I have sent the following response to Dublin City Council’s consultation on the redesign of the junction of North Wall Quay/ East Wall Road/ Eastlink Bridge at The Point.

Executive Manager,
Planning Department,
Dublin City Council,
Block 4, Floor 3 Civic Offices,
Wood Quay,
Dublin

A chara,

I live in Howth and work in Ringsend; this is my route to work. As Councillor for Howth/ Malahide ward on Fingal County Council I also represent constituents who use this route on a daily basis.  We have an excellent coastal cycle route as far as East Point Business Park at which point the journey becomes a lot more difficult.

The scheme objectives set out in the report fail to address cyclists’ and pedestrians’ needs for safe and convenient road design and the proposal fails to adequately provide for pedestrians and cyclists as a result.

The most significant element of this is the routing of cyclists through waiting bus passengers and alighting bus passengers on each side of East Wall Road.

There are significant bus passenger numbers at this location as it is an interchange between Luas and bus services through the Port Tunnel, as well as being in the vicinity of employment and the Point Depot theatre. Buses stopping here include Swords Express, Aircoach, Airlink 747, 33x, 33d, 142, 151. The result is a high frequency of buses stopping and significant bus passenger use of the area.

However, it seems that no passenger count data has been gathered in advance of the design, or even calculations of the total frequency of buses at the bus stops in question. Traffic counts are described in the report but they appear not to include pedestrians or cyclists.

At the moment, southbound buses stop at the bus stop on East Wall Road (the one which is proposed to be retained as is). Due to the nature of the bus service, there are almost no passengers boarding here. The buses stop to allow passengers to alight. As some buses are coming from the airport, many passengers have luggage and many are in the area for the first time. There is no gap between the stopped bus and the cycle lane and the potential for conflict is obvious.

At the moment northbound cyclists either stay on the carriageway or travel across the plaza to join up with the unmarked cycle track at the junction with Sheriff Street. Bus passengers wait at the minor forest of bus signs for northbound buses. At rush hours there are normally quite a few people waiting. Before and after an event at the Point Depot, there are large crowds of pedestrians in the area.

The proposal to retain the conflict between cyclists and bus passengers on the southbound side of East Wall Road and create a similar situation on the northbound side of East Wall road is directly contrary to the guidance in the National Cycle Manual.

That guidance recommends:

• Establish likely bus patronage profile at stop in advance of design choice
• Not suitable for dense pedestrian / passenger activity

There is no indication that the likely bus patronage profile has been identified.

This is an area of dense pedestrian/passenger activity and therefore this option is not suitable.

Point Roundabout Junction

The replacement of this roundabout with a signalised junction is welcome. However, the junction design will keep the speeds of turning traffic high, fails to prioritise pedestrians and cyclists. A junction taking less space providing direct pedestrian crossings and tighter corners would be far safer.

East Link Bridge

The Eastlink bridge has been excluded from this design. This is very unfortunate. Clearly the original design of this bridge did not take into account the needs of pedestrians and cyclists. Numbers of pedestrians and cyclists using this route have increased significantly in recent years and the current highly unsatisfactory situation needs to be addressed.

The design itself is not clear on how southbound and eastbound cyclists are expected to access the East link Bridge; it seems to be directing them onto the footpath, which would be illegal. Is this the intention?

North Wall Quay

The report states that there is a two-way cycle track on the south side of North Wall Quay. It is reassuring to learn this as the road layout is confusing. It would help greatly if sections such as the one in this photo were clarified. The road markings seem to suggest westbound cyclists on the left of the cycle track should move right to be on the left of the carriageway and then back to the left of the cycle track across the path of eastbound cyclists who seem to have nowhere to go.

The proposed layout where cyclists coming off the bridge turning west will pass the end of the shared surface to join a cycle lane and then immediately turn left to cross the cycle track seems unnecessarily complicated; in addition the turning radius seems too short.

My response to Fingal County Council’s consultation on Open Space Strategy focussed on sustainability, especially reducing pesticide use in parks and open spaces.

We have an entirely unnecessary habit of spraying herbicide at the base of every tree, hedge, fence and wall and I am proposing that this ends. Whether by alternative planting or by allowing Nature a bit of room, other places manage their trees without toxic chemicals. I included some photos of these as examples.

