Dunboyne Combined Residents Association
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Final DCRA Submission to MCC, Dec 2000
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Submission to Meath County Council on The County Meath Draft Development Plan 2000 Dec 20, 2000
Table Of Contents:
Meath County Draft Development Plan and amendments to same fail to promote sustainable development. The process of consultation with residents of Dunboyne has been deplorable. The Draft Plan and amendments will severely damage the quality of life and the living environment of the residents of Dunboyne. "Towards A Dunboyne Development Plan 2000" submitted in July '99 "The County Meath Development Plan 2000", submitted in June 2000 " Survey of Trees with Special Amenity Value", submitted February 2000 Apart from a cursory acknowledgement of receipt of these documents there is very little evidence that the wishes of our community expressed there-in have been included or have influenced your Draft County Plan or amendments to same. Regrettably, there has been an outright rejection of DCRA's two main proposals in respect of Dunboyne Castle Demesne and green belt lands east of the old railway line. It is a matter of record that these proposals were supported by the residents of Dunboyne by the submission to Meath County Council of approximately 1, 600 signed letters and by the vote of 700 people at a public meeting for the preservation of the green belt lands east of the railway line.
The Councillors in question cannot be said to be acting as representatives of our community. 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 potential population, if all these proposed rezonings go through together with the lands already zoned from previous development plans, would increase the population from its present 5,500 to 14,000. The proposed rezonings and consequent developments proposed are intended to satisfy overspill and immigration resulting in urban sprawl and not, as required by the Strategic Planning Guidelines, to meet local needs. "Given the recommendations of the Strategic Planning Guidelines for the Greater Dublin Area it is envisaged that this should be directed at the consolidation of the town and addressing key housing needs local to the area rather than absorbing the town into the Metropolitan area of nearby Fingal area. To this end, this plan provides for the development of a number of key infill sites." (MCC Draft Dev. Plan:13.1.7) It is further stated: "The existing allocation of water services for Dunboyne is effectively fully committed" and "Any further rezoning for residential development would be dependent on the expansion of sewage capacity."(MCC Draft Dev. Plan: 13.1.7) Appraisal of Statistical Basis A review of the reasons for the current development plan and its statistical foundations would be worthwhile at this time before the amended version is approved. Following the introduction of the Strategic Planning Guidelines for the Greater Dublin Area, all the local authorities involved were instructed to bring their current plans into line with the guidelines as a matter of urgency. The preparation of the guidelines required a thorough analysis of current population trends in the Greater Dublin Area in order to provide a sound basis for future development. Clearly the current development plan for County Meath must also of necessity be based on the statistical forecasts of the Strategic Planning Guidelines. Table 1 shows the Strategic Planning Guidelines forecasts for the Greater Dublin Area from 1996 to 2011. Column two gives the population forecast that would obtain in the absence of any migration, that is, based on organic growth alone. A separate analysis was done to determine the effects of migration on future population trends taking account of CSO labour predictions and similar factors. Three levels of migration were studied low, medium and high. For planning purposes the high levels were recommended despite some misgivings that the resulting forecast level for 2011 might not be reached until after 2011. The forecasts, subsequently amended upwards in 2000, are shown in column three. To summarize, assuming high levels of migration the population of the region could increase by some 25% by the year 2011. One cannot comment on the likelihood of this event, however, in view of the absence of any statistical information (standard errors, significance test results and confidence intervals) that usually accompanies forecasts of this nature. Appendix 3 of the Strategic Planning Guidelines also provide the population forecasts for County Meath that would obtain in the absence of migration and these indicate that a population of some 119, 000 would be reached by 2011 representing an increase of 8.6%. The Insert in the MCC Amendments to Section 2.2.3 of the Draft Development Plan states 'Assuming that the county plays its part of a regional population dynamic, the revised projections of the Strategic Planning Guidelines for the Greater Dublin Area indicate that a population of approximately a 130000 could be reached in 2011,161000 in 2006 and 180000 in 2011. In turn, of the order of 15000 extra households would need to be accommodated by 2006 and a further 18000 by 2011.' These projections represent a massive population growth of 64% by the year 2011, almost three times the maximum increase of 25% expected by the Strategic Planning Guidelines for the Greater Dublin Area as a whole and confirm the widespread opinion that MCC is pursuing a policy which is totally at variance with the principles of the Strategic Planning Guidelines. Because all of County Meath is in the Hinterland Area where according to the guidelines, apart from Navan which is the specified growth centre, development is to be confined strictly to meeting local needs, it could be argued that for planning purposes the appropriate forecasts should be based solely on organic growth. This would imply a modest population increase of some 9% up to the year 2011. Even if consideration is given to the intended development of Navan as a growth centre it would be difficult at present to put forward valid reasons for a planned population increase approaching the 25% for the Greater Dublin Area as a whole. This is because the guidelines envisage that future development would be