Dunboyne Combined Residents Association 

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Submission From: Dunboyne Combined Residents Association: 07.08.03

Regional Planning Guidelines Review 2003: Issues Paper

Intrduction

Initially we wish to register a number of dissatisfactions and deeply felt concerns:
1. Because of a history of inconsistency of Central Government on planning and development issues.
2. Because national policy is changed under pressure from parties with vested interests, namely, construction and development bodies.
3. Because of the structural exclusion of Community and Voluntary bodies from participation in Government established bodies dealing with planning, the environment and development.
4. Because of the creeping cynicism of the public in respect of participative democracy.
5. Because of a widespread belief that elected representatives do not, as a priority, represent their electorates in matters pertaining to planning and development.
6. Because of the failure of the previous and current Ministers for the Environment and Local Government to enforce the existing Strategic Planning Guidelines as is evidenced in the "Issues Paper".
7. Because The Strategic Land Use and Transportation document which KMWPA supported in its submission in 2001 never materialised - yet another broken promise.
8. Because of the failure of the Department of the Environment to comply with so many European Directives on the environment is a national scandal and sets an appaling role model for local authorities.

We believe, however, in making yet another submission in hope and expectation of restoring trust and gaining influence in decision making.

General Comments

1. We support that the principles of sustainability and consolidation should be fundamental dictates in the new SPGs. Two further principles should also be evidenced, namely, the European Human Rights charter and the liability of Local Authorities for mal-administration.
2. Progress towards sustainability requires indicators so that progress can be measured and targets set in key areas. The latter could be used as a basis for deciding acceptability of proposed developments.
3. Because there exists an international, European and National frame of reference in matters of the environment and planning there should be a corresponding hierarchical process. In contrast there exists de facto a bottom-up/developer driven process in operation (Ref. recent High Court Case: McEvoy v Meath County Council) with power to require compliance vested on the Minister making it impossible for a Regional Planning Authority or the Courts to force compliance.
4. Further "dispersal" within the GDA should be strongly discouraged and if possible should cease in respect of land use for housing development.
5. Transportation infrastructure should be planned, approved and put in place prior to any proposed development.
6. The necessary Community facilities should be time framed and provided in all developments and not later than the mid-phase of a housing development.
7. Environmental issues are major concerns for communities, local and regional, and have major impacts on the quality of life of residents. Approval by communities should be regarded as a "sine qua non" in the planning process.
8. We object to the extension of the Dublin Metropolitan Area. The Hinterland as designated in the SPGs should be retained to prevent sprawl and spread. In the case of South Meath the Hinterland/Metropolitan boundary clearly coincides with the Dublin/Meath county boundaries.
When a proposed development cannot be located within the Metropolitan area the option to locate in the Hinterland must be ruled unacceptable.
9. Strategic Green Belts within the Hinterland Areas must be clearly designated. Specifically significant is the need to designate a Green Belt between Dunboyne and Clonee.
10. The restriction and control of the servicing of inappropriate lands and developments in the Hinterland Area should be reserved to Central Government.
11. We deplore the absence of representation on the Steering Committee from the Irish Planning Institute and from the Kildare Meath Wicklow Planning Alliance which is the only NGO representative body of communities throughout the Mid-Eastern Region.
12. There exists a democratic chasm between being consulted as you have invited us, and the right to direct participation in the decision making process which is the true measure of participative democracy. In this respect the Regional Authority should be the model and example for Local Authorities.
13. It is not acceptable to us for Central Government to legislate on matters of planning and development and then pass the responsibility for implementation to the Minister for the Environment, Heritage and Local Government who may decide not to do so. As we have seen, enforcement in respect of the SPGs never happened because the Ministers responsible did not use their powers to enforce compliance. Should the same situation pertain in respect of the New SPGs then we suggest that this project be aborted. Yet another aspirational document would prove wholly ineffective. Compliance must be mandatory.
14. The New SPGs must clearly outline unambiguously the necessary constraints, restrictions and environmental protections in respect of all developments to ensure and, furthermore, to enhance the quality of life of communities.
15. The listing of the critical elements regarding the "quality of life" of residents. Such a list must be regarded as critical when planning and development decisions are being made.
16. A "justifying need" should be a planning requirement in respect of each development.
17. For developments outside of the Metropolitan Area the concept of "local need" must be clearly and unambiguously defined.
18. The "possibility" of constructing a rail-link to Navan must not be used to underpin arguments for future development. Until such time that work on such a rail-link has been completed development in South Meath must be severely restricted.
19. No further developments should take place along the suggested transportation corridor to Navan until work has commenced on the construction of the proposed railway line.
20. Meath County Council massively breached the 1999 SPGs ( as did Counties Kildare and Wicklow) and especially so in respect of the South Meath villages of Dunboyne and Clonee. The New SPGs must ensure communities that this will not happen in the future.
21. A vision with strategic intent to locate within Strategic Greenbelts and the Hinterland recreational parks, tourist and leisure amenities should be strongly asserted.
22. The New SPGs, while respecting the responsibilities of Local Authorities in maters of planning and development, must not be so flexible as to be subject to local political expediencies thereby allowing inconsistency with respect to strategic goals and priorities.
23. The concept of "consolidation" in the Metropolitan Area must be liked to population caps and the placing of severe restrictions on further development in the Hinterland.
24. Transportation: Consideration should be given to the idea that planning should seek to enhance "reverse" traffic flows along transport corridors.
25. We fully agree with the principle for the integration of land use and transportation planning in the interests of sustainable development.
26. We fully support the bulleted seven points on page 15 of your "Issues Paper". We wish to be assured their translation into policies and strategies that will be enforceable.
27. The New SPGs must address climate change and its implications for planning and development.
28. Flooding Issues:
· The restructuring that is required to adapt to and limit the effects of global warming.
· The retention of existing flood plains and their creative development as recreational amenities.
· The prohibition of developments in areas of potential flooding.
· The inclusion of the findings of the final hydrological surveys and reports in respect of the coastline and rivers of the region especially in respect of the Tolka and Castle Rivers.
29. Sport: Facilities and resources dedicated to sport need to be targeted, directed and dispersed to multiple forms of sport that provide opportunity for participants to be involved in international events, especially with respect to Europe. GAA assets and facilities that have received public funding and resourcing are a national inheritance to that extent, whose use should be diversified for multipurpose eventing and all future public funding and resourcing should be conditional on this.