Zürich

Houten, near Utrecht

Utrecht

Houten, near Utrecht

Yesterday’s meeting of the Eastern and Midland Regional Assembly unanimously agreed to an emergency motion I submitted with Cllrs. Francis Duffy (Green, South Dublin) and Pádrag McEvoy (Ind., Kildare):

​*​ ​​http://www.independent.ie/irish-news/politics/underground-dart-plan-sacrificed-for-other-capital-projects-31509205.html; http://www.irishtimes.com/business/transport-and-tourism/government-abandons-dart-underground-project-1.2344211

I was questioned by one other member as to whether I thought the Dart Underground was more important than the airport link; I replied that it was, and that I thought this was objectively recognised by most people, including, in 2010, the current Transport Minister, then an opposition spokesperson:
“The Dublin Underground DART is needed more than any other Dublin Transport 21 project as it will connect many of our existing services and stations throughout Dublin. Such integration is a vital part of Transport 21 as it will help us make better use of what we already have.” http://paschaldonohoe.ie/iarnrod-eireann-humiliates-minister-dempsey-fails-to-come-clean-on-dublin-underground-dart-delay/

Observation on Planning application F15A/0362

A chairde,

I would like to make the following comments on the above application.

1​. Material contravention of Development Plan

​The application is a material contravention of the County Development Plan in three significant respects.

a) The Plan, in Local Objective 513 provides for a mixed use development on the site, which has an urban centre zoning. This development is not a mixed use urban development but a residential development with a few shops. It could be argued that a big expansion in retail space is not required in Howth and this is correct. The mixed use does not need to be primarily extra retail.

There is a clear need in Howth, with its major tourism businesses and stunning natural environment, for hotel accommodation. The inclusion of a significant hotel would make this a mixed use development and comply both with Local Objective 513 and with objectives in the plan for local economic development, especially tourism.

b) The height proposed is in contravention of Local Objective 512 which limits heights to between 3 and 5 stories, specifying that not more than 30% of the development can be 5 stories high.

c) The location proposed for Traveller accommodation is not that identified in the County Development Plan; instead the Traveller accommodation is proposed to be located on the public park which is zoned for open space and recreational amenities.

Please note that while much of the content of the Howth Urban Centre Strategy is of course good, the document cannot be relied on in the same way as a County Development Plan or a Local Area Plan. For some reason it has not been presented to the Councillors for adoption as a Local Area Plan would be but is simply a piece of research by the Council. It cannot be relied on to alter or interpret the County Development Plan.

2. Wrong location and lack of plan for community centre

The proposed Community Centre is in the furthest part of the site from the developed urban area of Howth and the Railway Station. Community facilities such as this must be sited to facilitate public access. Even more fundamentally, there is no plan in place to finance the construction or the operation of such a centre. It would not be acceptable to grant an integrated planning permission in the absence of a sincere intention on the part of the developer to implement the entire permission as required by planning law.

In relation to the identification of this site in the Urban Centre Strategy (UCS) as a suitable site for the community centre, as I mentioned above, the UCS has no legal standing. The opposition of many of the local councillors, including myself, to the identification of this distant part of the site for the community centre in the UCS may have been one of the reasons that Council management did not propose it for consideration as a Local Area Plan as I asked them to do in 2008.

The community centre proposed in the application seems to be a simple box not designed for any particular purposes and visually not contributing to the local environment.

I urge you to seek further information on the proposed community centre, its uses and management.

3. The development will have an unacceptable impact on traffic levels in Howth and all steps should be taken to minimise this impact

The Howth peninsula does not have the capacity to accept increased traffic which would be generated by the development as proposed. One logical response to this is to develop this area as a ‘car-free neighbourhood’, excluding motor vehicles from the area (except for necessary deliveries), providing for a small multistorey carpark on the edge of the development which any residents with cars would have to use and designing the area to take advantage of the space and quality environment thus enabled. This is a practical option for the Techrete site because the it is right beside the railway station and within walking distance of many other local facilities. Experience with similar developments elsewhere such as Vauban in Freiburg, Germany¹ shows that such developments will attract people eager to benefit from living in an neighbourhood without cars and that the rate of ownership of cars (kept in the multi-storey car park) can be around 30% of households.

4. Views out to sea

The development should provide for three or four wide gaps in the buildings which would enable views from the public road to the sea and Ireland’s Eye; this is not the case at the moment with a development which is oriented east-west, blocking the views.

5. Bridge to beach

The first redevelopment planning application on the site, which was correctly refused for being an overdevelopment provided for a pedestrian bridge over the railway to access Claremont Strand. The benefits of this for residents and the general public are evident and it should be integrated into this or any other proposal for this site.

6. Sustainable heating system

The EIS is unclear as to what the heating system is, saying various features “can be incorporated” including district heating (3.6.1). However, the application seems to include individual chimneys and it is not clear where a district heating boiler would be located. The development should be required to meet high levels of thermal efficiency and hot water/heating should be provided by a district system for the entire development based on solar hot water and a district heating boiler.

Regards,

Cllr. David Healy

The deadline for objecting to the EPA against Dublin Port’s application to dump 10 million tonnes of dredge spoil just inside the Burford Bank is 30th August.

The proposal would cloud the water in the Bay throughout the 6 years dredging would continue for, and increase the siltation of Sutton Creek. My objection is here.

The easiest way to submit an objection is via the Uplift campaigning website.

