Howth Green Party Councillor David Healy congratulated all those
responsible for Howth being recognised as the cleanest town in
Ireland.  Cllr. Healy commented:  "The change in the appearance of
Howth over the last few years has been remarkable.  Previously litter
was a serious problem in Howth. Now the natural beauty of the area is
matched by a clean environment.  In particular I want to thank the
cleaning staff from Fingal County Council. The extended cleaning
service over the last few years is the key to Howth’s achievements. 
But there has been a virtuous cycle: residents and visitors to Howth
alike have kept the area much cleaner.

"Local businesses have
played an important role.  The local primary school Scoil Mhuire and
it’s Principal John Chambers deserve particular mention.  The
green-flagged school is putting environmental responsibilty at the core
of it’s teaching and it’s grounds were singled out for special mention
by the assessors."

Further info: David Healy 087 617 8852

Press release by Irish Business Against Litter  http://www.ibal.ie/press_releases/2009/PressRelease(1).pdf

Discovering Historic Fingal, a free guide to built heritage, has been published by Fingal County Council. PRESS RELEASE

ENDS 15/12/08

An exhibition has gone on display in the Tourist Office on the West Pier on the history of the re-building of the Harbour as a mail packet station between 1808-1818.
 
The exhibition was originally put on display at County Hall, Swords, during Heritage Week, but Colm McQuinn, the County Archivist, was determined that we would find a supervised venue for it somewhere in Howth, which he have finally managed to do with the help of Mr. Sean Doran.
 
The exhibition will be on view until some time in January at least.

My motion seeking to amend the County Development Plan was defeated by a majority of the Council.  It was seconded by Labour Cllr. Peter Coyle and supported by my Green colleague Cllr. Robbie Kelly.  Fine Gael and Fianna  Fáil councillors together with some Labour councillors united to defeat it.

That the following Variation to the County Development Plan be put on display:

Insert the following policy and objective into the Development Plan, renumbering existing policies and objectives

"Policy TP16 To protect the residential amenity of areas affected or potentially affected by aviation noise"

"Objective TO20  To restrict the use of the airport by night flights
primarily to emergency situations in order to protect residents from
night-time noise and sleep disruption."

A report on the meeting is here: http://www.herald.ie/national-news/city-news/no-respite-for-dubliners-losing-sleep-as-proposal-to-ban-night-flights-is-defeated-1533248.html

As a result of my motion to the Area Cttee., Fingal County Council have referred the question of the planning status of Howth Junction station to An Bord Pleanála.  I made a submission to the Board in relation to it today.  I have also put a copy of the referral below.

        
An Bord Pleanála,
Marlborough St.,
Dublin 1.

Re: Section 5 referral RL2580, Howth Junction railway station

A chairde,

I refer to the above reference and wish to make the following points:

Fingal County Council’s Planning Department formed the opinion that “Class 23 … clearly exempts works carried out within the grounds of [a] railway station.”

In fact the exemption under Class 23(a) of the clearly refers not to works within the grounds of a railway station, but to works “wholly within the interior of a railway station.”

The only logical construction that can be put on the reference to the interior of a railway station is that the reference to a railway station is to the building in question, as there it makes so sense to refer to the interior of a piece of land.  Therefore what is described as the construction of a new station cannot be exempted on this basis.

For the record I am particularly concerned and unhappy about the development as built for two reasons:
•    The blocking off of wheelchair/mobility impaired access to the station from the Fás centre and Baldoyle Industrial Estate (notwithstanding the conditions of Dublin City Council’s permission 2089/03)
•    The very poor environment offered by the station to all those using it.

I enclose the required €50 fee.

Regards,

David Healy

Referral from Fingal Co. Co.

6th October, 2008
 
 
An Bord Pleanála,
Marlborough Street,
Dublin 1.
 
 
      Re: Referral pursuant to Section 5 of the Planning and Development Act, 2000.

____________________________________________
 
 

 
Dear Sir/Madam,

A planning application was made to Dublin City Council by Iarnród Éireann on 7th May, 2003 for development and upgrading works at Howth Junction DART Station, off St. Donagh’s Road, Kilbarrack, Dublin 5. The works consist of the construction of a new DART station, approximately 8.5m in height, linked with a new footbridge providing stair and new lift access; the upgrading of the access road including the provision of a drop-off area; the upgrading of footpaths; and ancillary works including landscaping and planting.  Permission was granted by Dublin City Council on 10th December, 2003.  