concentrated in the Metropolitan Area. It is appropriate here to make the point that the common practice of forecasting on the basis of historical population trends is hardly relevant in the present context because the underlying process is basically deterministic rather than stochastic. The recent unprecedented population explosion is almost entirely due to immigration caused by a benevolent attitude towards urban sprawl, ribbon development and similar objectionable practices. Consequently recent population increases can readily be calculated from the number of new houses for which planning permission was given. Therefore, the usual forecasting techniques would only serve to permit further urban sprawl based on the amount of urban sprawl that has already been allowed to occur. This amounts to an unacceptable form of self-fulfilling prophesizing that can be perpetuated. Irrespective of any broad statement of policy about planned population projections, the likely outcome in reality can be estimated from an analysis of the Settlement Structure corresponding to the respective proposed zonings shown on the various maps. It will now be seen that a population increase of 110% would actually occur if the zonings presently proposed by the councillors are implemented. To put this in perspective, if the population growth rate forecast by the Strategic Planning Guidelines, based on the highest migration scenario, were to apply to County Meath indefinitely then the potential population resulting from the present proposed zoning would provide for future growth up to the year 2045 or for many years more at the estimated organic growth rate.
The recent severe flooding in Dunboyne is cause for serious concern. The Castle River was the source of the flooding in Dunboyne village, Woodview Heights, Beechdale and Larchfield estates. Serious flooding occurred at Bennetstown where the Tolka overflowed. East of the railway line there was expansive and severe flooding. The damage to homes and to their value, and the trauma caused to families, has been immense. The flooding was aggravated by housing developments that have been undertaken in recent years. Additional development will increase the risk of future flooding. Should Meath County Council decide to rezone and develop any lands in or adjacent to the village of Dunboyne they will be acting against the expressed wishes of residents and against the provisions of the Strategic Planning Guidelines for which both the Council and County Councillors will be held to account. We propose that Dunboyne Castle and grounds be developed for tourism and amenity uses. The mature wooded grounds, sweeping lawns, secluded walks and central location which is easily accessible to all residents of Dunboyne, make it an ideal location for a town park. While most housing estates have a number of small open spaces there is no proper park in the area and this is the only suitable land left for this purpose. We believe that the State should purchase this demesne as a regional tourism amenity with the castle developed along the lines of Malahide Castle, Ardgillan Castle and Newbridge House heritage craft centres. There are no such facilities in South Meath or indeed in the adjoining North/West Dublin area covering the Greater Blancharstown/Castleknock area which now has a population fast approaching 100,000. The grounds could be used for much needed football playing pitches for the GAA and soccer clubs and other such field sports. Alternative suitable uses for the demesne would suggest a hotel/leisure complex including golf. There are very few remaining country estates with such character and potential so close to the City and we feel it should be zoned as a community and regional amenity and leisure facility. Dunboyne Castle and lands are not only important tourist attractions but also are part of our local and national heritage which must be protected and preserved. Should additional land be needed for development there is land available in Dunboyne. But there is only one Castle and demesne and it's present zoning for agriculture should remain. Reasons put forward by the Councillors for rezoning the Castle lands. Reasons put forward by the proposer, Mary Bergin and by the seconder, Brian Fitzgerald:-
DCRA'S Reply This does not refer to the question of rezoning and cannot be used as an argument in support of rezoning. The term "phased basis" development is not enforced by Meath County Council as has been the experience in the development of Millfarm. MCC failed to enforce the phased development of Millfarm on the developer John Connaughton despite strong representation from the Millfarm Residents Association. The proof of this is that Open Space No. 3, which should have been landscaped on completion of phase 3, was not landscaped, while the developer was allowed by MCC to develop phase four and move off site. Meath County Council it seems are either unwilling or unable to enforce phased development. Despite Meath County Council having a Bond to protect residents in such instances there were no moves to ensure the developer complied with the phased development of Millfarm. DCRA Reply MCC Senior Planner in response said there are serious constraints in terms of waste water capacity at present. "The existing allocation of water services for Dunboyne is effectively fully committed" and "Any further rezoning for residential development would be dependent on the expansion of sewage capacity."(MCC Draft Dev. Plan: 13.1.7). It is our reliable information that Fingal County Council has barely enough capacity to service the lands already zoned for development in their area of authority and are not likely to increase, in the foreseeable future, the capacity (for a population of 5,000) allowed for Dunboyne. In fact services are not currently available to meet the developments proposed. For Meath County Council to rezone for massive developments given this situation would seem to be highly irresponsible. The primary outcome of this rezoning will be to increase the value of the lands proposed for development. DCRA Reply An Area Action Plan requirement is connected to planning not to rezoning and therefore does not apply here. An Area Action Plan is usually funded by the developer and drawn up by his planning consultant with little community input.
