Dunboyne Combined Residents Association

Dunboyne Combined Residents Association

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Dunboyne Combined Residents Association

Submission to Meath County Council Re:

Integrated Area Action Plan for Lands East of Disused Rail Line Dunboyne

February 2002

CONTENTS

Introduction 2

Flooding 4

Timeframe for Re-opening of the rail line to Dunboyne and Navan 5

Provision of water and wastewater services to facilitate development 7

Framing of Action Plan in context of Strategic Planning Guidelines 7

The implementation of the Green Belt policy between Dunboyne/Clonee 10

Integration of development east of railway with the town of Dunboyne 12

1. Introduction

1. We are replying to Meath County Councils invitation to make a submission to the proposed Integrated Area Action Plan for lands east of Disused Rail Line Dunboyne pursuant to the specific development objective for Dunboyne as described in the County Development Plan 2001, Volume 2, Section 13 (DB16).

The specific objective DB 16 requires: 'The preparation of an Integrated Area Action Plan in relation to the Lands east of the railway line providing for the residential and other mixed use development consistent with the sustainable development of public transportation corridors in consultation with the appropriate statutory agencies in tandem with decisions on the implementation of the rail proposal.'

2. The Dunboyne community is strongly opposed to the proposed development in the de facto green belt between Dunboyne and Clonee for a number of reasons given here but generally because it is certain to destroy the identity of the village. The objective of the community is valid in its own right and also with respect to the Meath County Council Mission Statement: To promote and implement the sustainable development of our county in partnership with local communities so as to improve the quality of life and living environment of all our citizens.

3. The proposed Action Plan is designed to give effect to initiatives that are in defiance of proposals put forward by the overwhelming majority of residents of Dunboyne. There has been an outright rejection of DCRA's two main proposals in respect of the County Development Plan 2001:

Retention of the de facto Green Belt East of the old railway line between Dunboyne and Clonee

Retention of the present zoning of Dunboyne Castle Demesne.

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 at the Draft Plan stage and a further 781 letters of objection to the amendments in December 2000. Apart from a cursory acknowledgement of receipt of these documents there is very little evidence that the wishes of our community expressed therein have been included or have influenced the County Development Plan with respect to Dunboyne.

4. DCRA disagrees with the listing of headings to which we are invited to respond as they presume the inevitability of the development of the lands East of the disused railway line.

5. A planning decision that irretrievably destroys a village identity, that permanently damages its landscaped environment, that brings about a deterioration of the life-style of its people, that can lead to the destruction of its traditional community life, that inevitably increases traffic congestion and consequent pollution and that ignores the will of the majority of its residents is bad planning and bad decision making.

6. The proposed development fails to comply with the Strategic Planning Guidelines on two essential counts :-

The SPG forbid development in the hinterland except at designated growth centres for other than strictly local needs.

The SPG call for effective Strategic Green Belts to be established in order to separate the metropolitan area and other growth centres from the hinterland areas and for these to be clearly shown on the maps.

7. The proposed Action Plan is an exercise to achieve rezoning and subsequent development of lands in this area and is initiated on the assumption that the lands have already been potentially rezoned for development. This is a misuse of this planning instrument. This route has been chosen to avoid direct confrontation with the fact that the proposed development is in breach of the Strategic Planning Guidelines by suggesting that the first does not apply because the proposed development is on an existing transportation corridor and by ignoring the second altogether apart from identifying the remnants of the existing Green Belt on the Map. This Action Plan initiative is being undertaken to "shoehorn" development into an area that has not been zoned for such and should not be so zoned as it would be contrary to existing Strategic Planning Guidelines for the region.

8. Before dealing with these and other relevant details of the subject under the headings suggested in your advertisement we wish to make a number of important statements.