In 2004 a further planning application was made seeking planning permission for modifications to a previously approved but un-built development at Howth Junction DART Station, off St Donagh’s Road, Donaghmede, Dublin 13 (Dublin City Council Register Reference 2089/03). These works consist of the construction of a new DART Station, approximately 16.7m in height with a new foot-bridge (approximately 21.1m in height) providing stair and lift access; the upgrading of the access road including the provision of a drop-off area; the upgrading of footpaths; and ancilalry works including landscaping and planting. This materially differs from the previously approved development with modifications including the revised design of the Station building (including reduction in overall floor area from 658 sq.m. to 604 sq.m and revised elevations); revised location of the building on the site (the building has been moved further southwest on the site); the omission of features including a retail unit and previously proposed canopies outside the station; and the revised alignment of the access road and pathways.  Permission was granted by Dublin City Council on 16th February, 2004.

The redevelopment works were carried out by Iarnród Éireann and a subsequent complaint was received in Fingal County Council relating to the carrying out of these works in the Fingal area.  No planning application was made to Fingal County Council for the works despite the fact that the Dublin/Belfast Railway Line is the boundary between Dublin City Council and Fingal County Council administrative areas and the redevelopment of the railway station included land in both areas.

Enforcement proceedings were served on Iarnród Éireann by Fingal County Council and a subsequent meeting was held with their Senior Architect, Operational Manager and legal advisor and the Enforcement Section of Fingal County Council.  Iarnród Éireann advised that the works carried out were exempted development pursuant to Class 23 of the Planning and Development Regulations 2001 in that the new works were carried out within the boundary of the existing station.  It was stated that an application for planning permission was made to Dublin City Council as the works on the Dublin City side necessitated acquisition of further land from Dublin City Council for the new station and were therefore not exempted development.  All works, it was said, carried out on the Fingal side were within the boundaries of the old station and were therefore exempted development.

At a meeting of the Howth/Malahide Area Committee on 17th April, 2008 the following motion was proposed:

"That the Manager make a section 5 reference to An Bord Pleanála in relation to the planning status of Howth Junction railway station."

The following reply issued by the Manager:

“A letter was issued to Iarnród Éireann relating to their failure to seek planning permission for the works carried out at Howth Junction Railway Station.

A Warning Letter under Section 152(1) of the Planning and Development Act 2000 was issued on 19/9/06.  This letter allows a period of four weeks for submissions or observations to be lodged by the person served.

An Enforcement Notice issued on 8/12/06 requiring the situation to be regularised.

A meeting was held on 19/9/07 with Iarnród Éireann.   They stated that the works carried out were exempted development under Class 23 (a) of the Planning and Development Regulations 2001: –

CLASS 23

“The carrying out by any railway undertaking of development required in connection with the movement of traffic by rail in, on, over or under the operational land of the undertaking, except –

the construction or erection of any railway station or bridge, or of any residential structure, office or structure to be used for manufacturing or repairing work, which is not situated wholly within the interior of a railway station”.

They stated that the works carried out are within the boundary of the existing station.  They stated that Iarnród Éireann applied for planning permission to Dublin City Council as the works on their side necessitated acquisition of further land from Dublin City Council for the new station and were therefore not exempt.  All works carried out on the Fingal side were within the boundary of the Old Station and are considered exempt.

The Planning Authority has accepted that the works carried out are exempt.

Section 5 (4) of the Planning and Development Act 2000 provides that a –

‘Planning Authority may refer any question as to what in any particular case is or is not exempted development to be decided by An Bord Pleanála’.

The Planning Department is satisfied that the works carried out are exempted development under Class 23 which clearly exempts works carried out within the grounds of the railway station.

It is not considered necessary, therefore to request a ruling on this matter from An Bord Pleanála.”

Following consideration of the report the motion was passed and accordingly, I request that An Bord Pleanála make a decision on this referral under Section 5 of the Planning and Development Act, 2000 as to whether works carried out in the administrative area of Fingal County Council by Iarnród Éireann are exempted development, i.e. are the works carried out on lands owned by Iarnród Éireann works “situated wholly within the interior of a railway station”.

The appropriate fee of €220 is enclosed.  Also, while no drawings were submitted to Fingal County Council I enclose indicative drawings circulated to local Councillors by Iarnród Éireann in relation to the works carried out at Howth Junction Railway Station.

I look forward to your response in due course.

Yours sincerely,
 
 
 

__________________

Noeleen McHugh

Administrative Officer

I have objected to the proposed 8-storey buildings on the Techrete site.  The site has the potential to be a great contribution to Howth, but the current application is about twice the height it should be.

        
Planning Department,
Fingal County Council

Re: Techrete site application, F08A/1172

A chairde,

I refer to the above application and wish to state my opposition to the current proposal.

