Category Archives: Climate Change / Athrú Aeráid

Submission to draft Airport Local Area Plan and Development Plan Variation

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I made this submission to the public consultation on the draft Dublin Airport Local Area Plan and on the associated draft Variation to the County Development Plan. It refers back to my previous submission on the draft Local Area Plan and deals in particular with issues of climate change, noise, cycling access and water quality.

Response to public consultation on Fingal Climate Action Plan

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My brief response to the consultation on a draft Fingal Climate Action Plan  focussed on the importance of a more detailed public participation process for taking climate action to achieve the 40% reduction in emissions which is a target we signed up to in the Covenant of Mayors . I advocate a major focus by Fingal County Council on  actions to reduce transport emissions, as transport is the largest emission sector and one for which Fingal has significant influence.

The submission: Meeting the commitment to the Covenant of Mayors through a process of public participation

This will be coming back to the Council for final decision in either April or May.

Response to Regional Spatial and Economic Strategy consultation

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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:

  • ensuring that effective sustainability indicators are used;
  • halting and reversing biodiversity loss in line with the UN Convention on Biological Diversity, including large-scale rewetting of peatlands and restoration of natural ecosystems including wetlands and woodlands across the region, taking account of the major social and economic benefits which could result;
  • ensuring the implementation of the Water Framework Directive through the planning system;
  • transitioning to the circular economy;
  • measuring the greenhouse gas emissions from the plan and ensuring it puts us on a path to a low -carbon economy
  • investing in walking and cycling, recognising their public health and environmental benefits
  • investing in public transport, in particular rail.

Letter to Fingal County Council in relation to Dublin Airport Third Runway

The Austrian Federal Administrative Court recently rejected plans for a third runway at Vienna Airport because it would have a negative impact on greenhouse gas emissions and would be contrary to Austria’s international obligations to tackle climate change.

I wrote to Fingal County Council drawing their attention

a) to the conflict between building a third runway at Dublin Airport and Ireland’s climate change obligations, and the Council’s duties under the Climate Action and Low Carbon Development Act 2017; and

b) to the fact that Dublin Airport Authority are applying to extend a permission they are simultaneously trying to alter, which I and many local residents suffering and expected to suffer from nighttime noise from the airport consider to be acting in bad faith.

My letter and attachments 1  and 2.

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Final stage of County Development Plan process

I have submitted the following motions in relation to the Amendments to the County Development Plan. The meetings will be on 14th and 16th February.

Cycling 
For background to the cycling motions, please see my report from the previous stage of the Plan.
7.10 Review of cycle infrastructure not designed in line with Principles of Sustainable Safety
That In light of policy 2.5 of the National Cycle Policy Framework, the proposed amendment
“Insert new Objective MT: Review existing cycle infrastructure which was not designed in line with the Principles of Sustainable Safety in a manner consistent with the National Cycle Manual and the Design Manual for Urban Roads and Streets and undertake appropriate remedial works.“
be confirmed.
(Unfortunately the Chief Executive is recommending that this amendment not be included.)
7.11 Design roads in accordance with the Principles of Sustainable Safety
That the Amendment agreed by the Council under Agenda item 284/ Motion AI028972
“Insert Objective after MT09: Design roads including cycle infrastructure in line with the Principles of Sustainable Safety in a manner consistent with the National Cycle Manual and the Design Manual for Urban Roads and Streets.”
be confirmed.
(Unfortunately the Chief Executive is recommending that this amendment not be included.)
7.15 30km/h environment in the immediate vicinity of schools
That the proposed amendment:
“Insert new Objective MT: Ensure that as soon as possible, but by the end of the lifetime of the Development Plan the environment in the immediate vicinity of schools is a safe and attractive low speed (30kph) environment with speed limits strictly enforced, and drop-off by car within a given distance restricted.”
be be amended to
“Insert new Objective MT: Ensure that as soon as possible, but by the end of the lifetime of the Development Plan the environment in the immediate vicinity of schools is a safe and attractive low speed (30kph) environment, and drop-off by car within a given distance restricted.”

