Uimhir Thagarta Uathúil:
SD-C383-704
Stádas:
Submitted
Submission:
Resident objects to the introduction of a 3G pitch in Greenhills Park
Comhairliúchán:
Part 8 for a Synthetic Grass Sports Pitch at Greenhills Park, Greenhills, Dublin 12
Dáta a cuireadh isteach:
30.10.2025 - 15:38
Teorainneacha Gafa ar an léarscáil:
Níl
Senior Executive Officer
Climate Action
South Dublin County Council
County Hall Tallaght
Dublin 24 YNN5.
Re: Part 8 for a Synthetic Grass Sports Pitch at Greenhills Park, Greenhills, Dublin 12
Dear Sir/ Madam
As a resident whose home backs on to Greenhills Park I wish formally object to SDCC in relation to the Part 8 for a Synthetic Grass Sports Pitch at Greenhills Park, Greenhills, Dublin 12.
This proposal is contrary to South Dublin County Council’s own stated policies around climate action:
“In South Dublin we have public parks, private gardens, grasslands, woodlands, hedgerows, roadside verges, streams, rivers, and upland bogland and heath which all support wildlife, native trees, and plants.
These spaces also absorb some of the carbon dioxide that we release into the atmosphere, which negates some of the damage to the climate. Making sure these areas remain healthy and expanding them where possible is key to climate action.”
“Adding to the risk, urban areas like South Dublin contain many hard, human-made surfaces like roads, buildings, and paved ground. Many of these surfaces do not allow water to drain through them and the traditional way of dealing with excess surface water is to pipe it into the sewer system, however there are downsides to this approach – these include increasing flood risk elsewhere or polluting our watercourses for us and the wildlife that rely on them, as rainfall picks up human-made pollutants on the ground, ultimately ending up in the local stream or river.”
Biodiversity and ecological continuity
Biodiversity comprises all living things; plants, birds and mammals, to insects, microbes and fungi, and the ecosystems, bogs, forests, rivers, oceans, grasslands, etc. that they are a part of. Healthy ecosystems are vital for human health and wellbeing, underpinning food production and food security, giving us clean water and fresh air, protecting against climate change and enriching our lives both culturally and spiritually. Soils host an astounding diversity of life; 25-30 % of all species on Earth live in soils for all or part of their lives. Loss of biodiversity influences the climate. The promotion of biodiversity is a key policy objective as stated in the County Development Plan.
To introduce a 3G pitch in place of a green space that will have a negative impact on the biodiversity value, is in conflict with national, regional and local policy on biodiversity and climate action.
The EU Water Framework Directive dictates our commitment to improving the quality of our waterbodies. This is an area that Ireland has committed to improving. There is a risk that any water runoff from a 3G pitch will leach into the soil around the pitch and further endanger the biodiversity of the area. The Poddle river is also close by and the River Poddle Flood Alleviation Scheme will provide protection to 921 properties in the floodplain of the Poddle River in SDCC and DCC areas which are currently vulnerable to flooding. It is critical that debris does not makes it way into our watercourses.
The EU Nature Restoration Regulation (NRR), which came into force in August 2024, establishes a legal framework for the restoration of various ecosystems, habitats, and species across the European Union. The baseline for mandatory improvement was set in 2024. In urban areas ecosystems must have no net loss of green urban space and tree cover by 2030, and a steady increase in their total area from 2030. This SDCC proposal runs contrary to the EU Nature Restoration Regulation.
I note Dún Laoghaire-Rathdown County Council are meeting their requirements under the EU Nature Restoration Regs by continuing with their programme of grass pitch upgrades throughout the County. “It is intended to develop these grass pitches to a high standard, in line with the Pitches Quality Standard (PQS). This upgrade will improve the provision for GAA and soccer use, while ensuring the facilities are flexible, so that rugby, and other such sports can also be played in a safe manner.
The scope of works generally includes; stripping and storing existing site topsoil, excavation to install primary and secondary drainage, which includes attenuation areas and outfall connections, placing topsoil back and adding additional topsoil (if required), regrading to improve surface falls, sand finish, reseeding and pre-fertilisation for grow in, top dressing, maintenance during the 12-month establishment period, and primary line marking. Where possible, fixtures and fittings such as goal posts and ball stop nettings are being reused, and where required new fixtures are being provided.”
