Submission on Proposed Material Alterations

Submission on Proposed Material Alterations to Variation No. 2

South Dublin County Development Plan 2022–2028

Finnstown Castle – Amendment Ref. No. 3

St Edmundsbury – Amendment Ref. No. 6

I wish to make this submission in strong support of the decisions of the Elected Members to reject the proposed residential rezoning of the lands at Finnstown Castle and St Edmundsbury.

I previously opposed both proposed rezonings during the earlier stage of Variation No. 2.

Following the public consultation process, consideration of the Chief Executive’s Report and debate by the Elected Members at the Special Council Meetings in June 2026, the proposed residential rezonings of both Finnstown Castle and St Edmundsbury were rejected.

I strongly support those decisions and submit that the resulting Material Alterations should be retained in the final Variation.

This submission should not be interpreted as opposition to housing.

Lucan and Adamstown have accommodated very significant population growth and will continue to make an important contribution to housing delivery through the continued build-out of Adamstown SDZ and other planned development.

The issue is whether sustainable planning requires every available greenfield site to be rezoned for residential development, irrespective of its existing function, environmental significance, infrastructure constraints or the cumulative development pressures already experienced by the surrounding community.

I do not believe that it does.

There are compelling and distinct reasons for protecting both Finnstown Castle and St Edmundsbury, alongside a wider cumulative case for ensuring that future development in Lucan is sustainable and infrastructure-led.

 

Part 1 – Finnstown Castle

Amendment Ref. No. 3

I strongly support the Material Alteration arising from the decision of the Elected Members to reject the proposed residential rezoning of Finnstown Castle and to retain the existing OS – Open Space zoning.

1. Retention of OS is the appropriate planning outcome

The Finnstown Castle lands were considered during the preparation of the South Dublin County Development Plan 2022–2028 and the decision was made to retain their Open Space designation.

A significant change to that established planning position only a relatively short period into the lifetime of the Development Plan requires a compelling site-specific planning justification.

The need to respond to revised national housing requirements does not, of itself, demonstrate why these particular lands must be rezoned.

The fundamental characteristics of Finnstown Castle have not changed.

2. Finnstown is not simply undeveloped land

The Finnstown lands perform an important landscape, environmental and green-infrastructure function.

They contribute to a significant green buffer along the Newcastle Road corridor and provide separation between existing and developing urban areas.

The Chief Executive’s Report acknowledged the strength and volume of submissions objecting to the principle of rezoning Finnstown Castle from Open Space to Residential.

Importantly, it also acknowledged concerns regarding the loss of greenfield land, the departure from long-standing planning intent and the role of the lands as an environmental and visual buffer between Adamstown, Lucan Village and the road network.

The importance of Finnstown Castle as a landscape feature and part of the wider green infrastructure network was also acknowledged.

Those acknowledgements should have a consequence.

The appropriate consequence is to retain the existing OS zoning.

3. The last strategic green buffer must be valued

Finnstown has a particular strategic importance because of its position within the remaining green landscape along the Newcastle Road corridor.

As Lucan and Adamstown continue to grow, these areas become more important – not less.

Population growth increases the need for green infrastructure, biodiversity, recreation, visual relief and accessible open space.

The planning system should therefore consider not only how many homes can be accommodated within an area, but what environmental and community assets must be retained to support the significantly larger population being planned for.

Once a strategic green buffer is developed, its function cannot realistically be recreated elsewhere.

4. Protected structure and historic setting

Finnstown Castle is a protected structure.

The protection of architectural heritage cannot be confined solely to the physical fabric of a building. Its setting, landscape context, mature vegetation, approaches and relationship with surrounding lands can contribute significantly to its character and special interest.

Residential zoning would fundamentally change the development expectation for these lands.

An SLO attached to residentially zoned land cannot provide the same certainty as retaining the existing Open Space zoning.

Where an existing zoning already provides substantial protection to the landscape setting of an important heritage asset, there should be compelling evidence before that protection is weakened.

5. Transport and the R120/Newcastle Road

The capacity of the surrounding transport network remains a fundamental concern.

The Chief Executive’s Report acknowledges significant congestion along the R120/Newcastle Road and surrounding routes and the impact this has on accessibility.

The issue is not simply whether a technical access solution could be designed for an individual development.

The appropriate question is whether the surrounding transport network can sustainably accommodate the cumulative impact of further development when substantial additional development within Adamstown remains to be delivered.

Old Tandy’s Lane is also a local access road and should not become a means of accommodating traffic generated by development of this scale.

Infrastructure should precede or accompany development.

Communities should not continually be expected to absorb additional development on the basis that existing infrastructure deficits will be addressed at some future point.

6. Schools, healthcare and community infrastructure

The Chief Executive’s Report also acknowledges concerns regarding pressure on schools, healthcare and wider community and social facilities within the Finnstown–Adamstown–Lucan area.

These are not secondary considerations.

They are fundamental components of sustainable communities.

Housing means people.

