I received a response on Friday 23rd to my queries of 9th January. It shows that important sites with permission for housing or zoned for housing have been omitted from the Settlement Capacity Audit. This includes 3 sites (Blanchardstown and Santry) with existing planning permissions amounting to 1511 units, and one Local Area Plan area (Kellystown) where the Council intends to seek Part 8 approval for the access road this year, with capacity for between 1000 and 1500 units.

I have made a submission to the public consultation with the following recommendations:

• The bringing forward of the Dunsink development is welcome and appropriate. This land is well sited and it really didn’t make sense to defer its development.
• The proposals to rezone green belt and agricultural land should be dropped. A number of the proposed sites were considered and rejected for rezoning in the development of the 2023 Development Plan. The Green Belt zoning has always been intended as a permanent zoning and the proposas to eat into green belt land undermine the proper planning and sustainable development vision for the County. In addition there are grave concerns about flooding and public transport access which haven’t been investigated as they should have been.
• In the light of the over-calculation mentioned above, it is not necessary to find other lands for zoning to replace these rezoning proposals.

I have put more details on the calculations below.

The following three sites with planning permission for the construction of housing units on land currently only used for car parking were omitted from the Settlement Capacity Analysis.

• 348 units at Blanchardstown Shopping Centre
• 971 units at Blanchardstown Shopping Centre
• 192 units off Northwood Avenue, Santry

There are a few other planning permissions on the spreadsheet but I haven’t included them as they are smaller and more complex than simply using brownfield car park areas for residential.

In addition, an area of between 16.8 and18.8ha zoned residential at Kellystown has been excluded from the Residential Zoned Land Tax because “development of these lands is dependent on the provision of infrastructure including a length of road and a connection to the public road network, that is over lands not in the appellants control and for which there is no timeframe for the development of this necessary infrastructure.” This quote is from an An Bord Pleanála decision in June 2023. 

Looking at the Inspector’s report this is because the Council envisaged the road through Phase 1 of the Kellystown LAP lands, which is owned by a different landowner, being provided by that landowner and had no expectation as to when that would happen. 
Our Capital Programme 2026 says that the Kellystown road is to go for Part 8 approval this year. 

The Kellystown Local Area Plan, adopted in 2021, indicates approximate unit ranges for this land of between 1065 and 1610 units.

It appears that the Settlement Capacity Audit has underestimated the existing residential capacity by between 2,500 and 3,000 units.