30. DCRA condemns the practice of the incentivisation by developers of selected organisations, to the exclusion of the majority of residents in a community, to achieve development objectives and to win the consensus of the local community for developments. This is an unhealthy and divisive form of community "bribery". If there any "dividends" for the community then the community as a whole should be involved in deciding the outcome.
31. We support the development of a National Stadium and a National Convention Centre.
32. In all new housing developments community facilities should be time-framed and phased as an integral and sequential aspect of the plan.
33. More important even than the upgrading of transportation is the development of satellite, broadband and digital communications national, and especially Mid-Eastern, networks to top of the international rankings.
34. Investment in the development of wind, wave, river and other renewables for the production of electricity is essential if Ireland is to satisfy its international commitments on the reduction of greenhouse gases. The Mid-Eastern region should present many such opportunities.

Concluding Statement

1. The New SPGs should retain the same statutory status as the existing SPGs and retain the same recognition in the Planning Act 2000.
2. The monitoring and enforcement of the New SPGs should not be the responsibility of the Minister for the Environment, H & LG, but should be given to a new legal body established for that purpose.
3. The membership of such a body should have two representatives from the Dept. of the Environment, one each from the Dublin Regional Authority, Mid-Eastern Authority, Irish Planning Institute and the Kildare Meath Wicklow Planning Alliance. An independent/judge should chair this group. The necessary resources must be made available and a secretariat approved.
End
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