The Strategic Planning Guidelines deal with the subject of Area Action Planning on page 138 and Recommendation 32 requires the preparation of plans for all significant areas of new housing. The plans will set out inter alia:-

The general mix and form of development, including housing to be accommodated;

Building forms and layouts that allow for the penetration of area by pedestrians, cyclists and public transport;

Appropriate minimum development densities;

The location, extent and character of open space; and

The integration of social and private housing.

Strangely none of these aspects are identified by MCC in its advertisement as requiring attention. Instead we are invited to consider aspects that clearly belong to a far more extensive exercise necessitating an Environmental Impact Study. The critical importance of the factors of the associated studies that would need to be addressed in the latter immediately reveals the defects in the present proposal due to its inherent limitations.

9. We have identified five critical aspects that must be addressed before undertaking any detailed planning East of the railway line. These are:-

The establishment of an effective Strategic Green Belt in accordance with the requirements of the Strategic Planning Guidelines

The extensive Hydrometric Survey of the River Tolka necessitated by recent severe flooding of the lands concerned - including a large part of the proposed development.

The decision regarding the exact route of a rail link to Navan together with a realistic time scale for its implementation.

The national survey on river flood plains being undertaken by the Office of Public Works.

Finally we regard it as quite inadmissible to proceed with the implementation of part of the Development Plan 2001 at this time when it is under Judicial Review as a result of a High Court Challenge on the grounds that it does not comply with the Strategic Planning Guidelines.

2. Flooding

The issue of flooding in Dunboyne is crucial to planning in Dunboyne and to its residents and therefore it is essential that this matter be addressed as a priority.

2. 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. There was expansive and severe flooding on these lands east of the disused rail line. The damage to homes and to their value, the implication for increased house insurance and the trauma caused to families, has been immense.

3. 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. These lands east of the railway are inappropriate for development and will be a cause of serious problems to Meath County Council should they be rezoned.

4. J. Fahy, Senior Planner, at area meeting 3/10/00, referring to these lands stated "The planners would have to deal with the consequences of having land zoned unnecessarily and in inappropriate locations". Furthermore, there should be no more rezoning of lands in the Dunboyne/Clonee area until the Flood Risk Mapping presently being undertaken by the Hydrometrics Section of the OPW is completed. As Dunboyne has a long history of flooding it would be irresponsible to rezone ahead of this critical information being available.

3. Timeframe for Re-opening of Rail Line to Dunboyne and Navan

The recommendation contained in the final report on the Dublin Rail Strategy Review prepared for Iarnrod Eireann by Ove Arup & Partners are only recommendations and it is premature to rezone or develop on the basis of such a recommendation.

2. In the letter from Ms M Moylan, Asst. Secretary Dept. of Environment, to Meath County Council 15/12/00 she stated: " With regard to the proposed rezoning to the east of the disused railway, the April Review and Update of the Strategic Planning Guidelines recognizes that the future role of settlements along transportation corridors, especially those not designated as Development Centers, may need to be reconsidered. However the guidelines state that this should occur only when agreement is reached on the fixed elements of the public transport infrastructure. Agreement in principle only has been reached to the future transportation corridor with no agreement on stations as yet. Pending this stage being reached, the recommendation in the Strategic Planning Guidelines is that additional zoning should occur in the designated Development Centres in the Hinterland Area (i.e Navan)."

While the Strategic Guidelines state that the future role of settlements along transportation corridors especially those not designated by Development Centres may need to be reconsidered, the evidence used by the Council to support their case is not legally binding and the Strategic Guidelines state that pending this stage being reached, that additional zoning should occur in the designated Development Centres (Dunboyne is not one) in the Hinterland Are (i.e.: Navan).

3. On best advice from a Transport Planning Consultant, should a rail line be approved, it would reasonably take 10-15 years to implement. In any event it will not be implemented in the life of the Meath Development Plan 2001. It would be premature to rezone before the railway line is provided. To do so would mean that people would have developed travel patterns mainly by car and eventually the rail line would not have the desired effect of reducing road traffic. The possibility of a rail line must not be used as a reason for rezoning lands in the Green Belt.

