Dunboyne Combined Residents Association 

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Submission to Meath County Council: 22.08.03

Planning Application for Dunboyne Castle

Planning Application Number: DA 30236

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Layout and Structure

Introduction
Flooding
Sustainable Development
Strategic Planning Guidelines
Planning Policy
Water Services

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Critical Aspects in the Interest of Proper Planning:

Transport
Infrastructure
Residential Density
Public Open Space
Landscape and Trees
Archaeology

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Dunboyne Community

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Conclusion

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Appendix: Flooding

Introduction

1. The proposed planning application 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 proposal for the development of Dunboyne Castle and its lands as submitted in respect of the County Development Plan 2001, namely, that the Dunboyne Castle Demesne should not be rezoned for housing development. We proposed that Dunboyne Castle and grounds be developed for tourism, community and amenity uses only. These are the only remaining lands in Dunboyne suitable for a public park, an amenity that is severely lacking in our area. It is a matter of record, that this proposal, was supported by the vast majority of residents of Dunboyne. The wishes of our community were rejected by the members of the County Council in its decisions taken about Dunboyne Castle and grounds.
2. This proposed development will contribute in a major way to destroy the Dunboyne village identity, will permanently damage a critical and inherited part of our landscaped environment, will bring about a deterioration of the life-style of residents, will lead to the deterioration of its traditional community life, will inevitably increase traffic congestion and consequent pollution and finally it ignores the democratically expressed will of the majority of residents of Dunboyne.
3. There are a number of important reasons why this planning application must be rejected:--
· It fails to comply fully with the requirements of the European Environmental Impact Assessment Directive (Flooding)
· It fails to comply with the requirement of the Planning Act 2000 for proper planning and sustainable development.
· It fails to comply with the Strategic Planning Guidelines which are themselves firmly based on the principles of Sustainable Development
· It fails to comply with the planning act that requires provision for essential services.
· It fails to comply with the stated objectives of Meath County Development Plan 2001

Flooding

1. The severe flooding in Dunboyne in November 2000 and again in 2002 is cause for serious concern. The Castle River was the source of the flooding in Dunboyne village, Woodview Heights, Beechdale, Castle View, Larchfield and River Court. Serious flooding also occurred at Dunboyne Castle, Summerhill Road and at Bennetstown where the Tolka overflowed. The damage to homes and to their value, the implication for increased house insurance and the trauma caused to families, has been immense. 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 flooding was aggravated by housing developments that have been undertaken in recent years. Additional development will increase the risk of future flooding. The proposed development of the Castle Demesne not only interferes with the natural drainage and water retention of this area but will also contribute to future flooding due to run-off water. Moreover the proposed development of the hotel actually encroaches on the flood plains of the river.
3. DCRA encloses as a critical element of this submission its two papers, previously submitted to Meath County Council, on flooding in Dunboyne. We will be calling for some form of flood risk management on a catchment wide basis as recommended by recent studies undertaken under the auspices of the EU Environment Commission. This will almost certainly forbid the sort of interference with the flood plains and the natural drainage of the catchment created by the proposed development.
4. The Environmental Impact Study (EIS) merely treats the matter as if it were simply a question surface water drainage that can be dealt with by "attenuation on site in accordance with current Meath County Council guidelines, before being discharged into the Castle River. This attenuation on site will ensure that the development of these lands will not impact in any way on the existing performance of the river as it will not result in any increased flows in the river". We do not accept this unverifiable claim. Even assuming that the proposed measure were based on accurate calculations and reliable forecasts of storm return periods, soil conditions, river peak flows and so forth there is no guarantee whatever that they could be relied upon to perform as designed in all eventualities.
5. The EIS made several references to 70.13 OD as being the highest recorded flood level reached in November 2000. This is not true. We have previously corrected this error by stating that there is evidence that the flood level reached at least a few centimetres above the 71.5 OD benchmark at the Castle gate.
6. The EIS also include a special catchment study undertaken by DBFL consultants. The report attempts to determine whether the peak flows for storms with various return periods will give rise to flooding by comparing the peak flows with calculated flows through the culverts at the Maynooth Road, Rooske Road and the old Railway. Not only are the estimated peak flows hugely inaccurate but the calculated flows are based on implicit assumptions that avoids the tricky problem of having to specify the water levels involved. The conclusions drawn that the Rooske Road and Railway culverts would be subject to flooding at the 1 in 50-year peak flow is therefore quite unfounded. The details of our analysis are given separately.
7. In view of the above it would be a serious error of judgement if the conclusions drawn in the DBFL study contributed to the decision as to the necessity for the proposed interim remedial work on the above two culverts. If future events show this work to be either unnecessary or ineffective then there is the risk that the waste of taxpayers money will be attributed to facilitating the proposed development.
8. Prevention is always better than cure and in the present instance there is no justifiable reason why the community should be put to an increase risk. We note that the proposed preventative measures are of a structural nature and we refer to the findings of the RIBAMOD project regarding the unreliability of structural measures:-
"Traditionally planning has been restricted to a select few politicians and professionals but future planning will have to be open with an informed public. There is a different philosophical basis for the provision of structural and non-structural flood defence. Historically man has sought to tame the flood through the construction of embankments and reservoirs to provide security for occupants of the flood plains. However, non-structural measures, such as flood plain zoning, development control, infiltration standards for new development and flood warning, recognise that flooding will still occur as part of the natural processes within the river basin. Difficult choices may arise in the management and protection of existing development and infrastructure on the river flood plain where this conflicts with the policy of sustainable flood plain management.

