Introduction

The designation of the Clonburris lands as a Strategic Development Zone is welcome. The country is currently facing the biggest housing crisis since the foundation of the state with over 8 000 people living in emergency accommodation. More than 2000 children are homeless, and many more are living in overcrowded, temporary and unsuitable accommodation.

However, the urgent need for housing must not lead to bad planning and rushed development. The mistakes of the past must not be re-made. Instead, development of residential lands must be co-ordinated with the provision of services for new and existing residents. The draft SDZ plan goes some way in addressing this, however there are areas where improvements could be made.

Planning process

Before discussing the details of the SDZ draft plan, it is necessary to comment on the planning process as a whole. There are several aspects of planning in Ireland which are unsatisfactory.

Firstly, the emphasis on the land owners and developers to carry out the plan. Due to the onerous process of Compulsory Purchase Orders land owners and developers can choose not to implement a plan and the consequence is that the land is left undeveloped. The introduction of a vacant site levy will go some way towards incentivising development, however while the levy remains below the rate of land price inflation it may not have the desired effect.

Secondly, plans proposed to local councillors to vote on contain aspects of which they have no power over. For example, the provision of public transport is determined by the National Transport Authority and the construction of schools are decided by the Department of Education. Local councillors can’t force either of these bodies to provide desperately needed services for people in their Local Electoral Area.

This ‘demand’ or market-driven approach has utterly failed in areas such as Adamstown, where people bought properties in the expectation that the SDZ plans would happen. Instead, due to the collapse of the housing market, they were left without services and amenities.

The problems outlined above can’t be solved without significant change in legislation, which won’t happen before the adoption of the Clonburris SDZ. It does mean however, that the SDZ plan will be a recommendation to all stakeholders rather than a definite plan.

Traffic and Transport

General comments

The Lucan and Clondalkin areas have been left behind when it comes to public transport. The Luas red line touches the southern end of Clondalkin but is virtually useless for the large majority of residents due to the lack of a feeder bus. Bus services are unevenly spread throughout the area and there is no or limited connectivity between the major urban centres of Clondalkin, Lucan and Tallaght. This has led to the over reliance on the private car for transport, in turn leading to severe congestion on the roads. In addition, the way we work and live has changed significantly over the last number of years. Most people do not live and work in the same area, partly due to the housing market and partly due to the location of large businesses in industrial estates cut off from public transport. Public transport has not been planned and delivered to suit these changing needs forcing people to use private cars.

The SDZ draft plan proposes new and expanded public transport services for the area. However as outlined above, these proposals will be nothing more than a ‘wish list’ as it is the responsibility of the NTA to provide these services. Unfortunately the NTA will only provide services if they believe that there is a demand for them. This means that if only a certain part of this plan gets developed and the NTA deems there to not be enough demand for a service they will not provide it, regardless of the needs of the community. People Before Profit strongly urge a more holistic approach that integrates transport, construction, amenities and services into an overall coherent plan.

Public transport: 

The Kildare rail line which intersects the site offers a great opportunity for public transport. However, in order to achieve the benefits of it the service needs to be significantly improved. The currently closed Kishogue train station should be opened immediately when construction starts.

There is a need for increased train services to carry more passengers and to offer a viable alternative to private car journeys. The number of journeys travelling through the Phoenix Park tunnel and terminating at Grand Canal Dock need to be increased to offer more convenient options for travelling to Dublin City Centre. The current service of 7 services a day is totally inadequate. The proposed DART expansion to Hazelhatch needs to be prioritised to allow for more frequent train services.

Lucan Luas needs to be approved and planned immediately by the Government. The Lucan area is heavily congested and public transport is inadequate. Bus services are currently operating to full capacity at peak times causing many to abandon public transport in favour of driving.

New bus routes and increased services on existing routes are needed immediately. The new proposed orbital routes are welcome and they must operate at high frequency to offer a viable alternative to car journey’s across urban areas. As outlined in the Transport Assessment & Transport Strategy document (p. 74) “the routing for these services have not been finalised and may be subject to change”. New bus routes must not prioritise the new development ahead of existing communities. The routes suggested in Figure 7.7 (p. 70) Clonburris PT Strategy Measures leave several existing communities in both Lucan and Clondalkin without through services, such as Green Park/Sruleen, Bawnogue and Ballyowen.

Traffic:  

There is already pressure on the road networks and an additional 8,000 housing units will significantly increase this pressure. The projections in the Traffic Assessment were based on a review of existing transport behaviour based on 2012 travel data extracted from the Eastern Regional Model. This data does not necessarily reflect current behaviour in 2017 due to the significant increase in employment since that time. A new review should be conducted using the more recent 2016 census data. If it is necessary to delay the plans until later in 2018 in order to provide these figures then that should be seriously considered.

The projections for 2035 are based on the existence a Lucan Luas, the DART extension to Hazelhatch, the DART underground and improved bus services. However, there is no guarantee that these services will be in existence by then and without these, the use of private cars will be significantly higher than projected.

The use of off road pedestrian and cycle routes are very welcome as a safe and environmental alternative to cars. The permeability routes through estates linking different parts to schools and amenities should encourage cycling and walking within the area. Boundary walls of existing estates should not be removed for permeability routes (Figure 7.21 p.88) unless ALL residents are in agreement.

The provision of car parking spaces must be adequate for the population. With the upgraded public transport services such as the Lucan and the DART extension not being delivered for many years, it is likely that private car ownership will be high. The provision of maximum 1.5 spaces per 3+ bed houses in Zone 2 (Figure 7.51) is highly likely to be inadequate in the short term. For the time period while public transport remains inadequate this is likely to lead to cars parked illegally and in existing estates where more parking space is available.

