Strategic Housing Development Section
An Bord Pleanála
64 Marlborough St.
Dublin D01 V902
Re: Case reference: PL06F.300879
Planning Application Reference
300879-18: Former Baily Court Hotel, Main Street and lands located
south of the Martello Tower on Balscadden Road, Howth, Co. Dublin
(Edros site)
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.