4. In the context of the need for a strategic approach to the location of development along the corridor, and the reservation of the line free of development, the zoning proposed at Dunboyne, which includes the actual railway line, is premature and could prejudice the preservation of the line. Furthermore it constitutes a piecemeal approach to the development of this "Future Transportation Corridor" and could prejudice the preparation of a strategic land use plan."

5. On the possibility that the development of the land east of the railway could proceed independently and in advance of the provision of the railway line, as raised by the Elected Members, is not acceptable. Dunboyne today suffers from major traffic constrictions and delays. Current road infrastructures are inadequate. The inadequacy 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. The advice of J. Fahy, Senior Planner, to the Elected Members at area meeting 24/10/00 was: "That no development should take place ahead of the railway line restoration programme."

6. 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. 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.

7. The statement of J. Fahy to the Members of the Dunshaughlin Area, meeting 24/10/00 on this issue: "That the Members should be aware of a claim for compensation following refusal of a planning application on the grounds that the development proposed would impact on the provision of the railway line"

Likewise the contention of the Elected Members that the proposed zoning would help to drive the development of the railway line project, in planning terms is both wreckless and deplorable. 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. "There is, however, a real danger that other forms of development will preclude the realisation of projects that are essential to the strategy." ( SPGs recommendation 30, page 137).

9. No provisions have been made under the National Development Plan for a rail link to Navan nor to Dunboyne from Clonsilla.

4. Provision of Water and Wastewater Services Capacity to Facilitate Development

1. The proposed development of the land east of the railway line is conditioned by a number of assumptions. To develop on such a basis of speculative assumptions could place Meath County Council in a legal position of liability and therefore it could be held to have acted irresponsibly and so be held to account for such. Our residents are taxpayers and so they would not wish that public resources be squandered in this way. Again we quote J. Fahy, Senior Planner, at area meeting 3/10/00 when he stated "That zoned lands which are the subject of planning refusals on the basis of the absence of services could result in compensation being awarded against the Planning Authority" and again at area meeting 24/10/00 he stated "The serious constraints which currently exist in terms of services and in this regard a strategy is being prepared for the Greater Dublin Area and looking at the design capacity and requirements of the various centers over the coming years."

2. It is further stated under Future Development Potential: "The existing allocation of water services for Dunboyne is effectively fully committed" (MCC Dev. Plan 2001: 13.1.7) and under Water Services "The wastewater disposal system for Dunboyne involves a piped connection to Clonee and on to the Fingal County Council foul sewer at Mulhuddart. Treatment is then effected at the Dublin Corporation Ringsend works. Fingal County Council has limited the capacity of the system for Dunboyne and Clonee to 6,000 PE. The design of the sewer pipe system within Dunboyne could accommodate up to 16,000 PE. The availability of agreed services is therefore the effective limitation in the growth potential of Dunboyne." (MCC De. Plan 2001 :13.1.6. )

3. There are serious constraints in respect of waste capacity at present. To our knowledge no agreement is in place with Fingal County Council to increase sewage capacity to the level required to satisfy the need resulting from the increased domestic and industrial development proposed for the foreseeable future because of the huge demands on the limited wastewater services in the Fingal County Council area.

5. The Framing of Action Plan in context of Strategic Planning Guidelines

The massive increase in the amount of land being rezoned from 23 acres in the Draft Plan to over 200 acres in the Amended Plan calls into serious question on what basis the Draft Plan was drawn up, if there was need to increase the acreage by a factor of eight. If the Draft Plan was drawn up on the basis of the best planning advice available and accepted as such by the members why the need for the huge increase. On the advice of J. Fahy, Senior Planner, to the Elected Members 3/10/00 he stated "The Draft Plan provisions can accommodate a projected 7,000 population." or an increase of 32% in the population of Dunboyne from 5,300 in 2001 to 7,000 in 2006 which should be more than adequate to meet local needs for the next ten years.

