Proposed Amendments to the Draft Wicklow County Development Plan 2022 - 2028

These amendments all will help protect our woodlands tree and hedgerows, and our Kilranelagh Hillforts.

The addition of the sentence prioritising envirnmental protection in the design and construction of routes and surfaces is very important. Not all surfaces should be paved.

To better protect nature and biodiversity, stop noise and light pollution, and manage sites to protect the envirnoment during construction.

To raise the number of places for bike parking, and have good space allocated for waste and recycling bins. To make provision for community gardens in larger residential developments.

Introduction:

Community Gardens Ireland is a network of community gardens and allotments on the island of Ireland. In existence since 2011, it aims to support and promote community gardening in Ireland and Northern Ireland.

Community Gardens Ireland notes that the number of allotments and community gardens provided by local authorities in Ireland is low when compared to other European countries. Approximately 2500 allotments & community gardens are currently provided by local authorities in Ireland. Denmark, for example, has a similar population but has over 40,000 allotments. Other countries such as Germany, Britain, Poland, Finland, Austria etc. offer far more per capita allotments or community gardens than Ireland.

According to a 2020 Local Government Management Agency report, Wicklow County Council is one of 8 local authorities in Ireland that provide no allotments or community gardens. Community Gardens Ireland believes this should be rectified as soon as possible.

Community gardens and allotments actively contribute to the National Biodiversity Action Plan and the All-Ireland Pollinator Plan. Furthermore, many increase native hedgerow planting and add to urban forests. 

A large argument in favour for the provision of more community growing spaces is that the spaces assist in the improving of urban food security, reduces food carbon footprint by avoiding long distance food transport and reduces GHG emissions by recycling organic waste. 

Community growing spaces (allotments or community gardens) can contribute to adapting to climate change impacts by increasing water infiltration and slowing down run-offs which can prevent flooding. Community growing spaces also improves biodiversity and strengthens ecosystems.

Aside from this, community growing spaces contribute positively to mental health, physical health and community cohesion.

Food Security & Supply Concerns in Ireland:

In recent weeks it was announced that discussions were commencing regarding the need to bolster Ireland's food security as a result of the war in Ukraine: 

Link: https://www.irishtimes.com/business/media-and-marketing/all-farmers-to-be-told-to-plant-crops-amid-fears-of-food-security-crisis-1.4819680

In recent weeks it was also announced that there were "Tomato, lettuce and pepper supply challenges due to ‘perfect storm’ of issues": 

Link: https://www.irishtimes.com/news/ireland/irish-news/tomato-lettuce-and-pepper-supply-challenges-due-to-perfect-storm-of-issues-1.4845370

Intergovernmental Panel on Climate Change (IPCC) Report – WGIII:

Recently the IPCC released their Working Group III report. Detailed within this were climate actions related to increasing the amount of urban agriculture in urban areas, as detailed below:

D.2.1 Sustainable urban planning and infrastructure design including green roofs and facades, networks of parks and open spaces, management of urban forests and wetlands, urban agriculture, and water-sensitive design can deliver both mitigation and adaptation benefits in settlements (medium confidence). These options can also reduce flood risks, pressure on urban sewer systems, urban heat island effects, and can deliver health benefits from reduced air pollution (high confidence).  

8.1 Sustainable Development: Urban agriculture, including urban orchards, roof-top gardens, and vertical farming contribute to enhancing food security and fostering healthier diets.  

8.2.2 Economic development, competitiveness, and equity: Urban agriculture can not only reduce household food expenditure, but also provide additional sources of revenue for the city.  

8.4.6  Urban-rural linkages: Urban food systems, as well as city-regional production and distribution of food, factors into supply chains. Reducing food demand from urban hinterlands can have a positive impact on energy and water demand for food production (Eigenbrod and Gruda 2015) (see ‘food system’ in Glossary). Managing food waste in urban areas through recycling or reduction of food waste at source of consumption would require behavioural change (Gu et al. 2019). Urban governments could also support shifts towards more climate-friendly diets, including through procurement policies. These strategies have created economic opportunities or have enhanced food security while reducing the emissions that are associated with waste and the transportation of food. Strategies for managing food demand in urban areas would depend on the integration of food systems in urban planning. 

Link: https://report.ipcc.ch/ar6wg3/pdf/IPCC_AR6_WGIII_FinalDraft_FullReport.pdf  

Intergovernmental Panel on Climate Change (IPCC) Report – 2019:

In 2019, the Intergovernmental Panel on Climate Change (IPCC) released a report which included Urban Agriculture initiatives, as follows:

“Urban and peri-urban agriculture reduces the food carbon footprint by avoiding long distance food transport. These types of agriculture also limit GHG emissions by recycling organic waste and wastewater that would otherwise release methane from landfills and dumping sites (Lwasa et al. 2014). Urban and peri-urban agriculture also contribute in adapting to climate change, including extreme events, by reducing the urban heat island effect, increasing water infiltration and slowing down run-offs to prevent flooding, etc.

