town planning submission · draft fingal development plan 2017-2023 lands north of flemington lane,...

Town Planning Submission

Draft Fingal Development Plan 2017-2023

Formal Submission on behalf of John Smith

Lands North of Flemington Lane, Balbriggan, Co Dublin.

April 2016


Lands North of Flemington Lane, Balbriggan, Co Dublin. 1

1.0 Introduction Hughes Planning and Development Consultants, The Mash House, Distillery Road, Dublin 3 makes this submission, on behalf of our client John Smith in respect of its lands north of Flemington Lane, Balbriggan, Co Dublin. This submission is made in response to a public notice dated 19th February 2016, inviting submissions up until Friday 29th April 2016, in relation to the Draft Fingal Development Plan 2017-2023. In summary this submission requests the following:

That Fingal County Council rezone c. 9 hectares (c. 22.23 acres) of land located within the urban development boundary from Objective ‘RU’ (Rural) to Objective 'RA' (Residential Areas) in the Draft Fingal Development Plan 2017-2023; and

That Fingal County Council extend the Masterplan Area 4.A to include the submission lands; and

That Fingal County Council adopt a realignment of the proposed Balbriggan Western Ring Road along the western boundary of Masterplan Area MP 4.A and through the submission lands to connect with the R132 Old Dublin to Belfast Road.

The zoning of the land, as per the Draft Fingal Development Plan 2017-2023, is shown in Figure 1.0 below while Figure 2.0 shows the zoning as per this submission request. The submission lands, zoned ‘RU’ Rural, directly adjoin other lands in the ownership of our client, John Smith, lands which are zoned for residential development and subject to Masterplan Objective MP 4.A in the draft development plan. It is submitted that aligning the residential zoning and Masterplan Objective presents an opportunity for timely delivery of residential development to meet housing demand envisaged by the Regional Planning Guidelines. In addition, the realignment of the Balbriggan Western Ring Road is considered to be a more rationale proposal in terms of urban place making. We request that the recommendations of this submission be given full consideration in preparation of the forthcoming Fingal Development Plan 2017-2023.

Figure 1.0 Zoning Map as per Draft Fingal Development Plan 2017-2023, showing the submission lands (outlined in red) zoned ‘RU’ – Rural

‘GB’

‘HA’

‘RA’

‘RU’



Figure 2.0 Zoning Map as per Draft Fingal Development Plan 2017-2023, showing the Balbriggan 4.A ‘Masterplan Area’ extended north to include the submission lands and rezoning of the submission lands from ‘RU’ Rural to ‘RA’ Residential Areas, together with realignment of the proposed Balbriggan Western Ring Road

2.0 Submission Lands The submission lands comprise some 9 hectares (22.23 acres) in northwest Balbriggan, located north of Flemington Lane and west of the R132 Old Dublin to Belfast road. The lands are part of a pocket of ‘RU’ (Rural) zoned land contained within the urban development boundary of Balbriggan and immediately north of undeveloped ‘RA’ (Residential Areas) zoned land to which Masterplan Objective MP 4.A applies, in accordance with the provisions of the draft development plan. Balbriggan is a coastal town in north County Fingal. The early settlement of Balbriggan was based on its function as a fishing port, influenced by its location at a natural harbour on the coast of the Irish Sea. In the late 1800s, cotton manufacture was brought to Balbriggan with the construction of two factories. The consequential growth in the cotton industry transformed Balbriggan from a small fishing village to a place of manufacturing and commercial activity. The town experienced a population boom in the early part of the 2000s as a result of the demand for housing within the wider Dublin region. Census records show an increase from 6,731 persons in 2006 to 19,932 persons on 2011, equivalent to a 196% increase. The strategic location of the town in terms of the Dublin to Belfast train line and proximity to the M1, allows convenient access to Dublin City and Swords to the south and Drogheda and Dundalk to the north. It is also noted that the Government has recently announced an extension of the DART line to Balbriggan by 2022. Town centre retailing and services are concentrated around the central north-south thoroughfare through the town, being the former Dublin to Belfast main road. This thoroughfare commences as

‘RA’

‘RA’

‘RA’

‘RU’

‘GB’

‘HA’

‘RS’



Dublin Street on the entrance to the town from the south, becomes Bridge Street at St. George’s Square, and subsequently continues as Drogheda Street from its junction with Mill Street. Housing growth in Balbriggan over the last 10 years has been directed to the west and northwest of the town.

