This submission is made by KPMG Planning (within KPMG Ireland, of the above address) in response to the Proposed Material Alterations to Proposed Variation No. 2 to the South Dublin County Development Plan 2022-2028. It is made jointly on behalf of Cairn Homes Plc (“Cairn”), as strategic delivery partner, and the landowner, the Crowley family (c/o 45 Mespil Road, Dublin 4, D04W2F1), in respect of lands known as “Adamstown South” adjoining and to the south of Adamstown Train Station, Lucan, Co. Dublin.

Cairn’s submission is focused on three interrelated matters:
-Addressing the implications of the Proposed Material Alterations for the overall housing capacity, resilience and delivery assumptions underpinning Proposed Variation No. 2;
-Reaffirming the strategic importance of Adamstown South and West Outer within the future growth framework now being advanced by Council, seeking a strengthened and more time-bound policy commitment to actively progress the necessary technical, infrastructural and masterplanning work during the lifetime of the current Development Plan; and,
-Highlighting Cairn’s concerns regarding the proposed restriction on bulk purchases of residential units, including the risk that the wording, if retained in its current form, could undermine legitimate housing delivery models, specifically create uncertainty for apartment development, and fail to make appropriate provision for the role of Council, The Land Development Agency (LDA), Approved Housing Bodies (AHBs) and other State-supported housing delivery mechanisms.

Cairn respectfully submits that the final adopted Variation should be strengthened in three respects:
1.by including a reconciliation of the revised housing capacity position following the elected members’ amendments;
2.by providing a clearer and more active pathway for progression of Adamstown South and West Outer as a Future Strategic Development Area; and,
3.by materially amending the proposed bulk purchase restriction so that it does not constrain apartment delivery, State-supported acquisition mechanisms, LDA activity, affordable housing, cost-rental delivery or other legitimate mixed-tenure housing models.