The prominence of non-structural measures for flood defence will increase as part of the sustainable management of rivers.
Non-structural measures mainly control the "vulnerability" component of flood risk, they include:
· spatial-planning policy with a presumption against development or encroachment of economic activities onto flood plains
· building regulations to control the additional runoff from any green-field development in the catchment outside the flood plain
· regulation of increases in vulnerability to flooding and of flood plain use "
If structural measures are not the preferred defence option in the case of existing flood risks then their proposed use can hardly justify the needless creation of additional risks.
9. J. Fahy, Senior Planner, at area meeting 03.10.00, stated, "The planners would have to deal with the consequences of having land zoned… in inappropriate locations". There should be no more development of lands in the Dunboyne/Clonee area until work has been completed to ensure that Dunboyne is flood free.
10. The need for the present extensive hydrological / hydrodynamic study that is as yet uncompleted is sufficient evidence that the critical information needed for a reliable impact assessment is not available.
11. It would clearly be irresponsible to approve the proposed development on the assumption that the sort of structural measures proposed are in any sense adequate to offset the adverse affect on the vulnerability to flood risk created by the proposed development.
12. We must emphasize the need for catchment wide hydrodynamic modelling as the proper basis for decision-making as opposed to isolated measures based on intuition that cannot be guaranteed not to make matters worse. The Dunboyne Combined Residents Association reasonably demands that no development of lands should be considered in or near Dunboyne village until after a full area hydro-geological and hydro-engineering survey is completed for Dunboyne and district and the catchment areas of the Rivers Tolka and Castle and that the work needed to ensure that Dunboyne can be declared flood free has been completed and proven to be effective.
13. Please find enclosed copies of DCRA's two submissions on flooding to Meath
County Council. Please regard these as constituting substantive elements of this submission. Copies enclosed.

Sustainable Development

1. The popular definition of sustainable development is "economic development that meets the needs of the present generation without compromising the ability of future generations to meet their own needs." This definition does not give much assistance to one seeking to apply the principles in practice. However there can be no doubt regarding the sustainability of the proposed development in the light of the following:-
· Hunger is already a constant threat to many people, and the world's long-term ability to meet the growing demand for food and other agricultural products is uncertain. The global population was 5.5 billion in 1993 and is expected to reach 8.5 billion by 2025. One of the world's great challenges is to increase food production in a sustainable manner so that a rapidly global growing global population can be fed. The productivity of huge food-producing areas is declining even as the demand for food, fibre and fuel is growing. The needless use of fertile arable land such as Dunboyne Castle Demesne is unsustainable.
· Ireland is failing to meet the commitment given in 1997 under the Kyoto Protocol regarding the emission of greenhouse gasses. The development of dormitory towns generates a need for transportation, which in the case of Dunboyne is served almost exclusively by private cars. The proposed development will create some 840 new commuters (estimated at 1.5 cars per dwelling unit) whose contribution to the problem will amount to some 2,500 tons of Carbon-dioxide per annum solely from travelling to work.
· The essential element in the popular definition is the concept of 'need'. It is quite evident that in order to be judged sustainable a given development must not only be directed towards meeting a definite need but the need itself must be of sufficient magnitude to justify the use of the resources involved. There is clearly no need whatsoever either at local, county or regional level for the sort of housing development envisaged in the present application. It follows that the proposed development cannot be regarded as sustainable development.
2. The argument in favour of the proposed development expressed in the concluding paragraph of the Application amount to saying that the development should be approved simply because the lands would otherwise remain undeveloped. If this is the best that can be done then one could hardly find a better argument for rejection of the proposal on the ground that it cannot possibly comply with the principles of sustainable development.
3. It is stated in United Nations Agenda 21 :-
" Sound management is needed to prevent urban sprawl onto agricultural land and environmentally fragile regions."