Natural grass is the most efficient surface with regards to ecological and economic sustainability as it is naturally self-renewing. Natural turf areas provide numerous environmental benefits including carbon sequestration, providing habitat for wildlife, producing oxygen and absorbing and storing water. In comparison, artificial grass can contaminate the soil with chemicals, microplastics, and minerals, impact the health of subterrestrial organisms such as earthworms and increase flooding risks due to the loss of absorbent surfaces.
On the perimeter of the proposed development, alongside Greenhills College, there are healthy Elm trees, whose roots extend within the area to be developed. While the proposal states these trees will remain intact it is inevitable due to their placement that their roots will be damaged, therefore killing these mature trees. From a research and environmental science perspective, the proposed development of a full-size synthetic grass sports pitch at Greenhills Park presents significant ecological and climate concerns. The removal or disturbance of mature trees, particularly the healthy elms visible along the park boundary, would lead to irreversible losses in carbon storage, biodiversity, and landscape value.
The park’s mature trees provide habitat for birds, pollinators, bats, and countless soil and canopy organisms. Their removal fragments local habitat networks in an already urbanised area. The elms, in particular, could include individuals resistant to Dutch elm disease, which are of national conservation value. The lichen growth visible on the trunks indicates long-term air quality and ecosystem stability.
Protecting existing mature trees aligns directly with Ireland’s National Forestry Strategy (2023–2030) and climate adaptation goals. Retaining them is therefore consistent with national and EU obligations.
Each tree in Greenhills Park is more than a biological asset or a carbon store, it is part of our shared heritage. Its roots hold not only carbon but also memory; its canopy shelters both wildlife and people. These trees connect generations through daily walks, changing seasons, and moments of peace. Losing them would erase not just ecological value but the living bond between nature and community. Protecting them is both environmental stewardship and cultural responsibility, ensuring that the next generation inherits a landscape rich in life, beauty, and meaning.
While the loss of biodiversity that would result from this proposed development may be modest in national terms, it is very significant in a local context given that 1.5 ha of grass will now be replaced by a fenced 3G pitch.
This proposal runs contrary to the South Dublin County Council Plan which states:
“Strong neighbourhoods exist in this area crossing administrative boundaries. The eastern section is an established suburban area in South Dublin and is characterised by mature residential neighbourhoods including Templeogue, Walkinstown, Rathfarnham and Knocklyon. This neighbourhood is home to excellent public amenities, from local shopping to schools, public parks and cultural attractions. Against the backdrop of the Dublin Mountains, the Pearse Museum, St. Enda's Park and Rathfarnham Castle are fantastic local cultural attractions. The Dodder Valley Linear Park, Tymon Park and Greenhills Park with the adjacent Marley Park and Bushy Park are all family-friendly public parks that are all family-friendly public parks that are full of life and activity.”
“Climate Action & Energy
Future development within this neighbourhood will aim to reduce climate change impacts at a local level through efficient settlement and travel patterns, energy use and the protection and provision of green infrastructure. This neighbourhood will aim to increase access to sustainable transport routes in order to integrate land use and transport in a sustainable way and reduce carbon emissions.” Please see my piece below on the carbon currently stored and future rates as well as the emissions resulting from the proposed build.
“Natural Heritage & Biodiversity
The landscape character for this area is 'Urban' and has formed around existing natural features as an extension of Dublin City Centre. The River Dodder is positioned across the centre of the neighbourhood with a section designated as a proposed Natural Heritage Area. As a long-established neighbourhood area, this area also has significant numbers of mature trees, all of which act as Green Infrastructure and Climate Adaptation measures.” The removal of Greenhills Park removes an already natural green space as outlined above.
Carbon and soil ecosystem impacts
Mature trees are living carbon reservoirs. Each large tree can store several tonnes of carbon in its wood and roots while continuing to absorb CO₂ from the atmosphere every year. Disturbance, or removal, of these trees results in the rapid release of stored carbon and eliminates their future sequestration potential. Equally important, the soil beneath them, especially the top 30 cm, is a major carbon sink. Construction and soil sealing prevent further carbon capture and degrade the microbial and root networks that maintain soil health and fertility. The existing grass field holds ~2,860 t CO₂ on site mostly in the top 30 cm of soil, consistent with Teagasc data for Irish mineral grassland (~440 t CO₂/ha). This land also removes ~7.1 t CO₂ every year through ongoing biological sequestration.
