I wish to make a submission objecting to the proposed rezoning of the St Edmundsbury lands from HA-LV (High Amenity – Liffey Valley) to a residential zoning.

While I acknowledge the need to increase housing supply within South Dublin County, the proposed rezoning of these lands is inconsistent with the principles of proper planning and sustainable development. The proposal would result in the permanent loss of protected high amenity lands forming part of the Liffey Valley, without sufficient planning justification to warrant such a significant departure from long-established planning policy.

1. The Proposal Represents an Unjustified Departure from Long-Established Planning Policy

For many years, the St Edmundsbury lands have been protected under successive Development Plans as part of the Liffey Valley High Amenity area. This zoning reflects the recognised environmental, landscape and recreational importance of the site and has consistently guided planning decisions relating to these lands.

The proposed rezoning would reverse decades of established planning policy. Such a significant policy shift should only occur where there is clear and compelling evidence that the existing zoning no longer serves the public interest. No such evidence has been presented.

The Development Plan exists to provide certainty and consistency for communities, residents and landowners alike. The rezoning of protected high amenity lands without a demonstrable planning necessity risks undermining confidence in the integrity of the Development Plan process.

2. The Elected Members Have Already Declined to Proceed with the Rezoning

It is particularly significant that the elected members of South Dublin County Council did not approve the proposed rezoning when the matter first came before them. Following consideration of the Chief Executive’s recommendations and the public consultation process, the St Edmundsbury rezoning was omitted from the package of rezonings approved by the Council.

The present consultation arises because the statutory process requires a further round of consultation following amendments made by the elected members. However, this should not obscure the fact that the Council has already indicated that it was not satisfied that sufficient planning grounds existed to justify the loss of the existing HA-LV zoning.

No materially different planning circumstances have arisen since that decision. Accordingly, there is no persuasive basis for departing from the position previously adopted by the elected members. To do so would diminish public confidence in the planning process and weaken the importance of meaningful public participation.

3. Protection of the Liffey Valley

The St Edmundsbury lands form part of the wider Liffey Valley landscape, one of South Dublin’s most valuable environmental and recreational assets.

The lands contribute to:

• the visual and scenic character of the Liffey Valley;
• ecological connectivity and biodiversity;
• green infrastructure;
• climate resilience;
• the preservation of open space within an increasingly urbanised area.

These functions extend beyond the immediate locality and are of importance to communities throughout South Dublin and beyond. Once developed, the environmental and landscape value of these lands cannot realistically be restored.

4. Biodiversity and Climate Considerations

National planning policy requires planning authorities to address not only the need for additional housing but also the biodiversity and climate crises.

The loss of protected greenfield lands within the Liffey Valley would reduce habitat availability, weaken ecological networks and diminish natural carbon storage.

The Council should exercise particular caution before releasing lands that have long been recognised as forming part of an important green corridor and landscape resource.

5. Infrastructure Capacity

The wider Lucan area has experienced substantial residential growth over recent decades. This growth has placed increasing pressure on existing infrastructure and public services.

Despite ongoing investment, concerns remain regarding:

• road congestion;
• public transport capacity;
• school places;
• healthcare services;
• community infrastructure.

These concerns are not limited to existing residents of Lucan but affect the wider surrounding communities and those who rely on regional transport and public services.

Major residential development should only occur where the necessary infrastructure either exists or is demonstrably capable of being delivered alongside development.

In the absence of clear evidence that these constraints have been adequately addressed, the proposed rezoning is premature.

6. Availability of Alternative Lands

The need for housing does not require the release of every undeveloped greenfield site.

Significant opportunities remain to accommodate population growth through:

• development of existing residentially zoned lands;
• brownfield regeneration;
• urban consolidation;
• completion of major strategic growth areas already identified within the Development Plan.

Priority should continue to be given to these locations before considering the permanent loss of long-protected high amenity lands.

7. Undesirable Planning Precedent

Approving this rezoning would establish a concerning precedent whereby lands protected for environmental, landscape and amenity reasons may become vulnerable whenever additional housing capacity is sought.

This would weaken the credibility of zoning objectives throughout South Dublin County and reduce public confidence that long-established environmental protections will be maintained.

Conclusion

The St Edmundsbury lands have been protected for many years because of their contribution to the Liffey Valley landscape, biodiversity and public amenity. The proposed rezoning would permanently remove those protections without demonstrating that such a departure from established planning policy is either necessary or justified.

It is also noteworthy that the elected members have already declined to proceed with the proposed rezoning, indicating that they were not satisfied that an adequate planning case had been made. No materially different planning circumstances have emerged since that decision to justify a reversal of that position.

The protection of the Liffey Valley is a matter of importance not only to those living immediately adjacent to the lands but also to communities throughout South Dublin and the wider region who benefit from this important landscape and environmental resource.

For these reasons, I respectfully request that South Dublin County Council:

• reject the proposed rezoning of the St Edmundsbury lands;
• retain the existing HA-LV (High Amenity – Liffey Valley) zoning;
• continue to protect these lands as part of the wider Liffey Valley green corridor; and
• prioritise housing delivery on existing residentially zoned, serviced and brownfield lands in accordance with the principles of proper planning and sustainable development.

Yours faithfully,

Ciara Mc Closkey