Observation on Planning application F15A/0362
I would like to make the following comments on the above application.
1. Material contravention of Development Plan
The application is a material contravention of the County Development Plan in three significant respects.
a) The Plan, in Local Objective 513 provides for a mixed use development on the site, which has an urban centre zoning. This development is not a mixed use urban development but a residential development with a few shops. It could be argued that a big expansion in retail space is not required in Howth and this is correct. The mixed use does not need to be primarily extra retail.
There is a clear need in Howth, with its major tourism businesses and stunning natural environment, for hotel accommodation. The inclusion of a significant hotel would make this a mixed use development and comply both with Local Objective 513 and with objectives in the plan for local economic development, especially tourism.
b) The height proposed is in contravention of Local Objective 512 which limits heights to between 3 and 5 stories, specifying that not more than 30% of the development can be 5 stories high.
c) The location proposed for Traveller accommodation is not that identified in the County Development Plan; instead the Traveller accommodation is proposed to be located on the public park which is zoned for open space and recreational amenities.
Please note that while much of the content of the Howth Urban Centre Strategy is of course good, the document cannot be relied on in the same way as a County Development Plan or a Local Area Plan. For some reason it has not been presented to the Councillors for adoption as a Local Area Plan would be but is simply a piece of research by the Council. It cannot be relied on to alter or interpret the County Development Plan.
2. Wrong location and lack of plan for community centre
The proposed Community Centre is in the furthest part of the site from the developed urban area of Howth and the Railway Station. Community facilities such as this must be sited to facilitate public access. Even more fundamentally, there is no plan in place to finance the construction or the operation of such a centre. It would not be acceptable to grant an integrated planning permission in the absence of a sincere intention on the part of the developer to implement the entire permission as required by planning law.
In relation to the identification of this site in the Urban Centre Strategy (UCS) as a suitable site for the community centre, as I mentioned above, the UCS has no legal standing. The opposition of many of the local councillors, including myself, to the identification of this distant part of the site for the community centre in the UCS may have been one of the reasons that Council management did not propose it for consideration as a Local Area Plan as I asked them to do in 2008.
The community centre proposed in the application seems to be a simple box not designed for any particular purposes and visually not contributing to the local environment.
I urge you to seek further information on the proposed community centre, its uses and management.
3. The development will have an unacceptable impact on traffic levels in Howth and all steps should be taken to minimise this impact
The Howth peninsula does not have the capacity to accept increased traffic which would be generated by the development as proposed. One logical response to this is to develop this area as a ‘car-free neighbourhood’, excluding motor vehicles from the area (except for necessary deliveries), providing for a small multistorey carpark on the edge of the development which any residents with cars would have to use and designing the area to take advantage of the space and quality environment thus enabled. This is a practical option for the Techrete site because the it is right beside the railway station and within walking distance of many other local facilities. Experience with similar developments elsewhere such as Vauban in Freiburg, Germany1 shows that such developments will attract people eager to benefit from living in an neighbourhood without cars and that the rate of ownership of cars (kept in the multi-storey car park) can be around 30% of households.
4. Views out to sea
The development should provide for three or four wide gaps in the buildings which would enable views from the public road to the sea and Ireland’s Eye; this is not the case at the moment with a development which is oriented east-west, blocking the views.
5. Bridge to beach
The first redevelopment planning application on the site, which was correctly refused for being an overdevelopment provided for a pedestrian bridge over the railway to access Claremont Strand. The benefits of this for residents and the general public are evident and it should be integrated into this or any other proposal for this site.
6. Sustainable heating system
The EIS is unclear as to what the heating system is, saying various features “can be incorporated” including district heating (3.6.1). However, the application seems to include individual chimneys and it is not clear where a district heating boiler would be located. The development should be required to meet high levels of thermal efficiency and hot water/heating should be provided by a district system for the entire development based on solar hot water and a district heating boiler.