects successful experience in neighbourhoods such as Vauban in Germany and entire suburban towns like Houten in the Netherlands, as well of course in old cities around the world.