I respectfully request that South Dublin County Council retain the existing High Amenity designation for the lands at St Edmundsbury, Lucan.

This submission is based on consistency with the Planning and Development Act 2024, the National Planning Framework (First Revision, 2025), the Regional Spatial and Economic Strategy (RSES) for the Eastern and Midland Region, and the environmental objectives of the South Dublin County Development Plan.

1. Compliance with the National Planning Framework

The National Planning Framework (NPF) establishes that sustainable development must balance housing delivery with the protection of environmental assets, biodiversity, green infrastructure, landscape character and community wellbeing.

The NPF recognises that green and blue infrastructure forms an essential part of Ireland’s natural capital and should be integrated into all statutory land-use plans. Existing green infrastructure is not simply undeveloped land but strategic infrastructure that delivers biodiversity, ecosystem services, climate resilience and public health benefits.

Retaining the High Amenity designation at St Edmundsbury is therefore entirely consistent with the strategic direction of the NPF.

2. Protection of Green Infrastructure and Natural Capital

St Edmundsbury forms part of Lucan’s wider green infrastructure network.

The site contributes significantly to:

• biodiversity;
• ecological connectivity;
• carbon storage;
• urban cooling;
• sustainable drainage and flood attenuation;
• air quality;
• visual amenity; and
• recreational open space.

These ecosystem services represent valuable natural capital that cannot readily be replaced once lost.

The NPF specifically promotes the integration of green infrastructure into planning policy because it delivers long-term environmental, economic and social benefits.

Removing the High Amenity designation would be inconsistent with this objective.

3. Biodiversity and Ecological Corridors

The lands provide an important ecological link within the wider landscape surrounding Lucan and contribute to habitat connectivity associated with the River Liffey corridor.

Development would fragment existing habitats and sever ecological corridors that support birds, pollinators, mammals and other wildlife.

The NPF and the RSES both recognise that maintaining connected ecological networks is fundamental to reversing biodiversity loss and increasing resilience to climate change.

The precautionary principle should therefore favour the retention of established ecological assets where permanent fragmentation may occur.

4. Climate Resilience

Climate action is one of the central pillars of the National Planning Framework.

Protecting existing green infrastructure is recognised as one of the most effective and economical climate adaptation measures available to planning authorities.

The St Edmundsbury lands currently provide nature-based climate solutions through carbon sequestration, natural drainage, urban cooling and flood mitigation.

These environmental services will become increasingly valuable as climate change intensifies.

Retaining the High Amenity designation directly supports Ireland’s transition to a climate-resilient society.

5. Landscape Character, Heritage and Sense of Place

The National Planning Framework places significant emphasis on creating places with a strong identity and protecting landscapes that contribute to local character.

St Edmundsbury contributes to Lucan’s distinctive sense of place through its mature trees, open landscape, visual prominence and relationship with the historic landscape of the area.

Its landscape quality is an important element of Lucan’s identity and should be regarded as a strategic environmental asset rather than a reserve for future development.

Development would irreversibly alter the landscape character and diminish the environmental setting that contributes to Lucan’s heritage and attractiveness.

6. Community Wellbeing

The NPF recognises that high-quality green spaces are essential infrastructure for healthy communities.

Accessible natural landscapes contribute to physical health, mental wellbeing, recreation and social cohesion. St Edmundsbury was discovered by so many people during the pandemic & it holds a special place in the hearts of so many people.

As Lucan continues to grow, the protection of existing High Amenity lands becomes increasingly important to maintaining quality of life for both existing and future residents.

These lands therefore provide long-term public value extending well beyond their immediate boundaries.

7. Regional Spatial and Economic Strategy

The Regional Spatial and Economic Strategy (RSES) reinforces the objectives of the National Planning Framework by requiring local authorities to:

• protect strategic green infrastructure;
• strengthen biodiversity networks;
• safeguard ecosystem services;
• conserve landscape character;
• promote nature-based solutions; and
• improve climate resilience.

Retaining the High Amenity designation at St Edmundsbury is fully consistent with these regional objectives.

8. River Liffey Green Infrastructure Network

Given the site’s proximity to the River Liffey Valley, the lands contribute to the wider green infrastructure network associated with one of Dublin’s principal natural corridors.

This wider network provides ecological connectivity, visual continuity and landscape character extending beyond the site itself.

Fragmentation of this green infrastructure would weaken the resilience of the broader environmental network and diminish its ecological function.

Protecting buffer lands adjacent to strategic river corridors is recognised as good planning practice and supports both biodiversity conservation and climate adaptation objectives.

Conclusion

The St Edmundsbury lands:

• protect biodiversity and ecological connectivity;
• form part of Lucan’s strategic green infrastructure;
• preserve landscape character and heritage;
• contribute to climate resilience;
• provide essential ecosystem services;
• enhance public amenity and community wellbeing; and
• reinforce Lucan’s distinctive sense of place.

For these reasons, I respectfully request that South Dublin County Council retain the existing High Amenity designation for St Edmundsbury and reject any proposal that would facilitate development that would compromise these nationally recognised environmental assets.

References

1. Planning and Development Act 2024.
2. National Planning Framework – First Revision (Department of Housing, Local Government and Heritage, 2025).
3. Project Ireland 2040 – National Planning Framework.
4. Regional Spatial and Economic Strategy (RSES) for the Eastern and Midland Region (2019–2031).
5. South Dublin County Development Plan (current edition).

 

 

Policy Document	Relevant Theme
Planning and Development Act 2024	Sustainable development; consistency with national and regional policy
National Planning Framework (2025 First Revision)	Green and blue infrastructure; biodiversity; ecosystem services; climate resilience; quality of place; heritage; healthy communities
Regional Spatial and Economic Strategy (EMRA)	Green infrastructure networks; landscape protection; climate action; ecosystem services; healthy placemaking
South Dublin County Development Plan	Biodiversity, Green Infrastructure Strategy, landscape character, High Amenity lands, River Liffey Corridor