{"id":998,"date":"2018-06-30T16:51:52","date_gmt":"2018-06-30T16:51:52","guid":{"rendered":"http:\/\/davidhealy.dublin13.com\/?p=998"},"modified":"2020-01-18T20:29:09","modified_gmt":"2020-01-18T20:29:09","slug":"submission-to-an-bord-pleanala-re-baily-court-edros-application","status":"publish","type":"post","link":"https:\/\/davidhealy.com\/?p=998","title":{"rendered":"Submission to an Bord Plean\u00e1la re Baily Court \/ Edros application"},"content":{"rendered":"
<\/div>\n

Strategic Housing Development Section
\nAn Bord Plean\u00e1la
\n64 Marlborough St.
\nDublin D01 V902<\/p>\n

Re: Case reference: PL06F.300879<\/p>\n

Planning Application Reference
\n300879-18<\/a>: Former Baily Court Hotel, Main Street and lands located
\nsouth of the Martello Tower on Balscadden Road, Howth, Co. Dublin
\n(Edros site)<\/p>\n

A chairde,<\/p>\n

I refer to the above development and would like to make the following observations:<\/p>\n

1. SHD process is not compliant with the Aarhus Convention<\/p>\n

The decision-making process in the Strategic Housing Development
\ncategory is contrary to the Aarhus Convention, in particular as it
\nfails to meet the requirement of Article 6(4) to “provide for early
\npublic participation, when all options are open and effective public
\nparticipation can take place.\u201d<\/p>\n

\u200bThe\u200b process established for Strategic Housing Developments ends up,
\nas in this instance, pre-determining and pre-deciding choices and
\ndecisions about many elements of the development before any public
\nparticipation happens. That this is so is evident from the record in
\nthe planning file of pre-application discussions with both Fingal
\nCounty Council and An Bord Plean\u00e1la. The fact that there is no appeal
\nfrom this decision makes this failing considerably more significant
\nfrom the point of view of the public\u2019s ability to have an impact on
\nthe final decision and the quality of the decision-making process.<\/p>\n<\/div>\n

\n

<\/p>\n

2. Need for Environmental Impact Assessment and oral hearing<\/p>\n

The development is in an important, difficult and complex site from a
\nrange of perspectives. It is in an important location in a heritage
\ntown, beside a national monument (the Martello Tower on the site of
\nthe Norman castle, a location chosen for its natural visual
\nprominence), partly within an Architectural Conservation Area, on a
\nsteep sand ridge with a history of instability and landslides, in one
\nof the busiest tourism destinations in Dublin, with difficult
\nconstruction access. Given the potential for negative consequences and
\nthe complexity of the interaction of the above factors, it should be
\nsubject to Environmental Impact Assessment.<\/p>\n

Local residents adjacent to the site, and the wider community, have
\nprofound and valid concerns as to the risks the proposed excavation,
\nconstruction, and associated truck movements could pose to
\nneighbouring buildings and the public road. The application documents
\ndo not adequately address these risks. In these circumstances,  there
\nshould be a public oral hearing into the proposal.  Additionally the
\nBoard should ensure that it deploys the relevant expertise to address
\nthis aspect of the proposed development.<\/p>\n

3. Geology, hydrogeology, civil engineering and access<\/p>\n

You will have received detailed evidence in other submissions of the
\nhistory of landslides in the vicinity and the overall difficulty of
\ndeveloping on the sandy ground. This causes great concern to local
\nresidents, both those living immediately around the site and the rest
\nof us, given the threat to adjacent houses, to the adjacent road, and
\nto the Martello tower. It is vital that the Board ensures that the
\nproposed development can be built safely and will not interfere with
\ngroundwater movement in a manner which would destabilise the sandy
\nground on or off site.<\/p>\n

The proposal to use Balscadden Road as a construction access is very
\nworrying. Balscadden Road is a busy pedestrian route, giving access to
\nthe Howth Cliff Path looped walks, visited by over 250,000 walkers a
\nyear. A visit to the Road will demonstrate its importance for
\npedestrians. Sand regularly falls onto the road from Tower Hill. The
\ndeveloper has stated that they propose 30 to 35 trucks a day for 6
\nmonths to remove the sand plus a few years of construction access
\nalong Balscadden Road. This risks destabilising the road and Tower
\nHill as well as the Asgard Apartments.<\/p>\n

4. Visual and landscape impacts<\/p>\n

The visual aspect of the development is a major concern. Subject to
\nthe construction and ground stability problems mentioned above, it is
\nwelcome that the development proposes to lower the ground level in
\norder to reduce the visual impact. I’m concerned that the
\nphotomontages may not accurately reflect the visual impact of the
\ndevelopment and I would ask the Board to verify their accuracy. I have
\nasked the developer to put poles on site indicating the intended
\nbuilding heights. If they have not yet done so when the Board’s
\nInspector comes to read this, I recommend that the Board request that
\nthis be done to enable it and the public to estimate the nature of the
\nlikely visual impact.<\/p>\n