(The deletion of the reference to enforcement comes from the fact that the Council has no influence on speed limit enforcement.  Unfortunately the Chief Executive is recommending this much weaker version: “Support and promote the implementation of policy in the immediate vicinity of schools to provide for a safe and attractive low speed (30kph) environment.”)

SH9.10 Cycle Routes to Kinsealy
That the proposed amendment to add indicative cycle route Abbeville to Kettle’s Lane be confirmed with the addition of “subject to feasibility study”.
That the proposed amendment to add indicative cycle route Portmarnock to Teagasc Kinsealy be confirmed with the addition of “subject to feasibility study”.
That the proposed amendment to add indicative cycle route Balgriffin to Teagasc Kinsealy (along field boundaries east and north of Balgriffin cemetery) be confirmed with the addition of “subject to feasibility study”.
That the proposed amendment to add indicative cycle route Balgriffin to Kinsealy (via Malahide Road) be confirmed with the addition of “subject to feasibility study”.
(Unfortunately the Chief Executive is recommending that none of these routes be included.)
SH14.2 Mark Greater Dublin Area Cycle Network on the Development Plan maps
That the proposed amendment to mark the routes of the Greater Dublin Area Cycle Network Plan within Fingal on the relevant Development Plan maps be confirmed.
(Unfortunately the Chief Executive is recommending that this amendment not be included.)
4.32 Balbriggan to Skerries cycling/walking scheme
That the proposed amendment:
Insert new Objective Skerries Promote and facilitate the development of the Balbriggan to Skerries cycling/walking Scheme along the Coast Road within the lifetime of this Development Plan”
be altered to now read:
“Insert new Objective Skerries
Promote and facilitate the development of the Balbriggan to Skerries cycling/walking Scheme along the Coast Road within two years of the adoption of this Development Plan”
as requested in the submission received.
(Unfortunately the Chief Executive is recommending that this two year time limit not be included.)
Low-carbon development and building
3.15 Low-carbon developments
That the proposed amendment
“Insert new Objective PM at Section 3.4 Sustainable Design and Standards New urban developments in Fingal will be required to be low-carbon developments, in all aspects of layout design and construction”
be confirmed.
(Unfortunately the Chief Executive is recommending that this amendment not be included.)
3.16 Low-carbon building materials
That the proposed amendment
“Insert new Objective PM at Section 3.4 Sustainable Design and Standards In general, require the use of low carbon building materials and where available use Environmental Product Declarations (EPD) for the assessment of the sustainable use of resources and of the impact of constructions works on the environment.”
be confir(Unfortunately the Chief Executive is recommending that this amendment not be included.)
Quarries
5.18 Extractive industries
That in light of the SEA assessment that “The deletion of this text is directly negative for biodiversity, water, population, landscape, soil/ landuse.” the deletion proposed in amendment 5.18 not be made.
(Unfortunately the Chief Executive is recommending this amendment which deletes strict criteria to be met for quarrying.)
5.20 Extractive industries
That in light of the SEA assessment that “The deletion of this text is directly negative for biodiversity, water, population, landscape, soil/ landuse.” the deletion proposed in amendment 5.20 not be made.
(Unfortunately the Chief Executive is recommending this amendment which deletes strict criteria to be met for quarrying.)
Public transport routes
For background, please see my posts relating to these routes
a) in response to the Metro route announcement in 2006,
b) in motions to the Donabate Local Area Plan in 2006,
c) in response to the NTA North Dublin Transport Study in 2015.
SH7.7 Public transport reservation Swords to Donabate
That the proposed amendment to insert a public transport reservation Swords to Donabate be confirmed.
(Unfortunately the Chief Executive is recommending that this amendment not be included.)
SH9.12 Public transport reservation from Metro West alignment to Balgriffin
That the proposed amendment to insert a public transport reservation – Metro West alignment aka Light Rail Corridor to Balgriffin – be confirmed.
(Unfortunately the Chief Executive is recommending that this amendment not be included.)
SH9.13 Public transport reservation from Balgriffin to Portmarnock
That the proposed amendment to insert a public transport reservation – Balgriffin to Portmarnock – be confirmed
(Unfortunately the Chief Executive is recommending that this amendment not be included.)

