Uimhir Thagarta Uathúil: 
SD-C195-11
Stádas: 
Submitted
Údar: 
Proinsias Mac Fhlannchadha
Líon na ndoiciméad faoi cheangal: 
0
Teorainneacha Gafa ar an léarscáil: 
Níl
Údar: 
Proinsias Mac Fhlannchadha

Observations

Chapter 6: Housing

The Office of the Planning Regulator in their submission stated that "a significant proportion of the county’s future population growth will need to be directed to;

1)Naas Road / Ballymount Strategic Development Area, which has potential for residential development and more intensive employment / mixed use

2. South western corridor (western suburbs) – SDZ lands and Kilcarbery

3. South western corridor (LUAS red line) – Tallaght Town Centre / Cookstown and Fortunestown / Saggart / CitywestSouthwestern corridor (LUAS red line) – Tallaght Town Centre / Cookstown and Fortunestown / Saggart / Citywest."

In this regard, it is disappointing to note that not only does the draft plan not propose to rezone or zone new lands over and above those currently set out under the current 2016 County Development Plan and subsequently not delivered over the course of the previous plan (for whatever reason) but SDCC does not intend to de-zone residential lands in under-serviced areas such as Stocking Lane, Knocklyon where is an evident lack of infrastructure in schools/ roads and transport to deal with any increase in population.

I also think that SDCC should look to include the lands around Clondalkin Industrial estate as part of (1) in order to make use of the existing infrastructure (rail) to promote sustainable movement within SDCC in line with SM1 Objective 4 and SM1 Objective 5:.

Chapter 7: Sustainable Movement

South Dublin’s population is to grow by an additional 46,518 persons up to a total population of 325,285 persons by 2028 as envisaged under this plan and yet it is without an intercity train stop to serve these people. A major barrier to train utilisation in South Dublin is the fact that it will take someone 1 hour at best to get into the city centre to use an intercity train at Heuston. Whilst there is access to the Luas red line, the majority of south Dublin does not benefit from this access. This is despite the fact that the train will ultimately traverse to within 15-20 minutes of the majority of the population on the Kildare line. As per SM3 Objective 22, it is welcome to note that SDCC proposes to "investigate the option of an inter-county rail service stopping at Kishogue station which would provide access to new employment space at Clonburris and give direct access to the Grange Castle Business Park."

I propose that SDCC amend this objective to remove a specific reference to a station at Kishogue given that Kishogue station is a poor location for intermodal interchange. Parkwest or the new proposed station at Kylemore would surely make for a better location for an intercity stop given the re-development potential of the area, accessibility, and existing population base.

Chapter 6: Housing

The Core Strategy in Chapter 2 identifies capacity for approximately 23,370 units that are serviced and/or serviceable within the lifetime of the Plan period. As per Appendix 11: South Dublin Housing Strategy and Interim HNDA 2022 - 2028, SDCC acknowledges that "On average across the past 5 years up to the end of 2020, 1,278 residential units a year were built." As only a fraction of the lands developed which were zoned residential have been delivered over the course of the last plan, one would have to question the viability/ suitability of the lands already zoned given if only 1,278 units are completed a year that correspondingly a greater volume of lands will have to be zoned/ rezoned to meet The Housing Need for the County of 17,817 new homes up to 2028.

I hope that SDCC can revise their standpoint on not rezoning/ zoning additional lands/ dezoning unsuitable lands as part of this Development Plan

Chapter 7: Sustainable Movement

As per the submission of Mr. Garvey (ref; SD-C195-2), I would echo and support this submission of a proposed new "S5" orbital bus route along the R112 (Walkinstown Avenue-Dundrum) to be added to the New Dublin Bus Area Network as part of the Bus Connects Network Redesign. I would add that the proposed "S5" (maybe with a different route number) submitted as per ref; SD-C195-2 could extend to Kylemore (for Luas access) and to terminate at Parkwest (for potential Commuter train/ Dart + Access). This would greatly expand the potential users of this service whilst also promoting modal interchange depending on the journey. This new "S5" route has the potential to unlock modes of transport not available to the majority of South Dublin residents at present. I would hope that SDCC could engage with Busconnects for the establishment of such a route as part of this development plan as per their objectives SM3 Objective 4, SM3 Objective 5, SM3 Objective 6.

 

Chapter 7: Sustainable Movement

I hope that SDCC as part of a policy under SM3 will consider the following;

To investigate the option of;

1) an Extension of the proposed Dart + South West route from the Kildare line to a spur to Newcastle/ Rathcoole/ Saggart and the provision of stations at Grange Castle and associated park and ride facilities at the M7 interchange (Junction 4). (SM3 Objective 6, SM3 Objective 7) (subject to engagement with Irish Rail, TII, NTA)

2) an inland rail freight terminal at Newcastle to facilitate the movement of goods to this station from Dublin Port and to act as a hub for container drop off for trucks utilising the M7 corridor. This will greatly add to the attractiveness of the area as an industrial hub given the location of prominent multinationals in the area. (subject to engagement with Irish Rail, Dublin Port, TII)

Chapter 11: Infrastructure and Environmental Services

The wording as per IE6 Objective 6 implies that there is already an extensive network of green waste centres when is not the case - "To continue to roll out a countywide network of green waste centres in suitable locations to expand the collection system for compostable waste."  The word continue should be removed

The wording as per IE6 Objective 9 should be amended to remove the word "economically". The treatment of all waste is not economical but needs to be processed and managed accordingly regardless of the cost-effectiveness of same. "To support the development of indigenous capacity for the treatment of non-hazardous and hazardous wastes where technically, economically and environmentally practicable subject to the relevant environmental protection criteria for the planning and development of such activities being applied."