(Lwasa et al. 2014, 2015; Kumar et al. 2017a1209). For example, a scenario analysis shows that urban gardens reduce the surface temperature up to 10°C in comparison to the temperature without vegetation (Tsilini et al. 20151210). Urban agriculture can also improve biodiversity and strengthen associated ecosystem services (Lin et al. 20151211).”

“In summary, urban and peri-urban agriculture can contribute to improving urban food security, reducing GHG emissions, and adapting to climate change impacts (robust evidence, medium agreement).”

Ref: https://www.ipcc.ch/srccl/chapter/chapter-5/ 

Sustainable Development Goals:

Community growing spaces also clearly help contribute towards some of the UN’s Sustainable Development Goals, for example:

• 3 Good health and well-being
• 11 Sustainable Cities and Communities
• 12 Responsible consumption and production

Community Gardens Ireland Comments & Recommendations:

1. Community Growing Spaces Waiting List

Community Gardens Ireland notes that there is no waiting list in place for community growing spaces by Wicklow County Council. While other local authorities are able to gauge interest from the use of a waiting list and plan accordingly, the lack of a Wicklow County Council waiting list in place does not help with long term planning of use.

For example, there are reports from South Dublin County Council that there is a 10-year waiting list for allotments:

https://www.echo.ie/allotments-created-and-allocated-to-people-on-wait-list/

Knowing demand for community growing spaces would better enable Wicklow County Council to plan future use of land in an overall strategy and for specific locations throughout the county.

Community Gardens Ireland recommends that Wicklow County Council open a waiting list for community growing spaces throughout the county to better plan for demand for community growing spaces.

2. Other European Countries - Benchmarking

Ireland provides a poor level of allotments and community gardens compared to European figures.

For example, Denmark – a county with a similar population to Ireland – provides over 40,000 allotment gardens for the population of 5.8 million people. Germany provides 1.3 million allotment gardens for a population of 83 million people. Community Gardens Ireland’s recent report called “Let’s Get Growing” benchmarks community growing spaces from other European countries:

Ref: http://cgireland.org/wp-content/uploads/2022/02/Community-Gardens-Ireland_Lets-Get-Growing.pdf

Community growing spaces (i.e. allotments & community gardens) provide an opportunity for local climate action. Other local authorities with a high urban population are also taking the lead in increasing the number of community growing spaces in the timescale of their development plan.

3. Dublin City Council Development Plan

In the draft Dublin City Development Plan 2022-2028, the following is included as an objective:

"GIO28 It is an Objective of Dublin City Council: Urban Farming and Food Production

(i) To support the provision of urban farming and food production initiatives, where feasible, and in particular, on the roofs of buildings, as temporary uses on vacant, under-utilised or derelict sites in the city and in peripheral urban areas / near M50, and in residential developments;

(ii) to seek to increase the provision of allotments in the city in the order of 100%;

(iii) To carry out a survey of underutilised open spaces for community gardens with a view to identifying areas in the city appropriate and suitable for community gardens."

Ref: https://www.dublincity.ie/sites/default/files/2021-12/volume-1-draft-dublin-city-development-plan-2022-2028-low-res.pdf

4. Guidelines for Planning Authorities

In May 2009, the then Department of Environment, Heritage and Local Government issued guidelines for planning authorities on sustainable residential development in urban areas (Cities, Towns & Villages).

Page 38 of 79 detailed the following: 

"Development plans have tended in the past to emphasise detailed quantitative standards, but there is now an increasing focus on the quality of public open space, which ensures that the reasonable expectations of users are more likely to be fulfilled. Qualitative standards include:

Provision for allotments and community gardens: Allotments are small plots of land which are let (usually by a local authority) to individuals for the cultivation of vegetables and plants. They are of particular value in higher density areas."

Ref: https://assets.gov.ie/111252/bf943e60-30d5-4ac3-8c7a-dc4f68b3d688.pdf

5. Recommendations for Wicklow County Council Development Plan 2022-2028

According to Section 7.3.5 Allotments and community gardens, “The individual size of a plot/parcel ranges between 200-400sqm and often the plots include a shed for tools and shelter.”

This is incorrect. As referenced in Community Gardens Ireland’s Let’s Get Growing report from 2022:

“In practice, different size plots are often allocated for community growing. Fingal County Council, which has 900 allotments over four sites, offer three different plot sizes available to rent: 50sqm, 100sqm and 200sqm (the 200sqm plots are only available at Balbriggan and Turvey sites). According to Fingal County Council “This means that there is an allotment plot to suit all levels of interest, experience and time commitment.”

