GREEN PARTY COMHAONTAS GLASS SUBMISSION ON THE DRAFT DUN LAOGHAIRE RATHDOWN COUNTY DEVELOPMENT PLAN 2004-2010

CONTENTS

1 INTRODUCTION
2 STRATEGIC PLANNING GUIDELINES
3 STRATEGIC PLANNING GUIDELINE AND DUN LAOGHAIRE
4 DUN LAOGHAIRE RATHDOWN HOUSING STRATEGY
5 RECENT COMPLETIONS AND OTHER POTENTIAL HOUSING SUPPLIES
6 REVIEW OF THE STRATEGIC PLANNING GUIDELINES
7 PROPOSED REZONING
8 CARRICKMINES/CHERRYWOOD ACTION PLAN
9 STEPASIDE ACTION PLAN JULY 2000
10 POPULATION INCREASES IN THE GREATER DUBLIN AREA
11 CONCLUSIONS

presented by Ciarán Cuffe TD
and Eamon Ryan TD
DAIL ÉIREANN
Kildare Street
Dublin 2

1 INTRODUCTION

This submission is further to our letter of the 26th of July 2002 and sets out in some detail proposals which we hope will be taken into consideration in the preparation of the new Dun Laoghaire Rathdown Draft development plan. Our earlier letter outlined some policy concerns that we have in the areas of transportation, retail development, amenity and children's issues and waste management but in this submission we wish to concentrate our comments on the proposals for land use rezoning contained in the draft plan.

We believe that the level of existing zoned land within the borough is sufficient to meet development needs till beyond the life of the proposed plan and that the council should not re-zone any additional land for residential development as part of the plan.

We believe that the rezoning of four green belt areas in Old Conna, Woodbrook, Glenamuck Road and Kilternan , proposed in the plan would be a continuation of the worst type of sprawl of the urban area. This is unsustainable planning given the lack of public transport and other infrastructure to support these developments.

We believe that the other large proposed development in the area of Cherrywood should only come after the confirmed development of the Luas/metro extension to the area and that it requires a more detailed local framework plan to be completed prior to new development being approved.

We believe there is a lack of statistical information to back the County Manager's arguments for greater residential re-zoning. We call on the Council to demand that an updated review of the Strategic Planning Guidelines is provided prior to the plan being approved. We call on the County Manager to provide a detailed analysis on the potential development from small-scale in-fill development, urban regeneration projects and the changing demographics in traditional suburbs.

The last review of the Strategic Planning guidelines (April 2002) shows that some 21,000 new housing units in Dun Laoghaire were either in the construction phase, in the planning process or could be provided in existing zoned land. We would urge the Councillors not to rezone any additional lands in the 2004-2010 County Plan. We believe that the zoned but undeveloped residential land in the existing 1998 County Development Plan is sufficient to meet the target for new housing units in the Strategic Planning Guidelines for Dun Laoghaire Rathdown.

This is without taking into account the massive increase in rezoning in the other surrounding counties where the housing provision has been a multiple of what is required in the guidelines.

2 STRATEGIC PLANNING GUIDELINES

The Strategic Planning Guidelines (SPG) were commissioned by the 7 Local Authorities in the region in conjunction with the Department of the Environment and the then 2 Regional Authorities for Dublin and the Mid-East. They were published in 1999 and given statutory effect under the 2000 Planning Act. The principal objective of these Guidelines "is to put in place a broad planning framework which will provide an overall strategic context for the Development Plans of each local authority".

The SPG are intended "to provide a framework for future investment in sanitary services, transportation and other infrastructure." The SPG area is geographically divided into a Metropolitan area which is "the existing built up area of Dublin and its immediate environs"(the boundary line runs south of Rush and Lusk and just north of Blanchardstown and Kilcock then just west of Maynooth and Celbridge as well as south of Tallaght to the county boundary of Dun Laoghaire Rathdown. It then turns further south while west of Bray to include Fassaroe and concludes at Greystones).