The most concerning visual elements are the impact on the view from
\nTower Hill, the impact on the context for the Martello Tower, and the
\nimpact on the view for people walking on Balscadden Road.<\/p>\n

5. Scaling back to meet Public Open Space requirements and reduce visual impact<\/p>\n

The development is objectively oversized as it fails to provide
\nsufficient Public Open Space to meet the County Development Plan
\nrequirements. Reductions in height or setting back of elements of the
\nproposed development in order to bring the accommodation in line with
\nthe open space provision should occur at the locations above which
\nwould reduce its visual impact.<\/p>\n

6. New pedestrian street and opportunity for a view out to sea<\/p>\n

The provision of a pedestrian street from Main Street to Balscadden
\nRoad is a very welcome element of the proposal. This new street should
\nbe aligned so that there is a view, even just a glimpse of the sea
\ndown the new street from some point on Main Street. With the varying
\nheights on Main Street this must be possible if the correct analysis
\nis done to align the road accordingly.<\/p>\n

7. Loss of Baily Court Hotel and development incompatible with
\nArchitectural Conservation Area<\/p>\n

The Baily Court Hotel, one of the oldest and most prominent buildings
\nin the Howth Architectural Conservation Area has been subject \u200bto a
\ndecade of neglect and dereliction.  Permission is being sought to
\ndemolish the building on the basis that it is no \u200blonger in good
\ncondition and that it\u2019s architectural heritage value has been
\ndiminished. It would be bad public policy to reward dereliction by
\napproving this element of the application.<\/p>\n

The building proposed to replace the hotel building makes no attempt
\nto fit into the Architectural Conservation Area. It presents a gable
\nend to the street, in a manner inconsistent with the street. The two
\nbuildings on either side, more modern than most of the buildings, have
\nhipped roofs. It proposes to have asymmetrical windows, unlike almost
\nevery building on the street, and is of an overbearing scale.<\/p>\n

8. Layout of buildings at west end of new pedestrian street and Main Street<\/p>\n

The proposed layout of buildings at Main St. is hard to understand. It
\nis proposed to put a new large building on the Baily Court Hotel site
\nwith a pedestrian area behind it, cut off by the way the building juts
\nout. The layout in front of this building doesn’t prioritise the
\npedestrian route up and down Main St. The way this new development
\ninteracts with Main Street is a vital element of the design, which
\nreally doesn’t seem to have been worked out at all. Even the
\nphotomontage of this location differs significantly from the landscape
\ndrawings (which is one of the factors giving rise to my concern
\nmentioned under 4. above.)<\/p>\n

9. Mixed use development should include a hotel<\/p>\n

In this area of high tourism demand which lost significant hotel
\naccommodation over the last decade, in a town centre zoning, the
\ndevelopment should include a hotel to replace the derelict hotel on
\nthe site.<\/p>\n

I hope the above is of benefit to the Board in considering this
\napplication and that the local community and neighbours of the site
\nwill have the opportunity to engage with this application at an oral
\nhearing.<\/p>\n

Best regards,<\/p>\n

Cllr. David Healy<\/p>\n

+353 87 6178852<\/a>
\n54, P\u00e1irc \u00c9abh\u00f3ra,
\nBeann \u00c9adair,
\nCo. Bh.\u00c1.C.<\/p>\n<\/div>\n

 <\/p>\n","protected":false},"excerpt":{"rendered":"

Strategic Housing Development Section An Bord Plean\u00e1la 64 Marlborough St. Dublin D01 V902 Re: Case reference: PL06F.300879 Planning Application Reference 300879-18: Former Baily Court Hotel, Main Street and lands located south of the Martello Tower on Balscadden Road, Howth, Co. Dublin (Edros site) A chairde, I refer to the above development and would like to […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":[],"categories":[60,59],"tags":[],"_links":{"self":[{"href":"https:\/\/davidhealy.com\/index.php?rest_route=\/wp\/v2\/posts\/998"}],"collection":[{"href":"https:\/\/davidhealy.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/davidhealy.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/davidhealy.com\/index.php?rest_route=\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/davidhealy.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=998"}],"version-history":[{"count":2,"href":"https:\/\/davidhealy.com\/index.php?rest_route=\/wp\/v2\/posts\/998\/revisions"}],"predecessor-version":[{"id":1090,"href":"https:\/\/davidhealy.com\/index.php?rest_route=\/wp\/v2\/posts\/998\/revisions\/1090"}],"wp:attachment":[{"href":"https:\/\/davidhealy.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=998"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/davidhealy.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=998"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/davidhealy.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=998"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}