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.
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.
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 and Working Group III deals with Mitigation. 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. Aspects of particular relevance to Fingal include the consideration of climate mitigation and adaptation in coastal zone management.
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.
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.
The Transportation and Movement issues paper fails to consider parking, long recognised as a key issue in generating car-oriented environments and reducing proximity.
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.
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.
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. 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.
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.
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.
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.
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.
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.
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
15th May 2015
54, Páirc Éabhóra, Beann Éadair