There is also a Hinterland area including the remainder of the area with the intention that development be restricted to growth centres such as Drogheda, Navan, Naas and Wicklow Town as well as radial Transportation corridors linking these growth centres with Dublin City such as railways to facilitate more use of public transportation.

The SPG strategy is based "upon the principles of sustainability" and "implies that the preferred strategy must reduce growth in the demand for transport especially private transport." It also states that "the future form of development should reduce urban sprawl". As part of this "consolidation" of development the aim is to "increase overall densities of development".

3 STRATEGIC PLANNING GUIDELINES AND DUN LAOGHAIRE

Dun Laoghaire Rathdown is entirely situated within the Metropolitan area of the SPG where the strategy is "to consolidate the Metropolitan area in line with the principles of sustainable development". This "consolidation will allow it (the Metropolitan area) to accommodate a greater population than at present".

A major objective of the SPG is "the need to achieve a clearer demarcation between urban and rural land uses". This is relevant for Dun Laoghaire Rathdown in the context of the rural areas to the west of the M50/South Eastern Motorway which should remain rural rather than be zoned for significant industrial development at Glenamuck or residential development at Kiltiernan as is proposed in the Draft Dun Laoghaire Rathdown County Development Plan published in April 2003

There is actually no requirement under the Strategic Planning Guidelines for any local authority to define a target population as a percentage of the overall population growth in the Greater Dublin Area.

The only requirements under the Strategic Policy Guidelines are that a local authority "favours and facilitates public transportation in both areas [Metropolitan and Hinterland] and requires the consolidation of future growth into a limited number of locations where adequate[public] transport infrastructure can be provided"(SPG, Page 84).

Specifically within the SPG Metropolitan Area which includes almost all of Dun Laoghaire Rathdown apart from the hilly area in the extreme South-West of the county, the aim is consolidation of development "allowing for the accommodation of a greater population than at present, with a much enhanced public transport system. This will require some increase in overall development densities as well as measures to ensure priority for public transport. In time, this will lead to a more compact urban form, relative to the size of population, and will reduce the growth in overall demand for travel."(SPG, page 84)

The SPG does not require the local authorities within its area to meet specific population numbers, targets or percentages rather it refers to "indicative figures for each local authority area."(SPG, page 85) The indicative figures suggested in the SPG for Dun Laoghaire Rathdown is a total population of 200,000 in 2001 and the same figure in 2011. Dun Laoghaire Rathdown is the only local authority in the SPG area predicted to have no growth between 2001 and 2011.

This reflects the reality that large scale population growth in the county could only be achieved by wholesale rezoning of Zone F land(Open Space and Recreational Amenity) to residential. This is precisely what the County Manager is now proposing in that he wants 170 additional hectares above that provided for in the current 1998 County Plan be rezoned from mostly Open Space to residential.

4 DUN LAOGHAIRE'S HOUSING STRATEGY

The County Council incorporated the Strategic Planning Guidelines in 2001 when it also adopted its 2001-2004 Housing Strategy. The basis for the housing demand forecast used is the retention of Dun Laoghaire Rathdown's share of the population within the functional area of the Strategic Planning Guidelines for the Greater Dublin Area (consisting of Dublin City plus the 3 Dublin Administrative Counties as well as Counties Meath, Kildare and Wicklow) which was 9.5% in 1999.

This led to Dun Laoghaire Rathdown County Council adopting a target of 1750 extra residential units to be built each year in the period from 2002 to 2004 inclusive .

The 2002 Census population for the Greater Dublin Area was greater than that forecast under the Strategic Planning Guidelines in 1999 so for Dun Laoghaire Rathdown to retain its share of 9.5% of the total population of the GDA the County Council wants to allow 19,211 new residential units to be built from June 2002 to December 2010. This would mean an annual increase of 2,260 new dwellings per year.

