Uimhir Thagarta Uathúil: 
WW-C3-59
Stádas: 
Submitted
Údar: 
Billy Timmins

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"