Strategic Planning Guidelines

1. The Strategic Planning Guidelines (SPG) for the Greater Dublin Area propose separate development strategies for the Metropolitan Areas and the Hinterland areas. Future growth is to be concentrated in the Metropolitan Areas and in designated growth centres in the Hinterland area. Elsewhere in the Hinterland area development is to be confined to meeting local needs only. It is patently obvious from our preceding remarks that the principles guiding the strategy are those of "Sustainable Development".
2. It is not tenable for the EIS Application to describe this scheme as Sustainable Residential Development that will benefit the whole village. There is no "local need" for the proposed 564 additional residential units in this development and especially so when all the other proposed developments in Dunboyne are taken into account. This development is clearly targeting the commuter market and, as stated above, is unsustainable.
3. Moreover, unequivocal statements in the development Plan demonstrate that Meath County Council are fully aware the fact that the proposed development in the present application is unsustainable. Volume 2 Section 13.1.13 refers to recent development in Dunboyne as "driven by proximity to the Greater Dublin Area and by its intrinsic role as a developing dormitory town for the employment centres of the Dublin region". Also in paragraph 2.6.2 "These guidelines have significant implications for the development of areas both urban and rural in Meath" and further on , "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 …
4. The Review and Update 2000 of the SPGs emphasises:- "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".
5. During the Judicial Review the expert witness who was largely responsible for the preparation of the Strategic Planning Guidelines stated explicitly that the Meath County Development Plan departed fundamentally from the guidelines.
6. Ms M. Moylan, Assistant Secretary Department of the Environment in her letter to Meath County Council dated 15/12/00 stated "In the case of County Meath, Navan has been identified as a primary development centre. The Guidelines also indicate that development outside the Metropolitan Area and identified development centres 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." (The underlining is ours)
7. The proposed high density development of 23 acres at Courthill Estate, 45 acres at Dunboyne Castle Demesne, 17 acres near Old Fairgreen, plus some 10 acres already rezoned from the 1997 Dunboyne Development Plan, gives the potential to increase the present population from some 7,500 to some 11,500. This represents an increase of almost 55% and is far in excess of what is required to cater for local needs for many years into the future. It is evident that the proposed housing development is clearly a perpetuation of the policy expressly rejected by the Last Minister for the Environment when introducing the Strategic Planning Guidelines and by the County Development Plan 2001 itself: - "It is intended therefore that this development plan should set itself the task of implementing the guidelines as they apply to County Meath. Key issues that will arise therefore will relate to …
Constraint in relation to the expansion of south Meath towns allowing for primary organic rates of growth."
8. It may be noted that the above statement shows that the planners interpret "local needs" as synonymous with organic growth. As organic growth rate averages approximately 3% per annum, "local needs" for a population of some 7,500 represents a population increase of some 1,200 in a five year period.
9. We also note the advice given by J. Fahy, Senior Planner, to the Elected Members on 3/10/00: - "The Draft Plan provisions can accommodate a projected 7,000 population." or an increase of 32% in the population of Dunboyne from the estimated population of 5,300 in 2001 to 7,000 in 2006 which should be more than adequate to meet local needs for the next ten years. (In fact the census population for 2002 was some 7,500 but the projected increase of 1,700 in view of the above is still more than sufficient.)

Planning Policy

1. The proposed development fails to comply with the stated objective of the Meath Development Plan itself. The recent High Court Review disclosed numerous inconsistencies between the development policies stated in the text of the document and the undisclosed agendas as indicated by land usage displayed on the accompanying maps (determined by the zoning approved by the members). The text clearly shows that the professional planners were attempting to draft plans in accordance with the Strategic Planning Guidelines as directed by the Minister for the Environment. On the other hand, as was determined by evidence at the High Court Judicial Review, the guidelines were never considered by the members when deciding matters of zoning.
2. Volume 2 Section 13 of the Development Plan deals with Dunboyne. The only references to the Dunboyne Castle Estate in the written statements are made in paragraphs:-
13.1.1 Urban Form: "A zone of archaeological interest identified by the Office of Public Works corresponds to the current Village centre, Dunboyne Castle and Courthill House."

13.1.7 Future Development Potential: "In terms of opportunities, these are primarily limited to the east of the town due to the limited drainage catchment to the west, the presence of major road proposals to the north and the sensitive landscape associated with the Demesne of Dunboyne Castle to the south."

13.2.4 Future Development Areas: "It will also be an objective of the planning authority to protect the character and landscape setting of Dunboyne Castle as an amenity area and for possible tourist uses."

Under Specific Objectives the only reference to Dunboyne Castle Estate is: -

DB14: "To preserve the deciduous trees in the village centre and Dunboyne Castle Demesne."

In contrast, Urban Detailed Map 13 that accompanies the written statements indicated extensive rezoning of the whole of Dunboyne Castle Estate that was decided as an amendment to the draft plan. We note that the internal boundary between the area zoned G1 and that zoned A2 shown on the map is not otherwise defined nor are the areas of the various parts given on the maps.

