Observation on Thormanby Woods appeal

My observation on the appeal against the proposed development by Thormanby Woods.

Councillor David Healy
Green Party/Comhaontas Glas
Howth ward / Dublin North East
01 8324087
54, Páirc Éabhóra,
Beann Éadair, Co. Bh.Á.C
54, Evora Park,
Howth, Co. Dublin

                                                                    14th May 2007    
An Bord Pleanála,
64 Marlborough Street,
Dublin 1

Re: Appeal PL06F.223250, aplication by Borg Developments, Thormanby Road, Howth

A chairde,

I would like to make the following observations on the above appeal.

1.    Visual impact and character of area

The site is in the Special Amenity Area Buffer Zone.  Other development in this vicinity has correctly been kept at a low level, mostly single storey.  The proposal for very large two-storey houses spread evenly across the site is entirely out of keeping with the character of the area and the existing pattern of development.  The designated protection of the Buffer Zone is intended to protect the character of the area as well as views to and from the Special Amenity Area proper.  The proposed development by virtue of its size and intrusive nature is not in keeping with these objectives. In particular, the importance of the tramway as an amenity route to the Special Amenity Area is recognised in the SAAO.  Views from the tramway are therefore of particular importance.

2.    Biodiversity

The site is one of significant biodiversity value, containing woodland and important wildlife corridors, including for bats (which are legally protected).  Development of low density housing is not incompatible with maintenance of biodiversity value provided that sufficient appropriate and interlinked planting is carried out, and existing woodlands and hedgerows are retained, improved and connected as needed. Unfortunately the current plan seems to envisage considerable enclosure on the site in such a manner as would disrupt wildlife movement.

The Council’s response to this has been to impose the following condition:

Condition 4
a)  A detailed scheme with full specification for the development of the woodland as an amenity to be submitted for the written agreement of the Planning Department following consultation with the Parks Division prior to the commencement of development works on site.  This to include full details of paths, bridges, gates and boundary treatments.  The chain link fence on the northern boundary of the woodland to be replaced with a railing.  A woodland management strategy that identifies an appropriate level of access and penetration but leaves other areas inaccessible for wildlife will form a major component of the scheme.  Bird and bat boxes to be erected at appropriate locations.
b)  The cause of the flooding within the woodland to be identified and rectified as part of the woodland development.

There seems to be a mistake in the wording of the proposal to “leave other areas inaccessible for wildlife.  This condition does not provide for any public consultation or information.  These important aspects of the proposal should be specified in the application and not left to be dealt with by condition.

3.    Drainage and hydrology

The development is proposed to be located in a damp hollow which acts as a reservoir at the head of Gray’s Brook which drains the valley around it, flowing down through the town of Howth under Main St. and Abbey St.  Interference with this hydrological regime could cause flooding locally and/or downstream.  The planning application does not ensure that this development is not allowed to have negative impacts.  

The requirement in Condition 4 that
“The cause of the flooding within the woodland [be] identified and rectified as part of the woodland development”
is likely to be directly contradictory to the maintenance of the wildlife and conservation value of the site.

The wetness of the area undoubtedly contributes to its biodiversity value.  Therefore solutions which would seek to drain the woodlands and adjoining areas should not be contemplated.  These considerations argue towards clustering of the development on the site (together with dedication or sterilisation of the remaining land).

4.    Water supply

The existing water supply in the area is inadequate, with generalised low pressure leading to frequent complete loss of supply on the upper stretches of Thormanby Road and adjacent areas.  Adequacy of water supply should be a central consideration in deciding on a planning application.  The Council is entirely aware of the inadequacy of the water supply in this area.  Extra houses will add significantly to the demand on an already inadequate supply.  Further development in this area is therefore premature until such time as the necessary water supply is made available

5.    Traffic

The entrance to the site is between two dangerous bends and would increase traffic hazard at this location.

6.    Existing Rights of way

There are claimed rights of way in the area and through the woods which would be interfered with by the proposed development.  The Council as planning authority and An Bord Pleanála on appeal are required to respect and protect rights of way.

7.    Proposed new public roads/rights of way

The proposal from the Parks Department that the development and the woods be accessible from the Tramway is a good and important one.  This is both to maximise the amenity benefit of the woodland and to maximise the access for residents of the proposed development to local facilities by foot.

Proper planning and sustainable development requires that walkability be prioritised in developments.  The The tramway is the primary walking route to Howth village from this location including the local school.

The pedestrian access does not need to be beside Grey’s Lane as identified by the developer, nor indeed from a design point of view should it be at this location.  From an inspection of the maps, the logical location for the access to/from the tramway is along the access road to the flagpole lot, house site 14.  This is a walking route link to another walking route which does not meet accessibility specifications in a naturally hilly area, acting as an alternative access to the site, and therefore it is not necessary that it meet accessibility specifications.

8.    Affordable housing

The proposed provision of affordable housing in Castleknock does not help to meet local demands and needs.  An Bord Pleanála should not allow the Council and developer to sidestep the intentions of the Planning and Development Act in this way.  The affordable and social housing component of this development should be provided on the Howth peninsula and this should be a condition of any grant of permission.

9.    Naming

Condition 10 reads

“That an acceptable street naming and house numbering scheme be submitted to and approved by the Council well in advance of commencement of any works on site or marketing by title.

”Reason:  In the interest of the proper planning and sustainable development of the area.

”Note:  Failure to have a naming and numbering scheme approved in time could result in a delay in marketing or the provision of utility company services to the site.  It is suggested that a number of alternative names be submitted together with a brief history of their origin, which should be of local historical significance.  The street naming scheme should be in both English and Irish and the Irish version should be an Official translation, which can be obtained by contacted the Official translator, Dial Eireann (sic).”

I assume that a “note” to a condition is in fact part of the condition.  The specification that the base language is English and the Irish version is a translation of the English version is in contravention of Objective RO24 of the Development Plan:

“To require the use of meaningful local names in bilingual format or in Irish alone in naming housing estates.”

An Bord Pleanála should reword the last sentence of the condition to comply with the Development Plan; something like would be appropriate:

“The street naming scheme should be in either Irish or in both English and Irish.”

10.    Conclusions

A number of the issues above are capable of being addressed by condition.  

Others should have been addressed as part of the application and should not be left to resolution outside the planning applicatoin process.

However, I feel that the development as a whole is of over-sized houses and fails to comply with many of the planning objectives for the area, in particular the protection of views, as set out in the County Development Plan and the Special Area Amenity Order.

Additionally, the lack of an adequate water supply and the effect the development would have on the users of the existing supply means the development is premature.

Therefore permission should be refused for the applicant to come back with a proposal more in keeping with the area and the planning objectives for the area, after an adequate water supply has been made available.

I enclose the €50 fee.

Is mise, le meas,
Cllr. David Healy