Ref: http://cgireland.org/wp-content/uploads/2022/02/Community-Gardens-Ireland_Lets-Get-Growing.pdf

In addition, community gardens vary in size and setup throughout Ireland. For some community gardens there are shared plots or raised beds, while others have designated growing areas. It is common place for all community growing spaces to have some form of shared design e.g. shared polytunnel, compost area, storage area etc.

Community Gardens Ireland believes section 7.3.5 should be changed to the following:

“The individual size of a plot/parcel varies in size according to the needs of the community and often the plots include a shed and polytunnel for tool storage, shelter and for extending the growing season.”

CPO 7.48 currently states:

“To support and facilitate the development of allotments and community gardens, of an appropriate scale, on lands which meet the following criteria:

• land situated within or immediately adjacent to the edge of towns/villages;
• land that is easily accessible to the residents of a particular town or village;
• where an adequate water supply can be provided;
• where adequate road infrastructure and access exists/can be provided; and
• where adequate parking facilities can be provided.”

Community Gardens Ireland believes that the proposed amendment requires strengthening. Currently no target is included in the above action associated with allotments and community gardens. As referenced earlier, Dublin City Council in their draft development plan have highlighted that they aim to increase the number of community growing spaces by 100% in the next 5 years.

As per Chapter 1 of the draft Wicklow County Development Plan, the population of Wicklow has increased 13% from 2006 – 2016 censuses. According to Chapter 3, another 15% population growth is expected up to 2031. As Wicklow County Council currently offers no community growing spaces at all, and strong population growth is proposed for the county, Community Gardens Ireland believes that CPO 7.4.8 should be expanded to include the following:

CPO 7.4.8:

(i) To support and facilitate the development of allotments and community gardens, of an appropriate scale, on lands which meet the following criteria:

• on the roofs of buildings, as temporary uses on vacant, under-utilised or derelict sites in the county and in peripheral urban areas, and in residential developments.

• The lands are of appropriate scale and at appropriate locations, situated within or immediately adjacent to the edge of towns/villages;
• Proximate to public transport links and walking / cycling infrastructure; and
• Adequate water supply and adequate parking facilities can be provided.

(ii) to seek to provide an adequate number of community growing spaces to meet community demand in all municipal districts;

(iii) to carry out a survey of underutilised open spaces for community gardens with a view to identifying areas in the county appropriate and suitable for community gardens.

Section 8.5       Residential public open space

Community Gardens Ireland welcomes the introduction of the following requirement for residential public open space:

“In larger developments (in excess of 1ha), consideration should be given to dedicating part of the residential open space (not exceeding 25% of the total space) to community gardens; at a minimum, landscaping plans will be required to identify a suitable area (in terms of soil type, gradient, light, drainage etc) within the residential open space area that would be suitable for future community garden use by the resident community.”

Department of Transport submission

Dear Sir/Madam,
Please find attached a copy of TII's observations on the Proposed Material Alterations to the Draft Wicklow County Development Plan, 2022 - 2028.
Yours sincerely,
Michael McCormack
Senior Land Use Planner

Proposed addition to this amendment.

Submission on Newtownmountkennedy

Further to our Cover Letter, we estimate that approximately 5 acres would be the ideal amount of land to acquire. This would enable us to install 2 pitches, a car park and a clubhouse. But even enough land for one pitch, a training pitch, a car park and clubhouse would appeal.

We believe some of the land earmarked in the above amendments could potentially be redesignated for this purpose.

We would appreciate any assistance the council could provide and we would be prepared to invest if anything suitable becomes available.

The European Club

Hi, I am a local resident in Brittas Bay and feel compelled to make a submissions on behalf of locals.  Throughout the Development Plan there is reference to Brittas Bay being a tourist attraction, the beaches of Wicklow get recognition, focus on outdoor swimming etc but there is nothing in the Plan to show any investment into the Brittas Bay Area to support it.  The area is so badly in need of footpaths running from the car parks right up to the shop/school/McDaniels area.  There is no foothpath outside the school which is just extraordinary. The junction at McDaniels is dangerous with all the parking for the restaurant.  It was a miracle that somone was not hurt on the road last summer as thousands of cars queued along the road & kids weaved in & out of them walking on way to the beach.  The area needs proper support from the Council and to be recognized as the tourist destination that it is and for the local people.  The closing off of beach entrances by holiday homes must also be addressed.  I do not believe there is another Council in Ireland that would allow this happen or would have so little investment out in to its most beautiful beach area.  I had reason to be in Morriscastle in Wexford recently and could see the significant investment that had been put in to long foothpaths to the beach for people to walk & cycle along.  Glendalough etc is a beautiful gem for the County but tourism for the Irish people needs to be cultivated and Brittas Bay is a prime example.  I would urge the Council to specifically include Brittas Bay in the tourism locations to be focused on in the development plan. 