Figure 3.0 Locational context of the submission lands (outlined in red) 3.0 Current Planning Context 3.1 Regional Planning Guidelines for Greater Dublin Area 2010-2022 On a regional level, the submission lands are strategically located within the Hinterland Area of the Greater Dublin Area and more specifically within the Large Growth Town II of Balbriggan, ‘…strong active growth town, economically vibrant with high quality transport links to larger towns/city. ’ The Regional Planning Guidelines state that Large Growth Towns II such as Balbriggan “plan for growth in scale with level II planning with a range suitable to the scale of the town – approximately 15-30,000 persons. It is essential to the achievement of the delivery of the RPG settlement strategy that new and appropriate mechanisms are developed to deliver enabling infrastructure to allow the planned development and consolidation of these towns to take place, particularly for key non-national roads, bus services and investment in water services.” 3.2 Fingal Development Plan 2011-2017 Under the Draft Fingal Development Plan 2017-2023, the land is zoned ‘RU’ – ‘Rural’, the objective of which is to ‘Protect and promote in a balanced way, the development of agriculture and rural-related enterprise, biodiversity, the rural landscape, and the built and cultural heritage’. The vision for this zone is as follows:

‘Protect and promote the value of the rural area of the County. This rural value is based on:

Agricultural and rural economic resources

Visual remoteness from significant and distinctive urban influences

A high level of natural features

Agriculture and rural related resources will be employed for the benefit of the local and wider population. Building upon the rural value will require a balanced approach involving the protection and promotion of rural biodiversity, promotion of the integrity of the landscape, and enhancement of the built and cultural heritage.’

Balbriggan

Development

Boundary

Masterplan Area

4.A

R132 Regional

Road



Figure 4.0 Extract from Zoning Map No. 4 in the Fingal Development Plan 2011-2017,

showing the submission lands outlined in red The zoning map in Figure 4.0 above also provides details on the zoning context of the surrounding lands. The map shows the urban development boundary, represented by a dashed red line, already extending around the submission lands. The map also shows the the ‘RS’ Residential zoned lands adjoining the submission lands to the south, to which Local Objective 8 applies. Local Objective 8 reads as follows:

‘Allow low density housing - circa 12 per hectare (5 per acre) gross, in accordance with a Masterplan.

Development of these lands shall include provision for significant traffic calming and re-alignment of Flemington Lane. Access to these lands from the R132 shall form part of the Gateway Strategy for the northern approach to Balbriggan.’

Other objectives for the area include the provision of the Balbriggan Ring Road, which would have an alignment along Flemington Lane, connecting to the R132 Old Dublin to Belfast road to the east. The map also shows an indicative cycle/pedestrian route along Flemington Lane. We would note that a Masterplan, prepared in accordance with Local Objective 8, is at an advanced stage and has already been presented informally to the Planning Department of Fingal County Council. 3.3 Draft Fingal Development Plan 2017-2023 Under the Draft Fingal Development Plan 2017-2023, the zoning provisions relating to the submission lands and surrounding area are generally unchanged from the current development plan. The submission lands remain zoned ‘RU’ Rural, and remain located within the urban development boundary for Balbriggan. The only discernible change is that the lands to the south of the submission lands, to which Local Objective 8 currently relates, are now zoned ‘RA’ Residential Areas and assigned Masterplan Objective MP 4.A. Section 4.3 of the draft development plan provides the following broad objectives for guiding the preparation of a Masterplan for the Flemington Lands:

Provide for architecturally designed buildings with high quality finishes.

Prior to any proposed design or layout of development on these lands a detailed archaeological study shall be carried out.

Allow low density housing only.

Provide for significant traffic calming and re-alignment of Flemington Lane.