People require school places, healthcare, public transport, community facilities, recreation, green space and accessible environments in which they can participate fully throughout their lives.

The completion of existing planned communities and delivery of the infrastructure required to support them should therefore be prioritised before additional strategic greenfield lands are opened for development.

7. Relationship with Adamstown SDZ

The location of Finnstown immediately adjoining the Adamstown SDZ also requires careful consideration.

Adamstown was specifically designed as a Strategic Development Zone to facilitate coordinated and planned development, including housing, transport, schools, open space and community infrastructure.

There is a legitimate planning question as to why additional lands immediately adjoining that planned development area should now be rezoned before the SDZ itself has been completed.

Any potential implications arising from the relationship between the Finnstown lands and the established Adamstown SDZ boundary should also be considered carefully and transparently.

Where legal uncertainty has been raised regarding this issue, appropriate legal advice should be obtained before any future proposal seeks to fundamentally change the planning status of these lands.

8. An SLO is not equivalent to OS zoning

An important distinction must be maintained between protecting land through zoning and seeking to mitigate development through an SLO.

Under OS zoning, the fundamental planning premise is protection of the open-space function.

Under residential zoning accompanied by an SLO, residential development becomes acceptable in principle and the focus moves to managing its impacts.

Those are materially different planning positions.

If Finnstown’s landscape, environmental, heritage and green-infrastructure functions warrant strategic protection, that protection should occur at zoning level.

9. Finnstown conclusion

The elected members made the appropriate decision in June to reject the proposed residential rezoning.

The evidence arising through the Variation process has strengthened rather than weakened the case for retaining Finnstown Castle as Open Space.

I therefore strongly support the Material Alteration and request that the OS zoning of Finnstown Castle be retained in the final Variation.

 

Part 2 – St Edmundsbury

Amendment Ref. No. 6

I strongly support the Material Alteration arising from the decision of the Elected Members to reject the proposed residential rezoning of St Edmundsbury and retain the existing HA-LV – High Amenity Liffey Valley designation.

10. Long-established protection of the Liffey Valley

St Edmundsbury cannot appropriately be considered as an isolated parcel of potentially developable land.

Its HA-LV zoning reflects a long-standing planning commitment to protecting the outstanding natural character and amenity of the Liffey Valley.

The lands form part of the wider green-infrastructure and landscape network and contribute to ecological connectivity between St Catherine’s Park, Lucan Demesne and habitats associated with the River Liffey.

The proposed residential rezoning would therefore have represented a fundamental departure from the established planning approach towards these lands.

11. What has changed?

There is a simple but important question at the centre of the St Edmundsbury proposal:

What has changed about these lands to justify removing their long-standing High Amenity protection?

The revised national housing requirement does not alter the environmental characteristics of St Edmundsbury.

It does not reduce its ecological sensitivity.

It does not change its relationship with the Liffey Valley.

It does not remove its protected structures.

It does not improve the capacity of the surrounding road network.

And it does not diminish the importance of maintaining green infrastructure as the surrounding population increases.

The housing requirement may have changed. The characteristics which justified protecting St Edmundsbury have not.

12. Ecological sensitivity

Particular weight should be afforded to the concerns identified by the Department of Housing, Local Government and Heritage through the National Parks and Wildlife Service regarding the ecological sensitivity of the lands, including their relationship with the Liffey Valley proposed Natural Heritage Area and Special Amenity Area.

The lands form part of a wider ecological network.

Fragmentation can affect habitat connectivity and biodiversity resilience far beyond the boundaries of an individual development site.

Once such ecological connections are severed or substantially diminished, recreating their function is extremely difficult.

A precautionary planning approach is therefore appropriate.

The most effective way to protect an important ecological corridor is to avoid unnecessarily fragmenting it in the first place.

13. Liffey Valley Special Amenity Area

The proximity of St Edmundsbury to the Liffey Valley Special Amenity Area further distinguishes these lands from ordinary development land.

The Liffey Valley has recognised scenic, ecological, recreational, historic and cultural significance.

Development decisions affecting its wider landscape should therefore be approached with particular care.

Retaining HA-LV provides a clear, coherent and long-term planning framework for that protection.

14. Protected structures and historic landscape

The presence of protected structures within the St Edmundsbury lands adds another significant consideration.

Heritage protection is about more than individual buildings.

Setting, landscape, views, mature vegetation and the relationship between historic structures and their surroundings can contribute substantially to their significance.

Introducing residential zoning would fundamentally alter the development expectation for this historic landscape.

Retaining HA-LV provides a considerably stronger framework for protecting that setting.

15. HA-LV versus RES-N with an SLO

The suggestion that CS7 SLO2 could adequately address environmental and heritage concerns does not resolve the fundamental issue.

HA-LV and RES-N accompanied by an SLO do not provide equivalent planning protection.

With HA-LV, protection and enhancement of the outstanding natural character and amenity of the Liffey Valley is the starting point.

With RES-N, residential development becomes acceptable in principle and the SLO seeks to manage the consequences of that development.