2. What appears to be happening here is that this Area Action Plan is being used as a smokescreen for rezoning additional lands either because the Members were attempting to sidestep the Strategic Planning Guidelines or they were afraid of the political fall-out of such a decision in conjunction with all the other rezonings in March 2001. Now they are coming back in an attempt to legitimize this reckless rezoning. The Members ignored the advise of their Senior Planner J. Fahy and Area Manager D. Mc Loughlin "That almost quadrupling the amount of land rezoned over what was shown in the draft plan would raise serious questions about the adequacy of the Draft Plan" (Minutes of Dunshaughlin Electoral Area Meeting 3/10/00.

3. The fact that there were already sufficient lands rezoned to cater for the needs of Dunboyne for the next six years was pointed out to the members by J. Fahy, Senior Planner, in response to the issues raised by the members he reiterated his opposition to the proposed rezoning of the lands east of the railway line by saying: "That while the population projection figures will have to be increased based on revised Strategic Planning Guideline Projections it is not necessary for rezoning both the lands east of the railway line and the lands in Dunboyne Castle to facilitate such projections as applied to Dunboyne" (Minutes Dunshaughlin Electoral Area Meeting 3/10/00) and again "The adequacy of lands zoned in the Draft Plan to cater for Dunboyne’s needs for the next six years taking cognizance of the earlier decision to zone the lands at Dunboyne Castle."(Minutes of Dunshaughlin Electoral Area Meeting 24/10/00 )

Ms M. Moylan, Assistant Secretary Dept. of the Environment in her letter to Meath County Council 15/12/00 stated "In the case of County Meath, Navan has been identified as a primary development center. The Guidelines also indicate that development outside the Metropolitan Area and identified development centers in the Hinterland Area should be primarily to meet local, rather than regional, needs. In this regard the Council should note that the continued growth of the South Meath towns/villages as part of the unrestrained growth of the Dublin Region was specifically rejected in the Strategic Guidelines for a number of reasons including issues of sustainability, difficulty in providing an effective public transport system, the fiscal costs in providing water services and the implication for the Liffey catchment from the long term servicing of the South Meath centres. In light of the above, the Department has serious concerns about the proposals for development of a number of areas, in particular Clonee, Dunboyne and Kilbride."
It is a matter of record that in our discussions with County Councillors they were dismissive of the Strategic Planning Guidelines, published in March '99. Referring to the Strategic Planning Guidelines the County Development Plan 2001 (2.6.2) says, "These guidelines have significant implications for the development of areas both urban and rural in Meath". This document has now received statutory recognition in the Planning and Development Act 2000. The Draft Development document continues, "The guidelines considered a number of "strategic options" in relation to the future of development of the greater Dublin area such as continuation of existing trends to further disperse growth on an unstructured basis in Meath and options such as significant growth of centres in South Meath and new towns. These were individually rejected for their failure to accord with the principles of sustainable development … It is intended therefore that this development plan should set itself the task of implementing the guidelines as they apply to County Meath." It is our understanding that the rezonings in Dunboyne in the Meath County Council Development Plan 2001 contravene these guidelines.

6. The reasoned and informed presentations we have made to Meath County Council together with this submission, we believe to be convincing. They are set out in compliance with the Strategic Planning Guidelines and environmental legislation and informed by good planning practice and principles. The proposals put forward for the rezoning of lands in Dunboyne are not supported by such.

7. Houses on lands already rezoned residential together with housing on lands at Dunboyne Castle and lands shown on Map DB16 brings the total number of units way beyond what is required to meet the needs of Dunboyne for the next six years. The County Secretary pointed this out to the Councillors at their full County Council meeting on the sixth of November '00 when he stated in reference to the lands east of the disused railway line: "It is clear that more than adequate provision has been made for expected residential growth in the Plan period without having to include this amendment."