‘RU’

‘RU’

‘RA’

‘HA’

‘OS’

‘GB’ ‘RS’



Other objectives which remain unchanged for the area include the provision of the Balbriggan Ring Road, which would have an alignment along Flemington Lane, connecting to the R132 Old Dublin to Belfast road to the east. And also an indicative cycle/pedestrian route along Flemington Lane.

Figure 5.0 Extract from Zoning Map No. 4 in the Draft Fingal Development Plan 2017-2023, showing the submission lands outlined in blue

4.0 Submission Request This submission requests the following:




It is submitted that the rezoning of the submission lands to ‘RA’ Residential Area, and the inclusion of the submission lands as part of Masterplan Objective MP 4.A is justified in the context of its strategic location within the Development Boundary of Balbriggan, being a Large Growth Town II, and more importantly, we would contend that further residential zoning is required to ensure that Balbriggan can accommodate the housing allocations up to 2023 and beyond to 2026. There is therefore an opportunity to incorporate our client’s lands in the Masterplan Area, which will serve to advance the long term growth objectives of Balbriggans main urban growth area. We submit that the realignment of the proposed Balbriggan Western Ring Road to take a route along the western side of the MP 4.A lands and through the submission lands is more conducive to sustainable urban place making. The realignment will avoid the need for a major distributor road through the proposed Masterplan MP 4.A lands along Flemington Lane, allowing better integration between existing and proposed residential neighbourhoods.

‘HA’

‘GB’ ‘RA’

‘RU’

‘OS’



4.1 Settlement Strategy Balbriggan is designated as a ‘Primary Development Centre’ in the NSS and as a Large Growth Town Level II in the RPGs, being the only Large Growth Town II in Fingal and the largest urban settlement in Fingal outside of Swords and Blanchardstown. According to the RPGs, these towns, with populations of between 15-30,000 persons, are “strong active towns, economically vibrant with high quality transport links.” Following on from the enactment of the Local Government Reform Act 2014, three new Regional Assemblies came into effect in January 2015, replacing the previous Regional Authorities. Fingal is now part of the Eastern and Midlands Regional Assembly which is made up of the counties of Leinster less Carlow, Kilkenny and Wexford. The new Assembly will produce a Regional Spatial and Economic Strategy which will, when adopted, supersede the current RPGs. However, until such time as new Regional Strategies are prepared, the preparation of the Development Plan will continue to be guided by the RPGs. The RPGs translate the national and regional population targets set by the NSS to county level. Development Plans are required to be consistent with these targets albeit there is recognition that they may not be achieved within the allotted timeframe.

Census 2006 Census 2011 RPG Target 2016 RPG Target 2022 RPG Target 2023 (estimated)

Population 239,992 273,992 287,547 309,285 312,908

Figure 6.0 Actual and RPG Population and Housing Targets for Fingal

Fingal Census 2006 Census 2011 RPG Target 2016 RPG Target 2022

Estimated RPG Target 2023

Population 239,992 273,992 287,547 309,285

Housing Stock 89,909 102,793 118,646 142,144 145,340

Persons per hhd* 2.66 2.66 2.42 2.17

Figure 7.0 Actual and RPG Population and Housing Targets for Fingal The table in Figure 7.0 above shows that an increase of 15,853 units in Fingal is required to meet the 2016 RPG targets from the 2011 level. This represents an annual requirement for 3,170 units (over a 5 year period). The table above further shows that between 2011 and 2022 a total of 39,351 units were targeted representing 3,577 units per annum. In the Core Strategy, Fingal County Council considers that in normal market conditions the lower figure per annum would not be an unreasonable target for Fingal. The Core Strategy finds a discrepancy between the target housing numbers and the actual completion rates for Fingal. The Core Strategy finds that under recent market conditions Dept. of Environment, Community and Local Government completion figures indicate a total of 2,599 units completed in Fingal between the Census in April 2011 and July 2015 (the most recent completion figures available), indicating an average of 650 units per annum. This gives an estimated housing stock in Fingal in mid-2015 of 105,392 units. The Core Strategy concludes that based on current housing stock, 5,700 units per annum over the 7 year period 2016 to 2023 would be necessary to fulfil RPG targets. This is outlined in Figure 8.0 below. Fingal County Council considers this to be an unsustainable target and refers to research done on behalf of the Housing Agency in 2014 indicated that an average annual production of c.7,500 units is



required in the Dublin Region’s urban settlements between 2014-2018. Fingal County Council note that if Fingal took 20% of this growth, to align with its RPG target share, completions would need to be in the order of 1,500 units per annum, representing just 26% of the RPG target units per annum between 2016 and 2023.