In contrast, in replacing our natural grass field with a 3G pitch it must be noted that artificial turf fields are made of polyethylene and nylon and these produce greenhouse gasses.
Embodied emissions of the new build
The Programme for Government affirmed that Government will deliver actions to achieve a 51% reduction in emissions from 2018 to 2030 and net-zero emissions no later than 2050. However, if this proposal proceeds constructing the aggregate base and porous asphalt alone embodies ~136 t CO₂e (materials to factory gate), rising by ~14 t CO₂e for local HGV transport (per 25 km). The synthetic turf system adds at least ~125–213 t CO₂e for the carpet/backing, ~355–710 t CO₂e for a typical full system to factory gate, and potentially around ~200 kg CO₂e/m² over its life for filled systems.
Given the calculation only allows for transport of 25km and the preferred bidder, as a result of the tendering process, is a UK based company I believe I am underestimating the emissions which are based on the data above only.
Neither do the above figures take into consideration the emissions involved in transporting players, managers and spectators to and from the proposed site.
Wildlife disruption
Each year a flock of Brent geese winter in Greenhills Park. We cannot continue to lose green space inland for wintering birds. We also have a badger sett, fox dens, hedgehogs and bats that have their homes in the park, not to mention the insects and worms in the soil. Badgers are protected under the Wildlife Acts 1976 and 2000 Amendment, and their setts enjoy full legal protection. Bats are protected by law under the 1976 Wildlife Act and 2000 Amendment. They are also protected under the EU Habitats Directive. The narrow scope of daylight-only surveys, over one winter in the Greenhills Park Wintering Birds and Badger survey cannot be considered a robust ecological assessment. This goes against best practice which requires two surveys to be carried out over two years to allow for anomalies. I note Enviroco visited Greenhills Park on 23 October at 13:00 to carry out a wildlife study, approx. one week after cutting the hedges and during daylight hours, again this study is useless from a wildlife perspective as badgers, bats and foxes are nocturnal animals.
3G Pitch concerns
The documents provided do not give this reader any confidence that the type of infill being used is not the subject of an EU ban that takes effect in 2031 as the make-up of the performance infill is not described. The Regulation (Regulation (EU) 2023/2055) intends to reduce microplastic pollution from products. The synthetic turf infill is a key example of a pollutant. Planning decisions are required to consider environmental legislation and risks, approving a pitch without ensuring compliance with EU law would be inconsistent with both national and EU obligations on environmental protection.
Additional concerns must be considered, namely, the risk of pollution from the run off from the chemical cleaning agents used to clean the pitch; synthetic pitch sub-bases are known to clog over time, reducing permeability increasing the risk of flooding; commonly used polymeric infills shed microplastics and may contain hazardous chemicals; a porous sub-base and drainage to attenuation, but offers no evidence that these systems will prevent microplastics and chemicals from migrating into surrounding soils or entering the water environment. Small-scale measures such as boot brushes or a recessed “detox” tray are inadequate for containing the known volumes of infill loss from heavily used synthetic pitches; no plan is provided for end-of-life disposal or recycling of the synthetic system, which generates large volumes of contaminated plastic waste.
If, as Mayor Kearns stated recently, cork infill is to be used why did SDCC not ensure this was called out in the report made by Sports Lab. If rubber infill is to be used in the construction of this 3G pitch it will in all intents and purposes be obsolete so any promises of alternative replacements, at a later date, should not be accepted.
Research tells us that artificial turf and rubber playground surfaces are all made with materials that can be dangerous for children and adults, and for our environment. Many professional athletes dislike playing on artificial turf. It increases the severity of abrasions due to sliding, puts additional stress on joints, and heats up much more than grass does in the sun and therefore can become dangerously hot. Research has shown that sick days following a fall on 3G pitches are higher when compared to the same injuries on grass. Tyre rubber doesn’t need to be on fire to release chemicals into the air we breathe. Those chemicals can also get on our skin and clothes and even be inhaled into our lungs. According to the EPA, breathing air contaminated with polycyclic aromatic hydrocarbons PAHs may increase a person’s chance of developing cancer. PFAS, commonly known as "forever chemicals," are a group of synthetic compounds used in various products for their water and grease resistant properties, but they pose significant health and environmental risk because they enter the body and the environment as “forever chemicals,” which means that they are not metabolized and do not deteriorate, accumulating over the years.