We fully support the inclusion and recognition of Swimming in the Wicklow County Development Plan as an inclusive sport which has many benefits for all ages and the role that swimming plays in improving health and safety for communities based near large bodies of water.

We welcome the commitment from Wicklow County Council to support the expansion and improvement of swimming facilities both outdoors and indoors.

We are delighted to see the inclusion of the need for a Social Infrastructure Audit to be carried out and accompany any new significant residential or mixed use development proposals to establish if social and community facilities in an area are sufficient to provide for the needs of the future residents. We are also pleased to see the inclusion of access to sports facilities included in the list of amenities and facilities covered by the Accessibility Report required to be carried out by developers in relation to proposed developments.

We fully support the recognition of the need for schools to have access to local sports facilities and swimming pools and that this will be taken into account when the development of such facilities are being considered.

We are delighted to see a committment to engaging with and consulting National Goverming Bodies of Sport as well as community led groups during the local plan-making process for towns and villages to determine community / social infrastructure deficiencies and needs. This is especially welcome as Community Pool for West Wicklow and Swim Ireland are currently working to bring a Pop-Up Pool to West Wicklow this September and Wicklow County Council would be a very welcome partner on this project. 

We welcome the committement from Wicklow County Council to support the National Sports Policy.

We are very excited to see the inclusion of the following paragraph; 

To prioritise, facilitate and support the development of a community swimming pool facility and a sports complex within the western region of the County, so located to achieve maximum accessibility to the residents of West Wicklow.

These facilities are badly needed here in West Wicklow and the development of a swimming pool and sports complex would have far reaching benefits for our community. People here have been campaigning for the development of a swimming pool for over 50 years, our children's sports clubs either have no pitches of their own or have to travel long distances to acces facilities and local groups such as the Scouts have no base for their activities. The prioritisiation of the development of these facilities in West Wicklow is very welcome and has our full support. The Community Pool for West Wicklow committee look forward to continuing to work with Wicklow County Council and our community to ensure the development of a pool for West Wicklow.  

While we welcome the commitment from the Council to facilitate and support the development of a new supermarket for Baltinglass, Can special attention be given to zoning of lands outside the centre of the town - as this is where large supermarket chains such as Aldi and Lidl are usually situated.

We would appreciate this considertion being included in the Plan.

While we welcome the commitment from the Council to faciliate and support the development of a new large supermarket for Baltinglass we feel that attention must be given to zoning of lands outside the centre of the town, as large supermarkets such as Aldi and Lidl often situate their stores there.

We propose to change below

 A....BALTX1: To facilitate and support the development of a new supermarket on land zoned town centre that will improve the retail offer for Baltinglass and the surrounding area and will support a healthy and vibrant town centre.

TO

 B.....BALTX1: To facilitate and support the development of a new supermarket on zoned land that will improve the retail offer for Baltinglass and the surrounding area and will support a healthy and vibrant town.

As the population of Ashford has grown over the last few years we are in need of a Communiy Center/Multi sports field.

Should the Council approve the development of a Community Centre and Multi-use Sports facilities on an appropriate town-centre site, as recommended for a Level 5 Town Ashfortd Community Group look forward using this facility to it's full extent.

I agree fully with the submission of Wicklow Planning Alliance requesting to adhere to sustainable planning guidelines and reject all the amendments that break these, as listed by WPA.

I furthermore request that the CDP is amended to correctly designate Greystones-Delgany as a Self Sustaining Town (not a growth town) in order to allow services to catch up with the population explosion. This has already been requested by Delgany Tidy Towns, Delgany Community Council, Greystones Tidy Towns, several other community groups and the Eastern Midlands Regional Authority, based on official regional sustainable planning guidelines. It is not sustainable nor democratic to over-ride this.

I agree fully with the submission of Wicklow Planning Alliance requesting to adhere to sustainable planning guidelines and reject all the amendments that break these, as listed by WPA.

I furthermore request that the CDP is amended to correctly designate Greystones-Delgany as a Self Sustaining Town (not a growth town) in order to allow services to catch up with the population explosion. This has already been requested by Delgany Tidy Towns, Delgany Community Council, Greystones Tidy Towns, several other community groups, and the Eastern Midlands Regional Authority, based on official regional sustainable planning guidelines. It is not sustainable nor democratic to over-ride this, and it does not have my support.

Thank you and please continue the further education of our Planners in Climate & Biodiversity Planning since we have declared that our Emergency priority for Wicklow.

