Greens oppose high-rise proposal for Techrete site

Green Party Councillor David Healy has restated his opposition to the proposed high-rise buildings at the Techrete site in Howth.  In a submission to the draft Urban Centre Strategy he made a number of points including:

    * The appropriate building height for the site is about 4 stories, given the escarpment behind the site.
    * Views from the Howth Road to the sea and Ireland’s Eye must be protected and new views created
    * The proposals for infill behind the West Pier should be dropped
    * The proposed Community Centre should be on the east of the site, on the former Teelings garage near the Dart station, so that it is in walking distance of most of the houses of Howth, and near public transport and existing parking.

For further information please see attached submission or contact Cllr. David Healy at 087 6178852

Comments on the draft Howth Urban Centre Strategy

The following are my comments on the draft Urban Centre Strategy.


I believe this strategy, appropriately amended, should be adopted as a Local Area Plan.  I think it is important to give it a legal status so that it will be of use in the planning system.  The preparation of the Strategy is mandated by the County Development Plan.  However, unless it is adopted as a Local Area Plan it will not be possible for the Council to rely on it in making planning and other decisions in the area.  There is a well established legal principle that the holders of statutory powers cannot delegate those powers other than as foreseen by statute.   Therefore the elected Council as the body responsible for adopting Development Plans and Local Area Plans which set the framework for planning consents, cannot delegate to the Manager or anyone else the power to draw up documents which set the framework for planning consents.  

Not being able to rely on the Strategy for Development Control purposes would of course, negate the entire purpose of producing it.  Therefore I would recommend that the Plan, subject to amendments as suggested below and others which will arise from the current public consultation be put forward for adoption as a Local Area Plan.

Techrete/Teelings/Baltray Park Site

Heights on Techrete site (p.56 , p.69)

Where is the analysis to support the statement that "The former Techrete site has the capacity to promote heights of up to 7 storeys", plus the proposed tower (height unspecified but presumably over 7 storeys)?

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

In particular the document should contain a visual analysis including of views from the Hill, from the core of Howth, from Harbour Road and Howth Road, from adjacent coasts, and from the beach, Ireland’s Eye and the adjacent coastal waters.  

Location of Community Centre
(p.62 )

No reason is given for putting the community facility to the far end of the site.  This appears to have been assumed by the consultants. Placing the community facility at the greatest distance from the centre of population and the train station significantly affects its attractiveness for local residents, militates against its use by non-car-owners including children and old people, and increases the traffic generation for the site.

Using this distant location means that parking has to be provided on site, using a considerable are of land. Siting the community facility to the east of the overall site would mean that the spare capacity in the existing parking on Harbour Road and in the Harbour could be used.  

The provision of a community centre without a swimming pool and a separate private swimming pool is contrary to the first finding of the Community Needs Analysis where a pool was identified as the first priority.

Division of uses on site

The Development Plan says "mixed-use", yet the Strategy seeks to physically divide the different uses.  There is no rationale presented for this.

Layout (p.64- 65)

The built form proposed by the developer seems to be a significant improvement on this proposal in a number of respects including views.

Views through the site (pp.66-67)

The proposed built form does not allow for sufficient views through the site looking out to sea and to Ireland’s Eye from the Howth Road. The built form proposed by the developer has the potential to be a significant improvement on this proposal with much better views through.

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. 

Materials (p.58)

The document should recommend against the use of tropical hardwoods.  For energy conservation reasons, it should not provide for more glazing on the north-facing facades.

Beach access over railway

Why is this location suggested for the beach access?   

Beach Promenade

The document should include recommendations for the renovation, improvement and extension of the Beach Promenade. This is within the Strategy Area and it is surprising that such an obvious need hasn’t been addressed.
Access from West Pier to Beach (p.51)

The document should contain an objective to replace all or as much as possible of the train station wall along the Claremont Beach access with railings to give natural overlooking to this route.  It should include provisions to improve and maintain the existing access.  The fencing along the railway could be replaced by extending the railings on the west end of the northern platform along the length of the beach.

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 when other areas lack necessary analysis or detail.

Tuckett’s Lane site

There is no analysis in this. Why not build along the lane?  No account has been taken of the potential for improvement of the community use of St. Columbanus’ Hall. No account has been taken of the potential for making a pedestrian street, through the park site to St. Lawrence’s Road or Main St.  As it stands there is nothing worth retaining in this section.   
The Steps (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.        
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.  Therefore it would appear that the consultants were supplied this relevant background information.

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 (

The ideas here are good. However, other elements require substantial further work.  In particular the scheme needs to rely more on the shared space philosophy, allowing motor traffic to access the village but communicating to them that priority is given to pedestrians.  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



Minutes of Meeting of County Council held on


An apology for inability to attend was received by:

The Councillor , presided.


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.