3. We have already referred to Section 2.6.2 of the County Development Plan 2000 entitled "Implications for Urban Growth from the Strategic Planning Guidelines " which states:
"The Guidelines considered a number of "strategic options" in relation to the future 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 through-
· The difficulties of providing an effective public service transport system.
· The fiscal cost associated with providing water services
· The increased stress on the catchment of the river Liffey that the long term servicing of some south Meath centres is dependent on.
These guidelines have been formally adopted by the Government and given statutory recognition in implementing physical planning legislation. It is intended therefore that this development plan should set itself the task of implementing the guidelines as they apply to County Meath. Key issues that will arise therefore will relate to …
Constraint in relation to the expansion of south Meath towns allowing for primary organic rates of growth."
The proposed housing development is clearly a perpetuation of the policy of developing dormitory towns expressly rejected by the Last Minister for the Environment when introducing the Strategic Planning Guidelines and is patently inconsistent with the policy of County Development Plan 2001 itself as stated above.

4. The proposed development fails to comply with the Planning Act 2000 because no provision was made in the development plan for the essential services. Section 10 subsection (2) of the Planning Act states: -
"The objectives to be included in a development plan shall at least include the following matters:-
The provision or facilitation of the provision of infrastructure including transport, energy and communication facilities, water supplies, waste and wastewater services, and ancillary facilities "

5. The above extracts from the Development Plan 2001 emphasise the severe limitations to future development, particularly in South Meath, due to the serious constraints imposed by the provision of both water supplies and wastewater services. We will refer to this point again separately later under water service. Meanwhile it is evident that the proposed developments in South Meath and particularly in Dunboyne are in direct conflict with the above statements. Moreover it is manifest that the quoted statements give the true situation, certainly at least as far as Dunboyne is concerned, and show that the proposed developments cannot be implemented because of failure to provide properly planned services that comply with the principles of sustainable development.
6. We note that the proposed development conflicts with the following objective declared in Section 13.1.7 of the Development Plan:- "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."

Water Services

1. In relation to Water Services at Dunboyne Volume 2 Section 13.1. 6 states:-"The waste water 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 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 service is therefore the effective limitation in the growth potential of Dunboyne."
2. Under "Future Development Potential" Volume 2 Section 13.1.7 states:-"The existing allocation of water services for Dunboyne is effectively fully committed. Notwithstanding this, the installed infrastructure has capacity to accommodate greater development and in line with the development role assigned to the town by the County Settlement Strategy it is considered reasonable that an appropriate level of further growth be provided for. Given the recommendations of the Strategic Planning Guidelines for the Greater Dublin Area it is envisaged that this should be directed to 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."
3. Both water supply and wastewater treatment services required for the proposed development are not under the control of Meath County Council and therefore it would be wrong to assume that Meath County Council can avail of them without firm agreement from Fingal County Council. However, it would surely amount to bad planning to permit the scarce resources required by Fingal County Council for development in the Metropolitan area to be hi-jacked to facilitate unsustainable urban sprawl in the Hinterland area in direct conflict with the Strategic Planning Guidelines.
4. It is also evident that the agreed capacity limit of 6000 PE in the case of waste water service has already been exceeded by the present population of 7,500. The Environmental Impact Assessment merely notes that Meath County Council are in discussion with Fingal County Council in relation to Fingal County Council accepting additional flows from Dunboyne and Clonee. 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 developments proposed for the foreseeable future because of the huge demands on the limited wastewater services in the Fingal County Council area. We draw attention again to the failure to comply with the requirements of the Planning Act regarding proper planning in relation to the provision of services.
5. Dunboyne residents in a number of estates have been complaining of poor levels of water pressure over the past few years, presumably due to increased demand of new developments in both Clonee and Dunboyne. We understand that a booster pump has been recently been installed to increase the pressure. It is obviously not possible to add a further 564 residential units onto an already over-stretched water supply without a seriously degrading the service to existing households.
6. In the case of water supply the Environmental Impact Assessment suggests that "… if the additional supply is not made available by Fingal count Council or until such time as it is made available, the water supply to the proposed development will be designed in a manner that will ensure that it will have no adverse impact on existing supply to the town." What follows is pure deception that would ultimately amount to robbing existing residents of their supply. Clearly this procedure is a far cry from the proper planing and sustainable development required under the Planning Act in relation to the provision of essential services. It would amount to gross irresponsibility to countenance this sort of bizarre proposal in place of the proper provision of the necessary services.

Critical Aspects in the Interest of Proper Planning

Transport

It is mentioned in the EIS that the proposed development would be used to strengthen the case for the building of the railway. We also note that the members at the Dunshaughlin Electoral Area Meeting on 24th October 2000 displayed a similar attitude towards developments which deliberately created a need for transportation and thereby 'would help drive the development of the railway line project' It is not acceptable to use the proposed development as an instrument to drive the development of a railway.

