Dunboyne Combined Residents Association
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Submission to Meath County Council Re: Draft Green Belt Strategy February 2003.
We welcome the proposal by Meath County Council to incorporate a
Green Belt into the Meath County Development Plan 2001. There are many excellent
points in the document relating to Green Belt strategy, land use in the green
belt, recreational facilities, dwellings new and replacement, etc together with
development control criteria and standards and protection of amenities .Our
concerns relate to the boundaries of the proposed Green Belt, and the need to
prevent coalescence of Dunboyne with Clonee and with the Metropolitan Area. The
Strategic Planning Guidelines (SPGs) states that the need for protection will be
greatest close to the Metropolitan Area.
As documented in our previous submissions to Meath County Council in June 2000, December 2000 and February 2002 we have consistently opposed the following rezonings, which took place during the preparation of Meath Development Plan 2001. Furthermore we ask that because these previous submissions contain substantive material in reference to this issue, that they will be taken fully into account when considering this submission. Copies enclosed.
DCRA is opposed to:
1.The extension of the development boundary of Dunboyne to include lands east
of the disused railway between Dunboyne and Clonee, (objective DB16)
2.The
zoning of Dunboyne Castle Demesne.
3.250-acre industrial zonings at Portan
Clonee.
4.The area covered by objective CE8 in the Clonee Development
Plan
DCRA's grounds for opposing these rezonings have been consistent on the basis that:
1. The rezonings were excessive and beyond what was required to meet local needs.
2. Are situated in what has been de facto Green Belt between Dunboyne and the Fingal County boundary, which was also the boundary of the Metropolitan Area as per the SPG's.
3. They constitute a breaching of the Strategic Planning Guidelines.
Basic Points
1. To have a meaningful green belt between Dunboyne and Clonee and the boundary of the Metropolitan Area, with no intervisibility between boundaries, and those boundaries to be permanent and defensible it is essential that the areas mentioned above form part of it. Such boundaries we suggest are the railway line east of Dunboyne and the Fingal County boundary.
2. In your Introduction to Draft Green Belt Strategy you quote from the SPG Strategy "A consequence of the strategy is that large parts of the Greater Dublin Area will require to be protected from development, other than that necessary to meet local needs. This need for protection will be greatest close to the Metropolitan Area and between that area and the 'development centres' in the Hinterland Area" (SPGs, page 102). What has happened in Dunboyne/Clonee area has been a failure to protect from excessive development from that which is necessary to meet local needs.
3. In fact it is a fine example of what Mr. Justice Quirke referred to in his recent judgment on costs in the case of the Judicial Review of the Meath Development Plan 2001 when he stated ".. in a number of respects the Meath Plan does not comply with the guidelines and indeed .in some of its provisions it has substantially departed from the Guidelines' policies and objectives. Navan is the only "development centre" identified in the Guidelines for which any growth other than that for "local needs" is recommended. Nonetheless elected members at electoral area meetings have decided to zone large amounts of land for residential purposes in dozens of small towns in a manner which appears to be quite inconsistent with the recommendations of the Guidelines. In many instances, "local interests" appear to have overcome the concept of "local needs". Overall the Meath Plan recommends that land sufficient to accommodate an enormous population increase should be rezoned for residential purposes in the period up to 20111 notwithstanding the fact that the Guidelines (and indeed the plan itself) envisage a much more modest population increase during that period."
Green Belt Boundary at Dunboyne
Lands east of old railway line: DB16 Meath Deveopment Plan.