During the second open meeting SDCC officials said they were investigating cork infill. Why, if this is the case, does the documentation for this proposal include a detox tray that is specifically required for the non-biodegradable rubber crumb infill?
So, ignoring the type of infill used for a moment it must be recognised that each 3G pitch typically contains 80 - 120 tonnes of infill and about 2-5 metric tonnes (2,000-5,000 kg) of infill must be replaced every year for each pitch, meaning that tonnes of the infill have migrated off the field into grass, water, and our homes. While cork infill can technically be recycled, the original cork itself is not made from recycled material. Instead, this cork comes directly from tree bark and while natural it means that cork surfaces may only be made by felling trees, further degrading ecosystems, biodiversity and the environment at large. Cork is particularly susceptible to cracks especially in climates with excessive rain or freezing temperatures and is unproven in Ireland.
Cork is estimated to be 24% more expensive than crumb rubber. Cork infill granules will deteriorate over time at a faster rate than rubber, so the infill will need topping up more regularly. Further evidence that this proposal and the associated costs has not been properly investigated. To propose the acceptance of the proposal as it stands with a promise to use more biodegradable infill in the future should not be accepted.
Under the Infrastructure Guidelines of the NDP, Climate and Environmental Performance are an explicit appraisal element at the Preliminary Business Case stage of the project lifecycle. Omitted from the published documentation is a clear explanation, or the business case/ feasibility study indicating how this site was identified as being the most suitable, and what the existing contributing factors are that made it the most preferred site for development. It is a small park of 6.5 ha, surrounded on three sides by houses, (St James Road, St Brendan’s Crescent and St Anthony’s Crescent with the nearest houses being 22m from the site) and on the fourth side by Greenhills College.
From my very limited knowledge on the subject in the immediate area there is access to 3G pitches in St Judes (2.3km), Spawell (2.7km), Astro park on the Greenhills Road (4Km), Kimmage’s Larkside FC (4Km) as well as Terenure FC (4Km), Bluebell (4.8km), Sean Walsh Park (5km), Ballyboden (Santa Maria)(5.9km), Roadstone (7Km), Killinarden (8Km), GAA Thomas Davis (8km) Tallaght Leisure Centre (8km) Lucan Sarsfields (14Km) and Adamstown (14Km). Unfortunately, we don’t have the same widespread access to green spaces.
Public access diminished
Commercial facilities, such as this proposed 3G pitch are not covered in Article 80 of the Planning and Development Regulations of 2001.
No one can dispute the WHO’s findings in relation to physical activity which include:
“Regular physical activity provides significant physical and mental health benefits. In adults, physical activity contributes to prevention and management of noncommunicable diseases such as cardiovascular diseases, cancer and diabetes and reduces symptoms of depression and anxiety, enhances brain health, and can improve overall well-being. In children and adolescents, physical activity promotes bone health, encourages healthy growth and development of muscle, and improves motor and cognitive development.”
Individual sports develop self-reliance, independence, focus, resilience, and discipline.
The proposed conversion of this park will transform a widely available, walk-on community green park into a commercial pay to play, fenced, single-purpose facility for formal team sports. Many current informal users, including children, dog walkers, rounders teams, runners, people practicing their golf swing, yoga enthusiasts, older residents and their carers will be excluded from the grass area, leaving only a strip of grass along the pathway for our use. Schools will also be locked out as they continue to use the lower part of the park for Sports Days and other events. This proposal therefore reduces access and the public good, and any claimed benefits must be weighed against this loss of inclusive access. In a world where we are striving for inclusivity and diversity this proposal is counter intuitive.
The perimeter fencing at just over 4.6 metres will reduce the availability of the park for those of us not involved in formal team sports to just a strip around the pathway. At present I walk my dog at any time of night or day and always feel secure doing so. I know if I am uncomfortable in a situation I can change direction or cross the field. This fenced area will reduce my visibility of the park and mean that choice, if faced with an uncomfortable situation, is limited for me.
