Uimhir Thagarta Uathúil: 
SD-C226-41
Stádas: 
Submitted
Údar: 
BCEI
Líon na ndoiciméad faoi cheangal: 
1
Údar: 
BCEI

Litir Chumhdaigh

We, Marston Planning Consultancy, 23 Grange Park, Foxrock, Dublin, D18 T3Y4 are instructed by our clients EdgeConneX Ireland Limited, with a registered address at 6th Floor, South Bank House, Barrow Street Dublin 4 to make a formal submission on the provisions of the Proposed Material Alterations of the South Dublin Draft County Development Plan 2022-2028. This submission is accompanied by a legal opinion on the Proposed Amendments by Stephen Dodd SC. This sets out the legal considerations, including statutory provisions of the need for the adopted South Dublin County Development Plan 2022-2028 to be consistent with the National Planning Framework (NPF) and the Eastern and Midland Regional Assembly Regional Spatial and Economic Strategy 2019 (EMRA RSES).

Observations

Chapter 13: Implementation and Monitoring

Select Proposed Amendment on which you are commenting: 

To not adopt Proposed Amendments 13.1, 13.2 and 13.3 as follows:

To not adopt Proposed Amendment 13.1 and Amend Table 13.4 Zoning Objective ‘REGEN’ so that ‘Data Centre’ is moved back from being ‘Not Permitted’ to being ‘Open for Consideration’.

To not adopt Proposed Amendment 13.2 and Amend Table 13.9 Zoning Objective ‘MRC’ so that ‘Data Centre’ is moved back from being ‘Not Permitted’ to being ‘Open for Consideration’.

​​​​​​​To not adopt Proposed Amendment 13.3 and Amend Table 13.10 Zoning Objective ‘EE’ so that ‘Data Centre’ is moved back from being ‘Not Permitted’ to being ‘Open for Consideration’.​​​​​​​

We would refer the Council to the fact that it is not current policy either of the CRU, EirGrid or the Government to cease data centre grid connection or development in any form.  However, as we have demonstrated under this submission, there are a range of criteria under which EirGrid (and indeed ESBN as appropriate) will consider in providing connections to data centres to the national grid..  There is clearly an intrinsic link between power and data centre development and this is recognised in current policy set out by the CRU and adopted by EirGrid.  This is reflected in Policy EDE7 Objective 2 of the Draft Plan that is also amended under the Material Alterations.

We respectfully submit, for reasons that are set out under this submission, that there is no basis for making data centres ‘not permitted’ uses under the Material Alterations of the Draft Plan. On that basis we would request that South Dublin County Council do not adopt its Proposed Amendments 13.1, 13.2 and 13.3 under the Material Alterations as outlined above.

Faisnéis

Uimhir Thagarta Uathúil: 
SD-C226-41
Stádas: 
Submitted
Líon na ndoiciméad faoi cheangal: 
1