Dunboyne Combined Residents Association
Home - About DCRA - Contact DCRA -Archive - News- Politicians Directory - Planning - Environment - Links Page - Newsletters - DCRA Meetings - Soapbox - Waste & Recycling
Draft Regional Planning Guidelines Greater Dublin Area
Submission To: Dublin and Mid East Regional Authorities - 01.03.04
1. Part A Introduction page 2 and Part B p 93
It is a fundamental weakness of the document that even though is says it enjoys
"statutory effect" that Local Authorities are required only to "have
regard to" RPGs. There is no enforcement or requirement to comply and therefore,
in respect of each instant, there can be no sanction for noncompliance.
2. Part B Section 9.3 page 83
"Planning Authorities should develop policies to…" We approve
of and fully agree with the five bulleted points made here. However, we now
have the Final Report on the River Tolka Flooding Study and the immanent publication
of the GDSDS Report. These reports are critical to development in the Region
and especially to Dunboyne and Clonee. It would be regrettable if, though the
Reports are not yet finalised, that their findings and recommendations were
not acknowledged and included. Without reference to these Reports this RPG document
will with immediate effect become dated and with respect to the preservation
and protection of the environment will be defective in highly critical aspects
and areas of concern. As a consequence this document fails to comment on inappropriate
development in areas at risk of flooding.
3. Part B Section 5.3 Page 28
The Metropolitan Area is modified to include parts of County Meath including
Dunboyne and Clonee. The reason given for this is "…to provide a more
suitable planning context for these areas." This is indeed arguable and
certainly not convincing. It also militates against Goal 2 - Section 4.4 page
26 - which says, "Urban sprawl would compromise the green space between
settlements." And Section 2.4 page 18 "The aim should be to avoid
creating urban sprawl." Part A Section 1 page 4: "It is not desirable
for the city to continue to spread physically into surrounding counties."
4. Climate change and its implications should be addressed as a major potential cause affecting the environment, the social wellbeing of residents and their quality of life.
5. Part A Section 1 Page 10
.1 The setting up of structures by Local Authorities as mentioned here is fundamentally a controlling initiative, the antithesis of participative democracy and counter to the principles of community development. While EU Directives require local authorities to consult communities the method by which this is done is not and cannot be wholesomely dictated by the Local Authority. The Local Authority should find ways of accommodating to partnership processes that respect a community's preferences in this matter and not have their participative role inhibited by unilateral constructs.
.2 Local Authorities must find not structures but community motivating processes by which communities take ownership of their role in partnership and are assured of the attention they can get and that their influence can affect outcomes.
.3 A way must be found to remove distrust, dissipate antipathy and encourage participation. To selectively organise for a few "community representatives" into structured groups politically dominated and controlled is abhorrent to constructive democratic partnership.
.4 The current level of consultation by officials and elected representatives of communities is deplorable and in respect of many local communities is nonexistent.
6. Part A Section 12 Page 28 Part B Page ix and 7.3 Page 53
"…to provide integrated provision of community facilities…".
In all new housing developments community infrastructures and facilities should
be included as an integral part of phase one.
7. Part A Section 3 Page 33
Strategic Goals: No mention is made here of the protection, preservation and
enhancement of the environment.
8. Part B Page x
"…to identify, describe and evaluate the likely significant effects
on the environment." (EU Directive 2001/42/EC). The RPG document itself
should comply and should include an Environmental Impact Study.
9. Part B 2.4 Page 11
We very much welcome the intention to identify quantifiable indicators and to
setting up of a "…specific monitoring framework for the review of
the recommendations on an annual basis…" and section 2.5 "The
implementation of regional policies should be progressed through the application
of a compliance framework…"
10. Part B Section 5.3 Page 20
.1 " The provision of non-road-based public transport should be planned and delivered as an integral part of regional and county systems." We wish to repeat here as in our previous submission to you on the "Issues Paper": Transportation infrastructure should be planned, approved and put in place prior to the construction of any proposed development.
