I have submitted the attached observation to Fingal County Council in relation to Borg Developments application F06A/1484.
Councillor David Healy
Green Party/Comhaontas Glas
Howth ward / Dublin North East
54, Páirc Éabhóra,
Beann Éadair, Co. Bh.Á.C
54, Evora Park,
Howth, Co. Dublin
15th November 2006
Fingal County Council,
Re: Application F06A/1484
I would like to make the following observations on the above application
1. Visual impact and character of area
The site is in the Special Amenity Area Buffer Zone. Other development in this vicinity has correctly been kept at a low level, mostly single storey. The proposal for very large two-storey houses spread evenly across the site is entirely out of keeping with the character of the area and the existing pattern of development. The designated protection of the Buffer Zone is intended to protect the character of the area as well as views to and from the Special Amenity Area proper. The proposed development by virtue of its size and intrusive nature is not in keeping with these objectives. In particular, the importance of the tramway as an amenity route to the Special Amenity Area is recognised in the SAAO. Views from the tramway are therefore of particular importance.
The site is one of significant biodiversity value, containing woodland and important wildlife corridors, including for bats (which are legally protected). Development of low density housing is not incompatible with maintenance of biodiversity value provided that sufficient appropriate and interlinked planting is carried out, and existing woodlands and hedgerows are retained, improved and connected as needed. Unfortunately the current plan seems to envisage considerable enclosure on the site in such a manner as would disrupt wildlife movement.
3. Drainage and hydrology
The development is proposed to be located in a damp hollow which acts as a reservoir at the head of Gray’s Brook which drains the valley around it, flowing down through the town of Howth under Main St. and Abbey St. Interference with this hydrological regime could cause flooding locally and/or downstream. The Council must ensure that this development is not allowed to have negative impacts. There is a further issue here in that the wetness of the area undoubtedly contributes to its biodiversity value. Therefore solutions which would seek to drain the woodlands and adjoining areas should not be contemplated. These considerations argue towards clustering of the development on the site (together with dedication or sterilisation of the remaining land).
4. Water supply
The existing water supply in the area is inadequate, with generalised low pressure leading to frequent complete loss of supply on the upper stretches of Thormanby Road and adjacent areas. Adequacy of water supply should be a central consideration in deciding on a planning application. The Council is entirely aware of the inadequacy of the water supply in this area. Extra houses will add significantly to the demand on an already inadequate supply. Further development in this area is therefore premature until such time as the necessary water supply is made available
The entrance to the site is between two dangerous bends and would increase traffic hazard at this location.
6. Rights of way
There are rights of way in the area and through the woods which would be interfered with by the proposed development
In conclusion, while some of the issues above are capable of being addressed by further information request or condition, I feel that the development as a whole is of over-sized houses and fails to comply with many of the planning objectives for the area as set out in the County Development Plan and the Special Area Amenity Order. Additionally, the lack of an adequate water supply and the effect the development would have on the users of the existing supply means the development is premature Therefore permission should be refused for the applicant to come back with a proposal more in keeping with the area and the planning objectives for the area, after an adequate water supply has been made available.
I enclose the €20 fee.
Is mise, le meas,
Cllr. David Healy