Submission on Proposed Material Alterations to Proposed Variation No. 2 to the South Dublin County Development Plan 2022–2028 (St Edmundsbury, Lucan)

To: South Dublin County Council

Re: Proposed Material Alterations to Proposed Variation No. 2 to the South Dublin County Development Plan 2022–2028

I wish to make this submission in support of councillors voting not to make the proposed material alterations to Proposed Variation No. 2 to the South Dublin County Development Plan 2022–2028. I respectfully ask the elected members to reject the proposed material alterations and to ensure that any changes to the Development Plan are made only where they are clearly justified, evidence-based, environmentally sound, and consistent with the proper planning and sustainable development of South Dublin County.

Grounds for Supporting a Vote Not to Make the Proposed Material Alterations

The proposed material alterations arise after the public consultation on Proposed Variation No. 2 and after the consideration of submissions and the Chief Executive’s Report. While the statutory process allows for material alterations to be considered, the scale and significance of the proposed changes mean that councillors should exercise particular caution before making them. A vote not to make these material alterations would be a reasonable and responsible decision where the alterations have not been shown to be necessary, proportionate, or sufficiently supported by the evidence before the Council.

1. The Development Plan Should Not Be Altered Without Clear and Robust Justification

The South Dublin County Development Plan 2022–2028 is the statutory framework for the orderly planning and sustainable development of the county. Any material alteration to that plan should be supported by a clear planning rationale and by sufficient evidence that the change is required at this stage. Where proposed alterations would significantly change land use zoning, settlement strategy, infrastructure expectations, environmental considerations, or local community outcomes, councillors are entitled to conclude that such changes should not proceed unless the justification is compelling.

2. Proper Planning Requires Alignment Between Housing Growth, Infrastructure and Services

Housing delivery must be supported by adequate infrastructure, including transport, schools, childcare, water services, drainage, open space, community facilities, healthcare access, and active travel connections. A vote not to make the proposed material alterations would support a plan-led approach that avoids rezoning or policy changes ahead of confirmed infrastructure capacity. It is not sufficient to identify land for possible development without also demonstrating that communities can be properly served and that new growth will not place unacceptable pressure on existing residents and services.

3. St Edmundsbury, Lucan: Nature, Biodiversity and Green Infrastructure Should Be Protected

Particular care is required in relation to the St Edmundsbury lands in Lucan. These lands are not simply vacant or underused land; they form part of an important green setting with mature trees, hedgerows, open fields, woodland character and a strong relationship with the wider Liffey Valley landscape. Publicly available planning material refers to the area as being associated with river valley and riparian corridor landscape character, with objectives to preserve and enhance existing woodlands and hedgerows at St Edmundsbury and to explore improved connectivity between Lucan Demesne and the St Edmundsbury lands. This demonstrates that the area has a recognised role in green infrastructure, landscape quality and ecological connectivity.

At a local level, St Edmundsbury provides an increasingly rare natural buffer in Lucan, an area that has already experienced very substantial residential growth. Its trees, hedgerows and open lands support biodiversity, provide habitat and movement corridors for wildlife, contribute to carbon storage and urban cooling, assist natural drainage, and offer residents visual relief from continuous built development. The loss or fragmentation of such natural assets cannot be fully compensated for by small landscaped spaces within future development, particularly where mature landscape features have taken decades to establish.

The nature value of St Edmundsbury should therefore be treated as a central planning consideration, not as a secondary matter to be addressed later. Any material alteration that could weaken the protection of this green corridor, reduce access to nature, undermine woodland or hedgerow protection, or intensify development pressure on the Liffey Valley setting should be rejected unless it is clearly proven to be environmentally necessary, sustainable and compatible with the long-term protection of Lucan’s remaining natural landscape.

4. Environmental and Flood-Risk Considerations Must Be Treated Conservatively

The proposed material alterations are accompanied by environmental screening and flood-risk documentation. However, the presence of such documentation does not remove the responsibility on councillors to apply a precautionary approach. Where there is uncertainty about environmental effects, cumulative impacts, biodiversity loss, climate resilience, drainage capacity, or flood risk, the prudent course is to avoid making material alterations until the Council is satisfied that all risks have been fully assessed and addressed.

5. Public Confidence in the Development Plan Process Must Be Protected

The original Proposed Variation No. 2 was already subject to public display and generated a substantial level of public engagement. The introduction of material alterations after that stage can create concern among communities, particularly where residents feel that significant changes are being advanced without the same level of scrutiny as the original plan. By voting not to make the proposed material alterations, councillors would demonstrate that public consultation is meaningful and that major changes to the Development Plan will not be adopted unless there is broad, transparent and evidence-based support for doing so.

6. A Plan-Led Approach Is Preferable to Piecemeal Alteration

The Development Plan should provide certainty for communities, landowners, service providers and public bodies. Material alterations that significantly adjust the plan outside a wider, fully integrated review risk creating a piecemeal approach to development. A decision not to make these material alterations would not prevent appropriate future planning decisions; rather, it would ensure that any future changes are considered through a comprehensive process that properly weighs housing need, infrastructure delivery, environmental constraints, community facilities and local character.

Conclusion

For the reasons set out above, I support councillors voting not to make the proposed material alterations to Proposed Variation No. 2 to the South Dublin County Development Plan 2022–2028. Such a vote would be consistent with a cautious, transparent and plan-led approach to development. It would also help ensure that any future changes to the County Development Plan are founded on robust evidence, full consideration of infrastructure and environmental capacity, and the proper planning and sustainable development of South Dublin County.

I respectfully request that the elected members do not make the proposed material alterations.