2. Using the restoration of the railway line, as a reason to support the development of Dunboyne Castle and lands 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." Dunboyne must not develop as a dormitory town. This proposed development of 50 acres of housing should not happen.

3.The Strategic Rail Review prioritises improvements/upgrades in the greater Dublin area as the Dart line, Kildare route, Maynooth line and Northern line. Development of a Navan passenger service via Drogheda (if built) would therefore be a long-term objective 2015-2022. Therefore a rail line via Dunboyne will not be built to service existing or future residents. The Strategic Rail Review further states that "stand alone" developments (new lines) perform poorly when projected patronage is factored in, due to high capital costs and low population densities.

4. A key factor in the development of passenger services to the Northern line and the Maynooth line is the development of Spencer dock station. Without this development capacity will be seriously constrained by city centre area Connolly - Pearse. The full development is a Medium to long-term goal (2009-2022). With the Interconnector tunnel between Spencer dock and Heuston station providing true transport flexibility by linking Northern, Maynooth and Kildare lines with the Dart, Luas and intercity trains.

5. "Agreement in principle only has been reached on 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)." (Dept of the Environment: Ms Moylan's Letter to MCC, 15.12.00)

Infrastructure

1. The sports clubs are not provided with car parks and consequently there will be no need to provide for vehicular traffic to the GAA playing pitches from the Rooske Road. The proposed access to the Rooske is unnecessary and undesirable. It would certainly be misused by facilitating a rat-run between the Maynooth Road and the Rooske Road and cause congestion and traffic hazards along the Rooske road. The creation of a link road of this nature cannot be simply regarded as an integral part of the development. Moreover the location of such a road if it were deemed to be both necessary and desirable should not be dictated by the narrow interests of the developer but by the needs of the community. This particular item illustrates the huge gulf that exists between local needs and local interests.

2. We draw attention to the fact that the 'access' road runs right across the area zoned G1 for Community Facilities on the Develpoment Plan. The development of this area should be determined solely by the needs of the community for whatever facilities are required at present but also to provide scope for whatever may be required at some future time. This road splits the area arbitrarily into two parts purely to suit the developer and thereby seriously restricts the scope for future development. We hold the view that merely because the Castle estate is presently under single owenership does not mean that lands zoned G1 may be treated as if they were zoned A2.
3. Vehicular traffic to and from the community facilities proposed should, in the first instance, be discouraged and secondly, should be required to use the two entrances from the Maynooth Road. A walkway and cycle entrance from the Rooske Road is all that is needed.

4. Vehicular access from the Rooske Road to houses will facilitate Dublin-bound traffic from the entire estate and would of course be used as a "rat run" for Maynooth/Rooske road traffic avoiding the village. Therefore there should not be an entrance from the Rooske Road to service houses in the proposed development.

5. The traffic implications for the Dunboyne area resulting from an additional 564 residential units or 121 bedroom hotel are not adequate as addressed in the Planning Submission. Allowing for 1.5 cars per house this will add a further 846 additional cars on to our already congested roads each morning and evening. The existing situation is that every weekday morning we have gridlock with a tailback of traffic from Clonee towards Dunboyne Village and in the opposite direction each evening. This extra traffic will further aggravate the morning gridlock on the N3 from Clonee to the roundabout at Blanchardstown on to the Dublin city.

6. The educational facilities in Dunboyne will be unable to cater for the additional students from this development.
· Presently parents are having great difficulty enrolling infants in Dunboyne Primary School, as the school is full to capacity. The Junior & Senior Primary Schools currently have 34 classrooms and a total of over 900 pupils. There are 119 pupils enrolled for 4 Junior Infant Classes in September 2003 and a prefab has to be obtained as there will be only 3 classrooms available. A further 9 children have been told they cannot be accepted until next year. These children are all from the parish or have siblings in the school. The schools are situated on the main road into Dunboyne at the junction where the Rooke Rd meets the main road. This area is already heavily congested at school times and more housing on the Rooske Road will exasperate the problem. The council have previously refused to place traffic lights at this junction, as it is extremely dangerous for children and parents.
· St Peter's Community College is also struggling to cater for the volume of new applicants with 8 prefabs already in the school grounds and all rooms in the school building being used to capacity .The present school building was build to accommodate approx. 650 pupils and by next September there will be 900 students there. The Parent Association is currently trying to arrange a meeting with the Minister for Education to discuss their concerns regarding the school.

