Dunboyne Combined Residents Association
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Dunboyne Castle: Area Action Plan
Dunboyne Combined Residents Association
Draft Integrated Area Action Plan: Dunboyne Castle
Submission to Meath County Council: 10.04.02
Contents
The Area Action Plan in the Context of the Strategic Planning Guidelines
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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.
1. The proposed Draft Integrated Area 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 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. Residents constantly complain that they have to travel to the Phoenix Park as there is no proper public park locally. These are the only remaining lands in Dunboyne suitable for a public park, an amenity that is severely lacking in our area. People constantly complain that there is nowhere suitable for people to walk around Dunboyne as most of the roads are either without footpaths, or as on Station Road it is too dangerous to walk across the hump-back bridge. It is a matter of record, that this proposal, was supported by the vast majority of residents of Dunboyne. There is very little evidence that the wishes of our community expressed therein have been included in or have influenced the County Development Plan 2001 with respect to Dunboyne.
2. This proposed development will contribute in a major way to destroy the Dunboyne village identity, will permanently damage its landscaped environment, will bring about a deterioration of the life-style of its people, will lead to the destruction of its traditional community life, will inevitably increase traffic congestion and consequent pollution and ignores the democratically expressed will of the majority of its residents.
3. The proposed development fails to comply with the Strategic Planning Guidelines on at least one essential count, namely, that the Strategic Planning Guidelines for the greater Dublin Area forbid development in the hinterland except at designated growth centres for other than strictly local needs. Dunboyne is not a designated growth centre.
4. This Action Plan initiative is being undertaken to progressively facilitate development in an area that should not have been zoned for such, since it is contrary to existing Strategic Planning Guidelines for the region now incorporated into the Planning Act 2001.
5. We have identified eight critical aspects that must in the first instance be addressed. These are:-
v That an extensive Hydrometric Survey of the Castle and Tolka Rivers necessitated by recent severe flooding of the lands concerned, be completed. A solution is sought to a problem not yet fully analysed. 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 carried out for Dunboyne and district.
v That no decision regarding the development of a railway line either to Navan or to Dunboyne from Clonsilla has been taken. It is not acceptable to use the proposed development as an instrument to drive the development of a railway line.
v That the national survey on river flood plains being undertaken by the Office of Public Works should be completed prior to any development approval.
v We regard it as quite unacceptable 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.
v The European Environmental Impact Assessment Directive 337/85/EEC, as amended by Council Directive 97/11/EC, we understand is normally applied to individual developments. However, because of the major environmental impact for Dunboyne, due to the massive housing and other developments being proposed by Meath County Council for Dunboyne, we are asking that a holistic Environmental Impact Assessment be undertaken for Dunboyne and surrounds, prior to any further developments. If the proposed development is ratified then it is very likely that project splitting will be used to avoid thresholds under the Environmental Impact Assessment Directive
v The proposed development on Dunboyne Castle and lands cannot be considered in isolation from that proposed for lands East of the disused railway line and other developments envisaged for the Dunboyne area.
v The potential population, if all proposed housing developments go through together with the lands already zoned from previous development plans, would increase the population from its present 5,500 to potentially 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.
v Section 2.6.2 County Development Plan 2001 entitled "Implications for Urban Growth from the Strategic Planning Guidelines", 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."
6. 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. The proposed developments in South Meat and particularly in Dunboyne are in direct conflict with the above statements. This confirms our belief that a realistic plan, conforming to the SPG, was initially prepared by an experienced planner and that subsequently widespread unrealistic zoning resulted in anomalies and contradictions throughout the text. 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.
1. 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 severe flooding in Dunboyne in November 2000 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. 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 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 are inappropriate for development and will be a cause of serious problems to Meath County Council should they be developed.
4. 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 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 develop ahead of this critical information being available.
5. Surface Water (5.2): DCRA made a detailed survey of the flooding in Dunboyne in November 2001.Our findings are more pessimistic than those suggested in the IAAP. For example, the Rooske Road, at the entrance to River Court was flooded and the level of the road given on our map is 70.3. However, of far greater significance is the fact that it would be more appropriate to use the flood levels at the other side of the village on the Maynooth Road for the IAAP. Here there is evidence that is still visible that the flood water in November 2000 reached a height of an estimated two inches above the 71.51 Bench Mark at Dunboyne Castle Gate. Therefore it would be prudent to add at least 1.4 meters to the maximum flood level of 70.13 used as a basis for the IAAP and to revise all calculations accordingly.
