I made the following response to the Public Consulation on Development Levies in Fingal.

1. The list of projects ​in Appendix II to be funded by the scheme should include the following:
   • Full implementation of those elements of the Greater Dublin Area cycle network which are in Fingal (https://www.nationaltransport.ie/publications/transport-planning/gda-cycle-network-plan/ );
   • Road and street redesign to to ensure compliance with the Design Manual for Urban Streets and Roads;
   • Works to improve access to and amenity at beaches.
2. ​The costs in Appendix I should be adjusted accordingly.
3. The proposal is that development contribution rates​ remain unchanged. This is predicted to lead to a shortfall of €31m or about 10%. If this happens then infrastructure which we have identified as essential will be unfunded. This is not acceptable; the Scheme should provide for full funding of the required infrastructure.​
4. Commercial/industrial and residential development are levied at different rates. When I asked why this was I was told because they require different levels of infrastructural expenditure. In fact the commercial/industrial rate is simply 78% of the residential rate for all of the types of infrastructure (transport, surface water, parks) to be funded. That this is not related to the associated infrastructure cost is demonstrated by the fact that the same surface area of development attracts different charges for provision of surface water infrastructure depending on whether its residential or commercial. At a first glance it seems daft that at a time of housing demand in Dublin and when we have large quantities of derelict/empty commercial property we would effectively subsidise commercial at the expense of the residential.Therefore the same contribution should be required for commercial/industrial and for residential.
5. Car parking is proposed to be either exempt, or in the case of ‘stand-alone commercial car parks’ levied at 50%​ (10(i)(j))​. Given that transport policy both nationally and locally seeks to achieve significant and rapid modal shift away from cars, all car parking should pay development contributions at the normal rate.