The extension of the development boundary of Dunboyne to include lands east of railway towards Clonee covered by objective DB16 is a major breach of what had been accepted by both planners and elected members as being de facto Green Belt prior to the Development Plan review in 2000. The comments of the MCC senior Planner, R. Somers S.E.P. on 25th. April 1996 in a letter to MCC Engineer Oliver Perkins re the proposal to rezone 50 acres of land east of the railway show these lands were at that time de facto Green Belt as (Sc.3.1.1 MCC Dev. Plan 1994). "The rezoning request relates to some 50 acres of land on the east of the former railway line. I recommend that the existing development boundary be retained for the reasons below: …Development of these lands for housing would effectively lead to the area being absorbed into the land use structure of the Greater Dublin Area and would conflict with the County Development Plan (Sc.3.1.1) which seeks to retain a controlled green belt area. The line of the old railway is the 'natural' barrier or dividing line and forms a good boundary to the development of Dunboyne to the east….The proposed green belt is at its narrowest at this point only 500 metres between the two village boundaries as expanded, it is essential that it be extended to the line of the old railway as it is a clear natural defensible boundary, essential to prevent the coalescence of Dunboyne with Clonee."
Dunboyne Castle
These lands were also included in the Green Belt-Pressure Area in the 1994 MCC Development Plan. In the Draft Dev. Plan 2000 13.2.4 - Future Development it states:
"It will also be an objective of the planning authority to protect the
character of and landscape of Dunboyne Castle Demesne as an amenity area and for
possible tourism uses. It is envisaged that any residential component of the
development of this area be confined to the castle precinct itself and
would
be primarily addressed at providing guest accommodation"Under 2.3 Objectives for
the Green Belt Areas in your Draft Green Belt Strategy it states:-
" To preserve demesne type landscapes. Where demesne landscapes exist within the Green Belt, it will be the policy to protect and enhance the setting, character and integrity of such landscapes. Developments which would not advance this objective will not be permitted." This is the only demesne in the whole of the Blanchardtown, Clonee or Dunboyne Green Belt area and it is environmentally most disastrous that it should be turned into yet another housing estate.
Green Belt Boundary with Metropolitan Area
The Strategic Planning Guidelines for the Greater Dublin Area clearly show the boundary of the Metropolitan area in this region as corresponding with the Fingal County boundary (Page 166 SPG's) The industrially zoned 250 acre estate at Portan Clonee is a clear example of what the guidelines were aiming to prevent when they also showed a Strategic Green Belt on the Meath side of the Mertopolitan boundary with a view to preventing overspill of development into Meath, where they state the need for protection will be greatest. Local need was not an issue in this zoning or in the inclusion of Objective CE8 to zone 50 acres at Williamstown residential. These lands were already protected from development in the MCC Development Plan 1994 Section 3.1.1 entitled 'Pressure Areas' it stated that "It is intended that the area adjacent to the Dublin County boundary and indicated on Fig.4 will retain existing uses and will not be absorbed into the land use structure of the Greater Dublin Area.
Flooding
In the light of recent flooding in Dyunboyne it is essential that land uses in the catchment areas of the Tolka River and the Castle Stream are protected as rainfall absorbent and retention areas. This underpins the need to retain and incorporate all lands especially in the immediate environs of Dunboyne village and lands immediately east of the old railway line into the Green Belt area. To providing the evidence for this assertion please find attached to this submission DCRA's recent Submission to Meath County Council entitled "Flooding in Dunboyne: 14th & 15th November 2002". Copy enclosed.
Dunboyne Community
The majority of the Dunboyne Community has expressed clearly, in a previous submission to Meath County Council of approximately 1, 600 signed letters and by the vote of 700 people at a public meeting, that all the lands east of the disused railway line should be preserved as part of a green belt and that they should not be zoned for development.
The Dunboyne Community furthermore has made it known to Meath County Council by the submission of approximately 1,200 signed letters and through DCRA that the Dunboyne Castle demesne should in its totality be preserved as a local amenity and regional park and that no housing development should take place on its lands.
Summary
Not to include the lands immediately east of the old railway line within the
Green Belt is in fact to provide occasion for their development. The intention
to rezone these lands is stated under DB16 of the Meath Development Plan and is
for that reason ringfenced. It should not be protected for that reason. Indeed
development on these lands would constitute an additional breaching of the
Strategic Planning Guidelines for the Greater Dublin Area.
End 11.02.03