Draft Local Area Plan for Portmarnock

The Planning Department has produced a draft Local Area Plan for the
land south-east of Portmarnock Railway Station.  Together with
Robbie Kelly the Green councillor for Malahide ward, I have prepared a
submission which points out that the draft fails to address many of the
most important issues in the area.  A copy of our submission
follows

Submission in relation to Portmarnock local area plan
Cllrs. David Healy and Robbie Kelly, Green Party

           
           
           
           
           
We
are making this submission at this early stage because we believe that
there is a considerable amount of further work to do in relation to the
Local Area Plan. This is work shich we as councillors are not in a
position to do ourselves.  Additionally, given the statutory
framework within which we must work, amendments to the draft Plan must
be made within a tight timeframe which would not allow for a process of
further research to develop those amendments. 
On
this basis we are making this submission in the hope that the necessary
research will be carried out in time to make the changes we believe are
necessary.
In general we feel that the Local Area Plan is
lacking in important details in a number of significant respects. 
We deal below with various thematic areas, but in general we feel that
most of what is in the plan is of itself good, but is insufficiently
detailed and clear.  In fact, the plan contains very little
additional to the County Development Plan.  Given that the area is
zoned RS1, the obligation to make a plan must mean doing something
significantly more detailed than the County Development Plan.  We
note from the meeting held between the planning department and the
landowners on 23rd September 2004, that the landowners have had input
into this plan.  We are not clear to what extent and would be
grateful if this could be clarified.  Some of the suggestions such
as that on “coastal aspect” appear to contravene provisions of the
County Development Plan.
1.        
Biodiversity – Do biodiversity surveys and use the information gathered
in order to draw up the design of the local area plan and of the
adjacent parkland/green belt area.
The area is being
converted from farmland to medium density residential.  If
properly planned this can lead to an increase in biodiversity and have
a positive effect on the area. 
However, without
planning this will not necessarily be the case.  There is a risk
that unless biodiversity sites are identified, they could  be
obliterated in the building process.  Additionally, simple
recreational pressure could impact on biodiversity in the surrounding
area.  If the amenity areas surrounding the housing are not
planned, then people will create their own walking routes, which could
put pressure on biodiversity.  The development has the potential
for negative impacts on surface water systems, including the local
rivers and wetlands which are otter/salmonid habitat and on water
quality and bird activity in Baldoyle Estuary which is subject to
multiple designations because of its ecological importance.
Therefore
it is essential that the full biodiversity studies and subsequent
design work for this area and for the Millennnium Park go ahead
now.  The carrying out of such studies is mandated to be part of
the development of Local Area Plans in Action 70 of the Fingal Heritage
Plan, adopted by the Council on 11th July 2005.
There is no
plan for the Millennium park area, no plan for the northern part of the
high amenity area.  Insofar as there are areas of the Green Belt
which are not to be part of the Millennium Park, there is no plan as to
what their planned uses are.
The plan should identify
biodiversity features for retention/ incorporation in open space and
wildlife areas in the plan. This includes streams, hedgerows, bat
habitats, badger setts, etc.  The value of the railway as a
wildlife corridor should be considered and the ecological links between
the green belt area, the Sluice Marsh and Baldoyle Estuary should all
be part of the biodiversity component of the Local Area Plan.
Local
seeds should be gathered in autumn 2005 and/or autumn 2006 for use in
planting on finished development. We understand that Forest Friends and
Conservation Volunteers Ireland, among other NGOs are involved in seed
collection and might be able to assist.
Now is also the
time for contact with NGOs such as Birdwatch in relation to maximising
the amenity value of the parkland and coastal walk for the general
public, including birdwatchers, while protecting birds on the Estuary.
2.        
Visual impact – Do land contour maps and visibility analysis to
determine appropriate site ground levels and building heights in order
to meet the Development Plan Objective 234
Specific
Objective 234: “The visual impact on the Green Belt of this new housing