.2 Ensuring patronage of use by prior development of densely populated settlements based on expectation and promise of infrastructures - social and physical, especially rail - should not be permitted. It is not sufficient as the draft document states in Section 5.4 to bring the Dublin/Dunboyne rail proposal to "development stage". The basic requirement here is that work on the "construction stage" of the railway should have begun.
.3 It is further stated in Section 7.8 page 60 referring to transport links: "In the absence of
such infrastructure, expansion targets in such a case should be modest". It would be more appropriate to say that expansion targets should be positively discouraged.
11. Part B Section 9.3 Page 83
"Restrict...". This is most welcome. Due to work recently and currently
being undertaken, developments in designated flood prone areas and flood plains
should be prohibited. All developments within the catchment areas of rivers
are inappropriate since they affect, more or less significantly, river behaviours
and potential for flooding.
12. "Local needs". As long as this term remains undefined it is open to diverse and multiple interpretation and therefore is meaningless. If it cannot be defined it should not be used in the document. An alternative term or description to make known the mind of the authors of this text should be given.
13. The population in the Metropolitan Area increased more slowly than projected in SPGs but increased significantly in the Hinterland Area. Yet it is proposed to re-enforce this dispersal/sprawl trend by extending the Metropolitan Area to include parts of Counties Meath and Fingal.
14. It is a matter of concern for residents that Dunboyne is included in the Dublin Metropolitan Area and that this has been proposed by Meath County Council without consultation with our community which amounts to a violation of our mutual partnership and without an Environmental Impact Study. Concerns focus on the following three areas:
.1 Flooding: Dunboyne and the catchment areas of the Tolka and Castle Rivers experienced severe flooding in 2000 and 2002. Some interim remedial work has been carried out. The "River Tolka Flooding Study - Final Report" is in the process of being agreed. We have registered definite observations and reservations to Meath County Council on the draft report. The high densification and urbanisation implied as a consequence of designating Dunboyne within the Metropolitan Area, will significantly increase flood risk in the area.
.2 Landscape Character: Dunboyne is now unique in being a rural, sef-contained, and historical village on the edge of a very large urban settlement. To become an extension of that complex would be to irretrievably and severely diminish the heritage status of this environment. Furthermore, it is contrary to the principle of sustainability to do so.
.3 Residents' Opposition: It is a matter of record as submitted to Meath County Council that the majority of residents of Dunboyne have registered their opposition to the zoning of lands East of the disused railway line and the lands of the Dunboyne Castle demesne for housing development.
15. Part B Section 2.5 Page 11
We fully endorse this section.
16. Status of this document:
.1 It is stated that RPGs are advisory. As such then they may be disregarded without sanction.
.2 The SPGs were "guidelines" and as has been proved both legally (Ref. High Court case McEvoy v Meath County Council) and politically compliance was not required.
.3 It is stated that RPGs enjoy a "statutory function" and the same statutory status within the Planning and Development Act 2000 as the SPGs. It has been evidenced and proved that compliance cannot be required except by direct order of the Minister in specific instances, which undermines the very legislative underpinning required.
.4 The RPG document presents "guidelines" to which regard must be given. In law for an Authority "to have drawn attention to" satisfies the requirement "to have regard to" and no more.
.5 To "guide" implies indicating or requiring direction. If then guidelines imply no element of compliance then the title of the RPG document should not include the word "Guidelines". The RPG document is critical in acknowledging and implementing several international, European and national policy and strategic commitments. Surely what should be issued is a document of Regional Policy Directives the implementation of which Local Authorities should be held accountable.
17. The very least that should be done is to change Section 11 from "Next Steps" to "Directives".
18. For reasons given above this RPG document is highly permissive facilitating
developers to their own commercial ends, allowing County Councillors to prioritise
interests other than those of residents/citizens, as they have done (Ref. High
Court Case McEvoy v Meath County Council) and giving County Council Management
expansive discretion, something they may not wish to enjoy.
End