Category Archives: Howth/Beann Éadair

Leave granted for a Judicial Review of the permission for demolition of Deer Park Hotel.

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This morning I have been granted leave to take a Judicial Review of An Bord Pleanála’s handling of a proposal to demolish and replace the Deer Park Hotel on Howth Demesne.

Why I’m lodging this JR

The new owners want to knock down Deer Park Hotel and build a new hotel but they did not even consider renovating/reusing the existing building – and I believe they should have.  

That’s why I have applied for a Judicial Review of An Bord Pleanála’s handling of the proposal: ABP should have sought a demolition justification report to address the sustainability of knocking down the existing hotel rather than retrofitting and restoring it. 

Too much of Dublin’s building stock is destroyed and dumped in favour of new builds. Many people see this for what it is – an enormous waste of resources. Demolition can and should be justified, and ABP should have made sure it was. That’s why I’m lodging this Judicial Review.

The grounds for the application are threefold:

  • that the planning application was not accompanied by a demolition justification report addressing the sustainability of demolishing rather than retrofitting the existing hotel,
  • that the report from the landowner in response to my appeal to the Board was not circulated to me although that was recommended within the Board, and
  • that the handling of screening for environmental impact assessment did not meet EU law requirements.

My concerns are about the sustainability of demolition. I agree with the principle of a hotel at this location, and I don’t consider that the existing hotel is of architectural heritage value. But buildings of poor quality can be turned into high quality buildings with low environmental impact; see the prize-winning examples by Lacaton and Vassal linked from the details below.

Background and details:

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Submission in relation to Dart+ Coastal North

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My observations to An Bord Pleanála can be summarised as follows:

  1. I strongly welcome the electrification of the railway to Drogheda.
  2. I am concerned by proposals for infrastructure changes at Howth Junction to facilitate the operation of an enforced transfer at that station for passengers to/from Bayside, Sutton and Howth. The European Investment Bank’s analysis unit, JASPERS, predicts a 50% reduction in passenger numbers due to the enforced transfer. In consequence, they recommended:
    “Further analysis and public consultations should be made on the ideal operating
    model for DART+CN, in particular whether or not to enforce transfer at Howth
    Junction for Howth route trains (with the overall operational consequences this
    implies).”
    The Minister for Transport has asked his Department to follow up with NTA and Iarnród Éireann in relation to the implementation of this recommendation. The only potential operating model which has been presented for the Howth Junction
    transfer infrastructure shows only disbenefits. In the absence of an operating model which shows benefits, this element of the project cannot constitute proper planning and sustainable development.
  3. Iarnród Éireann needs to improve walking and wheeling access to stations, especially where it would enable more direct routes for public transport interchange or to/from local destinations. Safe permanent access is needed at Clongriffin. Sutton Station is being addressed by Fingal County Council as part of the Sutton to Malahide scheme; these two projects need to be integrated and made complementary.
  4. The opportunity which Dart+ Coastal North presents to provide high quality additional bicycle parking to meet future needs should be taken.

Dart + Coastal North: Howth Junction transfer

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Minister Eamon Ryan has directed his Department to liaise with the National Transport Office and Iarnród Éireann to ensure that the recommendations from JASPERS (the European Investment Bank’s evaluation unit) for a review of the Howth Junction transfer proposal are implemented.

See this letter for details.

AIE request confirms that Iarnród Éireann hasn’t analysed the impact of a shuttle service from Howth Junction on local services

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I have received a response from Iarnród Éireann to an Access to Information on the Environment (AIE) request. The request sought the following:

  • Any analyses of potential operational patterns involving a shuttle service between Howth Junction and Howth, requiring passengers to change at Howth Junction to access Bayside, Sutton and Howth.
  • Any analyses of the time delays or reduced capacity of the network at Howth Junction caused by the current arrangement where northbound trains to Howth cross the southbound track from Malahide.
  • Any analyses of the time savings or increased capacity of the network should one or more Howthbound trains be replaced by a shuttle service.
  • A copy of the terms of reference for “studies which will examine the doubling of track capacity between Dublin’s Connolly and Malahide train stations, where DART and intercity traffic currently share the same tracks”, for which funding was awarded on 22nd June.
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Appeal in relation to Deer Park Hotel

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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

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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

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

It follows my previous observations.

Observations on Deer Park Hotel application additional information

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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.

Observation on Howth Castle planning appeal

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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

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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.