DCRA Reply At a large public meeting in Dunboyne in 1996 to discuss the 1997 Draft Development Plan for Dunboyne the proposal to include a distributor road was unanimously rejected by the meeting and in fact that proposal was removed from that plan a few weeks later. Councillors Conor Tormey and Mary Wallace (Fianna Fail Newsletter '96): "That the By-Pass road section from the Maynooth Road to the Rooske Road was dropped by agreement by our local five Councillors". The development of this distributor road is being introduced to facilitate a housing development that is not necessary to meet local needs and is contrary to the expressed wishes of residents. The Residents of Rooske Road and the estates off it are strongly opposed to the development of this distributor road as it would be used as a "rat run" especially for heavy traffic. In planning terms the proposal is ill conceived. Other Points Raised by Members in support of the rezoning of the Castle lands
DCRA Reply The price of destroying a unique community heritage to gain lands for community facilities which Meath County Council should provide for a town of Dunboyne's size is dearly bought. These are the only lands left in Dunboyne with such rich landscape and trees and, most importantly, these lands enjoy a central location to provide a much needed community facility and public park for the people of Dunboyne and a regional tourism amenity for the surrounding area including Dublin 15. If this amenity was located in any other town in such close proximity to Dublin it would be purchased by the State and developed for amenity and tourism uses like others of its kind including the Lucan Demesne, recently acquired by the State, in adjoining Fingal. The only reason this is not happening is because our politicians don't have the political foresight or will to see the treasure we are losing here. What good will 20 acres of community grounds do for our community when we increase our population by another 2000 as a pay off? The answer is that when these new residents move in we will have an even greater shortage of community land. Of course this will give the Councillors more reason to rezone additional lands once again with a community planning gain. This is highly questionable planning. DCRA condemns the practice of the incentivisation of selected organisations, to the exclusion of the majority of residents in our community, to achieve rezoning objectives. The seconder of this motion, Brian Fitzgerald said at a pre-election meeting called by DCRA in May 1999 said that the Dunboyne Castle lands "… must stay in their present zoning". In his pre-election manifesto he promised to ensure that Dunboyne Castle and its lands would remain zoned as at present and not be changed to residential. The primary beneficiaries of the rezoning of these lands and the destruction of this amenity forever is certainly not the residents of Dunboyne. If kept in its present zoning it could be purchased back by the state allowing a generous profit to the owners to which they would be entitled. This rezoning is premature, unnecessary and very bad planning. DCRA Reply The development of a hotel is a commercial enterprise and should be viable and justified as such. It is a flawed planning principle that a developer needs be gifted with the rezoning of 50 acres of land for housing so that a hotel can be developed. Meath County Council has no such obligation. The development of 50 acres of housing is not required to meet local needs. How can building houses on 50 acres of Castle grounds facilitate the development of a hotel? It certainly will not improve the ambiance of the Castle and will if anything be a disincentive to the environmental and holistic development of the demesne. If the present owners had wished to develop a hotel prior to this rezoning they made no such moves that we are aware of. DCRA Reply Dunboyne Castle Demesne should be maintained and protected as one unit. DCRA Reply Reply as in No.1 above. DCRA Reply A decision was made by the Meath County Council at its meeting on 29th April '96 that there would be no more rezoning of land in the Dunboyne area for five years. It is not surprising that no lands have been rezoned since 1997. The population of Dunboyne has more than doubled in the past five years and the 1997 Development Plan zoned sufficient lands for Dunboyne's needs for the five years up to 2002 which is not technically due for review until then. DCRA Reply The development of an industrial estate at Portan, Clonee, is against the Strategic Planning Guidelines. The Councillors now use this development to justify a need for additional housing. In other words they admit there isn't a local need for all these residential rezonings, so they create a need. This claim cannot be substantiated since the number of parameters required to reach such a conclusion are multiple; some are unpredictable and, in respect of others, critical information is not available at this point. This assertion cannot be validated statistically. In a recent study carried out in Leixlip only approximately 11% of workers in Intel lived locally. Lands East of the Railway Line - Green Belt: Reasons for Retention
Lands East of the Railway Line - Green Belt Issues raised by Councillors in support of the proposed rezoning