At the first open meeting we asked SDCC officials about emergency services access, they had no response, however at the second meeting they informed us that the pathway at the back of St James’ Road would be widened to 3.5 m with an additional 10m turning space to allow a fire engine or ambulance to enter the park. This is not captured on any documents or on the map outlining the proposed pitch and would result in a further erosion of our grass. This lack of foresight indicates an ill-conceived plan.
Noise and light Pollution, littering and flooding
A Noise Impact Assessment was not undertaken. Greenhills Park is generally silent once darkness falls but should this proposal be successful it will now be full of the sounds until after 22:00 weekdays and 21:00 on weekend nights.
The proposed development is likely to significantly increase noise levels as a result of, balls hitting the kickboards that will be installed of the base of the ball-stop fencing, balls hitting the six-metre-high perimeter fencing, as well as whistles and the roars from managers, players and spectators alike.
In a recent email from one councillor, he mentioned that SDCC would investigate the use of hoarding around the pitch. This is further evidence of a lack of planning, how can a mitigant, such as hoarding, be offered when the risk around the noise levels has not been quantified ?
The Lighting plan does not include an assessment, and the legend does not explain the various numbers over property lines which are presumably an indication of the light pollution each residence will be subjected to. Floodlighting until 22:00 on weeknights and 21:00 at weekends risks unacceptable light spill into residential properties and will have a detrimental effect on our bat population. There are no measurements recorded in the map legend indicating the distance the pitch or lighting is away from each dwelling however SDCC officials indicated that this distance was 22m from the nearest two properties.
The associated light pollution will be hugely disruptive to wildlife species who forage and nest freely here, like protected badgers and bats as well as the foxes who have made this park their home.
The lighting would not appear to be the minimum of 50 metres away from an existing bat colony recommended by Bat Conservation Ireland in a guidance note to planners. Where there is too much light, bats vision can be reduced resulting in disorientation. Light falling on a roost exit point can delay bats from emerging, thus missing peak levels of insect activity at dusk. Column heights of lamp posts should be restricted restricting the height of lamp columns to less than 8 metres. The ball nets are also a major concern to the bats. The proposed height of the floodlights are 21m. To put this into perspective houses in this area are approx 7m, the lights will be three times higher than the houses. To further demonstrate this, we flew a drone beside the church spire. The drone is within the red circle.
I note in a number of submissions of support for this proposal it is mentioned that there are no lights in Greenhills Park. The images below are taken from St James Road (left image) across the field and the pathway in the field in front of Wilkins estate (right image) of the area that is lighted and available for said teams to use.
No parking or road traffic impact assessment was carried out. In fact there was no engagement with An Garda Síochána, nor with the Emergency Services.
The proposal mentions that green travel will be encouraged, however there is no evidence presented as to how is this to be “encouraged”. The idea of green travel, while well-meaning will not happen in reality. Parking is already an issue for residents and at the weekends and training nights it is proving more and more difficult to access garages on our back lanes.
At the second meeting SDCC officials informed us that they are now investigating parking, when asked did this mean we would lose a further part of the park they were non-committal. If SDCC plan to remove additional space from the park we should have been notified in a transparent way as part of the process. There will also be further costs associated. Have these been factored into SDCC’s business case or is, as it appears, SDCC throwing everything at this project in order to get it across the line despite Greenhills Park not being an appropriate area.
The increased use of the park under this proposal will inevitably lead to further littering, already an issue post-match and training days as we see coffee cups, food, socks, plastic bags and containers and other litter strewn across the park. However, should the proposal be accepted, this will be exacerbated due to the longer hours of operation.
SDCC Refusal of Planning Permission
SDCC previously refused to grant planning permission when an application was made to install four floodlights around the existing Leinster Senior pitch in the top end of our park.
As recently as August 2025 SDCC also refused planning permission to Lucan Sarsfields. An article by Ellen Gough in the Echo on 28 August 2025 wrote “However South Dublin County Council refused permission for six 22m high and four 16m high lighting masts and floodlighting as they “would be contrary to the provisions of the South Dublin County Development Plan 2022-2028”. “The proposed floodlighting for the proposed pitch and hurling wall, at a location proximate to the Grand Canal proposed Natural Heritage Area and within the Grand Canal Primary Green Infrastructure Corridor, would disrupt nocturnal wildlife, particularly light-sensitive species like bats, and undermine the ecological integrity and function of this corridor as a dark, natural refuge for species including bats which are protected under the EU Habitats Directive,” the report from the chief executives’ orders stated.”