Estimated Existing Units July 2015

RPG Target Unit 2022

RPG Target Units 2023 (estimated)

New Unit Target 2016-2023

Headroom Requirement 2023-2026

New Unit Target 2016-2026

105,392 142,144 145,340 39,948 9,588 49,536

Figure 8.0 Number of New Residential Units in Fingal required to meet RPG Targets The Regional Planning Guidelines indicate that 85% of new housing allocations should be directed to the metropolitan areas of the region, with the remaining being accommodated in the hinterland area. This would suggest that for the period 2016-2026, c. 7,430 new units (15% of 49,536) would be directed to the hinterland area, with the majority accommodated in Balbriggan, being the only Large Growth Town Level 2 within the County. The total available zoned land supply in Balbriggan in the Draft Fingal Development Plan 2017-2023 is 153 hectares, with a stated capacity to provide 4,332 residential units. This data is shown in the table in Figure 9.0 below.

Figure 9.0 Total Residential Capacity provided under the Draft Fingal Development Plan 2017-2023



The figure for ‘Potential Residential Units’ represents an average density of 28 units per hectare. This is considered to be questionable when compared to extant planning permissions and development plan provisions for Balbriggan. F15A/0437 Planning permission granted on 1st February 2016 for alterations to previously approved

development (Reg. Ref. F13A/0240), to increase in number of dwellings from 99 no. to 131no.

The permission allows for 129no. dwellings on a 6.2461ha site, representing a density of

20.6 dwellings per hectare. The Planner’s Report provides the following commentary with respect to density:

‘In respect of density, the application site has a stated total site area of 6.2461ha. The

resultant density is therefore c. 21 dwellings per hectare. A density of this nature at this location is considered acceptable and in accordance with the guidance set out in the relevant guidelines. ‘Sustainable Residential Development in Urban Areas 2009’ DOEHLG.’

Based on the above commentary, a suitable density for residential zoned land in Balbriggan is in the region of 21 dwellings per hectare. With 153 hectares of zoned lands available within the development boundary for the town, there is potential for 3,213 new dwellings over the lifetime of the draft development plan. There is further uncertainty when we look at the development potential of lands within Masterplan Area MP 4.A, the development parameters for which dictates that development must be delivered at ‘low density’. There is no further guidance on what constitutes ‘low density’ in this regard however it is our interpretation that low density is anything below 35-50 units per hectare, which according to the Sustainable Residential Development in Urban Areas – Guidelines for Planning Authorities 2009, represents the most efficient use of development land. It is submitted that delivering 3,213 new dwellings in Balbriggan over the lifetime of the draft development plan falls well short of the RPGs target of c. 4,000 new dwellings over the same period (10% of 39,948 – See Figure 8.0 above), or c. 4,950 new dwellings up to 2026 (10% of 49,536 - See Figure 8.0 above). The Development Strategy for Balbriggan under the draft development plan is as follows:

‘Further consolidate and regenerate the town in line with its designation as a Large Growth Town II and a ‘secondary economic growth town’ in the RPGs. Development will focus on the town as a primary commercial, industrial, retailing and social centre in the north of the County providing for the needs of its developing community and promoting the growth of sustainable local employment in the industry, service and tourism sectors.’

Relevant draft development plan objectives include: Objective SS16 Support and facilitate residential, commercial, industrial and

community development to enable Balbriggan to fulfil its role as a Large Growth Town in the Settlement Hierarchy recognising its important role as the largest town in the hinterland area.

Objective BALBRIGGAN 1 Promote and facilitate the development and growth of Balbriggan as

the primary service, social, cultural and local tourist centre in north Fingal.

Objective BALBRIGGAN 2 Facilitate the implementation of the Urban Design Framework Plan and

Balbriggan Public Realm Plan for the town centre to encourage the regeneration of the identified potential development sites within the town centre.