The Draft Housing Strategy states that in June 2002 the County had 323 hectares (775 acres) of zoned undeveloped land available for residential development. It estimated by January 2003 this zoned undeveloped land had decreased to 297 hectares (713 acres) due to ongoing development.

Applying the recommendations of the Residential Density Guidelines for Planning Authorities (Department of the Environment, Dublin 1999) this land-bank of 297 hectares could be developed at 35 residential units per hectare which would produce 10,935 new dwellings. At 45 units per hectare it would provide 13,365 new dwellings and at 50 it would provide 14,850 dwellings.

5 RECENT COMPLETIONS AND OTHER POTENTIAL HOUSING SUPPLIES

The average number of new residential units built for each of the previous 5 years had been 812 . In 2000 860 new residential units were built and in 2001 the figure was 1166.

It is important to remember that these figures are based on a land-bank containing sites of over 0.5 of a hectare(1.2 acres). In addition there would also be in-fill sites in the existing developed part of the County though no figures are supplied for new in-fill despite the fact that the Draft plan shows that suitable sites do exist in areas such as Dun Laoghaire town centre.

The main housing supply issue in existing developed parts of the county is the under-utilisation of the existing housing stock. The traditional housing suburbs built between 1950 and 1980 have a remarkable low occupation rate and several areas of the county suffered up to 10% decreases in population from 1996-2002 due to the ageing profile.

These cyclical population movements are quite common in areas of relatively uniform suburban family houses and such areas will recover their population as new families replace the older generation.

The Manager should provide the council with a detailed report on the projected ownership profile and the related demographic changes that will occur in these existing suburbs over the next ten years. The council should also lobby for innovative tax measures to lower house transaction costs in these areas. There would be an overall saving to the state if existing schools and other local infrastructure already provided in these areas are fully utilised rather than additional services having to be provided in new green field sites.

6 REVIEW OF THE STRATEGIC PLANNING GUIDELINES

Each April with the exception of 2003 to date the Strategic Planning Guidelines Office has published its Review and Update. The most recently published Update is for 2002. It reported that 1166 housing units had been built in Dun Laoghaire Rathdown in 2001 which was the highest in any year since 1996(See Table 6 on page 9).

The most significant data in the 2002 Update is contained in Table 5 on page 8. It reveals the content of the Housing Land Availability Returns made by each local authority in the GDA-SPG area to the Housing Supply Unit in the Department of the Environment in June 2001.It reveals that 1566 planning permissions for residential units were granted in the year prior to June 2001 by Dun Laoghaire Rathdown County Council and that there were also 139 permissions granted which were over a year old but had not been built by June 2001. In addition there were 852 pre-planning discussions with applicants and/or their agents. While it is unlikely all of these 852 discussions would lead to formal planning applications it would be reasonable to assume that about 80% of them will lodge planning applications for residential units.

The most significant statistic from Table 5 is that Dun Laoghaire Rathdown County Council estimated that the capacity of land zoned for residential development in its current county development plan(1998) which had yet to be developed but which would be serviced by 2007 and thus would provide when developed, 15,113 new residential units. This figure of 15,113 on its own excluding existing residential construction and existing planning permissions granted but not yet started would supply 6.6 years of housing units at the County Manager's Draft Housing Strategy stated annual requirement of 2260 new housing units.

Since the Development Plan runs for 6 years from 2004 to 2010 there is already sufficient zoned land available under the existing county development plan to meet the County Manager's housing demand until 2010 and therefore no additional land should be rezoned.

7 PROPOSED REZONING

Despite the fact that the last review of the SPG shows that there is sufficient land available to meet the projected housing needs in the County, the County Manager has requested the County Council to rezone 175 hectares most of which is zoned as recreational amenity and open space under Zone F in the 1998 County Development Plan. The County Manager wants this 175 hectares to be developed at an average density of 38 new residential units per hectare.

