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Principal: John O’Connor Page | 1

Fingal County Development Plan 2017 – 2023

First Stage Submission (deadline 15th May 2015)

1. INTRODUCTION:

Fingal County Council is seeking submissions on the vision for strategic spatial

development and direction that should be included in the Fingal Development Plan

2017 – 2023 that is now under consideration. This submission on behalf of Sneem

Properties Ltd, 25 Merrion Square, Dublin 2 is in relation to ‘GE’ zoned Lands to the

south-west of Skerries Railway Station, Skerries, Co. Dublin, as illustrated on

attached drawing 11.105.FCC01.

Fingal County Council has invited submissions on the Development Plan and has

outlined in the strategic issues paper that it will be underpinned by the principles of

sustainable development, climate change adaptation, social inclusion and high quality

urban design. This submission is concerned with the principles for the appropriate

use of Masterplans and Local Area Plans within the hierarchy of planning policy, and is

discussed in particular in relation to these lands.

1. Executive Summary:

Submission in relation to strategic development of GE Zoned Lands

at Townparks to the south-west of Skerries Railway Station

1.1. It is proposed that the ‘LAP’ requirement be removed, and replaced with

the requirement for a MASTERPLAN in the Fingal Development Plan.

1.2. Due to the size and scale of these zoned lands, we suggest that the Local Area

Plan (LAP) requirement is not necessary, and is overly burdensome for the proper

and sustainable development of this small parcel of land, zoned ‘GE’ in the

Development Plan 2011 - 2017.




1.3. The total area of these zoned lands is approximately 10.357 Ha./ 25.6Acres, but

with the application of the FEMFRAMS Report, only 5.61Ha./ 13.9 Acres are

deemed available for development.

1.4. Given the lengthy timescale and onerous staffing requirements that are required

for the preparation of a Local Area Plan, the Masterplan process would be a more

efficient and effective means to procure the future development and sustainable

use of these lands. The Local Area Plan system and process is clearly not fit for

purpose for such a small and clearly defined site.

1.5. A Masterplan would secure the strategic development of these lands in a timely

manner, and would address all of the relevant infrastructure, zoning, and specific

objective and development proposals. A Masterplan structure would allow a

holistic approach to the lands, and facilitate the planned and coordinated

development of the site, similar to an LAP but without the statutory procedures

and inordinate delays necessitated by the process.

1.6. An appropriate level of residential development should be allowed for on

this site as a specific objective.

1.7. Construction 2020 outlines clearly the necessity for development on strategically

advantageous zoned and serviced land, located in close proximity to key

infrastructure such as the railway station at Skerries. The replacement of the

LAP requirement for a Masterplan would assist in the expeditious procurement of

development on this site.

1.8. Skerries Railway Station is one of the key infrastructure and service benefits to

development at this site. It is proposed that a specific objective for a ‘park and

ride’ facility on these lands, connecting with the Skerries Railway Station should

be included. This would benefit both new and existing communities, and is in

keeping with green infrastructure and sustainable transport strategies of Fingal

County Council.

1.9. It should be noted that the owners of Sneem Properties, (Tower Homes and

Winsac Limited) have a demonstrable interest in Skerries, and a history of the




successful delivery of projects at Skerries Rock, Kelly’s Bay and Barnageeragh

Cove dating back over 20 years.

2. Local Area Plans

The Planning Act of 2000 introduced, the concept of a hierarchy of planning policy,

placing Local Area Plans within the framework of higher-level plans (such as Regional

Planning Guidelines and City and County Development Plans). Local Area Plans provide

more detailed planning policies for areas where significant development and change is

anticipated, without having to prepare very detailed local planning policies and objectives

for many specific areas within City and County Development Plans.

We contend that the size and scale of the site, coupled with the current zonings and

specific objectives including the FEMFRAMS study, that sufficient site specific and

statutory guidance has already been outlined for this site and that a masterplan is a

more appropriate strategy to secure its future sustainable development. We believe that

the core strategies of the Development Plan can be upheld in the development of this site

in the context of a Masterplan, which would ensure that a holistic approach is taken by all

Stakeholders. The zoning and specific objectives of this site would remain in keeping with

the core strategies of the relevant development plan. A Masterplan would be informed by

these and therefore continue those visions and aspirations. Agreement of a Masterplan

with Fingal County Council would be a quicker and more efficient process than the

preparation of an LAP and will allow for the development of these lands in a more timely

manner. Having regard to the scarcity of development land in Skerries, to the overall

shortage of suitable employment and residential lands in the county and to the pressure

to satisfy the demand for sustainable development, the subject lands can be delivered

without delay whilst retaining and implementing the core strategies of the Development

Plan.