To zone beyond the requirements for the next five years is a clear breach of the Strategic Planning Guidelines and the Planning and Development Act 2000, in that lands should only be zoned if they are to be developed within the life of the development plan and that zoning should wither when the plan expires. With current services restrictions, these lands can not be developed during the next five years and should not be rezoned.
The potential population, if the lands east of the disused rail line were developed together with the lands already zoned in Development Plan 2001 and previously zoned lands from the 1997 development plan, 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.

10. "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)

11. The Strategic Planning Guidelines (SPG) say that development in the Hinterland Area is to be concentrated into designated "Development Centres". Elsewhere development is to be strictly limited to local needs as opposed to regional needs.

To develop on the lands east of the old railway line between Dunboyne and Clonee is contrary to the SP Guidelines because the location selected was designated as the Green Belt in the County Development Plan '94. This should now be regarded as 'Strategic Green Belt' in order to prevent precisely the sort of development that is proposed.
The proposed development of the lands east of the old railway line is contrary to the logical development of the village. The clearly defined features that should form the 'stop lines' for development are the old Dublin-Navan Railway to the east and the proposed Clonee By-Pass Extension and R.157 Relief/ Ring Road to the west. Once the boundary of the old railway line is breached the pressures to extend development further with each subsequent development proposal, would result in the total abolition of the Green Belt. This would result in Dunboyne becoming absorbed into the metropolitan area of the nearby Fingal Area contrary to 13.1.7 of the Draft Development Plan. As a consequence the planning principle of providing a division between settlements would be abandoned as per the Strategic Planning Guidelines for the Greater Dublin Area.

14, The proposed development of the lands east of the old railway line is contrary to the policy statements in the speech made by the Minister for the Environment and Local Government when introducing the guidelines "---- 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) acknowledged that Dunboyne is tending to develop as a dormitory town. This should now stop.

The proposed development of a number of infill sites in the village, together with the rezoning of 25 acres high density at Courthill, 50 acres at Dunboyne Castle Demesne, 17 acres near Old Fairgreen, plus 20 acres already rezoned from the 1997 Dunboyne Development Plan, gives the potential to increase the present population from 6,000 to 10,200 - an increase of 70%. This is far in excess of what is required to cater for local needs for at least ten to fifteen years. Any additional rezoning such as lands east of the railway line beyond that for local needs would be contrary to the SP Guidelines.
It should be noted that the Government audit (2000) has said that enough zoned and serviced sites are available to satisfy housing requirements. This is an added reason why County Meath should not rezone land to satisfy overspill from the Dublin Metropolitan Area.

17. To rezone the Dunboyne Green Belt for building is contrary to the Strategic Guidelines for the Greater Dublin Area - Review and Update 2000 - which says: "In overall terms the approach should be to accommodate population, household and employment growth in line with the Strategic Planning Guidelines, that is, within the Metropolitan Area and the designated Development centres."

6. Implementation of the Green Belt Policy between Dunboyne/Clonee

1. The new Green Belt as shown of Map13 is totally inadequate as it only extends a few hundred yards half way from the proposed development boundary towards 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. The Strategic Planning Guidelines (page 116) clearly shows the boundary of the Metropolitan Area as corresponding with the Fingal County boundary on the city side of Clonee, and shows the area of the Strategic Green Belt as extending from there towards Navan, the Development centre for Meath. The Meath County Council Development Plan 2001 totally ignores that fact and has almost obliterated the old Green Belt by a combination of the rezoning - 250 acre industrial at Clonee and these lands extending east of the disused railway line from Dunboyne.

It is ironic that it is only now when an overall strategy is being taken of planning in the Greater Dublin Area with the Strategic Planning Guidelines that this area should be proposed for rezoning. One of the core principals of SPGs is the protection of green belts between the boundary of the Metropolitan Area and towns like Dunboyne which are within the Hinterland Area but are close to the Metropolitan Area boundary that the opposite is happening in this case. One could conclude that developers/landowners saw this as a last opportunity to have their lands rezoned residential and the huge financial gains that all that entails before the Strategic Planning Guidelines are properly enforced. This might explain why our Councillors have done such an amazing U-turn on this issue, from their promises to the electorate less than a year earlier.

