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

Demolition or refurbishment/adaptation

Following on a Green motion, the Council agreed to include strong text in the 2023 Fingal Development Plan including an obligation to analyse the sustainability of any proposals for demolition:

“Where demolition is proposed, the applicant must submit a demolition justification report to set out the rationale for the demolition having regard to the embodied carbon of existing structures as well as the additional use of resources and energy arising from new construction relative to the reuse of existing structures.”

For some background to this see the Irish Green Building Council, the RIAI’s showcasing of the work of Lacaton and Vassal and the Architects’ Journal’s RetroFirst campaign.

This necessary demolition report hasn’t been done in this instance, despite the fact that I raised it in observations on the application.

The appeal recommends that the planners rely on existing standards, specifically EN15978.

Access by foot

Pointing out that this is both a matter of access to amenity land and to places of natural and historic heritage, and a pedestrian permeability issue for customers and staff of the Castle, Hotel and Golf Course, the appeal asks the Board to ensure pedestrian accessibility between the hotel and the neighbouring town and residential areas and with the other amenity lands in Howth, in line with the landowner’s own proposal in its master plan.

New Road

The appeal supports the Council’s decision to refuse permission for a proposed new road which seems intended to facilitate a proposal for rezoning of high amenity land already rejected by the Council.

For more details, please see the text of the appeal.