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DCRA Submission to EU Commission

TO:Commissioner Margot Wallstrom, The European Commission

Re: Environmental Impact Assessment Directive 85/337 and Dunboyne, Co. Meath, Ireland.

Dear Ms. Wallstrom

The Dunboyne Combined Residents Association (DCRA)has a membership of sixteen Residents Associations and represents more than 80% of the 5,000 population of our village. We are interested in both the development and the preservation of Dunboyne and its environment. Meath County Council is in the process of drawing-up a county development plan. As a community participating in this process throughout the past eighteen months, we have been in communication with Meath County Council (to whom we have submitted various documents), County Councillors, our Prime Minister (An Taoiseach), The Minister for the Department of the Environment and Local Government, Members of Parliament (TDs), Members of our Senate, Members of the European Parliament, specialists, consultants and support organisations.

We now feel it necessary to contact you for your active support.

The Irish Department of the Environment and Local Government recently authorized a major study to provide a coherent strategic planning framework for Development Plans and for the provision of major transportation, sanitary services and other infrastructure for the local authorities in the Greater Dublin Area which includes the county of Meath. The study was undertaken by a team of consultants under a Steering Committee, a Technical Working Group and a Local and Regional Authorities Members Committee. The Strategic Planning Guidelines that emerged represent the preferred option from a number of alternative models that were assessed. The strategy embraces the principles of sustainable development as set out in the National Sustainable Development Strategy and adopted by the Irish Government and conforms to similar principles emerging from the European Spatial Development Perspective.

The Strategic Planning Guidelines were formally accepted by Department of the Environment and Local Government and each of the seven local authorities in the greater Dublin Area were instructed to amend their current development plans so as to conform to the new guidelines. Under these circumstances and in view of the scope of the basic study, there must be full regard for compliance with the Environmental Impact Assessment EU Directives in accordance with the EU Directive 337/85. Furthermore the Strategic Planning Guidelines have now been incorporated in the new Planning and Development Act 2000 and so enjoy the force of law. Therefore, failure by any of the local authorities concerned to ensure that their development plans conform to the new guidelines should be regarded as a very serious matter and one which should immediately demand corrective action by the Department for the Environment and Local Government.

The total amount of land zoned and proposed in the current Draft Development Plan would allow the population of Dunboyne to grow from 5,000 to 13,000 an increase of 136%. The projected population for Dunboyne for 2006 is 8,000. This is the re-zoning of lands beyond population projection requirements. Clonee is a village approximately one kilometer east of Dunboyne and has a population of 350. The proposal to rezone 250 acres of land for industrial use is contrary to the Strategic Planning Guidelines and will inevitably incur a major increase in travel in the area.

The European Environmental Impact Assessment Directive 337/85/EEC, as amended by Council Directive 97/11/EC, we understand is normally applied to individual developments. However, because of the major environmental impact for South Meath, and especially for Dunboyne, due to the massive housing and other developments being proposed by Meath County Council, we are asking that a holistic EIA be undertaken for the area, and especially for Dunboyne and surrounds, and that this should be undertaken prior to the rezoning of lands for development. We have been informed that the final decision on the rezoning of lands for development for Dunboyne will be taken by Meath County Council when the period of public consultation ends on 20^th December 2000.

The basic objectives of the Strategic Planning Guidelines for the Greater Dublin Area are to:-

• Fundamentally seek to reduce the growth in the need for travel
• Prevent urban sprawl and create a clearer demarcation between urban and rural areas.
• Encourage a shift towards public transport modes.

These are to be achieved by adopting a separate strategy for the metropolitan area and for the hinterland areas of the region. Future development is to be concentrated in the metropolitan area and in designated growth centres in the Hinterland area. Development in all other parts of the hinterland area is to be strictly confined to meeting local needs.

The revised development plan for County Meath in no way complies with any of the above objectives and there is wide spread opposition to it. According to the maps furnished with Strategic Planning Guidelines the Hinterland Area includes all of County Meath where, according to the strategy, no significant development is permitted except for Navan, the designated growth centre for the county. In contrast, Meath County Council development plan amounts to little more than widespread urban sprawl. Excluding Navan, the designated growth centre for the county, according to Meath County Council's proposed development plan the population of the main towns and villages is planned to grow by 274% from a total of 28,200 in 1996 to a potential of 105,775 by 2011. A population explosion of this magnitude would result in massive commuting with all its objectionable features and consequences.