7. Dunboyne is lacking in infrastructural support such as water and wastewater drainage (Fingal Co.Co. capping of capacity) major areas of public open space, schools unable to cope with current demand. Meath C.C. Dev. Plan 2001 Vol 1. 3.3.3 states: "The Planning Authority considers it reasonable that where such facilities are in need of enhancement and support to sustain increased demands from new development, that their provision and or enhancement should be encouraged as part of major new residential developments through Public Private Partnerships. This may be done by way of development contributions or direct provision by the developer under planning authority supervision. Realising the provision of public gains in this manner will be in turn a material bearing on the planning authority's consideration of a given proposal." There is no provision in this proposed development to enhance infrastructure in Dunboyne, but rather to put additional pressures on already inadequate services.

Residential Density

The density of housing units per acre in this proposal is inappropriate for residential development in the Hinterland Area. Heretofore six houses per acre have been the norm in Dunboyne This density is only suitable in Metropolitan Areas where provision has been made for the required levels of facilities especially recreational and public transport. MCC Development Plan 2001 Vol.1 3.3.1 Residential Density lists the benefits of higher densities at certain locations such as more economic use of existing infrastructure etc but it goes on to state, "Before these benefits may be exploited, there are several challenges that should be considered such as … Identification of key public transport corridors and other suitable locations where higher densities may be considered". The reopening of the railway service to Dunboyne is no longer part of Government Plans, and therefore Dunboyne is not a suitable location for such high residential densities.

Public Open Space

Meath County Council has no parks department to provide or maintain the level of town park facilities required for residents of high-density development. We believe it is a recipe for social problems further down the road to fail to provide adequate safe play areas for children close to their homes where parents can keep a watchful eye on them. The vast majority of the housing units in this development are bereft of such facilities. The amount of open space in this residential development is minuscule. When you deduct the acreage of lawns in the grounds of the Castle Hotel Complex from the total of 21.3acres public open space you are left with only a tiny amount for residents use.
MCC Dev. Plan 2001 Vol. 1 3.3.4 Open Space states " In general the Planning Authority will require the developer to provide a minimum of open space provision of 2.5 hectares per 1,000 population with each person being equivalent to a bedspace. Bedspace provision in given development scenarios are set out below

Bedroom Numbers + Bedspace Equivilant
1 + 2
2 + 3
3 + 4
4 + 6
In certain circumstances where these standards cannot be met a more intensive recreational facilities may be desirable, the provision of such facilities in lieu will be considered or contributions may be levied towards the provision of public facilities"

Taking the numbers and sizes of housing units proposed we look at the open space requirement

Unit Size + Bedspace Equivalent + Number of Units + Total Bedspace

2 Bed House + 3 + 9 + 27
3 Bed House + 4 + 240 + 960
4 Bed House + 6 + 95 + 570
1 Bed Apartment + 2 + 55 + 110
2 Bed Apartment + 3 + 125 + 375
3 Bed Apartment + 4 + 40 + 160
Total 564 Total 2,202

Based on this total of 2,202 bedspaces (population) there should be an allocation of 5.5 hectares 13.75 acres residential open space in this development, however the proposed allocation is way short of the development plan's requirements or are there any levies towards the provision of public facilities.

Landscape and Trees

1. DCRA objects to aspects of the proposed development that needlessly damages the landscape in general and the trees that contribute largely to its characteristics in particular. DCRA notes the reference in the Development Plan Volume 2 Section 13.1.7 to "the sensitive landscape associated with the Demesne of Dunboyne Castle" and to the Specific Development Objective DB14: "To preserve deciduous trees in the village centre and at Dunboyne Castle Demesne." DCRA insists that this objective is fully implemented. It follows that DCRA objects to any interference with trees except under the guidance of the forestry services or of an expert chosen by DCRA. DCRA will not accept any building or roadwork within 50 feet of any tree as this would result in serious damage to tree roots leading to eventual death of trees and would also result in the eventual felling of trees because of insurance cover for new home owners.
2. DCRA specifically opposes the incursion of the proposed development into the woodland strip along the Southern boundary of the estate. This would certainly lead to the felling of a large number of trees because they are to be declared dangerous by the new residents. It is also noted that this incursion is caused by the inclusion of the five additional blocks of flats not shown on the Area Action Plan.
3. DCRA is also strongly opposed to destruction of the continuous shelterbelt on the eastern boundary along the Rooske Road that would be caused by allowing the proposed access road in the location shown. Not only would the screening affect be greatly impaired but also an unsightly gap would be needlessly created. Furthermore the protection presently afforded the residents along the road from westerly gales would be replaced by an undesirable wind tunnel. There is not sufficient reason why the traditional access to the site from the Rooske Road, which will be used for the community facilities nearer the bridge in any case, should not also be used for the new development if a road is considered essential. The upgrading of this access would not involve the felling of any trees.
5. Please find attached a copy of DCRA's Submission to Meath County Council on February 2000 entitled "Survey of Trees with Special Amenity Value" and include same as an integral part of this submission.