There are many welcome elements to the proposed application.  This is a good brownfield development site with the potential to house a major improvement to the area.  However, there are fundamental problems with the current application which mean it should be refused.

The EIS is inadequate in many respects but in particular in relation to overshadowing of the beach and promenade.

The appropriate building height for the site is about 4 stories, given the escarpment behind the site and the overshadowing impacts on the beach

Views from the Howth Road to the sea and Ireland’s Eye must be protected and new views created.  Although the photomontages are inadequate, it seems that the proposed development would not give sufficient good views through.

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.

I enclose the required €20 fee.  I also enclose a copy of my comments in relation to the Howth Urban Centre Strategy much of which is relevant to this application.

Regards,

Cllr. David Healy

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.

Process

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 (p.63.)

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 (p.68)

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 (6.3)

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 (p.95)

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
   9.
  10. Yes
  11.  
  12.  
  13.  
  14.  
  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
  20.  
  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?  
  30.

 
Appendix 1
 

Extract from County Council meeting 03 April 2008

Minutes HomeYear HomeCommittee HomeMeeting Home

COMHAIRLE CHONTAE FHINE GALL

FINGAL COUNTY COUNCIL

Minutes of Meeting of County Council held on

PRESENT  

An apology for inability to attend was received by:

The Councillor , presided.

PARKING RESTRICTIONS AT HOWTH DART STATION

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.

I have objected to the proposed Variation to the Fingal Development Plan to facilitate a road parallel to the Malahide Road and another parallel to the N32 road between Malahide Road and M1 motorway.

Senior Executive Officer,
Planning Department,
Fingal County Council,
Main St.,
Swords,
Co. Dublin.

Re: SEA on Variation to Development Plan – Malahide Road/ East-West Distributor Road

A chara,

As you know, in September 2008, the Council approved the following recommendation from the Howth/Malahide Area Cttee.:

      “That this Area Committee recommends that the Council direct the Manager to carry out a multi-modal transport study in relation to transport in the North Fringe/South Fringe area (Stapolin, Donaghmede, Balgriffin, Belcamp, Clonshaugh) with Dublin City Council’s co-operation if possible, to include consideration of the possibilities for a light rail link between the Dublin-Belfast railway line at Stapolin and the Metro in the vicinity of Ballymun/Dublin Airport and other possible rail links and to include consideration of roads, bus routes, cycling routes and walking routes in the area.”

This has not been done.

As you know, this proposed Variation has been put on display despite the opposition of the Howth Malahide Area Cttee.  The full Council were not notified of the proposed display.

As an elected representative I greatly resent being asked to make submissions in relation to a draft Variation which does not reflect the policy of the Council as agreed in 2006 and which is on display against the wishes of the local Area Cttte.

I attach below the submission I made to the last public consultation in relation to roads proposals in this area and which led me to proposing the above motion in relation to a multi-modal study.  Please also consider it to be part of this current submission.  (see http://davidhealy.com/index.php?option=com_content&task=view&id=144&Itemid=40)

In the time available and given other responsibilities, I have not had a chance to fully review the Environmental Report.  However, I have read through with an eye on two issues:

   1. Consideration of Alternatives
   2. Traffic and emissions impacts
   3. Piece-meal development
 

   1. Consideration of Alternatives.

No alternatives to car-oriented road design have been considered.  The alternatives such as a public transport only route which I brought forward for consideration in my 2006 submission (copy below) have been ignored.
 

      2. Traffic and emissions impacts

Although traffic modelling and predictions have been carried out, they are not presented in the Environmental Report.  This is an unacceptable omission.

I was informed in the previous consultation that all traffic predictions in the area are based on a maximum 50% car share of modal split, something which no similar suburban area in Dublin achieves, even those with quality rail / light rail serving the entire area.   

The textual comments in the document appear to assume that traffic levels are independent of the provision of infrastructure.  This is not the case.  For a good overview please see Litman, T., Generated Traffic and Induced Travel, Victoria Transport Policy Institute, http://www.vtpi.org/gentraf.pdf  

Similarly there are no emissions predictions in the Report.  It would appear that these haven’t been carried out.   It is quite straightforward to do outline emissions predictions based on traffic predictions.  This should have been done.   

I attach a report from an EPA-funded research project by FEASTA, the Foundation for the Economics of Sustainability which cover aspects of SEA in the wider context of a Sustainability Assessment process, also at http://www.feasta.org/documents/epa_transport/ . Please see the sections 1 on the assessment process and 2 on air and climate impacts in particular.

Induced traffic effects are of course of great consequence for emissions assessment.
 