Objective BALBRIGGAN 3 Cooperate with representative stakeholders in particular the IDA,

Enterprise Ireland and the local Chamber of Commerce to attract and facilitate new employment generators into the town.



Objective BALBRIGGAN 4 Develop Bremore Regional Park incorporating an Active Recreational

Hub including integrated sports facilities to serve Balbriggan and the surrounding area, including plans to facilitate the restoration and use of Bremore Castle, Bells Cottage, Boat House and the Martello Tower as community facilities, with a maritime museum/museum and civic facility to serve the town.

Objective BALBRIGGAN 5 Promote and facilitate the establishment and development of a third

level educational facility. Objective BALBRIGGAN 6 Prepare a Regeneration Strategy for Balbriggan Harbour in

consultation with local fishermen, businesses and community groups having regard to its historic character subject to Screening for Appropriate Assessment.

Objective BALBRIGGAN 8 Facilitate the development of a Marine Conservation and Education

Centre. Objective BALBRIGGAN 9 Promote and facilitate the development of a swimming pool with a

sports complex within the town. Objective BALBRIGGAN 12 Promote and facilitate an enhanced rail station (a protected structure)

and rail service, including the extension of the DART rail service to Balbriggan.

The draft development plan recognises that planning policy remains one of consolidation within the metropolitan area with expansion only happening in tandem with the planned, committed development of high quality heavy or light rail based public transport projects. While we do acknowledge that Balbriggan is located within the hinterland area of Fingal, there are significant attributes which make it feasible for further growth or at the very least, realising its potential as a Large Growth Town Level II. Of greatest relevance is the announcement of the DART Expansion Programme including the electrification of the Northern line between Malahide and Balbriggan. Located c.18 kms north of Swords, with easy access off the M1 Motorway, Balbriggan has developed as a major residential town in the north of the County with a young and expanding population which has more than doubled over the past 20 years. The current population is estimated at c. 20,000. Major infrastructural projects involving major upgrades to the water supply, foul drainage and roads infrastructure have been carried out throughout the town and its environs. Balbriggan is eFibre broadband enabled with superfast fibre delivering speeds of up to 100Mb. The Urban Improvement Scheme has significantly enhanced the streetscape of the town centre. The Urban Design Framework Plan identified potential development sites within the town centre. The draft development plan recognises that implementation of the Urban Design Framework Plan is central to the regeneration of the town centre. In addition, the Balbriggan Public Realm Plan – ‘The Heart of Balbriggan’ sponsored by the Heritage Council, seeks to focus on strengthening the social, economic and environmental capital of the town promoting the pivotal role of the town centre area in developing a sustainable community. It is submitted that with these initiatives, together with the infrastructural and environmental improvements sought through draft development plan objectives, will provide the impetus for further development and investment in Balbriggan. The submission lands extend to an area of 9 hectares, located within the urban development boundary and adjacent to ‘RA’ (Residential Areas) zoned land. A masterplan, pursuant to Local Objective 8 under the current development plan, has been progressed by our client in conjunction with the other landowners with a timeframe of immediately post adoption of the Fingal Development Plan 2017-2023 for completion and ready for submission to Fingal County Council. The rezoning of the submission lands and inclusion of the lands within Masterplan Objective Area 4.A, would facilitate additional



residential development at a density of between 20 and 30 dwellings per hectare, equating to between 180 and 270 new dwellings, delivered in a managed and considered approach under an approved Masterplan, and seeking to achieve housing development in accordance with the RPGs. 5.0 Conclusion The submission lands comprise some c. 9 hectares (c. 22.23 acres) located on the north side of Flemington Lane in north-west Balbriggan. This Submission Requests the following:




The justification for rezoning the submission lands to ‘RA’ Residential is based on the settlement strategy in the draft development plan and how this relates to the population projections and housing allocations as forecasted in the Regional Planning Guidelines. We trust that the Planning Authority will have regard to the contents of this submission in it adoption of the Fingal County Development Plan 2017-2023 _____________ Kevin Hughes MIPI MRTPI

Director

town planning submission · draft fingal development plan 2017-2023 lands north of flemington lane,...

Documents