I made an observation on the application to demolish a large house on Thormanby Road as part of a development of its garden and field behind, arguing it was contrary to the Fingal Development Plan’s requirement to only demolish where it is the more sustainable option.

The demolition justification chose, unreasonably, to compare demolition with retention of the existing house unaltered, instead of comparing demolition with a retrofit of the existing house. Unfortunately, despite this being pointed out, ABP accepted the demolition justification report as valid, but then correctly concluded that demolition was an unsustainable choice.

 8.2.7. I note the grounds of appeal have submitted to a sustainability report assessing the environmental impact of a proposed deep refurbishment versus new-build options for a residential development. I note the planners report did not comment about this report and I believe there is no specific policy requirement in the plan for this report. Nevertheless, I have reviewed the report which concludes, deeply refurbishing the existing home will emit over 5.7 times more CO2 per year than constructing a sustainable new build. Deep refurbishment and extension of the existing property would also contribute to more than 58% of the embodied carbon emissions associated with a new build. The report states from a carbon emissions perspective, demolishing the existing E1-rated building and constructing four new A1-rated buildings is a more sustainable long-term solution than refurbishing the existing building. 
8.2.8. I note the conclusions of the report, however in the context of the above policies and objectives SPQHO44, DMSO256 HCAP22 and HCAP23 and the Climate Action Plan which highlights that buildings represent a significant resource of ‘sunk’ or embodied carbon and their retention and reuse will be critical to avoiding unnecessary emissions associated with demolition and replacement. It is my view from the policies and objectives SPQHO44, DMSO256 HCAP22 and HCAP23 that there is clear presumption against the demolition of existing housing stock. Furthermore, I note no structural engineering report has been provided with the appeal to justify demolition which is a requirement of DMSO256 (Re-use of existing Buildings) and section 14.21.1 of the plan. In my opinion the existing habitable dwelling appears to be in sound condition. Given the architectural merit of the existing habitable dwelling, the areas distinctive character, it is my view the adaptive re-use and transformation of existing building should be the first consideration which is supported by various policies and objectives of the plan before demolition and replacement.

https://www.pleanala.ie/anbordpleanala/media/abp/cases/reports/321/r321299.pdf

Update: a revised application retaining and retrofitting the existing house has since been approved.