Uimhir Thagarta Uathúil: 
WW-C3-59
Stádas: 
Submitted
Údar: 
Billy Timmins
Líon na ndoiciméad faoi cheangal: 
0
Údar: 
Billy Timmins

Litir Chumhdaigh

Personal observations

Tuairimí

Chapter 6: Housing

Please select the amendment number on which you are commenting.: 

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.

 

 

 

Chapter 6: Housing

Please select the amendment number on which you are commenting.: 

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.

Chapter 6: Housing

Please select the amendment number on which you are commenting.: 

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.
 

Chapter 11: Tourism and Recreation

Please select the amendment number on which you are commenting.: 

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.

Chapter 11: Tourism and Recreation

Please select the amendment number on which you are commenting.: 

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. 

Level 4 - Baltinglass

Please select the amendment number on which you are commenting.: 

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"

 

Faisnéis

Uimhir Thagarta Uathúil: 
WW-C3-59
Stádas: 
Submitted
Líon na ndoiciméad faoi cheangal: 
0