Reports on County Development Plan – Cycling motions

Last month’s County Development Plan meetings discussed a wide range of issues. I’m posting some reports in particular on the motions I submitted. I also supported important motions by my Green colleague Roderic O’Gorman and a range of Councillors from all parties.

The largest batch of motions were those on cycling so I’ll address those first.

One of the results of the public display of the draft plan was the receipt of a range of submissions criticising the inadequacy of the policies contained in the draft as regards cycling.These came from a range of parties, including the National Transport Authority which suggested that the policies in relation to cycling in the plan could be strengthened.

In response to these submissions, I submitted a range of proposed amendments, many of which were directly extracted from the National Cycle Policy Framework (NCPF), particularly the policies and actions identified in the Framework for implementation by local authorities.

In advising the Councillors on the motions submitted, the Council management first claimed that many of the motions submitted were invalid as they didn’t relate to submissions received. This label was applied to 15 of the 21 amendments which I proposed based on the NCPF. When I pointed out their origin this claim did not resurface.

When it came to the discussions, the first two cycling related motions were

  • to mark the cycle routes from the Greater Dublin Area Cycle Network Plan on the Development Plan maps the same as the other cycle routes already proposed
  • to provide safe routes to school as part of the process of identifying and procuring new school sites

It was a bit of a surprise that, unfortunately, the Planning Department opposed both of these. The majority of Councillors supported my motion to mark the GDA routes on the maps despite the official advice against it.

However they also opposed my proposal that safe walking and cycling routes would be provided to new schools  as part of the school development process and a slim majority of Councillors voted it down. The media, starting with the cycling journalism website Irishcycle.com, naturally took an interest in this and reported it the following week: Irishcycle.com, TheJournal.ie, DublinLive.ie.

At the following meeting, the officials continued to oppose the cycling motions and a number of other important motions were defeated including a proposal to implement HGV management strategies in urban areas, a proposal to carry out remedial measures to existing cyclist unfriendly urban roads and a proposal to provide safe cycling and walking routes to existing schools during the lifetime of the plan including an audit of all schools. These motions were all based on the National Cycle Policy Framework adopted in 2009, but despite that the officials convinced a majority of Councillors to vote them down.

At a subsequent meeting, the media attention to the vote against safe routes to schools started to have an impact and my motions to provide cycle routes from Holywell, Portmarnock and Balgriffin to Kinsealy to serve the proposed new secondary school there and the existing primary schools were all successful. So overall, a mixture of good and bad news.

 

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Proposed greenway style cycle route from Kettle’s Lane to Kinsealy via Abbeville

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Proposed greenway style cycle route from Portmarnock to Kinsealy

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Proposed greenway style cycle route from Balgriffin to Kinsealy

The amendments to the Draft Plan are on public display until 2nd December. At this stage they are only proposed amendments; they could be overturned following the consultation. So if you agree with any of the amendments, make sure to make a submission!

I’m still following up on the National Cycle Policy Framework (NCPF) issue. The media reports on the motion for safe routes to schools which was defeated, led to me learning from a member of the public of the existence of Planning Circular_pssp_8_2010_on NCPF_and_development_plans. This circular requires the Council to make the Development Plan consistent with the NCPF.

All of the cycling related motions had already been dealt with when I received the Circular but I immediately drew the attention of the next Council meeting dealing with the Development Plan to the obligations placed on the Council by the Circular. The Council officials were unwilling to recognise that the Circular had any significance to the process or to revisit the issues.

I have written to the Minister for Housing and Planning in relation to this.

Amendments to County Development Plan

Fingal County Council is currently preparing the County Development Plan to run from 2017 to 2023. The Draft Plan was on public display between February and April 2016 and a report on the over 900 responses received was supplied to Councillors at the end of July.