1. DCRA objects to any interference with trees except under the guidance of the forestry services or of an expert choosen by DCRA. DCRA will not accept any building or roadwork within 100 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. "…substantially maintained wherever possible…" (4.9). This freedom must not be afforded to the developer. DCRA insists that the advice of an expert of our choosing must be followed in respect of all matters pertaining to the landscape. This is what "working in partnership with local communities" (MCC Mission Statement) means in practice. 3. DB14 ( County Development Plan 2001 - 13.3.0): "To preserve deciduous trees in the village centre and at Dunboyne Castle Demesne." (MCC County Development Plan 2001, p45)
1. COUNTY DEVELOPMENT PLAN 2001 - WATER CONSTRAINTS
· In section 2.3 it states: "The provision of water services to many parts of the south of the county is both costly and technically difficult due to their distance from the Boyne catchment and the increasing stress on the Liffey catchment which is in the control of the other sanitary authorities."
· In the same section: "The proximity of South Meath towns to Dublin and the services constrictions in terms of being able to sustain the water services demand of industry, make the creation of self sustaining settlements difficult"
· In section 2.6.3 entitled "Infrastructure Needs - Implications for Urban Growth", it further states: "Without water services, unlike for example a broad range of transport options, urban development is almost impossible. To this end several factors in water services planning are relevant to a settlement structure in Meath.
· Increased reliance on the Liffey catchment is difficult to progress due to pressure on its resources from Dublin and north Kildare areas. This also requires capital intensive engineering solutions which are maintenance intensive and fixed in capacity terms. · Expansion of centres in south Meath will place increased stresses on particularly water supply necessitating a regional solution which will be linked to the Boyne catchment."
2. This proposed housing development 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.
3. It is stated under Future Development Potential: "The existing allocation of water services for Dunboyne is effectively fully committed" (MCC Dev. Plan 2001: 13.1.7) 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 the new house/apartments development in both Clonee and Dunboyne. Under 8.2 of IAAP it states "In order to avoid reducing existing pressures and flows in the town the water supply to these tanks will be designed to ensure that they are topped up during non-peak times." It is not possible to add a further 500 houses onto an already overstretched water supply without a significant reduction in the water pressure to existing households.
4. It is stated under Future Development Potential: "The existing allocation of water services for Dunboyne is effectively fully committed" (MCC Dev. Plan 2001: 13.1.7)
1. 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. )
2. 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 developments proposed for the foreseeable future because of the huge demands on the limited wastewater services in the Fingal County Council area.
3. Reference 2.5: The services indicated are not under the control of Meath County Council and therefore it would be wrong to assume that MCC can avail of them. To imply the facilitation of the provision of services without agreement with the other local authority violates the Planning Act and heightens the gulf between MCC's objectives and "proper planning and sustainable development".
1. "Castle River to be cleaned up…" (7.13). The work that will need to be carried out on this river will depend on the publication of the national survey now being carried out by the Office of Public Works on river flood plains. This type of cosmetic work will not be sufficient to prevent future flooding of this river.
2. Ref 7.17: 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.
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. A footpath will be required either running along the Rooske Road from the village or inside the boundary ditch on the Rooske Road for pedestrian and cycle traffic to community facilities. In either instance trees and hedgerows must not be damaged.
5. The proposed access road from the Rooske Road which is intended "primarily" to service 150-200 houses will also 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.
6. There should not be an entrance from the Rooske Road to service houses in the proposed development
7. There is no mention of the traffic implications for the Dunboyne area resulting from an additional 500 houses. Allowing for 1.5 cars per house this will add a further 750 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 all the way to Dunboyne Village and in the opposite direction each evening. The much talked about rail service to Dunboyne will not be open for at least another 10/15 years if ever, so mention of walking distances to a facility the may or may not ever be provided is irresponsible at this stage.
8. To describe this scheme as Sustainable Residential Development (2.6) that will benefit the whole village is not tenable. There is no local need for the proposed 500 additional houses in this development and especially so when other proposed developments are taken into account as indicated at Number 17, Page 9. The development is clearly targeting the commuter market. A 50% increase in traffic will have a disproportional effect on the deplorable level of congestion that exists at present.
The Area Action Plan in context of Strategic Planning Guidelines
1. No mention is made in the Draft IAAP of the 23 acres of zoned land at Walshe's, Courthill, which is to the West of Dunboyne and close to the Castle lands. These lands, zoned for high density development, were envisaged as being adequate to cater the needs of Dunboyne for the next five years. (MCC Draft Plan) In addition there are 17 acres zoned near Old Fairgreen/Millfarm, West of the old railway line, as per MCC Development Plan 2001.
2. We disagree that the population has to grow by a further 2500 over the life of this plan to 2006 which is significantly beyond what is required to meet local needs. There is absolutely no basis for the 'forecast' increase in population of 2500. The trends in Dunboyne population in the recent past are due almost entirely by immigration resulting directly from the council's decision to approve the building of a specified number of houses. Therefore the population is basically deterministic and not the proper subject of forecasting. MCC are in effect using past decisions to justify a continuance of past policy. This is exactly what the SPG are designed to prevent.
3. 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 posits a serious question as to why there was need to increase the acreage by a factor of eight. Assuming 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.
4. What appears to be happening here is that this Area Action Plan is being used to legitimize the reckless and allegedly flawed rezonings in Dunboyne approved by Meath County Council in its Development Plan 2001. 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.