The difference is fundamental:

one protects the landscape; the other facilitates development and then seeks to mitigate its impact.

Where the strategic objective is protection, HA-LV is the more coherent planning mechanism.

16. Access and cumulative transport impact

Concerns regarding access, egress and the capacity of the surrounding Lucan road network also remain relevant.

The assessment cannot be limited to whether an engineering solution could provide access to an individual development.

It must consider the cumulative traffic impact of existing and planned development across Lucan and Adamstown.

Where significant housing capacity is already planned within established development areas, there is no compelling justification for opening environmentally sensitive HA-LV lands while substantial infrastructure challenges remain.

17. St Edmundsbury conclusion

St Edmundsbury is precisely the type of landscape that becomes more important as surrounding communities grow.

Retention of HA-LV does not prevent South Dublin County Council from meeting its housing obligations through appropriate alternative locations.

Development of St Edmundsbury, however, could permanently alter an ecologically, historically and environmentally sensitive part of the Liffey Valley.

Housing can be delivered elsewhere.

The Liffey Valley cannot be relocated elsewhere.

I therefore strongly support the Material Alteration and request that the existing HA-LV zoning of St Edmundsbury be retained in the final Variation.

 

Part 3 – The Wider Lucan and Adamstown Context

18. The cumulative impact cannot be ignored

While Finnstown and St Edmundsbury each have compelling individual reasons for protection, they must also be viewed within the wider cumulative development context of Lucan and Adamstown.

The Chief Executive’s Report records consistent and strongly expressed concerns regarding the level and concentration of development within the Lucan–Adamstown area.

That wider context matters.

Adamstown SDZ remains to be fully built out.

Clonburris SDZ will accommodate substantial additional development.

Other residential developments across the wider Lucan area will also continue to contribute to population growth.

The question therefore cannot simply be:

Where can we fit more housing?

It must also be:

What infrastructure, services, green spaces and community assets must we protect and deliver to ensure that this growth remains sustainable?

19. Housing delivery must be infrastructure-led

I fully recognise the revised national housing requirements that have led to Variation No. 2.

South Dublin County Council must play its part in responding to the housing crisis.

However, meeting numerical housing targets cannot become the sole measure of successful planning.

Sustainable housing delivery requires:

• transport and active-travel infrastructure;
• sufficient school and childcare capacity;
• healthcare and community services;
• recreational and sporting facilities;
• accessible and inclusive public spaces;
• biodiversity and functioning green infrastructure;
• appropriate water and physical infrastructure; and
• protection of the landscape and heritage assets that give communities their identity.

These are not barriers to housing delivery.

They are what turn housing development into sustainable communities.

20. A proportionate County-wide response

The revised National Planning Framework creates a County-wide planning responsibility.

The response should therefore be evidence-based, balanced and proportionate across South Dublin.

Lucan and Adamstown should continue to contribute strongly to housing delivery.

However, national housing policy should not result in environmentally sensitive or strategically important green lands being selected simply because they are adjacent to areas where large-scale development is already taking place.

The cumulative impact on existing and planned communities must form part of that assessment.

21. Protecting green infrastructure while communities grow

There is also a broader principle at stake.

As South Dublin becomes more urbanised, the remaining strategic green spaces, ecological corridors and historic landscapes become increasingly valuable.

They support biodiversity and climate resilience.

They provide visual and recreational relief.

They contribute to physical and mental wellbeing.

They help maintain the individual identity of communities.

And they provide environmental assets for future generations.

A growing population strengthens the case for protecting strategically important green infrastructure rather than weakening it.

 

Final Conclusion

I strongly support the decisions of the Elected Members to reject the proposed residential rezonings of Finnstown Castle and St Edmundsbury.

These decisions do not undermine South Dublin County Council’s commitment to housing.

They demonstrate that housing delivery and sustainable planning must go hand in hand.

Finnstown Castle performs an important open-space, landscape, heritage and green-buffer function at a location already experiencing significant development and transport pressure.

St Edmundsbury forms part of the environmentally sensitive and historically important Liffey Valley landscape and has benefited from long-standing High Amenity protection.

Neither site should be considered simply as undeveloped land available to meet a numerical target.

Lucan and Adamstown have accommodated significant growth and will continue to do so.

Our responsibility now is to ensure that the infrastructure, services, green spaces and environmental assets necessary to sustain that growing population are protected and delivered alongside housing.

The decisions made in June recognise that balance.

The housing requirement may have changed, but the environmental, heritage and infrastructure reasons for protecting these lands have not.

Once strategic green infrastructure, ecological corridors and historic landscapes are lost to development, those decisions cannot easily be reversed.

For these reasons, I respectfully request that the proposed Material Alterations arising from the decisions of the Elected Members be retained and that:

Finnstown Castle remains zoned OS – Open Space; and

St Edmundsbury remains zoned HA-LV – High Amenity Liffey Valley.

This represents a balanced, proportionate and sustainable approach to the future development of Lucan and the wider South Dublin County area.