Chapter 2

CHAPTER 6 HOUSING

“It is Council policy to encourage higher residential densities at suitable locations in accordance with the Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (2009). Locations that are appropriate for higher densities include sites that are particularly close to existing or proposed major public transport corridors and nodes”. Higher density developments should only be considered in locations with access to public transport which provides and fast and frequent service. Housing that is located within 1km of a rail service or 500mof a bus stop will not necessarily provide a reliable and frequent public transport service. This statement requires considerable clarification. The proposed use of “bus stops” in the County Development as an indicator for increased density (up to 50 units per ha) makes little sense if the road infrastructure in small villages, such as Delgany, cannot support frequent bus services.

We endorse the principles outlined in section 6.3.1 Sustainable Communities. A social audit with subsequent action can have the potential to transform how we build housing in Wicklow. We strongly support the provision of housing for our older citizens as well as others who might require supported living.

CPO 6.18 is welcomed but will require more clarity to ensure that it is implemented correctly-

“Require all development proposals, including infill development, to include an analysis of the impact of building height and positioning of buildings on:

The immediate & surrounding environment - streetscape, historic character; Housing Adjoining structures; Open spaces and public realm; Views and Vistas.”

Please identity a practical tool to show how the impact will be assessed.   We believe that full 3D tools should be used to see the impact on the local environment and heritage sites in the village.   We would also welcome more interaction with the planners in this area in terms of two-way conversations about future plans.

Sequence and Phasing of Housing

CPO 6.20 “Housing development shall be managed and phased to ensure that infrastructure is adequate or is being provided to match the needs of new residents. Where specified by the Planning Authority, new significant residential or mixed use development proposals (of which residential development forms a component), may be required to provide a social and community facility/facilities as part of the proposed development or the developer may be required to carry out a Social Infrastructure Audit…”

The intent of CPO 6.20 is excellent but it needs to be strengthened, suggest replacing “may be required” with “will be required”.

The Plan does not adequately address the value of Biodiverse ecosystems. If the biodiversity value of a site is damaged by development, it cannot be compensated for by a requirement for the developer to allocate or retain a percentage of the site after development as new open space. New planting takes many years to mature to maintain a complex eco system. The emphasis should be on retaining and conserving biodiversity where possible even if this means a reconfiguration of plans and lower density.

Identify “Local Nature Reserves and wildlife corridors”. While there are Special Areas of Conservation (SAC) in Greystones/Delgany, there are also valuable wildlife corridors which should be identified, named and protected.

Trees: A better system for preserving trees is required. Trees also need to be protected from harm during the construction processThere are a number of development sites in this area where only a very limited amount of healthy mature trees have been retained.

Waterways: The recommendations of IFI (Inland Fisheries Ireland) should be implemented as part of the planning process.

CHAPTER 9 Economic Development

Sustainable living means a detailed employment/job plan is needed for the areas of housing expansion in County Wicklow.   This is particularly noticeable in the Greystones/ Delgany area in recent years where within a radius of two miles of Delgany village there has been a huge increase in urbanisation from a semi-rural area. The population within this two kilometre radius has increased dramatically within the last three years. As a result, we have significant and ever-increasing infrastructural deficits in Delgany/Greystones in relation to key services such as education, health, public transport and road infrastructure. Given permission for housing and residential units alone does not constitute planning, a more holistic approach is urgently needed. Planning needs to be joined-up and integrated and the draft County Development Plan would benefit hugely from the evidence of joint plans with the Departments of Education, Health. Transport,,Environment, Climate and Communications and Housing. Local Government and Heritage.  There also needs to be strong contacts established with Enterprise Ireland and the IDA in order to attract more sustainable high quality employment into the area.   This Report would also benefit from more up-to-date information and data in relation to the population forecasts and projections as these are crucial for all stakeholders to understand the future planning needs in this area (the widespread use of and reliance on the 2016 Census data does not accurately reflect the current population in Delgany and Greystones).   While it can be difficult to get up-to-date data, the use of forecasting and econometric methods and tools would help to ensure that the most accurate projections are made and this would help to ensure that all services, amenities and infrastructure can be planned for.  