 
      3. Incoherent and piecemeal planning

The draft Variation shows part of a route which from previous discussions I know to be part of a planned Baldoyle to Blanchardstown Road which the Council’s Roads Department is proposing.  The Environmental Report shows the East-West Distributor Road leading to a minor road in the vicinity of the Airport. This is not what is intended and is fundamentally misleading.  The two sections of this road proposal should be considered and assessed together.
 

Is mise, le meas,
 
 
Cllr. David Healy

I have objected to the proposed Variation to the County Development Plan to bring a major new road through lands west of Malahide Road and from there parallel to the M50 motorway.  I also included a copy of my previous submission in 2006 which was ignored.

The Council management continue with a roads-first planning policy and are continuing to marginalise pedestrians, cyclists and public transport users.  The result of course, is more traffic, more congestion and more noise and pollution.

Particularly shocking is the fact that the Manager is claiming the power to put a proposed variation to the Development Plan on public display, without Council approval and indeed, despite the opposition of 6 out of the 7 local councillors.  Of course, we as Councillors do not have the resources to mount a legal challenge to this.

13th October 2008
Senior Executive Officer,
Planning Department,
Fingal County Council,
Main St.,
Swords,
Co. Dublin.

Re: SEA on Variation to Development Plan – Malahide Road/ East-West Distributor Road

A chara,

As you know, in September 2008, the Council approved the following recommendation from the Howth/Malahide Area Cttee.:

“That this Area Committee recommends that the Council direct the Manager to carry out a multi-modal transport study in relation to transport in the North Fringe/South Fringe area (Stapolin, Donaghmede, Balgriffin, Belcamp, Clonshaugh) with Dublin City Council’s co-operation if possible, to include consideration of the possibilities for a light rail link between the Dublin-Belfast railway line at Stapolin and the Metro in the vicinity of Ballymun/Dublin Airport and other possible rail links and to include consideration of roads, bus routes, cycling routes and walking routes in the area.”

This has not been done.

As you know, this proposed Variation has been put on display despite the opposition of the Howth Malahide Area Cttee.  The full Council were not notified of the proposed display.

As an elected representative I greatly resent being asked to make submissions in relation to a draft Variation which does not reflect the policy of the Council as agreed in 2006 and which is on display against the wishes of the local Area Cttte.

I attach below the submission I made to the last public consultation in relation to roads proposals in this area and which led me to proposing the above motion in relation to a multi-modal study.  Please also consider it to be part of this current submission.

In the time available and given other responsibilities, I have not had a chance to fully review the Environmental Report.  However, I have read through with an eye on two issues:

1.    Consideration of Alternatives
2.    Traffic and emissions impacts
3.    Piece-meal development

1.    Consideration of Alternatives.

No alternatives to car-oriented road design have been considered.  The alternatives such as a public transport only route which I brought forward for consideration in my 2006 submission (copy below) have been ignored.

2. Traffic and emissions impacts

Although traffic modelling and predictions have been carried out, they are not presented in the Environmental Report.  This is an unacceptable omission.

I was informed in the previous consultation that all traffic predictions in the area are based on a maximum 50% car share of modal split, something which no similar suburban area in Dublin achieves, even those with quality rail / light rail serving the entire area.  

The textual comments in the document appear to assume that traffic levels are independent of the provision of infrastructure.  This is not the case.  For a good overview please see Litman, T., Generated Traffic and Induced Travel, Victoria Transport Policy Institute, http://www.vtpi.org/gentraf.pdf

Similarly there are no emissions predictions in the Report.  It would appear that these haven’t been carried out.   It is quite straightforward to do outline emissions predictions based on traffic predictions.  This should have been done.  

I attach two reports from an EPA-funded research project by FEASTA, the Foundation for the Economics of Sustainability which cover aspects of SEA in the wider context of a Sustainability Assessment process, also at http://www.feasta.org/documents/epa_transport/ . Please see the sections on air and climate impacts in particular.

Induced traffic effects are of course of great consequence for emissions assessment.

3. Incoherent and piecemeal planning

The draft Variation shows part of a route which from previous discussions I know to be part of a planned Baldoyle to Blanchardstown Road which the Council’s Roads Department is proposing.  The Environmental Report shows the East-West Distributor Road leading to a minor road in the vicinity of the Airport. This is not what is intended and is fundamentally misleading.  The two sections of this road proposal should be considered and assessed together.

Is mise, le meas,

Cllr. David Healy

Last night a group met in St. Columbanus Hall and formed a Friends of Balscadden Beach, aiming to restore this wonderful swimming beach to at least a degree of its former glory. It will be doing a clean-up on Saturday 11th October at 12noon.  It’s next meeting will be on 5th November at 8pm in St. Columbanus Hall, Main St., Howth.