5. 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)
6. 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."
7. 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 Development Plan 2001 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 development proposed contravenes these guidelines.
8. The reasoned and informed presentations we have made to Meath County Council on rezoning and planning issues over the past two years, together with this submission, we believe to be evidently convincing. They are set out in compliance with the Strategic Planning Guidelines and environmental legislation and informed by good planning practice and principles.
9. 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."
10. 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.
11. 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. The potential population increase based on the total zoned lands of 250 acres (assuming the Castle is 47 acres) and assuming 12 houses per acre and the present occupancy of 3.4 persons per dwelling is 10,200. A decrease in the occupancy to 3.0 by 2006 for County Meath was forecast in the SPG. This would give a potential increase of 9,000. It is now questioned whether the decrease will actually occur because of the huge increase in house prices is likely to reverse the trend. Conservatively the potential population from the proposed zoning is therefore some 14,500 to 15,500. This represents the total destruction of a village which had a population of only 1,450 in 1981.
12. "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 Dev. Plan:13.1.7)
13. 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.
14. 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." The Draft Development Plan for Dunboyne (13.1.3) acknowledged that Dunboyne is tending to develop as a dormitory town. This proposed development of 47 acres of housing should not happen. "Sound management is needed to prevent urban sprawl onto agricultural land and environmentally fragile regions." (United Nations - Agenda 21)
15. "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)
16. No provisions have been made under the National Development Plan for a rail link to Navan nor to Dunboyne from Clonsilla.
17. The proposed development of a number of infill sites in the village, together with the development of 25 acres high density at Courthill, 47 acres at Dunboyne Castle Demesne, 17 acres near Old Fairgreen, plus 20 hectares 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.
18. Meath County Council should not develop lands to satisfy overspill from the Dublin Metropolitan Area. "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." (SPGs - Review and Update 2000). " Sound management is needed to prevent urban sprawl onto agricultural land and environmentally fragile regions." (United Nations - Agenda 21)
1. The price of destroying a unique community heritage by the proposed development, to gain lands for community facilities 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. There is not the political foresight or will to see or acknowledge the loss, forever, of this community heritage. What good will 23 acres of community grounds do for our community when the population will increase by another 2000? When these new residents move in we will have an even greater shortage of community land.
3. Twenty-three acres are said to be allocated to recreational and community use (Ref 4.3): GAA 7.5; Athletic Club 4; Gaelscoil 2.5; TOTAL: 14 acres. Nine acres are not accounted for.
4. Because we are dealing with an integrated area plan it is incumbant on MCC to state the development envisaged for:
· The eight acres that are owned by the Council adjacent to the Demesne.
· The four acres on the Maynooth Road that will be developed, but not in the short term, which are currently an integral part of the demesne.
5. "However the quantitative private amenity space standards in the County Plan may be relaxed…."This intentional commitment written into this IAAP by Meath County Council is both shocking and disturbing. This statement is in breach of the County Development Plan 2001 and must be removed from the text.
6. 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.
7. It is now evident that not only was the Dunboyne community as a whole excluded from the process but also that future residents of the proposed housing development will be deprived of their rightful share of open space because it has been hived off to selected organisations.
8. It is both deceptive and incorrect to refer to this development as 47 acres. It is in fact 47 acres plus 23 acres which are designated community lands but which should be counted as part of the residential entitlement of open space.
9. 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 win the consensus of the local community for this development.
10. The primary beneficiaries of the rezoning of these lands, with the consequent destruction of this amenity forever, are certainly not the residents of Dunboyne. If zoning of these lands from agricultural to development had not been carried out by our Dunchaughlin Area County Councillors, supported by their co-councillors in the County Council, the owners would not be in a position to make a profit of approximately €30 million. It could indeed have been purchased back by the State allowing a generous profit to the owners. Sadly the Councillors sided with the owner and developer and against the expressed wishes of the majority of the Dunboyne Community. They "sold" our inheritance.
11. 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.
12. 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.
13. 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 the Dunboyne residents 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. Unilateral arrangements between the said organisations and the Developer will not be acceptable.
1. DCRA, in its submissions to Meath County Council in 1999, June 2000, December 2000 and now again in this submission, states its opposition to housing development on the lands of Dunboyne Castle Demesne.
2. We allege that the rezoning of the Dunboyne Castle Demesne was a collusive initiative between the owners, the developer and the County Councillors of the Dunshaughlin Electoral Area to the exclusion of the expressed wishes of the majority of the residents of Dunboyne.
3. In the light of the framework and levels of accountability of the County Council referred to throughout this submission DCRA recommends that this IAAP be parked until the pending High Court case concludes and the legal implications of allowing this development to proceed are clarified.
4. There is an ascending order of accountability to which this IAAP must respond:
· 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.
· Central Government was also legally obliged to draft planning legislation with respect for European Union Environmental legislation. 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. END