I note the inclusion of zoning for a minimum 3.25 hectare Active Open Space within the proposed Inchanappa SLO, and fully support the development of a Community Centre and playing pitches for all at this location. I further request that the wording be amended to require the development of the Community Centre and playing pitches at the commencement of development and that no residential element be allowed to be occupied until completion and handing over of these facilities to the Community.

I agree fully with the submission of Wicklow Planning Alliance requesting to adhere to sustainable planning guidelines and reject all the amendments that break these, as listed by WPA.

I furthermore request that the CDP is amended to correctly designate Greystones-Delgany as a Self Sustaining Town (not a growth town) in order to allow services to catch up with the population explosion. This has already been requested by Delgany Tidy Towns, Delgany Community Council, Greystones Tidy Towns, several other community groups, and the Eastern Midlands Regional Authority, based on official regional sustainable planning guidelines. It is not sustainable nor democratic to override this, and it does not have my support.

Thank you and please start planning sustainably for our county's present and future, in accordance with the Climate & Biodiversity Emergency declared in 2019. 

As part of the county and town development plan, housing demands will obviously be a significant issue. Your own figures and projections no doubt will highlight a need for additional housing and zoning of suitable lands in Baltinglass. 

In our view our land is suitable for zoning to residential for several reasons: 
•    60 acres (24 hectares) of suitable land for development  
•    Adjacent to existing town boundary lines – natural progression as town population and economy expands  
•    Immediate area has existing residential developments (19 bungalows directly opposite)
•    Several lands in immediate area granted planning permission for dense residential development  
•    Several existing vehicular access onto the L4015 local primary road
•    Lands are within 1km of the town centre
•    Existing footpath adjoin lands leading to town circle – ideal for pedestrian and cycle access
•    Not near any of the flood zone sites or areas of concern

Please find attached a map from the existing Baltinglass Town development plan with our site marked. 

Please see attached letter

I agree fully with the submission of Wicklow Planning Alliance requesting to adhere to sustainable planning guidelines and reject all the amendments that break these, as listed by WPA.

I furthermore request that the CDP is amended to correctly designate Greystones-Delgany as a Self Sustaining Town (not a growth town) in order to allow services to catch up with the population explosion. This has already been requested by Delgany Tidy Towns, Delgany Community Council, Greystones Tidy Towns, several other community groups, and the Eastern Midlands Regional Authority, based on official regional sustainable planning guidelines. It is not sustainable nor democratic to override this, and it does not have my support.

Please see submission attached. 

Please see submission attached. 

Requesting amendment to third bullet point of SLO

Plese find attached on behalf of Irish Water

Newtownmountkennedy Town Team supports the recommendations of the draft plan and the Chief Executive's Report in relation to these lands.  

CWPA Planning & Architecture has been retained by our client, First Step Homes First Step Homes, 13-14 Woodford Court, Santry, Dublin 17 to make a submission regarding the amendment to zoning as proposed in the Recommended Amendments document. Please find the Submission enclosed. 

Covemore Properties Limited submission on amendment V1-17 

The development of a swimming pool and sports complex in the Baltinglass Municipal District should be made a priority in the County Development Plan. I am a Medical Scientist in Tallaght University Hospital and a mother to an 8 year old daughter. We have lived in Blessington for 15 years. The first thing I see when I open my blinds in the morning is the Blessington lake. As picturesque as this is, it is also extremely dangerous as is any water. Although swimming is prohibited in the lake lifesaving is a skill that people should learn and is necessary where there is access to water.

My husband is a keen sailor and is a member of Blessington sailing club.He also has his own sailing boat on the lake. Thankfully as he grew up in Dublin he attended swimming lessons as a child and as such is a strong swimmer. However is it fair that because we as parents choose to live in Blessington that our daughter is not given the same opportunity as her father to learn how to swim? Yet if we lived in Dublin or indeed over the other side of the mountain in East Wicklow she would easily have access to swimming lessons! Is it fair that in 2022 a child is at a disadvantage because of geographical location?When she was 6 months old I started bringing her to aquababies swimming lessons every week in Naas Co. Kildare. She loved the water and so began what I had hoped would become a lifetime of love for the water. But unfortunately in 2014 when she was just 15 months old I was diagnosed with a benign brain tumour. So 8 years later following 11 hospital admissions and 6 surgeries I am thankfully tumour free but have developed epilepsy which unfortunately means I am unable to drive. So her lessons had to stop! There is no bus to Naas or East Wicklow. The only bus from Blessington to Tallaght doesn't stop at the 1 pool so again due to geographical location and my medical condition my daughter suffers again! Also throughout the years I have attended several neurologists and neurosurgeons for both my seizures and my chronic headaches and each of them have told me that strenuous exercise is not recommended but that swimming would be good and may even ease my headaches. I laughed when they told me that because I said "I can't drive and can't get to a swimming pool without getting 2 buses" to which the consultant replied thats ridiculous in this day and age. Surely there is one closer. Because stress is something that can cause seizures and getting 2 different buses there and 2 buses home (a 40km round trip away) is definitely stressful, a stress that would increase my headaches rather than ease them and thus undoing any of the benefits of the swim.