In October 2024 SDCC refused planning permission for floodlights at St Anne’s GAA Club in Bohernabreena. In the planning application, the club sought permission for six 18 metre columns as part of a new LED floodlighting system. It is important to point out that these floodlights are three metres shorter than the floodlights proposed for Greenhills Park. SDCC requested “spill light and glare assessments on any potential impact the floodlights would have on existing housing”. Where were these assessments for the proposal in Greenhills Park?
On 04 April 2024 the Echo reported that Greenhills Park is not ‘an appropriate location’ for teenspace. “Public Realm examined Greenhills Park as a prospective site for a teenspace, and did not consider that it would be an appropriate location for such a facility,” said the council. “It is difficult to find a suitable site that is not too close to existing houses, or does not already have an existing use by clubs, but yet remains within an active/well-overlooked location.” It was noted this teenspace would be too close to existing houses.
An almost identical Part 8 (theirs did not include a pavilion or CCTV) was proposed for Knocklyon in a park that is significantly larger than Greenhills Park, where the nearest house to be impacted was 75m from the pitch. The nearest houses in Greenhills Park are 22m from the pitch. For context Knocklyon Park is 9.5ha, the proposed 3G pitch measured at 90 X 140m however Greenhills Park is only 6.5ha and the proposed 3G pitch is larger at 100m X 146m excluding ball stop nets which will be placed behind the fenced area.
Please see CAD drawings below of the proposed pitch, based on the dimensions of the pitch and the height of fencing and lighting provided for in the SDCC documents.
As you can see from the map below Greenhills Park is the only green space in the townland of Greenhills, indeed a good proportion of the park is situated in the neighbouring townland of Limekiln Farm.
Greenhills Townland, Co. Dublin
South Dublin County Council Sports Pitch Strategy Document LINK
Page 35: “Map 4.1 below shows proposed potential sites within the local authority. These sites cover the vast majority of the local authority and also expand to other local authority areas who might to look to use these pitches, detailed feasibility studies should be created to further explore these sites.”
This strategy document makes no reference to Greenhills Park an as you can see from the X on the map, indicating Greenhills Park, our field is not in the immediate environs of any of the preferred locations.
South Dublin County Council Pitch Development Report
In this report following the completion of South Dublin’s Sports Pitch Strategy (March 2020), a new All Weather Pitch (AWP) or Artificial Grass Pitch (AGP) was recommended within the area of Dodder Valley & Knocklyon, close to the M50. The preferred sites are listed below with the scores of the feasibility studies. As you can see Greenhills Park is not mentioned in these shortlisted sites. How then were the sites at Castlefield and Dodder Park overlooked in favour of Greenhills Park? I have requested a feasibility study carried out on Greenhills Park by SDCC, or its contractors, none has been provided.
Counter proposals
Why has South Dublin County Council not considered improving the drainage in Greenhills Park, if needed, similar to the works completed on pitches 129 and 130 in Tymon North, this would allow continued unlimited access for all residents and other informal and formal users. This drainage offers excellent value for money and could be delivered at a fraction of the cost that developing a 3G pitch will cost as well as the resulting costs of the maintenance over its lifetime. What must also be considered is the need to replace these pitches every 8-12 years and the cost, both financial and environmental for the recycling of the materials within the pitch.
I am an avid sports fan, both team and individual but I am fundamentally against the removal of a healthy, green space for the reasons outlined above. I would urge SDCC to consider space in an Industrial park or similar where your commitment under the Sports Strategy can be achieved without affecting the biodiversity of any green space.
If alternative green space is to be considered, St Aidan’s Community College is sitting at the foot of the Dublin mountains on 14 acres of land, it is a Deis + school and they are crying out for facilities for their community. While I understand it is private land the school is very willing to work alongside SDCC to develop a facility. Public Private Partnerships have provided the country with some excellent infrastructure and should not be ruled out.