The wording as per IE6 Objective 4 should be amended to include the provision of a number of "bring centres" as part of this development plan, which manages a number of waste streams that are required to the public at a smaller scale to a civic amenity sites. As things stand, there is 1 civic amenity site in Ballymount for the entire population. For context, DCC operate 8  smaller bring centres which include collecting a number of additional waste streams closer to the community, whilst SDCC has no facilities of a comparable nature. https://www.dublincity.ie/sites/default/files/2021-04/bring-centres-information-leaflet-april-2021.pdf 

As part of SDCC commitments to the Circular economy

1)SDCC to consider a scheme similar to that which was rolled out in Cork in November last year where used paint is recycled and given to good causes and continues its use as part of the circular economy rather than treated as waste in civic amenity sites in line with IE6 Objective 1: https://www.corkcity.ie/en/council-services/news-room/latest-news/new-paint-re-use-scheme-comes-to-cork.html 

2) As requested by Cllr Carly Bailey, SDCC conduct a feasibility study and work with the appropriate SPC(s) to look at the setting up of at least one Library of Things and Repair Cafe in the county and/ or each local area in line with IE6 Objective 1. There is an opportunity to link in with groups such as the local Men Sheds organisations etc etc. 

 

Chapter 9: Economic Development and Employment

As per EDE7 Objective 2, there is no reference to electricity which is disappointing given the warnings issued by Eirgrid/ Commission for the Regulation of Utilities (see https://www.irishtimes.com/business/energy-and-resources/electricity-grid-warnings-causing-disquiet-among-multinationals-says-ida-1.4627029) as to the current supply constraints on the national grid. I propose that the following wording is amended to include the following;"Sufficient capacity within the relevant water, wastewater and electricity* network to accommodate the use proposed*";

*Where anticipated usage greater than 10 MWh

As per EDE7 Objective 2,  there is no reference to " GI5 Objective 7:" Require the provision of green roofs and green walls, providing benefits for biodiversity and as an integrated part of Sustainable Drainage Systems (SuDS) and Green Infrastructure, in apartment, commercial, leisure and educational buildings, wherever possible and develop an evidence base for specific green roof requirements as part of the Council’s ongoing SuDs strategy development." GI5 Objective 7 should form a key requirement under EDE7 Objective 2

SDCC to work with the OPW to explore the feasibility of converting Rathfarnham Castle into a Digital hub to support remote working as per EDE4 Objective 12.

Chapter 8: Community Infrastructure and Open Space

8.4 Social community Infrastructure should include libraries and public swimming pools/ gyms as they are key elements of social infrastructure. Appropriate guidelines and standards should be applied to ensure alignment with projected population growth for new development areas. Suitable sites should also be identified as part of this Development Plan for same.

COS4 Objective 10 to be amended to include BMX, skate park and mountain bike track also.

COS4 Objective 11 makes reference to a specific sport (rugby) whereas per the findings of an ESRI report (https://www.esri.ie/system/files/publications/RS97_0.pdf), "just over 1 per cent of the adult population played rugby during the previous seven days...and only a small minority of children who play rugby continue to play as adults." There is no requirement to single out an individual sport in this objective particularly given the poor participation rates of the same. This wording also goes against COS4 Objective 1 for multi-functional facilities.

The sporting facilities at community centers and public parks are very much focused on organised sports (GAA/ Soccer). In very few of the public parks are there any 5 a side pitches, teqball tables, one on one basketball, etc etc. Greater consideration needs to be given to these informal facilities where there is a demand for the same. A great example of this is at Bushy Park http://www.bushytennispadel.ie/

Chapter 12: Our Neighbourhoods

For each of the 7 neighbourhoods identified there has been no breakdown provided of the Social/Community Infrastructure Audit, the standards for same and how each of these areas at present fare in relation to standards as per 8.4.1 Social/Community Infrastructure Audit, which are very specific in relation to metrics in relation to population. This should be presented as part of Chapter 12 for each neighbourhood at it presently stands and what the goal will be for each at the end of the Development Plan in light of the proposed developments and population increases.

Chapter 13: Implementation and Monitoring

SDCC to commit to maintaining a live 3D model of the built environment to aid in the greater understanding of how new developments will interact with the built environment. Examples of this can be seen in cities like Perth in Australia where the model is an integral part of the City's Planning and Development assessment process, with all new major development applications required to submit detailed 3D models. As part of engagement for the City’s Planning Strategy, the 3D City Model has also been used to demonstrate what the City of Perth could look like in the future, taking into account anticipated growth, approved developments and known planning policy directions. An example of the outputs can be seen at the following - https://www.youtube.com/watch?v=5LC_KuHpFPU

I attach a policy document from the Government of South Australia in this regard. https://www.dpti.sa.gov.au/__data/assets/pdf_file/0008/497051/Community_Engagement_Charter_Tool_-_Types_of_Engagement_-_3D_Models.pdf

Faisnéis

Uimhir Thagarta Uathúil: 
SD-C195-11
Stádas: 
Submitted
Líon na ndoiciméad faoi cheangal: 
0
Teorainneacha Gafa ar an léarscáil: 
Níl