Swimming is the one form of exercise that is accessible to all age groups, genders and abilities. It is an essential life skill which all members of every community should have the opportunity to learn.It is also a skill that could one day save a person's life. Unfortunately the Baltinglass Municipal District is the only district in Wicklow without a swimming pool and in 2022 that is just not good enough! We are failing each and every member of this community and its time for this to change. The community would benefit from a multi sports complex which could open endless possibilities for adults and children. Blessington currently has no basketball club, gymnastics club or football pitches in the town. The only pitches are based outside the town and must be accessed by car. We are doing our children a disservice with the lack of facilities provided to them. I strongly believe a sports complex and community swimming pool would boost morale and community spirit and encourage people to stay active. It will help both the physical and mental health of everyone for generations to come.Wicklow County Council needs to make this a priority. Now is the time to INVEST IN THE WEST.

p.s Please see attached a drawing and some words from my 8 year old daughter. It makes me sad to think that I as a mother am failing her because of my illness and my lack of ability to currently drive and access a swimming pool (a basic facility that should be available to all).

Thank you

Dunmoy Properties Limited Submission on Amendment V1-17 

Dunmoy Properties Limited Submission on Amendment V3-126

Add an additional line at the end after the word "mobility" to read as follows "The Council will examine the feasibility of making available for sale at least 10% of all new housing developments of 10 or more units,whether public or private".

The reasoning for this is based on the outcry and subsequent national policy change following the publicity whereby an investment fund purchased a scheme of houses in Maynooth in 2021. The fact that no units were available for purchase was deemed unacceptable. I suspect that the proposal at CPO 6.X. in this document is also meant to deal with the problem. However many potential home buyers are also excluded from the market by the public purchase of such schemes. This is happening in many areas of this county. There is a responsibility on the local authority to assist in the provision of "private houses for sale" and solely selecting investment funds doesn't adequately address the issue. If the council could provide housing purchase figures re public bodies/investment funds it could give a clearer picture of the issue.

Add after "countryside" the following two lines "The council will prepare a draft report on the feasibility of developing a new town in immediate proximity to a main transport artery and in close proximity to a public transport route. This will be completed within 24 months of the adoption of this plan"

There are many reasons for this proposal. The factors whereby towns were located and grew have  evolved over time. Many of our existing towns may not be suitable for further development due to infrastructural deficits that cannot be overcome. The continuous "adding on" of development can be impossible to integrate with the present "town characteristics". In addition there is almost universal opposition to any major housing development proposal in this and other counties. When a critical mass is reached it can impact on short term social cohesion. Our projected population figures can often get it wrong. However recent population trends, locally and globally, are going in one direction. The provision of housing is essential and we must examine every and any measure that might address this.

With respect to CPO 6.X. which appears to be part of this amendment add the following after commercial and investment bodies "or public housing bodies". 
The reasoning is as outlined in amendment VI-14.

I don't believe that this measure as worded has been given due consideration. It will add another cost onto a "truck load" of requirements that an applicant is already obliged to do. The concept of such an audit is a good idea and should inform the local authority where improvements and adjustments can and need to be made. An excellent document on the Dublin Docklands was produced in 2015. Maybe this information is available for Wicklow. 
However it's important that the detail of this proposal is outlined. In Dunlavin or Rathdrum if several applications are made will each have to produce a "social audit"? What qualifications, if any, are required to draw up such a report? What is the template for such an audit? What cost will it add? Is there a certain "bar" that such an audit will have to reach before receiving a planning grant"?

The obligation to carry out such an audit should be at the discretion of the local authority.
 

At the end of paragraph "Tourist Hubs and destination towns" insert an additional line to read as follows "The council will engage with Coillte and The National Monument Service to examine the feasibility of developing the Hillfort at Rathnagree, Tuckmill, Baltinglass as a tourist attraction".

My understanding is that this hillfort, one of nine in the area, is the only one in public ownership. Two public bodies, Coillte and The National Monument Service, are the organisations concerned. Ideally Coillte would dispose of their interest to the NMS and facilitate access. The potential of such a move is endless.

Add a new bullet point as follows: "The Council will engage with TII, Kildare Country Council and Fáilte Ireland with a view to erecting signs for the Wicklow National Park on the M9  at the North and South exit lanes at Kilcullen and Castledermot." Linked signage to the National Park would be erected from these points.