in Portmarnock will be minimised by its siting, design and by planting”
The
necessary information must be mapped and analysed in order to meet this
objective.  Post –development ground levels and building heights
at various locations within the area must be determined using analyses
of visibility from various locations, in order to maintain the visual
break between Baldoyle and Portmarnock.
We note that the
minutes of the meeting between the planners and the landowners
regarding Portmarnock Action Area Plan held on 23rd September 2004
include the following:
“The planners stated that a section
on Design needs to be incorporated into the LAP, to include;- building
height 2 storey with some 3/3 ½ at visual locations, boulevard design
of the streets (not roads) in the development, also design of open
space and how the development addresses the edges of the LAP (open
space, roads, train track etc.)
Unfortunately this has not
been done.   However the draft LAP does refer to maximising
views from the houses, which would appear to be in contravention of
Objective 234 above.
3.        
Building designs – Require high standards of design and construction to
meet energy efficiency, renewable energy, water efficiency and other
sustainability criteria.
We propose inclusion of provisions such as the following:
“The
residential development will attain high standards of energy efficiency
and environmental sustainibility, including the following:
–    bio-climatic site design,
–    water conservation,
–    ventilation,
–    energy efficient strategies for housing design,
–    daylight analysis,
–    design of group heating system.
–  high insulation standards
“All
new buildings will meet the minimum low energy performance standards
(as defined below) as a prerequisite to receiving planning approval
(calculation report to be submitted with the planning application).
Each building’s energy performance calculation must be demonstrated on
the basis of a simple approved method (e.g. EN 832) carried out by
qualified or accredited experts.  Low energy buildings are defined
as building with an annual heating requirement (space and  water
heating) not exceeding 50 kWh/m2 of useful floor area.
The
development will utilise renewable energy supply systems to meet at
least 30% of the buildings space and water heating requirements as
calculated on the basis of an approved method carried out by qualified
or accredited experts.”
The buildings should be
required to incorporate provisions for reducing water use including low
flow fittings (toilets, taps, shower heads) and provisions for reuse of
rainwater and/or greywater for flushing toilets etc.
4.        
Transport – Display proposed street network for all road users as well
as specific extra provision for pedestrians and cyclists where
appropriate.
We would point out the overriding importance
of creating a walkable community in order to build social capital and
public health (Leyden, 2003).
The correct transport approach for a new residential area is set out quite effectively in the
Development
Plan in terms of giving priority to pedestrians and cyclists. It is not
so much about providing segregated facilities as about ensuring that
traffic speeds and volumes are low. 
However, this
is not being implemented in many of the designs proposed by
developers.   If the Development Plan is to be made
effective, the Local Area Plan should include the street layout. 
It is only by seeing a layout that statements such as that in the draft
plan that
“All new residential units within the plan area will be within 10 minutes walking distance of the station”
can be believed.
There should be no roundabouts, as these discourage pedestrians.
The suggestion that the existing bus routes in the area will continue to use the Coast Road (not

Strand Rd.

as stated) and new bus routes will serve the development is not credible.

5.         Drainage
The
SUDS-based drainage to be used in the area should be developed to an
outline stage for the Local Area Plan, not just stated as a generality
with no more details than in the County Development Plan.
6.         (Farmers’) Market
The
plan should specifically incorporate provision for a marketplace, on
public land taken in charge by the County Council, as this is one of
the traditional functions of a local authority and an essential element
of strengthening the local food economy.
7.         Shops
The
total area of shops planned for should be specified in the plan at a
level to meet the needs of the expected number of residents.  We
support the clustering of these shops at the Dart Station.
References
Leyden,
Kevin, 2003, Social Capital and the Built Environment: The Importance
of Walkable Neighborhoods Am J Public Health.2003; 93: 1546-1551
Cllr.
David Healy       
           
           
           
           
Cllr. Robbie Kelly
12th July 2005