DCRA Reply The route of the railway line has not been decided and even if it had been there is no way it is going to happen during the lifetime of this plan. Surely the main reason for the re-opening of the railway line to Navan is to facilitate the development of Navan as a major development centre. At the launch of the Strategic Planning Guidelines, the Minister for the Environment stated, "The local Authorities will need to put mechanisms in place to ensure that there is a clear distinction between urban and rural areas so that these Green Belts will be respected. This means resisting dormitory settlements along transportation routes." The Draft Development Plan for Dunboyne (13.1.3) acknowledges that Dunboyne is tending to develop as a dormitory town. This type of planning for dormitory development should now stop. Mary Wallace TD told DCRA Representatives (Meeting: 08.11.00) that even if there was a railway line already in place, all the money needed and rolling stock available, there still would not be a railway because of technical difficulties at Connolly station. John Bruton TD has stated that there should be no development until the railway through Dunboyne is operational. DCRA Reply Please refer to the reply given to the same suggestion of phased development of Castle lands above. John Connaughton, the major beneficiary of this rezoning, was the developer of Millfarm where, as already stated, the phased development was not implemented and not enforced. John Connaughton is also the developer of Beechdale Estate which development began approximately twenty years ago and has not yet been taken over by Meath County Council.
DCRA Reply Dunboyne today suffers from major traffic constrictions and delays. Current road infrastructures are inadequate. The inadquacy of transport structures in such a situation is not addressed. Indeed it could be said that this reasoning, that development should precede the provision of a railway, indicates a lack of confidence in the railway going ahead. This suggestion proposes that Dunboyne with or without a railway will become a dormitory town which would contravene the Strategic Planning Guidelines. DCRA Reply The identification of a site for a primary school is a long way from actually building a new school. We only have to look a mile down the road to Little Pace at Clonee where, despite an Area Action Plan, over four years after that development commenced, and with thousands of new houses occupied, there is still no primary school built in the area and children have to be transported to schools all around the city. This suggestion is put as an incentive to achieve consent to rezone but is not directly applicable to formulating a decision to do so. DCRA fully supports the provision of a location for a Gael Scoil but on an appropriate site taking into account safe access and proximity to other centrally located facilities. DCRA Reply Local housing needs are well catered for in currently zoned lands. The County Secretary advised: "It is clear that more than adequate provision has been made for the expected residential growth in the Plan period without having to include the amendment referred to above." There is no local need to develop lands east of the railway line. The houses provided will, in the vast majority of cases, be occupied by people from outside the county and in particular from the Dublin Metropolitan Area. Even at present this is the situation, there being far more houses for sale than what is required to satisfy local needs. Under the heading "Sustainable Urban Development Principles" the Meath County Council Draft Development plan asserts as a overall principle: "To provide for the supply of zoned serviced land in line with actual needs and the provisions of regional planning guidelines to avoid excessive over zoning and consequent difficulties in co-ordinating development." DCRA Reply This can not be a serious statement. Should services not be available to develop zoned lands the County Council will be held to account. DCRA Reply Until such time as the decision to route the railway through Dunboyne has been taken and the physical work has commenced no development should take place east of the railway line. No further consideration should be given to development east of the railway line until work on the railway has begun. DCRA are opposed to all development on the green belt east of the railway line. The issue of development consequent to the railway line coming through Dunboyne is a consideration for the future. DCRA Reply Repeated reference is made appealing to Area Action Plans as a protection in respect of future developments. The question here is about rezoning of lands which precedes Action Plans. The suggestion that there will be an Action Plan can not be put as an argument for rezoning lands. DCRA Reply While we welcome the fact that a Strategic Green Belt in now shown on the map, it is totally inadequate as it only extends half way from the proposed development boundary to Clonee as far as Loughsallagh. The obvious boundary for such a Green Belt should be from the railway line east of Dunboyne to the Fingal and Kildare County boundaries. These are the lands that have been protected by Meath County Council since the 1994 County Plan as a "de facto" green belt. DCRA Reply Community facilities provision should be confined to the "Cowpark".
Contact: Jim McGrath, Chairman, Dunboyne Combined Residents Association, 9 Elton Drive, Millfarm, Dunboyne, Co. Meath Tel: 01.8252189. Email: mcgrathjim@esatclear.ie
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