Observation on Howth Castle planning appeal

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

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

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

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.

Kinsealy Greenways update

At the September Council meeting I asked when for an update on the design of the Kinsealy-Portmarnock Greenway and was told it had gone to tender. I couldn’t find it on e-tenders so I raised at the Area Committee where I was told that the information at the Full Council was wrong and the request for tenders wouldn’t issue until early next year.

At the October Council meeting we considered the Capital Programme for 2023-2025. It only included the design work for Kinsealy Lane and the Kinsealy-Portmarnock Greenway. I submitted these motions to add to the plan the construction of the Greenways to Portmarnock and Kettle’s Lane and the redesign of Kinsealy Lane:

  • That this Council recommends that the capital programme line for the Kinsealy- Portmarnock Greenway continue subsequent to 2023 with a total expenditure of €12 million (based on the Feasibility Study already carried out) with funding to be from grants and levies.
  • That this Council recommends that the capital programme line for the Kinsealy Lane upgrade continue subsequent to 2023 with a total expenditure of €4 million (based on the Feasibility Study already carried out) with funding to be from grants and levies.
  • That this Council recommends that a capital programme line be included for the Kinsealy- Kettles Lane Greenway with a total expenditure of €9 million (based on the Feasibility Study already carried out) with funding to be from grants and levies.


The first was defeated after the Mayor wouldn’t let me amend it to delete the words “and levies”. The other two were agreed with that amendment. 

In our Development Plan process, I have submitted motions to include the two greenways on the Development Plan maps. Unfortunately the Chief Executive is opposing these motions. This is despite the feasibility study done in 2018 which is at https://davidhealy.com/?p=907.

Planning observation on proposed infill behind the West Pier

Following the non-statutory consultation in 2021 (see my submission here), the Department of the Marine made a planning application (F21A/0368) for the dredging and infill. I didn’t hear about it until just before it was appealed to An Bord Pleanála (PL06F.314487). I have submitted an observation on the appeal.

Overall, I’m very concerned that the application really hasn’t thought through the amenity or biodiversity potential of an infill development, but will provide a road and some extra car parking neither of which is needed.

Road markings to improve conditions for walking and cycling on Stockhole Lane

The Council plans to resurface part of Stockhole lane south of the junction with Baskin Lane. I have made the following observation in response to the public consultation on the temporary closure:

If we are to achieve the necessary improvement in conditions for walking and cycling to achieve national and local goals for road safety and climate, we need to ensure that that all maintenance and repair work on roads avails of the opportunity to improve conditions for active travel.

In this instance, the road to be resurfaced lacks a footpath over most of the stretch to be resurfaced and is unpleasant for cycling. The M1 motorway and R139, R132 and R107 regional roads provide alternatives for all potential through trips. Therefore there is no reason for this road to be used by motor vehicles for anything other than local access to/from Stockhole and Baskin Lanes. 

In these circumstances, the road layout should reflect this purpose and be designed to prioritise active travel access. These examples from the Netherlands  http://www.aviewfromthecyclepath.com/2009/07/country-road.html and France https://actu.fr/occitanie/villeneuve-la-comptal_11430/aude-une-voie-innovante-ou-les-velos-ont-la-priorite-dans-un-village-du-lauragais_49069204.html show the road markings appropriate in these circumstances.

Observation on Belcamp SHD application – need for light rail-based development

A very large urban development application has been made on the Belcamp lands, in advance of the Local Area Plan which the zoning provides for. I have made an observation to An Bord Pleanála (version with appendices) focussing on the need to develop around high-quality public transport.

It has been clear to me for over 15 years that the large development area planned between Clonshaugh and Clongriffin, of which this Belcamp application forms part, should be served by an orbital light rail or metro connection to the Dart in the east and the Metro in the west, a link which will also be of wider benefit to the public transport network.

The only additional recent element is that NTA, in its proposals for revising the Greater Dublin Area Transport Strategy, now recognises that there will be a need for a light rail service on the Malahide Road, so it’s proposing a further link in the network.