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.

Abolishing car parking requirements and developing car-free neighbourhoods – Green Councillors’ submission to consultation on sustainable settlements

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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.

Our observation on proposed draft direction to delete noise insulation objective from Fingal Development Plan; make your observation by Tuesday 2nd May!

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Following advice from the Planning Regulator, the Minister of State for Local Government and Planning has drafted a Direction to Fingal County Council to delete a provision about noise insulation included in the Plan. The Draft Direction is open to public consultation until Tuesday 2nd May 2023 at 11.59pm.

The 5 Green Councillors on Fingal County Council have made an observation pointing out that there is no legal basis for the draft direction and that the provisions were included to protect human health.

The objective, agreed by unanimous vote of the Council, specifies that insulation for homes affected by aircraft noise should achieve 40 dB Lnight, which is the standard recommended by the World Health Organisation to protect people from the impact on health caused by sleep disruption.

Anyone affected by aircraft noise should make their views known before the deadline.

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.

Comments on Kilbarrack Road / Oscar Traynor Road cycle route design

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I have sent the following observations to Dublin City Council in response to their public consultation:

Thanks very much for coming to the meeting of the Howth/Malahide Area Committee to present this cycle route.  As Chair of the Committee, I know I speak for the Committee as a whole that we welcome the improvements for active travel that you propose. 
The following comments (some of which were raised at that Committee but are repeated for completeness) are made with the goal of further improvements:

Orcas at junction narrowing

​The consultation document says that ​“radii of all the junctions are tightened up to a maximum radius of 6.0m with road marking.”​ This is very welcome. On the maps,​ in some locations. these are also marked by orcas. In others they aren’t. e.g. Alden Road, Verbena Avenue, Kilbarrack Avenue, St. Margaret’s Avenue etc.​ They should be marked by orcas/bollards at all junctions.​

​N​arrowing of wide side roads at junctions

As well as the radius of the kerb, the width of the road at the junction should be narrowed where it’s very wide (e.g. St. Margaret’s Avenue.)

Tonlegee Road/Raheny Road/ Grange Road junction. ​

This is a r​eal problem junction​ for less confident cyclists​. In the absence of a more fundamental redesign, steps need to be taken to ensure that the use of the junction is ​appropriate for mixed traffic. Maybe ​a)​ a 30km/h speed ​at this junction for the interim scheme​ and b) signage reminding cyclists to take the lane and reminding other road users to expect cyclists to take the lane.​

Kilbarrack Road/Howth Road junction​. 

This junction needs to be addressed in this scheme. There are​ no ​traffic light​ phase​s​ to access​ and leave the​ cycle route.​ The consultation documentation says​ “Cyclists are encouraged to access the existing two-way cycle lane along Howth Road via the proposed toucan crossing.” ​With the narrowness of the footpath, t​his is geometrically difficult for ​users of ​all bicycles, impossible for​ users of​ some​ bicycles (e.g. cargo bikes) at all times and impossible for all bicycles when there are people walking. I understand Fingal has already forwarded correspondence from one cargo bike user describing the diffi​culties she experiences at this junction; if this isn’t to hand, I would be happy to send it on.

Cycle lane width

The width of the cycle lane, stated to be 1.5m, is however showing in the drawings as less than 1.5m because of orcas placed in the cycle lane. They should be outside the cycle lane, between cycle lane and general lane.​

Bus stops

The scheme should provide island bus stops at any opportunity and should consider whether moving bus stops can help with achieving this.

The NTA is also considering how to extend the N6 to the coast as originally planned in the Bus Connects redesign, with a possible terminus at Blackbanks. It would be important to ensure that any new bus stops are well sited.​

Shops on Kilbarrack Road

Although this area is lined for parallel car parking between the cycle lane and the pavement, cars currently usually park diagonally, partly on the cycle lane and reverse out across the cycle lane. The proposal effectively intends to maintain the current road markings, which can be expected to mean that the current dangerous use of the road will continue. The scheme should provide for car parking outside the cycle lane.


Thanks for considering the above.

Commissioner for Environmental Information has upheld my appeal on refusal of access to information on Station Road junctions

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The Commissioner for Environmental Information has ruled on my appeal against Fingal County Council’s refusal to release planning compliance documentation in relation to condition 2 of planning permission SHD/012/19. The condition required the redesign of the junctions at either end of Station Road before development started, which didn’t happen. One has since been redesigned. The other still hasn’t. More background here.

The Commissioner found

36. Articles 7(4) and 11(4) of the AIE Regulations require public authorities to provide reasons for refusal at both original and internal review decision stages, consistent with Article 4(5) of the AIE Directive. It is clear that the Council did not provide adequate reasons for refusal of the appellant’s request.

37. I am satisfied that the Council adopted a blanket approach to its refusal of the records at issue under article 8(a)(i) of the AIE Regulations and to its refusal of the records at issue under articles 8(a)(iv) and 9(2)(d) of the AIE Regulations, without having regard to the nature or content of the records.

The Commissioner has now directed the Council to undertake a fresh decision-making process.