The Meath County Council Development Plan 1994 was obviously very much in line with the views expressed in the Strategic Planning Guidelines when it designated all the lands between Dunboyne and the Fingal /Kildare boundary as Pressure Areas and we quote "It is intended that the area adjacent to the Dublin boundary and indicated on Figure 4, will retain existing uses and will not be absorbed into the land use structure of the Greater Dublin Area."

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.

The entire Dunboyne community as evidenced in previous DCRA submissions to Meath County Council are united on the need to retain this green belt from east of the railway line as it essential to preserve the very character of our community otherwise we become just another suburb of the urban sprawl of Dublin which over the last few years has spread to the Fingal boundary at Clonee.

The Strategic Planning Guidelines recognise that large parts of Greater Dublin Area will need to be protected from development other than development necessary to meet local needs. This need for protection will be greatest close to the Metropolitan Area and between that area and the principle 'development centres' of the Hinterland Area. Therefore, the Strategic Planning Guidelines call for the establishment of 'Strategic Green Belt' areas in Development Plans aimed at restricting land use within these areas and securing a clear distinction between urban and rural areas.

The boundary of the Metropolitan Area is clearly shown on the map on page 116 of Strategic Planning Guidelines and Dunboyne can be seen to be situated just within the Hinterland Area and in a location which the Strategic Planning Guidelines specifically identify as requiring special protection to prevent overspill from the neighbouring Metropolitan Area. We would therefore expect that this area should receive the special protection demanded by the Strategic Planning Guidelines and be clearly defined as 'Strategic Green Belt'.

The comments of the MCC Senior Planner, R Somers S.E.P on 25^th April 1996 in a letter to MCC Engineer Oliver Perkins re the proposal to rezone 50 acres of land east of the railway show that these lands were in fact de facto Green Belt as (sc3.1.1 Meath County Development Plan 1994)

"The rezoning request relates to some 50 acres of land on the East side 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 a 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."

"It is the intention of MCC to have Dunboyne develop in a balanced way with the appropriate amounts of the residential industrial, commercial and community-based enterprises.

Development of the 50 acre mentioned would further exaggerate the residential nature of Dunboyne, help strengthen the dependency on Dublin and lead to ever-increasing levels of commuting"

The rezoning of the Green Belt is contrary to the principles of Sustainable Development because it clearly represents urban sprawl and ribbon development. We refer again to the statement by the Minister regarding resisting the creation of dormitory settlements along transportation routes. The proposed development would create an increase in the demand for transportation that would inevitably be provided largely by private cars. This would add substantially to local commuter traffic and add significantly to existing congestion.

The reason put forward for the rezoning of the Dunboyne Green Belt is "future development" (DB16). This is a meaningless planning criterion. This is development for the sake of development

7. Integration of all development east of the rail line with Dunboyne.

There is no local need to develop these lands east of the railway line and the County Secretary advised the Elected Members of this at the full Council meeting November 2000 when he stated "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". 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.

2. 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."

When the Ring Road is constructed there will obviously be pressure for development along its route.

The additional population arising from the proposed development of the Dunboyne Green Belt would put intolerable pressure on the village's community facilities, especially on school accommodation, that would be detrimental to the education of the children of Dunboyne.

The second Bacon Report, which has been accepted by the Government, also suggested the creation of Special Development Zones which would deliver housing needs for the Greater Dublin Area which proposal obviously does not include Dunboyne.

DCRA fully supports The Board of Management of An Gaelscoil in their objection to having their school located east of the old railway line.

The development of the Green Belt is contrary to the wishes of all the twenty Dunboyne Residents Associations. These Residents Associations enjoy membership of approximately 87% of the residents of Dunboyne.

End

Contact: The Chairman, Dunboyne Combined Residents Association, 9 Elton Drive, Millfarm, Dunboyne, Co. Meath.