Existing communities: 

The possible addition of over 8, 000 housing units will have a significant impact on the existing population of all the surrounding areas. In order to create a thriving community, facilities and services must be provided in conjunction with the construction of housing units so as not to have a negative impact on existing services such as schools and community facilities.

In addition, developers, builders and SDCC must liaise with neighbouring communities during construction periods. There should be a designated community contact person for the Clonburris SDZ in SDCC.

Existing residents are concerned about the possible permeability routes as seen on Figure 7.21 on p. 88 of the Transport Assessment & Strategy document. While permeability is best planning practice it must be done by agreement of all local residents. Existing boundary walls should remain unless all residents agree to open them up.

The traffic impact on existing communities needs to be reviewed. For example, the plan includes housing units at the back of Ashwood estate, however it doesn’t indicate any additional roads to support the extra traffic. The entrance to Ashwood estate is already congested during peak hours. A review of the impact on existing housing estates should be carried out.

 

Community facilities, amenities and phasing:

The provision of facilities and amenities are essential to creating a vibrant community. Many community centres in the surrounding area are already operating to full capacity, so it is crucial that new facilities are built in conjunction with the new housing units. According to figures in Table 4.3, 4.4 and 4.5 (p. 137-8, Draft Planning Scheme) there is no requirement to build community floor space up to the first 1,000 units. This means that if 800 units are constructed there is no requirement for any community floor space. There is also a so called ‘Roll Over’ whereby an additional 250 units can be constructed in the next phase without fulfilling the requirements. This means that up to 1 250 units can be built without any community facilities. This is completely unacceptable.

In addition to floor space there is a need for green areas and parks. Again, the Draft Plan (Table 4.3) sets out that these are not required within the first 1 000 units, or rather 1,250 units.

The provision of community floor space, the commencement of works at Griffeen Valley Park Extension or Barony Park, to make available a school site for the Department of Education and the availability of childcare spaces should all be moved from Phase 1B to Phase 1A. This would help avoid developers building smaller numbers and encourage them to build larger numbers of units in conjunction with the required facilities. It avoids making the mistake which was made in Adamstown where the phasing meant that none of the facilities required were developed, with residents being left waiting for many years.

The ‘Roll Over’ mechanism mentioned on p. 140 should be removed. No further units should be constructed unless ALL requirements of the previous phase has been met.

In addition to the multi-purpose community hubs, the Clondalkin-Lucan area needs a dedicated Arts Centre, similar to Rua Red in Tallaght. This should be located in either of the main Urban Centres of Clonburris or Kishogue. It should include rehearsal, performance, studio and exhibition spaces, and could be co-located with a library and/or civic centre.

The provision within the plan for 8 schools, 6 of which are new, is welcome. However, significant pressure needs to be mounted on the Government and the Department of Education to deliver the schools to cater for the existing and new families.

Housing: 

Housing is desperately needed in the Dublin Mid-West area. Therefore, the reduction of employment space in this draft plan compared to the previous one in favour of residential units is welcome. Considering the large numbers of vacancies in existing industrial estates throughout the county the increase in residential units is positive.

While there is demand for housing both for sale and in the private rental sector, there is a large demand for social and affordable housing in the Clondalkin and Lucan areas. We need social housing for the thousands of people on the social housing list, and we need affordable housing for those who want to buy their own home but can’t get a mortgage. As of the 3^rd November 2017 approximately two thirds of homes for sale on daft.ie in the Dublin region are priced in excess of €300 000. There is no reason to build any homes over €300 000 in the SDZ, and as such all homes will be ‘affordable’ according the government’s definition. There should also be a consideration given to the possibility of council developed affordable housing.

More than 30% of the land in the area is owned by South Dublin County Council. This is one of the few remaining pieces of land in public ownership in the Dublin Mid-West area. It should therefore be used for housing construction for the many thousands who are in desperate need of housing. Instead of so called homeless hubs, we need to build permanent homes.

The majority of the SDCC land is currently proposed for the Griffeen Valley Park Extension. If this remains there needs to be a negotiated land swap or equivalent number of units provided for social housing by the land owners/developers in addition to the 10% Part V units.

Design:

The Design criteria and Design Statements (p.53-54) sets out good design with use of traditional materials and high quality building finishes. However, the promotion of ‘a vibrant mix of finishes, colour and detailing’ may be off-putting to some due to the unsuccessful use of vibrant colours in nearby Balgaddy.

The building heights across the SDZ are not clear and are in places contradictory. For example, on page 60 it says that “To ensure that building heights respect the surrounding context, new developments immediately adjoining existing one and two storey housing shall incorporate a gradual change in building height with no significant marked increase in close proximity to existing low-rise housing.” However, the Building Height Concept Figure 3.3.2 on p. 105 shows streets backing on to Oldbridge, Rossberry, Tullyhall, Foxborough and Ashwood as BH1 2-4 storeys residential. A different designation of maximum 2 storey should be given to these blocks, in order to ensure adherence to the comment made on p. 60 quoted above.

The visual aspect of the Round Tower from the 11^th Lock in Clondalkin should be preserved in order to promote the rich cultural heritage of Clondalkin and the newly developed Round Tower Visitor Centre.

The Development of Clonburris is an important opportunity to provide much needed social housing and to right some of the wrongs of the past. A successful development should prioritise creating communities with decent transport links, appropriate amenities and good public services. If this occurs the longstanding problems of transport and lack of amenities in the area can be reversed. If not the development will be yet another profit led initiative that only serves to magnify past mistakes.