Submission: Objection to Proposed Permeability Measures (Floraville – Per2–Per5)
I wish to respectfully object to the proposed permeability measures in the Draft Clondalkin Local Transport Plan that would affect Floraville Estate, specifically: Per2: Laurel Park – Floraville Avenue, Per3: Floraville Avenue – Round Tower GAA car park, Per4: New Road – Floraville Avenue, and Per5: Monastery Rise.
1. Lessons from the Past – Ignored Evidence
Before 1995, open laneways in Floraville were a source of antisocial behaviour, disturbance, and non-resident traffic. South Dublin County Council recognised this and closed 19 laneways, including three here. That action worked: it improved safety and quality of life. Re-opening cut-throughs would undo these gains and repeat past mistakes.
It is also unclear what evidence of demand supports these proposals. Has SDCC demonstrated that there is a real need for these permeability links, or is this being advanced as a matter of policy only? Without a clear demand analysis, the proposals lack justification.
Policy conflict:
- Strategic Environmental Assessment (SEA) Directive – requires past evidence and cumulative impacts to be considered.
- Planning and Development Act 2024 – requires strategies to support proper planning and sustainable development.
2. Safety and Traffic – Present-Day Risks
Floraville already experiences congestion during school drop-off and lunchtime periods, directly linked to the gated laneway that is opened for school hours. This shows that even managed permeability increases traffic inside the estate.
If the proposed cut-throughs were opened permanently, Floraville would become an overflow car park for schools, shops, and the GAA club — multiplying congestion, non-resident parking, and safety risks on streets designed as cul-de-sacs. This risk is not theoretical: residents already observe daily congestion during school drop-off and school collection periods. Permanent, unmanaged permeability would extend this problem to all hours of the day and night.
Equally important is perceived safety. Modern planning guidance, including CPTED principles, recognises that the fear of crime is as important as actual crime in determining whether people walk or cycle. Based on historic evidence, uncontrolled permeability would likely create “fear routes” avoided by families, children, older people, and disabled people.
Policy conflicts:
- DMURS & NTA Permeability Best Practice Guide – permeability should improve safety and street function.
- Planning and Development Act 2024 – requires protection of residential amenity.
- IHREC Act 2014 – requires safe, inclusive access for all.
- Climate Action and Low Carbon Development (Amendment) Act 2021 – requires reductions in car dependency and emissions.
3. Current Safety Context – Families at Risk
Safety concerns are not historic; they are immediate. Within a single week, residents were made aware through local alert groups of serious crime incidents in the village, including violent incidents and break-ins.
In this environment, opening new cut-throughs into Floraville would expose families to further risks and reintroduce the very issues that led to closures in the past.
Policy conflict:
- DMURS / CPTED – design should prevent conditions that enable crime and fear of crime.
- Public Sector Duty (IHREC Act 2014) – requires councils to protect vulnerable groups in practice, not just in principle.
4. Community Assets at Risk – Round Tower GAA
The Round Tower GAA Club already has safe access from Monastery Road. A cut-through into Floraville would invite uncontrolled access, encourage loitering, and increase parking spill-over — undermining both the club and the estate.
Here, the issue of proportionality arises. The minor convenience for a small number of pedestrians or cyclists is far outweighed by the negative impacts on safety, security, and residential amenity for the entire estate.
Policy conflict:
- DMURS & NTA guidance – permeability must respect local context and community assets.
Conclusion
The proposed cut-throughs (Per2–Per5) conflict with multiple statutory and design obligations:
- SEA Directive – ignores past evidence and cumulative impacts.
- Planning and Development Act 2024 – undermines proper planning and residential amenity.
- DMURS & NTA guidance – fail to demonstrate safe, positive permeability.
- IHREC Act 2014 – fails to provide safe, inclusive public space.
- Climate Action Act 2021 – risks increased car use and emissions.
- CPTED principles – disregard perceived safety and fear of crime.
- Clondalkin Local Area Plan – undermines commitments to preserve residential amenity and neighbourhood character.
The responsible choice is clear: leave the cut-throughs closed and support climate action through safe, evidence-based measures that take into account lived experience — not through reopening estate laneways that history shows are unsafe.
This proposal also raises a wider concern: it appears not to take account of lived experience and past evidence, as referenced in other residents' submissions. If such information- and experience-based feedback from residents is ignored, it calls into question the basis of other initiatives within the plan. What else has been advanced on the strength of data models alone, without genuine consideration of how communities actually use and experience these spaces?