To whom it may concern,
Please find below the submission from the Dublin West Green Party on the Draft Fingal County Council Development Plan 2011-2017. This document follows our initial submission to the first round of public consultation last year.
Yours sincerely,
Roderic O’Gorman
Green Party Representative, Dublin West
Summary of Key Points:
- Remove all references to the Castleknock Urban Centre Strategy
- Include a section on a Safe Routes to School Strategy
- Include a New Schools Strategy. This would set out a new means of identifying and securing sites for schools in areas where these are needed.
- Leave the zoning of the land along the N3 as it currently is – Green Belt.
- Amend Local Area Objective 537 to allow for a ¾ length 1 storey car park and associated landscaping works.
- Include a new Local Area Objective of a double pedestrian crossing at the Castleknock Road – Roselawn Road junction.
- Include a new Local Area Objective for Castleknock Village, stating that future development in Castleknock Village would be limited to three storeys.
- Include a new Local Area Objective for Hartstown Park, making provision for a scout den for Huntstown Scouts to be located there.
- Include a new Implementation Chapter, setting out clear targets in each of the areas that the Draft Plan covers. This will both allow a proper evaluation of the success or otherwise of the Council in putting the Development Plan into effect, but it will also meet the requirements of the legislation and statutory guidelines.
Detailed Points
Strategic Overview
Castleknock ‘Objectives’: There has been widespread dissatisfaction with the manner in which the Urban Centre Strategy or Castleknock Village was adopted, both as regards containing recommendations totally at varience with what residents suggested and the failure to allow a vote of elected councillors on the plan. In light of this, we call for the removal of all references to the Urban Centre Strategy from the Development Plan.
Green Infrastructure
We welcome this detailed section as innovative and a positive outcome from measures adopted by Fingal County Council, such as its ‘Green Infrastructure Conference’ to promote this aspect of planning.
Physical Intrastructure
Safe Routes to School
In our initial submission, we called for the Development Plan to commit Fingal County Council to initiating the introduction of a Safe-Routes to School scheme across the county. This has not made it into the Draft Plan and we would again recommend that this should form part of the Plan. We note that the Renewed Programme for Government of commits to the rolling out of a ‘Safe Routes to School’ strategy across the country by 2012. As such, Fingal should act now to be in the position to benefit from central funding to facilitate the roll out of the project.
In Fingal, such a Safe Routes to School strategy would involve bringing together parents, teachers, the Gardai and Council officials to plan a safe route to school strategy for each school. This would involve improving pedestrian crossings, cycle lanes and footpaths in the vicinity of schools as well as reducing speed limits and introducing a ban on heavy goods vehicles around school districts. A further element would be to ensure the provision of bike sheds in schools so students have a safe place to park their bicycles.
Urban Fingal
Schools
Fingal has suffered severely from the failure to adequately zone land for schools at primary and secondary level over the last 10 years. The Strategic Overview of the Draft Plan notes the very high percentage of young children in the county. This will have a significant impact on the need for new and larger schools over the period of the Draft Plan
Selecting School Sites – ‘New Schools Strategy’
Section 1.3 of the Strategic Policy Chapter emphasises at Point 17 the need for “timely provision of schools”. Similar sentiments are expressed in the Urban Fingal Chapter at Objective Cl18 which states “Reserve individual sites for primary & secondary schools in consultation with the Dept. Education …”.
We argue that as these provisions currently stand, they are too vague and run the risk of the same delays in obtaining sites for schools that have been experienced in the last five years. We would suggest that a New Schools Strategy needs to be devised, which will allow for enhanced communications between the Council, the Forward Planning Section of the Department of the Environment, Patron bodies and local communities. This New Schools Strategy should be given specific recognition in the Development Plan.
The first priority of the New Schools Strategy would be to identify if there is existing and planned capacity for the number of classrooms that the Forward Planning Section of the Department estimate will be needed across Fingal. In areas where there is a shortfall, measures must be taken immediately to remedy this situation.
As part of the New Schools Strategy, there needs to be consistency as to the zoning that is given to a site that is intended to be used as a school. All such sites should be zoned as Objective CI ‘Community Infrastructure’.
Zoning
We welcome the de-zoning of land out of the Residential Area category at the Castleknock College playing pitches and also the land between Mulhuddart and Tyrrelstown.
Zoning of land beside N3 between Ashtown and Little Chef
The zoning of this site has been at issue over a number of years. An effort was made to rezone it during the previous Development Plan process and there was an unsuccessful attempt to initiate a draft variation of the land in 2008. The current plan proposes changing the land from Green Space to High Technology.
We argue that at this time, the land in question should not be rezoned, but retained at its current zoning. We are concerned about the flooding implications that developing this piece of land could have for the N3, particularly in light of the fact it holds large amounts of rain water after heavy showers. Lack of similar absorbency zones resulted in the flooding of the N3 close to the Quinn Building last year.
We also believe that the site forms an important green break between the city at Ashtown and Castleknock/Blanchardstown. It also forms part of the wider Abbotstown greenbelt that Fingal County Council intend to develop over the next few years. Dublin 15 already has significant amounts of land zoned at High Technology and as such, it is not essential that this site be zoned similarly.
Local Area Objectives
Changes to Current LAO’s
- LAO 537 – “provide car park for the train station with not more than two levels of parking”. At this site, there is a need to balance the requirement for more car parking close to the train station, with the residential amenity of those currently living in Cherry Estate and Rosehaven. We would suggest amending the current LAO to permitting a 1 storey over ground level carpark, stretching back from the road three quarters of the way towards the border with Cherry Estate. The LAO should specify that landscaping measures should be undertaken between the car park and Cherry/Rosehaven and further, that no other commercial development should be permitted on the site.
Suggested new LAO’s
- We suggest the inclusion of a new LAO of a double pedestrian crossing at the Castleknock Road – Roselawn Road junction.
- We suggest the inclusion of a new LAO for Castleknock Village, similar to LAO 479 for Blanchardstown Village, stating that future development in Castleknock Village would be limited to three storeys.
- We suggest a new Local Area Objective for Hartstown Park, making provision for a scout den for Huntstown Scouts to be located there.
Requirement for an Implementation Chapter
While we warmly welcome much of the content of the Draft Plan, one area where is falls down is the lack of a clear plan to monitor implementation. Under S. 15 of the Planning & Development Act, 2000, there is a duty on the Local Authority to secure the objectives of the Development Plan. Further detail is set out tine S.6 of the Development Plan Guidelines 1997. These state that that policies and objectives must be capable of implementation and it must be possible to monitor and evaluate the effectiveness or otherwise of achieving stated aims. Monitoring involves the collation and analysis of performance data which must be linked to an evaluation process so that effectiveness can be measured against stated criteria.
Regrettably, the Draft Development Plan does not set out in detail any measures which will allow substantial monitoring of its implementation. This means that it will be extremely difficult to judge the success of Fingal County Council in achieving the goals set out in the Draft Development Plan.
In light of this, we request the creation of an Implementation Chapter, setting out clear targets in each of the areas that the Draft Plan covers. This will both allow a proper evaluation of the success or otherwise of the Council in putting the Development Plan into effect, but it will also meet the requirements of the legislation and statutory guidelines.