You can also object by email to licensing@epa.ie and view the full application on the EPA website.

More information on the campaign against the application is in the recent coverage in the Herald. Credit is due to FG rep Stephanie Regan for organising the public meeting reported on in the article and and to Clontarf Green rep Donna Cooney for her longstanding work including participating in the Bord Pleanála oral hearing into the port proposal.

Letter from Ministers Kelly and Coffey to Fingal County Council

Drop  in to Howth Yacht Club between 4pm and 7pm on Wed 17th.

Fingal County Council are hosting a stakeholder and public consultation meeting to obtain views and other important information in relation to flooding on the Howth peninsula. The area of interest extends to the entire peninsula of Howth and includes flooding arising from storm water drains and streams.

Relevant stakeholders and members of the public are invited to attend to make their views known and to discuss issues. The design team (Byrne Looby PH McCarthy) will be on hand along with relevant representatives of Fingal County Council. All comments received will be considered in the development of possible flood mitigation measures.

Howth FRS – PCM notice board ad_v0

We are canvassing for a YES vote with these leaflets:

Gaeilge English

Please vote YES on Friday 22nd!

Sustainable Development

The approach in the consultation document which envisages putting sustainable development at core of plan is very welcome. It is excellent that the plan is being developed by a process of policy analysis; this should integrate strategic environmental assessment from the start.

Public Health

The process of policy analysis building on environmental sustainability needs to fully include public health considerations. Health is briefly mentioned in the context of parks/green infrastructure in the consultation paper and there is some welcome discussion in the transport working paper. The analysis needs to go further and a Healthy Fingal should be a central goal of the Plan. Some years ago a major “Healthy Cities” project was run in Dublin; there must be lessons from that which can be incorporated in the plan. The Institute of Public Health in Ireland has also produced guidance on public health in the planning process.

Climate Change

The emphasis on climate change is strong which is appropriate and welcome. There is an understanding expressed in the working paper suggesting that adaptation is highly relevant to local government whereas mitigation isn’t fully relevant. This is not entirely accurate.

Climate Change Mitigation and Local Economy

Climate change mitigation requires fundamental changes to many areas of society and economy and local government faces this challenge in every area of its activity. Additionally, the local economy and local enterprise roles which Fingal and other local authorities are taking on needs to be integrated with the transition to a low-carbon economy and the opportunities presented by the green economy.

Learning from best practice on Climate Change

The Intergovernmental Panel on Climate Change (IPCC) provides a comprehensive overview of many areas of research relating to climate change including research on adaptation and mitigation and is an essential resource in developing local strategies to prevent and respond to climate change. Working Group II of the IPCC’s Fifth Assessment Report deals with Impacts, Adaptation and Vulnerability[1] and Working Group III deals with Mitigation[2]. In particular, the chapters on Energy Systems, Transport, Buildings, Industry, Human Settlements, Infrastructure and Spatial Planning, and National and Sub-national Policies and Institutions will be relevant to Fingal’s Development Plan.

Fingal should engage in the international cooperation of local authorities facing the challenge of climate change mitigation and adaptation, such as by joining the Covenant of Mayors referred to in the climate working paper, the International Council on Local Environmental Initiatives, etc.

Climate Change and Green Infrastructure

Fingal has already demonstrated itself a to be leader in thinking about green infrastructure and local biodiversity. Green infrastructure and the climate change mitigation and adaptation are intimately related. This is detailed in a report “Ireland’s Biodiversity: Our natural ally in the fight against climate change” from the Irish Environmental Network[3]. Aspects of particular relevance to Fingal include the consideration of climate mitigation and adaptation in coastal zone management.

Walkability

The first objective of transport as well as of spatial planning should be to create walkability. Too often high density is assumed to automatically create walkable communities. Impermeable layouts destroy walkability despite favourable densities. Street and road designs which are hostile, unsafe and unpleasant for pedestrians do the same. So walkability needs to be the first stated goal for both transport and spatial planning.

Cycling

The Development plan should incorporate Greater Dublin Area Cycle Network Plan and set out a timescale for delivery.  It should also commit to high quality road and street design to promote and facilitate cycling, learning from best practice elsewhere.

Parking

The Transportation and Movement issues paper fails to consider parking, long recognised as a key issue in generating car-oriented environments and reducing proximity.

Energy

The inclusion of an Energy working paper is very welcome, acknowledging the nature of the challenge for energy transition which we face. The recognition in the working paper of our renewable energy past (wind; tidal power also deserves a mention) is a good reminder worth carrying into the Plan itself.

Energy Efficiency

In considering energy in the Plan, the primary importance of energy efficiency should be emphasised. The suggestion in the working paper of requiring passive house or similar standards where appropriate is excellent and should be developed in the draft Plan.