Employment

There is a need for high value-added jobs (i.e. high quality employment) in the Delgany/Greystones area. The majority of new residents in Greystones/Delgany will need to commute to Dublin for their work when offices open again (using the 2016 Census data means that the number of commuters and their commuting times does not accurately reflect the current situation). Increasing the number of cycle and pedestrian path will not be useful unless residents can choose to work locally, which is currently not the case. Wicklow,as a county, needs a detailed strategyand plan to attract high value-added employment opportunities (e.g. ICT/financial services office/data hubs in Bray and Greystones).   A number of financial companies are also now looking to find suitable locations for satellite offices outside Dublin and Wicklow should be pro-active in seeking to attract these companies.   To make the area attractive to these type of industries and companies – there is need for a third level satellite hub/centre of excellence – most likely from one of the major universities in Dublin such as UCD, Trinity or DCU.   By locating a satellite centre in the county, this will act as an anchor and would be a suitable collaborator with the new industry partners.. This would help to encourage clustering of these new industries in the county. Clermont in Rathnew will not be sufficient.The Media/Filmsite in Greystones is welcome, but we recognise that while some high paid employment is available in this sector, it may not lead to high value, secure employment for all its employees.

CHAPTER 17 Natural Heritage and Biodiversity

The 2021 Greystones Biodiversity Action Plan identifies several areas of important natural biodiversity which are examples of Local Biodiversity Areas in the Greystones area and should fall under a new biodiversity zoning category in the next Greystones-Delgany and Kilcoole Local Area Plan:

· The Three Trout Stream riparian corridor and other watercourses

· St. Crispins Graveyard, Kilruddery Deerpark Stream and D’Arcy’s Field

· Greystones Coastal Cliffs

· Greystones Rocky Shoreline

· Greystones South Beach

These areas should be ‘zoned for biodiversity’ in the new CDP.

In conjunction with Delgany Tidy Towns and several other local interest groups, we support the proposed creation of a Community Nature Reserve to protect the course of the Three Trout Stream, which was identified as “the most important area of natural habitat remaining in the Delgany -Greystones area” in the recent Greystones BAP. We are happy to support the call for a new designation in the zoning plans and request a new category providing for land management with biodiversity and habitat restoration, regeneration, or preservation as its core objective.

DCC welcome the objective to protect watercourses.

"CPO 17.26 Protect rivers, streams and other water courses by avoiding interference with river / stream beds, banks and channels and maintaining a core riparian buffer zone of generally 25m

along watercourses (or other width, as determined by the Planning Authority having particular regard to ‘Planning for Watercourses in the Urban Environment’ by Inland Fisheries Ireland for urban location) free from inappropriate development, with undeveloped riparian vegetation strips, wetlands and floodplains generally being retained in as natural a state as possible."

We ask that the following stipulations be added:

“- All applicants for planning permission will be required to prove how they have complied with this condition, both at Application stage and again at notification of Site Plan before construction commences. 

- Wicklow County Council will urgently request EPA to ensure that the main watercourses in each Municipal District are monitored. One glaring current omission is that the main watercourse in our Greystones Municipal District, The Three Trout Stream, is currently completely unclassified and designated "Not at Risk", despite high levels of nutrient enrichment (High levels of N and P tested and reported by Delgany Tidy Towns in the 2019 and 2021 Earthwatch DCU Waterblitz) and unprecedented levels of construction along its catchment and heavy levels of construction silting detected, reported & stopped by Delgany Tidy Towns (with WCC enforcement and developer co-operation) in Nov & Dec 2020”

DCC support the request by both Greystones Tidy Towns and Delgany Tidy Towns to designate the Three Trouts Stream river systems from source(s) to sea as a key Local Biodiversity Area / Wicklow Community Nature Reserve & Wildlife Corridor. It should be recognised, protected and developed as the key biodiversity resource within the Municipal District in its own right and also as the buffer zone of the Glen of The Downs SAC.