Archaeology

Dunboyne Castle and grounds: Origins

1. There have been a number of explanations put forward as to the origin of the name "Dunboyne", most of these are mentioned in the archaeological survey produced by Arch-Tech as part of the submission by the Menolly Homes application. There was one particular explanation, by Joyce, not included in that submission, which states that the word "Dunboyne" means "the fort of the flood or stream". This suggests that water and/or floods have been a feature of the landscape in Dunboyne for centuries. It was common to name parts of a landscape in a way that described something of the physical elements within that landscape.

2. There is an explanation put forward by Flanagan and supported by the Irish Placenames Commission, which contends that the word Dunboyne means "The fort of the white cow goddess". This explanation is important as it implies a place of higher than normal importance. The goddess Boin is the same goddess as that referred to in the name of the river Boyne. The Boyne river is described as 'Bovinda' in the books of the Alexandrian cartographer Ptolemy - Bovinda refers to the same goddess. It may be that there is much more to be learned about the Dunboyne area, which is rapidly being covered in concrete.

Dunboyne Castle and grounds and its place in the Dunboyne landscape.

1. Dunboyne Castle has been a major influence in the development of Dunboyne town and its surrounding area. It is an area of importance in terms of the heritage and archaeology of the wider area.

2. It has a sensitive landscape, that has been shaped over the centuries, by people and nature, the destruction of which will be irreversible, and an irreplaceable and permanent loss for future generations.

3. It has huge potential as a recreational area for south Meath, which is rapidly losing its natural environment as a consequence of the urban sprawl from Dublin. The south Meath area is in serious need of such a recreational area. Dunboyne Castle and demesne would be ideal for this purpose. There is no justification for the destruction of such a landscape purely for commercial reasons.

4. In the course of the historical research, as part of the submission, the significance of some of the placenames, which border the grounds of Dunboyne Castle, was not addressed in the overall context of the landscape. Examples: Rooske bridge is translated in the "Ordnance Survey Field name Book for the Parish of Dunboyne .1836", as " the bridge of the morass". The area known as Rooske/Rusc in Irish Roscaigh means "morass, swamp" borders the lands of Dunboyne Castle. Just a short distance from Rooske bridge is an area which formerly acted as a temporary storage area in times of flood, that is now a housing estate. The results in the year 2000 and 2002 were devastating for many households in the area. In section 4.2.7.2. of the Archaeological Survey, the Farm Manager confirms that the area east of the convent is poorly drained and becomes flooded in wet conditions. The flooding problems seem to be directly related to the structure of the landscape itself and is unlikely to be solved by any attempt at drainage.

5. We learn from history that interfering with the landscape demands extreme caution especially in terms of the possible consequences into the future.

Dunboyne Community

1. The price of destroying a unique community heritage by the proposed development amounts to an environmental tragedy. 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 to achieve a commercial gain for the village by developing a regional tourism amenity for the surrounding area including Dublin 15.

2. The only community groups consulted with respect to the development of Dunboyne Castle lands were the three groups who stand to gain from this development at the expense of the entire community. The consultation amounted to the three groups being approached and being offered the "community gain". DCRA being the largest community group in Dunboyne and representing some 80% plus of residents was not approached nor consulted. This remains a questionable initiative.

3. It is now evident that not only was the Dunboyne community as a whole excluded from the process of the allocation of compulsory green space area to selected groups but also that future residents of the proposed housing development will be deprived of their rightful share of open space within their housing estate.

4. DCRA condemns the practice of the incentivisation of selected organisations, to the exclusion of the majority of residents in our community, to achieve development objectives and to endeavour win the consensus of the local community for this development.

5. A natural inheritance for Dunboyne community and the region will be irretrievably lost if this development is approved.

6. DCRA does not accept that the proposed housing development on Dunboyne Castle lands is necessary in order that the Castle be developed as a hotel. The development of the Dunboyne Castle as a hotel could be a commercially viable enterprise in its own right.

7. Should the proposed development take place; it is necessary to have in place the legal framework to ensure that the community groups mentioned will enjoy legal rights and entitlements to what is proposed for them. This should be a tripartite binding agreement with Meath County Council as the third partner and guarantor. Unilateral arrangements between the said organisations and the Developer will not be acceptable.

8. The grounds designated for GAA and Athletic Club are ceded for community use, to be used initially by the two stated sports organisations. It is therefore essential and an integral element of arrangements that the said acreage is held in perpetuum by Dunboyne representatives or in the their name and on their behalf by Meath County Council and that future use of these lands can be so decided my a majority vote of Dunboyne residents. The legal arrangements to ensure this proposal should be put in place forthwith.