As Councillors we had until yesterday, 6th September, to draft proposals to amend the Plan based on the public consultation.  Those  amendments which the Council agrees to will go on public display in November.

I submitted amendments to a wide range of topics in the plan. A copy of my proposed amendments is here. In order to make them easy to navigate I have grouped them into the following topics:

  • On Special Amenity Area Order and Dublin Bay Biosphere Reserve
  • On cycle pedestrian routes to be added to the map
  • On public transport reservation from Clongriffin/Portmarnock – Balgriffin – Belcamp – Clonshaugh to metro reservations south of Dublin Airport
  • In relation to the Moyne Road bypass proposal based on discussions at the previous stage of the Development Plan and in response to submissions by the developer of the adjoining residentially zoned land and Portmarnock Community Association
  • On the zoning of the industrial estates beside Howth Junction railway station based on issues I raised at the previous stage of the Plan and a submission from a local business.
  • On the process for sub-county level plans based on the experience of Fingal councillors and citizens as well as submissions from public authorities including the National Transport Authority
  • Based on Fáilte Ireland’s submission
  • In relation to the circular economy and sustainable resource use
  • In response to the submission by Keep Ireland Open, Fáilte Ireland and others concerned with access to the countryside
  • Based on concerns about Fingal’s approach to open space in high density development, an issue raised both by developers and residents
  • On the transition to a low carbon climate resilient economy, a legal obligation of the Plan under the Climate Action and Low Carbon Development Act and raised in a range of submissions
  • On adaptation to climate change
  • On Ecosystem Services Approach
  • Transport motions based on a range of submissions by local road users and public transport users and the NTA
  • Motion incorporating text from the Dublin City Development plan in relation to cycle parking as recommended by the submission from the National Transport Authority
  • In relation to cycling in response to a wide range of submissions seeking better and safer cycling insfrastructure.
  • Based on text in the National Cycling Policy Framework, to which some of the submissions refer.

Observation to Dublin Airport Authority on proposed removal of nighttime noise restrictions

Dublin Airport Authority carried out a consultation in relation to the Environmental Impact Assessment of a proposal to remove the conditions in a permission they received from An Bord Pleanála which would restrict night time flights in order to enable local residents to sleep soundly. Exactly how they would apply to make such a change has not been explained despite direct questions.

I made the following submission:

1. The public is entitled to know what sort of application DAA is apparently planning to make, especially if we are being consulted on it.
For many months now, residents and public representatives have been hearing that DAA will be applying to change the planning conditions. However, we have not, despite repeated requests been able to understand whether this is a planning application or some other form of application. My request under the Access to Information on the Environment Regulations directed at obtaining this information also failed to clarify it.
Some sort of legal stratagem is presumably being developed. The fact that the public is being asked to participate in a consultation process where relevant details of the overall decision-making process are apparently being withheld is worrying. This is particularly the case when it is the ability of local residents to live normal lives and get a proper night’s sleep that is at stake.
2. DAA should not assume that it will be legally possible to make an application of whatever unspecified form which would relate only to two conditions of its planning permission given the passage of time since the granting of that permission, the fact that it has not commenced work on the permission and the requirements of the Environmental Impact Assessment Directive.
3. Analysis of aviation demand must take account of the need to reduce greenhouse gas emissions drastically and rapidly in order to avoid dangerous anthropogenic interference in the climate system, as set out in the UN Framework Convention on Climate Change and the Paris Agreement. Predictions of aviation demand must incorporate anticipated and necessary measures to reduce emissions including measures to control demand and measures which would change the makeup of the fleet using the airport.
4. DAA has misled itself in concluding that it is not subject to the Climate Action and Low Carbon Development Act 2015.
5. Analysis of demand for night time take off and landing must set out the degree to which this is stimulated or discouraged by pricing as well as the degree to which it results from measures taken at airports elsewhere to protect their neighbours from night time noise.
6. Alternatives examined should include the use of other airports in Ireland as well as technical alternatives, alternative modes of transport, and alternatives to transport.