Clearly there is urgent need for Ireland to reduce emissions of carbon dioxide in order to meet its commitments under the Kyoto Protocol. This does not seem to carry any weight with the local politicians. It is worth mentioning that our emission of green house gases is already above the 2010 target and the emission of carbon dioxide by the transport sector in Ireland is forecast to rise by a massive 190% above the 1990 level by the year 2010.

It is now possible to obtain copies of Minutes of Council Meetings. These reveal that the advice of experienced planners has been ignored or overruled by the local politicians. They appear to have formed an alliance across party lines to promote their own private agenda. There is evidence that among other things this agenda is designed to support a demand for the reinstatement of the old rail link between Dublin and Navan and to bring this about by generating an obvious need for travel. The belief is that if the rail link were to be restored then, in order to ensure the economic operation of a satisfactory service, it would be almost impossible to oppose further almost unlimited development in towns along its route. It is therefore clearly intended that the development of extended urbanisation along its route is seen as necessary evidence to argue for the provision of a railway. The Dunboyne Combined Residents Association are opposed to this program because it would result in the destruction of the quality of life in the region, especially in Dunboyne, and in planning terms is flawed. DCRA asks that prior to any decision regarding the possible reinstatement of the Dublin to Navan rail link a special EIA be undertaken and we urge the Commission to take this matter up with the Irish authorities as a priority. We believe that this would be in the best interests of all concerned.

We are aware that under Council Directive 85/337/EEC, as amended by Council Directive 97/11/EC, the public have a right to participate in environmental decision making. Meath County Council's Mission Statement commits itself to work co-operatively and in partnership with local communities. We regret to inform you that the attitude to involvement by our village community in partnership with Meath County Councillors, can be gauged by reference to the statement made by the County Council Chairman at the time and which appeared in the local press: 'WE should not cave in to local pressure'. The Dunboyne Combined Residents Association agrees with the South Meath Planning Alliance, of which the Dunboyne Combined Residents Association is a member, which recently called for the resignation of our six local County Councillors because of their failure to democratically represent local communities in South Meath, their rejection of the advice given by Meath County Council professional planners and their dismissal at several meetings of the Strategic Planning Guidelines.

The Dunboyne Combined Residents Association wish to draw the attention of the Commission to the fact that the village of Dunboyne was recently subject to severe flooding and many houses which were built within the past 10 years were damaged. No EIAs were done in the case of developments concerned because they formed only a fragment of the total development plan for the area and therefore did not come within the scope of the Directive. What is even more reprehensible however is the fact that objections to the proposed schemes by those living in the area including an Engineer with particular experience in such matters, were totally ignored not only by Meath County Council but also by An Bord Pleanala (the Irish Planning Appeals Board). The Dunboyne Combined Residents Association are particularly concerned because the present development plan also contains proposals to rezone large areas of land for housing which were actually extensively flooded on this occasion. If the proposed development plan is ratified then it is very likely that project splitting will be used to avoid thresholds under the Environmental Impact Assessment Directive. Consequently, Resident Associations will be faced with an intolerable financial burden if they are to bring their objections to the appeal board. The Dunboyne Combined Residents Association reasonably demands that no rezoning of lands for development should be considered in or near Dunboyne village until after a full area hydro-geological and hydro-engineering survey is carried out.

We commend the Minister for the Environment and Local Government, Mr. Noel Dempsey, for his foresight in producing the Strategic Planning Guidelines for the Greater Dublin Area. It would be regrettable to have these guidelines undermined now by the establisment of precedents. We would urge the Commission to take up our cause with Mr. Dempsey.

Contact:

Jim McGrath, Chairman, Dunboyne Combined Residents Association, 9 Elton Drive, Millfarm, Dunboyne, Co. Meath Tel: 01.8252189.

Email: mcgrathjim@esatclear.ie