My understanding is that the Wicklow National Park meets the legislative requirement ( distance and visitor numbers) for such signage. It is the largest National Park in Ireland and I'm not aware of any signage for it on our main road networks. Signage on M11 and M50 for the facility should also be examined. 

Add bullet point

"The Slaney River at Baltinglass"

My understanding is that the implications of this are if an application was made for a change to the current house type granted on this site in order for a permission to be granted 11.2 acres, which would include an amenity park, would have to be given to WCC.

I believe the requirement of new green space outside the development is 45 times greater ( to facilitate a population of 18,000) than the councils own policy.

While the points I raise are specific to this amendment they have policy implications on other zonings in this plan and in other parts of the county. I'm also aware that permission has been granted on this site (with a correctly applies levy of €836,000 for infrastructure and amenities) without the proposed burden. Nevertheless I believe it is important to establish the impact and consistency of the policy. Does it mean for every 10 acres zoned in the Bray or Greystones plan an applicant will have to provide an additional 10+acres for green space outside the development site. It's estimated that land costs constitute about 17%/30% of housing construction. Developers (as distinct from builders/public/bodies/landowners) and those who entrust their pension funds to them, will only invest if it's economical viable to do so. Ultimately the buyer, first time or otherwise, and the public body pay the cost. Housing and planning policy impacts on cost, affordability and availability of houses. 

This section states that "no further permission shall be granted in SLO-1 unless accompanied by of a programme of delivery of Active Open Space of not less than 2 ha on lands zoned AOS and an amenity park of not less than 2.5 ha on land zoned OSI and dedicated to the public along the river which should be laid out and designed in such a way as to safeguard the integrity of the route of the old railway line as part of a possible longer amenity route". This basic requirement has been in the proposed new development plan since the first production of a draft plan. I am aware that in the process a proposal had been included for 1.3 ha mixed use. The number of permitted units on proposed lands of 3.8 ha for new residential is about 135. Not withstanding an existing grant and not wishing to confuse the issue I would like to make the following points. These points are equally applicable to SLO 2 and also to similar measures in other proposed residential zonings in the draft plan. In an earlier submission in the process I made an oblique reference to this issue in terms of cost. The points I wish to make are as follows 

* It is important that any new residential development brings a social benefit in terms of infrastructure and amenities. Due to the hap hazard nature of this during 1990\2000 period the Planning and Development Act 2000 enabled planning authorities to develop a levy system in order to contribute to infrastructure and amenities. In addition there is a requirement to provide adequate green space, generally with a play area, a creche if >75 units and maybe some other requirements. These are contained within the development site. 

* Most applicants have traditionally provided some additional benefits.

* The current granted permission has a 15% green space requirement , however there is 26.5% green space allocation.

* Historically for every 10,000 population a 2.4 ha of additional green space/ park area was added. While I'm not aware of any legislative requirement or EU directive my understanding is that the EU recommends a 2ha local park for every 10,000.

* In the case of SLO 1 a requirement is now placed for OS ( outside the development site ) of 4.5 ha. This is 11.2 acres. The max residential development is for 3.8 ha with about 135 units. This would lead to a population increase of about 400. The requirement that this draft plan places on SLO 1 is to meet the needs of 18,000. This represents 45 times the standard requirement.

* As far as I can establish the policy of Wicklow County County with respect to "play policy" and open space is similar as to that as outlined ie 2.4 ha to 10,000 population.

This is an important issue. It is not unique to this site and is outlined in the plan elsewhere.

I would appreciate if the following information is given to members.

1. What is the current new green space area policy of Wicklow C C and where is it available?

2. If different land owners are involved has it the potential to freeze the land.?

3. What is total the financial cost of such a requirement ?

4. What are the specifications for an amenity park, the estimated cost and who will operate it. I am conscious of the fact that WCC and other local authorities sought insurance indemnity on the recent outdoor facilities grant.

5. Will future developments in the county have to provide similar green spaces outside the development site and how would this impact on housing supply in the areas of greater demand.

6. Is there a national policy on which this is based and does any other local authority operate it? 

I believe that all these issues need to be addressed.

In conclusion I believe that most, if not all, developers and land owners are more than happy to enter into discussions on the provision of amenities with any proposed development. However such measures as outlined in SLO1 are not workable.

A more suitable and workable wording would be as follows

* " No further permission should be granted in SLO-1 unless accompanied by an agreed programme of delivery of Active Open Space of not less than 1 ha on lands zoned AOS or OSI and dedicated to the public and designed in such a way to safeguard the integrity of the old railway line"

Please find our submission attached in PDF format.
 

