Comments on draft Howth Urban Centre Strategy

In line with the requirements of the County Development Plan, a draft Urban Centre Strategy has been prepared for Howth. My comments on it are below.  It will be discussed at the Area Cttee. meeting in Baldoyle at 3pm on 18th September and I have supplied these comments in advance.
Comments on the draft Howth Urban Centre Strategy

Pages 12 to 39 contain a significant amount of overlap with the ACA Statement of Strategy.   My comments on p.44/45 are at the end because they are only really intelligible with the document at hand.

 “Safety and security” p.47

Are there any crime records associated with the steps which would justify CCTV.  Lighting as proposed and better cleaning and maintenance are needed.                        

Access from West Pier to Beach p.51
Replace dart station wall to Claremont Beach access with railings to give natural overlooking.  Improve and maintain the existing access.

Heights on Techcrete site p.56
Where is the analysis to support the statement that “The former Techcrete site has the capacity to promote heights of up to 7 storeys”, plus the proposed tower? In particular visual analysis.               

Materials p.58
Recommend against the use of tropical hardwoods
Do not provide for more glazing on the north-facing facades.

Techcrete/Teelings/Baltray Park site  Section 6.1 

Location of Community Centre p.62
As already mentioned, no reason is given for putting the community facility to the far end of the site.

Division of uses on site p.63. 
The Development Plan says “mixed-use”, yet the Strategy seeks to physically divide the different uses    

Layout p.64- 65
The built form proposed by the developer seems to be a significant improvement on this proposal.

Buffer Zone around pumping station p.64
Can we get an explanation of the 50m buffer zone and whether it applies at other pumping stations such as Sutton, Dún Laoghaire, etc.  A 50m circle is 2 acres, although some would fall outside the site (beach, railway). The centre of this circle seems to be in the wrong place.

Views pp.66-67
The built form proposed by the developer seems to be a significant improvement on this proposal with much better views through.

Beach access over railway p.68 
Why is this location suggested for the beach access?

Heights p.69 
There are no reasons given for the suggested heights. I had expected an analysis which would lead to the appropriate heights for the proposed development, including visual impacts when seen from the beach, the SAAO, Harbour Road, and the heritage areas of the Howth

West pier proposals 6.2
This is a flight of fancy which is not backed up by any analysis of the needs supposed to be met nor of the impact on natural processes including erosion and siltation patterns. It should be omitted. It is frustrating that so much attention has apparently been put into this.

Tuckett’s Lane site 6.3
There is no analysis in this. Why not build along the lane?

Traffic Management at the Dart Station. p. 89

The Transportation Department has already secured the agreement of the Council to changes at this location. See Appendix 1.  (This was correctly presented to the Councillors as a matter of great urgency and I am at a loss as to why it hasn’t yet been implemented. This is effectively the option 2 in the draft Strategy but including car drop-off as at present. Note the consultants’ favoured Option 4 does not provide visibility of the traffic lights as referred to in the report.

Harbour Road proposal p.94

This doesn’t seem to make sense. It note that objective 10 on p.45 envisages retaining the current layout but reducing the curves to improve safety. I agree with that.

Traffic Management in the Centre of Howth p.95
Some of the ideas here are good. However, other elements require substantial further work.  I’m disappointed that we aren’t further along in relation to this element.

The consultants have confused the churches of Howth and the street names.

Comments on the elements on Page 45

Some of the numbered elements don’t seem to relate to anything elsewhere in the text. It would be useful to have an indication of the corresponding page numbers for each of the numbered elements.

1.    Delete
2.    Delete
3.    Delete
4.    Delete
5.    Delete
6.    Delete
7.    no, improve existing route and connect to promenade
8.    Delete
10.    Yes
15.     what does this mean? I can’t find it in the text.
16.     lighting
17.     Yes, lighting
18.     Yes
19.     Yes, but proposal is not adequate
21.     Yes, but design it safely, not as proposed (see comments below)
22.     no, buses can turn at the Castle entrance
23.     Yes, in fact widen this consideration into redesigning this road such that, in keeping with the development of the Techcrete site, the entry to Howth is further east and traffic slows further east than as at present.  Widen footpaths on both sides of the road, narrow carriageway, possible segregated cycle routes, depending on access arrangements to new site.
24.    Delete.  “Landmark” seems to be planner code for high. In fact, page 56 explains that this is a tower of over 7 stories.  No reason is given for this.  No analysis of heights in document, just unsubstantiated conclusions.         
25.     Overtaken by new application
26.     Does this conflict with the views in 27
27.     Yes, but better views than those shown on the map – views to Ireland’s Eye in particular.
28.    Why at this location and not further east?
29.    Why do you recommend the furthest extreme of the site as the location for a community centre?

Appendix 1

Extract from County Council meeting 03 April 2008
Minutes HomeYear HomeCommittee HomeMeeting Home
The following report by the Manager was READ:-
“Consequent to an expression of concern from a motorist, a site meeting was convened during March 2008 between representatives of the Transportation Department, Dublin Bus and An Garda Siochána to review the operation of the east and west-bound bus stops at Howth Dart Station. At this meeting it was observed that on occasions where both stops are occupied by buses or HGV’s the east-bound view of both traffic signal heads are obscured.
To mitigate the potential for a pedestrian accident, a decision was taken at this meeting to relocate the eastbound bus stop from the carriageway recess to the area immediately adjacent to the Dart station. To facilitate this change it will be necessary to remove all commuter parking from this area. Disabled parking will be retained however. It is considered that there is adequate parking in the adjacent area to accommodate the displaced motorists.
The proposed measures will:-
·        Facilitate unimpeded bus access and egress
·        Increase drop off space for commuters
·        Reduce vehicular / pedestrian conflicts at peak periods
·        Facilitate future bus turnaround to/from Howth Summit
·        Facilitate off street loading for commercial premises
A formal application has been submitted to the Garda Commissioner’s office for this regulatory parking control. The Gardaí in Howth Station have also been consulted and are supportive of the measures. The proposed works will not involve civil engineering works and it is envisaged that they will be implemented at an early date if approval is received from the Garda Commissioner.”
Following discussion, Mr. Garry O’Brien agreed to erect information signs at the location, in advance of the changes, to advise the public of the proposals and stating reasons for implementing the above changes. He also agreed to examine an adjoining of parking area which is currently used to store wheelie bins.
The report was NOTED.