The South Dublin County Council Pitch Development Report calls these areas out:
“1.18 The major areas of deprivation are located in the central portions of the county within South Dublin such as Jobstown, Citywest and Kingswood. The other areas that also suffer from deprivation are North Clondalkin and West Tallaght.” The recent Health Assets and Needs Assessment (HANA) longitudinal study led by TCD partnering with the HSE, directly linked deprivation to the lack of resources which, they state, diminish the further away you travel from the city centre into the suburbs.
I also note a TD for Dublin Mid-West has proposed that SDCC should purchase a 10ha site in Coldcut, this site contains three astro pitches, two grass pitches, a GAA pitch and a pitch and putt course.
Tymon North
Greenhills Park
South Dublin County Council Green Infrastructure Map 13 LINK
At a recent meeting with SDCC officials we were told this 3G pitch could not be moved to Tymon North as it was a protected space. However as evidenced above on SDCC Green Infrastructure map and legend both Greenhills Park and Tymon North are both classified as “Existing Parks”. Where is it detailed that Tymon North is a Special Area of Conservation (SAC), Special Protection Area (SPA) or a Heritage area?
Public Spending Code - Circular 13 of 2013 and a lack of transparency
Under the Public Spending Code Local Authorities must conduct robust economic appraisals for capital projects in order to ensure value for money of exchequer funds . This process involves assessing the start up costs, lifecycle costs, the benefits, the projected revenue generation and user demand as well as an evaluation of the risks associated with each capital project. Were appraisals carried out?
Considerations outlined throughout my submission; the potential of additional parking being created in the park, emergency access resulting in the widening of the pathway, the higher cost of cork infill, if used, and the need for increased infill replenishment should have been factored into any proposal and we should have been presented with a full, transparent proposal outlining the total affected area within Greenhills Park.
During a meeting with SDCC officials we asked if a risk assessment was carried out to quantify the potential funding shortfalls and if contingency plans had been put in place to allow for periods of non-usage? An answer was not provided. Without this assessment being carried out there is a possibility that public funds may be required to cover recurring deficits. This raises serious concerns regarding value for money. Should deficits occur this could potentially place financial burdens on locals whose LPT may be impacted.
GDPR
Has a DPIA been carried out? If the proposed CCTV will extend outside the fenced area then data footage or images containing residents captured by CCTV systems are personal data for the purposes of data protection law. What measures will be put place to ensure that CCTV recordings will be stored safely and securely? How long will the recordings be retained for? Who will be the Data Protection Officer, the Data Controller and where will the footage be stored? Will Facial recognition processing be used? If so, it is important to acknowledge that it is considered biometric processing and accordingly the data processed is categorised as “special category” personal data and subject to the requirements of GDPR, which, sets out further conditions to provide for the lawful processing of the data.
At the second open meeting with SDCC officials we were informed that the Council would assign parking to clubs using the facility and if breached, we, the locals, should inform the council and the right to use the facility would be removed from the clubs. This makes us, the locals, data processers under GDPR as licence plates can be linked to an individual. What will SDCC do when all clubs using the facility breach the parking guidelines, leave the 3G pitch as a white elephant to become derelict?
Conflict of Interest
During the open meetings with SDCC officials they indicated that Greenhills Boys AFC will enjoy preferred time slots and there will be a tiered payment structure. Anecdotally we have also heard that other teams have been promised the same deal. Any submissions, therefore, from Greenhills Boys AFC, or others that have been afforded similar agreements must be viewed through the lens of conflict of interest as a pecuniary benefit is the definition of a conflict of interest. We, the local concerned residents, have nothing to gain and everything to lose.
Finally, at the first open Meeting in Tallaght County Hall we were informed by SDCC officials that they had engaged with Greenhills Boys AFC almost one year ago. Consultation with the Knocklyon residents also commenced well in advance of the publication of that proposed Part 8. Where was the consultation with residents in Greenhills? We had to wait until the Part 8 was hung on the field gates to be made aware. There is a lack of transparency around this Part 8 process.
I would urge SDCC to consider that this proposal is only welcomed by one cohort, those who play organised team sports. Greenhills Park is currently used by all, residents and otherwise, no matter their age, ability or level of activity and it provides health benefits for all, as well as the environment.
In summary, I strongly object to the destruction of the open green space in Greenhills Park to be replaced by a 3G pitch and ancillaries for the following reasons:
Thank you for taking the time to read my objection.
Regards
Fionnuala Malone