Best, Denis

I am in agreement with the original decision by Wicklow County Council to dezone the lands mentioned in the V2-92 amendement.

The growth rate in Newtownmountkennedy to date plus the addition of several hundred houses already approved by the council concerns me. Improvements in the public transport network to the area needs to be addressed as there is such a limited bus service and a non existant cycle corridor servicing the town necesitating the use of private cars. The increased volume of traffic from Newtownmountkennedy and neighbouring Wicklow towns is adding to and increasing the number of gridlocks on the N11 and further afield.

The building of houses must be accompanied by the building of schools to accomodate the influx of school-going children to these areas. There isnt currently enough places for the existing residents so these issues need to be prioritised. The ongoing situation in Greystones where children attend schools in portakabins and sports halls is not an acceptable option. In addition to schools , sports facilities should be earmarked for the town . 

Please see attached submission from the Department of Environment, Climate and Communications.

Administrative Officer

Planning Department,

Wicklow County Council,

Station Road,

Wicklow.

25th May 2022

Re: Wicklow County Development Plan – Submission – Robert Moffett, Moffash Ulc, Residential and Open Space– Amendment – Material Alteration V2 – 100.

To whom it may concern,

I wish to make a submission regarding the above material alteration to the Wicklow County Development Plan which saw the additional zoning of lands for the purposes of Residential and Open Space lands in the County from 2022-2028 (see map below).

These lands were added to increase the amount of land zoned as residential and open space in order to support growth of housing in Wicklow County Council over the next seven years.

The addition of lands as Residential and Open Space is welcome.  However, we believe that these lands are a better alternative readily available for Ashford Town.  We believe, it is more likely that the lands owned by Moffash Ulc are in a better position to be developed for this intended purpose during the lifetime of the new Wicklow County Development Plan.

The lands which are the subject of this proposed alternative are in the ownership of Moffash Ulc. The lands are located in close proximity and within 500m to the north-west of the centre of Ashford in the townland of Ballinahinch. The lands are located to the north-west of the new regional road that connects from the R763 to the R764; and the development known as the Hazels and the Willows that were undertaken by Moffash Ulc.

We can confirm that the lands are serviced to their southern boundary as a result of the permission granted by Wicklow County Council and was subsequently upheld by An Bord Pleanála in 2016.

The decision from ABP stated that they considered that having regard to the Ashford town plan and to the settlement strategy contained in the Wicklow County Development Plan, that they considered the scale of the development proposed (178 units) and the achievement of the road’s objective of the town plan, that the development would be in accordance with the proper planning and sustainable development of the area.

The lands are surrounded by residential development to the east and south, with further undeveloped lands to the west.

In this submission, we are requesting the Council, when considering this amendment to the County Development Plan, consider further amending the plan, after a review of the residential and open zoned lands is analysed and quantified, to ensure the appropriate and best residential and open zoned land to accommodate new developments during the lifespan of this development plan.

We firmly believe that Wicklow County Council, by considering the lands owned by Moffash Ulc, are would be better ensuring that housing need in Ashford and Wicklow is met over the course new County Development Plan.  We believe the lands owned by Moffash Ulc, as outlined above and in their previous submission, makes for a more sustainable and sequential town growth for Ashford over the next seven years.

Earlier in the County Development Process we made two submissions (Unique Reference Number:

WW-C2-117) regarding lands we own in order to have them zoned as Residential. We believe that these lands should now be considered as an alternative to the site at Inchanappa House, which have been proposed to be amended at this stage of the County Development plan process. 

We hope that you accept this submission and review these lands, with a view to amending the County Development Plan accordingly so that the most suitable lands can be zoned as residential in order to assist Wicklow County Council in achieving their housing targets over the next seven years.

Submission relates to a number of different amendments: V1 - 5, V1 - 6, V1 - 7, V1 - 8, V1 - 17, V3 - 126 and associated implications

Ardale Property Group Submission on Amendment V1 - 17

Ardale Property Group Submission on Amendment V2-112 

Ardale Property Group Submission on Amendment V3-126

See enclosed submission 

Please see attached document for observations relating to these amendments.

Please see PDF document titled 'Submission in relation to Proposed Amendments to the Draft Wicklow County Development Plan 2022' attached in relation to observation 'Level 4 - Newtownmountkennedy' for details.

We wish to support these amendments - please see PDF document titled 'Submission in relation to Proposed Amendments to the Draft Wicklow County Development Plan 2022' attached in relation to observation 'Level 4 - Newtownmountkennedy' above for details.

We wish to support these amendments. Please see PDF document titled 'Submission in relation to Proposed Amendments to the Draft Wicklow County Development Plan 2022' attached in relation to observation 'Level 4 - Newtownmountkennedy' for details.