Conclusion

1. DCRA, in its submissions to Meath County Council in 1999, June 200, December 2000 stated and now again in this submission states its opposition to housing development on the lands of Dunboyne Castle Demesne.

2. There is an ascending order of accountability in respect to this planning application:

· In the first instance, to the principle laid down by both the European Union and the United Nations of the right of local communities to be consulted and that means that their contributions must be respected in decision making by Local Authorities.

· The MCC Development Plan 2001 committed itself to have regard for Central Government Directives as per the Planning Act 2000 and the Strategic Planning Guidelines incorporated there-in.

· The Planning Act 2000 was written with regard for the United Nations Agenda 21 and to which Ireland is bound by international treaty, in particular with respect for the principle of sustainable development.

· Central Government planning legislation has been drafted with respect for European Union Environmental legislation.

6. Regardless as to whether the Minister for the Environment approves or fails to enforce with respect to the above does not relieve Local Authorities of the responsibility to comply.

Enclosures:
1. Flooding in Dunboyne: 14th & 15th November 2002 - Dated 30.01.03
2. Comments on Interim Report on Flooding dated 27.02.03
4. Dunboyne Castle: Area Action Plan dated 10.04.02
5. "Survey of Trees with Special Amenity Value" dated February 2000

Contact: J. McGrath, Chairman DCRA, 9 Elton Drive, Millfarm, Dunboyne.

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Appendix: Flooding

The EIS contains a special catchment study undertaken by DBFL to provide a basis for the proposed attenuation of the surface water in accordance with current Meath County Council guidelines. It would appear that these guidelines are in line with Dublin Corporation's "Stormwater Management Policy for Developers".
The report determines the Mean Annual Peak Flow in the catchment of the Castle River to be 3.75 m3/sec. This is then used to determine the maximum peak flows for the following storm events: -
1 in 20 year storm event 5.81 m3/sec
1 in 30 year storm event 6.37 m3/sec
1 in 50 year storm event 6.71 m3/sec
Unfortunately, these estimates are quite unreliable for flood risk assessment as can be seen by comparison with the estimated peak flow of some 16 m3/sec for the 2002 event, as follows. The Castle River has a catchment area of some 22 square kilometres and the peak flow for the 2002 event can be reliably estimated by proportion from the peak flow of 98 m3/sec recorded at Glasnevin for a catchment of some 138 square kilometres. This gives a conservative estimate of 15.6 m3/sec as no adjustment is made to the recorded flow for the huge volume of floodwater stored in the river basin itself.
The return periods for 24-hour duration rainfalls for the 2002 event were in the range of 15 years to 45 years. It follows that very serious errors would result form using the DBFL estimates as a basis for determining the likelihood of flooding as is done in the DBFL report. In fact, the report goes on to give details of calculations for the flows for the culverts on Maynooth Road, Rooske Road and the old Railway.
Maynooth Road Culvert 13.67 m3/sec
Rooske Road Culvert 5.22 m3/sec
Railway Culvert 5.81 m3/sec

These flows are deemed to represent the capacity of the culverts and are compared with the peak flows listed above with a view to determining whether or not the latter would give rise to flooding. This exercise is fundamentally flawed. Firstly because the culverts are treated in isolation and secondly because the relative differences between the water levels at the upstream and downstream sides are assumed to be fixed by the physical slopes of the culvert instead of by the energy gradients.
It is worthwhile making a comparative calculation in the case of the Rooske Road Culvert to show the effect of this error. Assuming the culvert is some 10 metres long, the slope of 1/693 gives a difference of 10/693 = 0.0144 metres between the upstream and downstream sides. In other words, a flow of 5.22 m3/sec given above gives rise to a head loss of only 1.44 centimetres or vice versa. In Manning's formula the head loss is proportional to the square of the flow. Thus for a flow of three times as great, that is 15.66 m3/sec - the same order of magnitude as the peak flow for 2002 event - the head loss would be nine time as great, that is a mere 13 centimetres. It is plainly evident that the water level on the downstream side of the culvert has an overriding affect on the risk of flooding on the upstream side of the culvert. In comparison the difference between a flow of the order of 5.2 m3/sec and one three times as great is a relatively insignificant 13 centimetres that can have little or no bearing on the risk of flooding.
The above exercise clearly demonstrates the essential need for integrated modelling that is designed to calculate the water levels throughout the system for critical flow conditions in order to determine whether or not these give rise to flooding in one location or another.
On the other hand, it is not possible to draw any valid conclusions regarding the risk of flooding on the basis of the sort of exercises described in the EIS. Consequently, in the absence of integrated modelling, properly validated, it would be clearly irresponsible to approve the proposed development based on the assumption that the sort of structural measures proposed are in any sense adequate to offset the adverse affect on the risk of flooding.
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