The Councillors are recommending that only 150 hectares should be rezoned which the County Manager wants developed at an average density of 43 new residential units per hectare in the Draft County Plan on display to the public from April to July 1, 2003 .

The main rezoning proposed in the Draft plan is in four significant blocks. Two of these blocks at Old Conna and Woodbrook are in the middle of a green belt which is vital for the separation of the sprawling outskirts of Shankill and Bray.

The other two main areas of rezoning are in the area of Kilternan Village and the Glenamuck Road. The lack of a proper public transport system and the already congested roads in the Kilternan area should rule out any such zoning in this area regardless of what the housing requirement are for the overall county.

The extensions to the residential zoning in the Glenamuck Road area are beyond an acceptable walking distance to any future Luas station and the size of the industrial zoning is such that major traffic congestion would develop on these narrow country roads. Any developments in this area are in any case on the mountain-side of the motorway which should be severely restricted.

The four major rezoned areas are not close to any significant urban centre and it is clear that the schools and other infrastructure could not be provided to make the areas sustainable living communities given the scale of development that is being proposed.

8 CARRICKMINES/CHERRYWOOD ACTION PLAN

Dun Laoghaire Rathdown County Council prepared a Draft Action Plan for Carrickmines/Cherrywood in May 2000. The aim is to provide 2,850 new dwellings, 11,500 new jobs and a population target of some 8,500 on an area of 51.4 hectares at varying densities of dwellings from 35 to 60 per hectare depending on topography and proximity to public transport like Luas. In May 2000 361 dwelling units had been built with a potential population of 1,083 people at an average number of 3 persons per house.

It is a major weakness of this Draft County Plan that no statistical data has been supplied indicating the amount and types of development e.g. the numbers of apartments and houses and the amounts of 1,2 and 3 or more bedroom apartments as well as the nature and amount of existing planning permissions which have yet to be built. From this data it would be possible to make informed estimates of the likely current population there and the likely further numbers of people that might reasonably be accommodated there by 2010. All of the above information would be available to the Council's Planning Department from the information supplied in planning applications for this area since May 2000.

Similarly it would be possible to analyse the employment statistics for this area and from surveys of residents and businesses there it would be possible to make a reasonably informed estimate as to how many residents of this area are currently working there as that was a significant aim of the Action Plan. No data has been supplied in the Draft County Plan as to the actual amount of affordable and social housing units provided in developments built to date in this area under Part V of the 2000 Planning Act.

It is completely inadequate to propose as recommended in Map No.9 on Page 218 of the Draft County Plan that the whole of Carrickmines/Cherrywood be covered by a composite zoning entitled "Special Development Area" and that the Detailed plan for this area will follow at an unspecified future date as "a local area plan".

Given the current uncertainty about the further development of the Luas lines from Sandyford to the Carrickmines area we would recommend that the permission for developments in any such plan should be contingent on the public transport infrastructure being approved.

9 STEPASIDE ACTION PLAN JULY 2000:

Dun Laoghaire Rathdown County Council prepared an Action Plan for Stepaside in July 2000. The aim was to provide up to 5,510 residential units on an area of 110.2 hectares and to have a population of some 20,000 people in an area of about 340 hectares. In July 2000 there were 2546 existing residential units with 402 under construction or un-built but with existing planning permission. The Draft Plan states on page 50 that "at the end of 2002 some 400 residential units were under construction but it is anticipated that, over the next 8-10 years, some 4,000-4,500 houses and apartments will be completed in the Action Plan area.

Regardless of the development of the M50 motorway it is clear that the road network will not be able to take the increasing traffic flows that will come with the proposed new residential units in the Kilternan and Glenamuck Road area.