3. Fingal Development Plan 2017 – 2023 – Strategic Issues

3.1. Settlement Strategy

Considering the key aspiration of the settlement strategy that the Plan’s ‘Core Strategy’

and ‘Housing Strategy’ set out how, and where, we plan to meet our housing targets, the

facility to develop services lands, zoned for a residential component and adjacent to key

public transport infrastructure is clear. Skerries is an established community, and with a

clear need for additional housing. It should be noted that under the current

Development Plan, 2011 – 2017, no additional lands in Skerries were designated for

residential development. The significant land banks that were zoned for new residential

development in Skerries at Hacketsown and Barnageeragh have now had planning

approvals for development, and despite the obstacles presented by the economic

downturn, are now progressing well. A Masterplan designation for these lands would

facilitate the delivery of the residential component of this site, alongside the employment

and tourism opportunities. As a town well serviced by water, drainage and transport

facilities including public transport, Skerries is an ideal candidate for planned, moderate

growth.

- Residential development at Hacketsown has now commenced for phase 1

(Ballygossan Park). It is expected that this first phase of 103 dwellings will take

approximately three years to complete.

- Residential development at Barnageeragh has continued throughout the

recession, with approximately 25% of the 300 dwellings approved completed, and

is progressing very successfully with a reasonable expectation that the scheme in

its entirety will be completed in the next three years.

- The additional demand for housing in Fingal as a whole is clear from both census

data and Construction 2020, and that this residential development be located

adjacent to key public transport infrastructure has been highlighted in the

strategic issues paper. A Masterplan that will ensure the delivery of the

residential component of these lands is of clear benefit.

- Please refer to detailed data in respect of population growth and transport

infrastructure in the enclosed report by ILTP Consulting




3.2. Placemaking and Communities

Skerries has the ability to deliver the subject lands quickly and efficiently. Therefore it is

imperative that the appropriate zonings and objectives for these lands are included in the

Fingal County Development Plan, which we believe can be best secured with a

MASTERPLAN. Skerries has the advantage of a strong community, and a history of

sustained, but controlled and relatively modest growth. This is a pattern that should be

encouraged. A balanced and controlled level of development has been the pattern in

Skerries, and one that should continue to be encouraged and facilitated.

3.3. Infrastructure and Movement

The subject site of this submission is located in a strategically advantageous location

adjacent to the railway station. Increased development in close proximity to the Railway

Station, in tandem with the provision of park and ride facilities and greater connectivity

would be entirely in accordance with the aspirations of sustainable development and

transport strategies for Fingal. Skerries is designated as a ‘Moderate Sustainable Growth

Towns and Other Towns’ under the Fingal County Development Plan 2011 – 2017.

Skerries is a well defined, connected and serviced community with the scope to improve

in a sustainable and strategic manner. The development of this site complies with the

five key goals of Smarter Travel – A Sustainable Transport.

Screening for Assessment required by the Habitats Directive was carried out on this site

as required under Articles 6 (3) and 6 (4) of the EU Habitats Directive and a report

prepared by NATURA Environmental Consultants, Broomhall Business Park, Rathnew, Co.

Wicklow in May 2008. The overall conclusions and findings of this report were that:-

“The local areas plan for lands located at Townparks, Skerries will not have a significant

effect on the Natura 2000 site of Skerries Islands Special Protection Area which is located

over 1.5km east of the site”.

The FEMFRAMS Report and proposed Management Plan for the Mill Stream in the

Skerries Area of Potential Significant Risk (APSR) will be an important component in

informing the preparation and direction of the development of these lands adjacent to

Skerries Railway Station. The Femframs Report has already identified an area of this site

that should not be built upon, but this can be integrated in to a Masterplan to provide for




open space and park land to complement the employment and residential opportunities.

The Masterplan structure will allow for the planned and coordinated development of this

site, within the framework of the Fingal Development Plan, and taking into account all

relevant policies, guidelines and reports including the Fingal County Development Plan,

FemFrams Report, the Greater Dublin Transport Strategy, Construction 2020, and

government Housing Policy.

3.4. Economic Development

Improving economic conditions will allow this site to provide opportunities for new

employment, for tourists and for new homes that are in great demand. A Masterplan will

give the opportunity to pursue a sustainable and rational plan for this site, in consultation

with Fingal County Council, and without the significant delays that the Local Area Plan

process would entail on this relatively small scale and defined site. All zoning, specific

objectives and future Masterplans would be cognisant of the Green Infrastructure,

Natural Heritage, Coastal, and Cultural Heritage policies of Fingal County Council.

4. Conclusion

Please refer to the enclosed report from ILTP Consulting for a more detailed outline of the

national policies in support of this submission, and in particular in relation to transport

and infrastructure. We trust that Fingal County Council will take cognisance of this

submission in their consideration of the 2017 – 2023 Development Plan. Sneem

Properties look forward to working with Fingal County Council to bring forward a

Masterplan for these lands, and the prospect of a future successful development.

References:

- Fingal County Development Plan 2011 – 2017

- Guidance for Local Authorities on the preparation of Local Area Plans

Appendices:

- Submission on Fingal County Council Development Plan Review

2017 - 2023 – Strategic Issues by ILTP Consulting

- 11.105.FCC01 – Aerial Photo/ Concept Map (NOT TO SCALE)

illustrating the above proposals

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