Most of Fingal’s existing housing stock, unfortunately is not energy efficient. The Plan should consider what Fingal can do, directly and indirectly, to bring the existing housing stock up to much higher standards of energy demand and ventilation. This would bring about great benefits in improving public health, addressing fuel poverty and social inclusion and reducing energy demand and associated emissions.

Renewable Energy

All forms of renewables including solar water heating and photovoltaics should be considered in the plan. In developing the plan, the Council should look at experience in Ireland and elsewhere in mandating renewable energy, e.g. the requirement for solar water heating[4]. The examination should consider what are the most effective and cost-effective means currently for using renewables to meet energy needs and how the Development Plan can promote the necessary changes. The recognition that the Plan needs to support innovation in the transition to sustainable energy is very welcome; the same openness to innovation should also be reflected in other areas of the plan including water and wastewater management.

Coastal erosion

The development plan needs to reflect a considered approach to addressing coastal erosion, identifying principles for prioritisation of resources and balancing of competing objectives taking account of all costs and benefits of various options.

Use of green belts

Green belts have been a central element of spatial planning in Fingal and have been very successful in ensuring credible development boundaries. However while correctly excluding a wide range of development uses, the Council has not always identified positive uses for greenbelt land. In some instances, such as between Portmarnock and Malahide and, to a lesser degree, between Baldoyle and Portmarnock, this has been done, with great success. The Plan, recognising their importance, should consider the best use for all green belts including meeting green infrastructure objectives, meeting demand for allotments and parkland, providing for local bioenergy, and performing a range of ecosystem functions.

Sustainable building

The recognition in the Energy working paper of the value of zero-carbon or low energy building standards such as Passive House standard is very welcome.

Other important elements of sustainable building should also be reflected in the plan.

The embodied carbon of buildings as well as the other impacts of buildings in terms of material sustainability of construction should be addressed.

Similarly design for adaptive re-use and for deconstruction and reuse/recycling should also be driven by the plan.

Policies such as adopted in many cities which require green roofs or solar roofs should be examined.[5]

Water and waste water management – surface water, rainwater, separated waste water

Although water supply and waste water treatment policy is unfortunately now handled by Irish Water, Fingal retains important functions.

Surface water management has reflected a ‘Sustainable Urban Drainage’ approach for some time now. However, although the possibilities for integrating SUDS and green infrastructure have been recognised by the Council, they are rare in practice and should be driven through the development plan and planning consent processes.

In approving developments, Fingal should drive the use of rainwater harvesting.

Similarly Fingal should be open to innovative approaches to waste water including separation of different streams (grey water, urine, black water) in particular with a view to reducing the environmental impact of treatment and the potential for nutrient recovery. In approving large developments where separate streams would currently be mixed, consideration should be given to ensuring they are capable of being retrofitted in future for separation.

New developments

Fingal can learn a lot from experiences, positive and negative, of large scale developments in recent years.  The Plan should reflect the commitment which the Council has to making all residential and mixed use developments work, including multi-unit developments and should empower the Council to take a pro-active role to resolve difficulties.

Developments must provide for mixture of unit sizes so that a range of household types can live in an area and that people are not obliged to move away just to find housing adapted to their household size and makeup.

Finally, three areas where the Development Plan must be informed by learning from our mistakes.

Phasing of development

The bursting of the property bubble was accompanied by a realisation that phasing of development had been allowed without accounting for the possibility that it could be interrupted, leaving essential elements of infrastructure missing. Fortunately many parts of Fingal were not as badly situated as parts of other local authorities. Nonetheless there were and remain significant and severe problems due to the abandonment of originally phased developments.

The Plan must set out a clear policy which will ensure that interruption of development will not leave the citizens of Fingal as a whole or residents of new developments in particular without facilities and amenities which the planning system and Development Plan have identified as essential.

Clarity

The plan needs to be vetted for clarity. Ambiguous terms must be avoided. Novel terms must be defined. The previous Plan contained objectives for “integrated tourism and leisure complex[es]”, something which was never defined in the Plan. It was quite a shock for those familiar with this objective and especially the Councillors who had agreed to its inclusion in the Plan when Fingal granted a planning application predicated on an interpretation that a hotel met the definition of an “integrated tourism and leisure complex”. Fortunately the first such permission was reversed by An Bord Pleanála following an appeal by local councillors. Unfortunately the second such interpretation at a different site was not appealed.

In order to avoid this sort of scenario, clear and unambiguous terms must be used, and definitions (consistent with ordinary usage) should be provided for the avoidance of doubt.

Enforcement

The Plan should set out an enforcement policy. Unfortunately the experience of many Fingal residents is that the Council is unwilling to enforce planning rules in many instances. Many residents find themselves doing the Council’s job in taking action to get planning laws enforced and this is not good enough.

Cllr. David Healy

15^th May 2015

54, Páirc Éabhóra, Beann Éadair

087 6178852

www.davidhealy.com