10 POPULATION INCREASES IN THE GREATER DUBLIN AREA

There is no enforcement mechanism to oblige a local authority to implement any or all of the Strategic Planning Guidelines. The latter is very clear as a result of the High Court judgement (by Mr. Justice Quirke on 2 September 2002) in the case of McEvoy and Smith V Meath County Council. Meath County Council have not abided by the Strategic Planning Guidelines as they have permitted a significant amount of development outside the designated growth centres in Navan and Drogheda and rezoned a considerable amount of additional land for residential development in its 2001 County Development Plan around Dunboyne, Clonee and Ratoath none of which are designated as "growth centres" under the SPG.

The effect of its approach is that the population of County Meath rose from 109, 732 in the 1996 census to 133,936 in the 2002 census which was the second highest growth in population in the GDA after Kildare which rose from 134,992 in 1996 to 163,995 in 2002.

The population increases in the 2 counties in Dublin with the largest amount of developable land between 1996 and 2002 were 28,540 in Fingal and 21,159 in South Dublin.

The net migration into the Mid East region(Meath, Kildare and Wicklow) at 42,462 was almost double the natural increase of 22.7812 in population there between 1996 and 2002 Net migration into the Dublin region (Dublin City, Fingal, South Dublin and Dun Laoghaire-Rathdown) in the same period was 13,257 compared to a natural increase of 51,079.

The average number of persons per household in the 2002 census for the county is 2.9. Should the proposed 20,000 additional households materialise by 2010 which the County Manager is demanding in this Draft Plan then the population of the area could increase by an extra 58,000 or a population increase of over 30% on the county total in the 2002 census of 191,389 persons.

To put this figure in perspective between 1996 and 2002 the entire province of Munster increased its population by 67,363 persons.

Given the massive population increases that have already occurred in the greater Dublin area in recent years and the regional imbalance that has resulted it makes no sense for Dun Laoghaire Rathdown to seek to maintain its 9.5% share of the total population of the GDA-SPG area. To argue for such a percentage share would mean Dun Laoghaire Rathdown will be hostage to the actual growth in other areas that can physically accommodate more population growth than it can. It is not a requirement of the SPG and even the SPG projections do not envisage the population of the county to rise beyond 200,000 by 2011 from its current figure of 191,389 in 2002.

11 CONCLUSIONS

The lack of data makes it almost impossible for the Councillors to assess the Manager's proposals in the Draft County Plan. Not only has the Manager failed to supply the up to date statistical data which would enable the Councillors to assess the need for his rezoning proposals, he has also failed to provide any information about the capacity for infill development in the already developed areas of the county. The Manager's Draft Housing Strategy is not compatible with the population projections for the county in the Strategic Planning Guidelines for the Greater Dublin Area.. It runs contrary to the directions in the SPG that new residential areas be linked to proper public transport provision.

Despite identifying the need for affordable housing it does not provide strategies for its implementation other than increasing the general supply of new residential units. While it refers to the need for new housing in both the affordable and social categories to provide a unit mix of 25% 1 bedroom; 50% 2 bedroom and 25% 3 or more bedrooms, it provides no data on what mixes have been specified in planning permissions granted in the county to date. The Manager needs to clearly outline how the council can meet its social and affordable housing objectives.

Dun Laoghaire Rathdown County Council should not rezone any land in the 2004-2010 County Development Plan for additional residential development until the existing zoned residential landbank of 297 hectares has been completely developed.

The County Councillors should insist that the County Manager's proposed large scale rezonings at Old Conna(approx 50 hectares) and Woodbrook(approx 30 hectares) are rescinded due to the unacceptable intrusions they represent into the greenbelts between Shankill and Bray which are necessary for the survival of the sense of identity, place and community in Shankill.

The proposed rezonings in the area of the Glenamuck road and in the area of Kilternan village should not proceed as the public transport and roads infrastructure cannot cope with the existing level of development in the area let alone the large scale developments that would come with the rezoning along what are in essence country roads.

The County Councillors should insist on a transparent and detailed Local Area Plan being included now within the 2004-2010 County Development Plan for the Carrickmines/Cherrywood "Special Development Area".