A Submission on Proposed Material Alteration 6.1 to the South Dublin County Development Plan 2022–2028 regarding the lands at St. Edmundsbury, Lucan

3/08/2026

From: Colm Gallagher

Personal Information

On behalf of: Liffey Salmon Project

 

 

BACKGROUND:-

Liffey Salmon Project

LSP was formed in 2020 with the aim of restoring populations of anadromous fish such as salmon, sea trout, freshwater eel and river lamprey to favourable status in the river Liffey and its tributaries.  The group does not view the river in isolation and is dedicated to protecting the rich biodiversity of the Liffey valley as a whole.  LSP has striven to build good working relationships with statutory bodies such as IFI and SDCC and with major stakeholders such as ESB, Uisce Éireann and Intel Ireland.  With funding from LAWPRO and ESB it is progressing projects in the Liffey catchment aimed at improving habitat and fish passage.

 

Liffey Weirs Project

In March 2025 the group was instrumental in bringing together representatives from Dublin City Council, SDCC, Fingal Co Co, IFI and LAWPRO in a co-ordinated effort to improve fish passage at the seven weirs between Islandbridge and Leixlip dam.  It was agreed that Fingal Co Co would lead the project and funding was successfully sought from the Inland Fisheries Ireland Barriers Programme.  Consultants MKO have been appointed to survey the barriers and to liaise with all stakeholders in finding solutions.  LSP will be represented on the steering group which will include representatives from the three local authorities above.

 

 

 

SUBMISSION:-

On behalf of Liffey Salmon Project, I am writing in support of the June 19th decision of the elected members to reject the proposed rezoning to ‘Residential’ of the lands at St. Edmundsbury and to retain their existing High Amenity(HA-LV) zoning.

 

Biodiversity

Retaining the existing zoning will help to protect the rich biodiversity of the Liffey valley. Its value has already been recognized by NPWS by its designation as a pNHA, hosting, as it does, threatened species listed in the Protected Species: Flora Protection Order and Annex IV species such as otter and numerous bat species.  There are also several established badger sets on the St Edmundsbury lands. Bird species such as Common Buzzard, Kestrel, Jay and Treecreeper are thriving in the relative peace of the riparian woodlands.  Recent sightings suggest that Pine Marten and Woodpecker may now be resident in the woodlands of St. Edmundsbury and Luttrellstown.

In addition to the adverse impacts of habitat loss and fragmentation, the light and noise pollution and human disturbance which would inevitably follow residential development on these lands will have a negative impact on all these species and on biodiversity in general.

 

Climate Action

In its own Climate Action Plan SDCC has identified key measures for Climate Action.  The SDCC plan emphasises the importance of ‘Nature Based Solutions’ such as:-

• Carbon sequestration
• Providing and enhancing habitats, biodiversity and ecosystems
• Preventing/reducing flooding by absorbing water and helping to control surface water run-off

The lands at St. Edmundsbury play a significant role in fulfilling all of these stated aspirations.

 

Public Amenity

In its brochure, ‘Protecting and developing Ireland’s green and blue spaces to benefit our health and wellbeing’ the EPA states that ‘human health protection is a fundamental aspect of environmental protection. Our health is impacted by the air we breathe, the water we drink, the noise levels we experience, the food we eat, the spaces we spend time in, and our sense of wellbeing.’

It further states that ‘from the perspective of spatial planning, healthy places are increasingly espoused internationally and nationally. By enhancing the provision and design of green spaces, local authorities and public agencies can contribute towards key objectives within the National Planning Framework (2018) relating to healthy communities, compact growth and sustainable land-use management.’

Maintaining the High Amenity zoning is, therefore, entirely consistent with the principles of proper planning and sustainable development.

SDCC already recognises the importance of these lands. They are currently zoned High Amenity – Liffey Valley (HA-LV) in order to protect the area's special landscape, enhance the Liffey Valley and preserve ecologically sensitive areas from intensive development.  Given the explosion in population in the Lucan area of the last 30 years it seems entirely inappropriate to rezone these lands for housing.  Lucan has borne a substantial share of housing delivery for the entire county. There is

already significant land zoned for residential development in the area, including two Special Development Zones at Adamstown and Clonburris.

 

Liffey Valley Land Banks

The purchase by the state of Lucan Demesne in 1996 was a far-sighted and brave decision, given the economic constraints of the time.  To its credit SDCC has recently acted in a similarly enlightened manner by acquiring Lucan House and lands in 2024.  With its recent acquisition of Bleach Green on the adjoining north bank of the river, Fingal Co Co has brought another valuable tract of Liffey valley lands into public ownership.

The preservation of the St. Edmundsbury lands would further consolidate this critical land bank and elevate it to national significance. If these lands are rezoned for housing, the aspiration of creating a Liffey Valley National Park will be lost.  Rather than being rezoned, the existing Special Amenity Area must be extended to cover all of the lands in St. Edmundsbury.

 

Services

Lucan has inadequate services for its already burgeoning population: poor public transport, insufficient school places, insufficient healthcare facilities, significant traffic congestion, under-resourced youth facilities and extreme pressure on utilities and drainage. Time is needed for services to catch up.  Building yet more houses in this area will make this situation even worse.

 

For these reasons, I ask, on behalf of Liffey Salmon Project that the elected members’ decision be upheld and that the existing High Amenity zoning at St. Edmundsbury be retained.

 

Signed: Personal Information

Liffey Salmon Project.