Enniskerry and Environs

Uimhir Thagarta Uathúil:

WW-C2-268

Stádas:

Submitted

Údar:

CarlandJulia Strickland

Comhairliúchán:

Draft Wicklow County Development Plan 2021-2027

Líon na ndoiciméad faoi cheangal:

Teorainneacha Gafa ar an léarscáil:

Níl

Údar:

CarlandJulia Strickland

Litir Chumhdaigh

Carl and Julia Strickland, Enniskerry

Tuairimí

Chapter 11 Tourism and Recreation

Caibidil:

Volume 1 » Chapter 11 Tourism and Recreation

Ch. 11 Tourism and Recreation

General Comment: In relation to developing much needed walking trail networks as identified within the objectives of the CDP. It is strongly suggested that housing zoning and development planning are interconnected to the Tourism Strategy. In so far as to ensure that where green field sites are to be developed that the developer must ensure a right of way trail to be included on the periphery of the site . This will allow the development of trail networks to facilitate the list of objectives under CPO. 11.37 (p.255)

p.246 - County Wicklow Outdoor Recreation Strategy 2020 – 2025.

‘’ The Strategy identifies five outdoor recreations hubs / clusters – Glendalough, Rathdrum, Blessington/Baltinglass, Tinahely/Shillelagh and East Coast maritime. Objectives identified include: Expansion of the trails network, preparation of an outdoor recreation transport plan and increase awareness of environmental and cultural responsibilities’’.

Comment: Enniskerry as a key gateway to the Wicklow Way should be included in this list of outdoor recreational hubs. Attached is a proposed trail route leading from Knocksink Woods location towards the Wicklow Way direction.

Chapter 17 Natural Heritage and Biodiversity

Caibidil:

Volume 1 » Chapter 17 Natural Heritage and Biodiversity

Ch. 17 Natural Heritage and Bio-diversity:

Creation and preservation of ‘wild spaces’ (for example, Upland areas, wooded areas, hedgerows , copses etc.) with controlled access via paths needs to be part of the bio-diversity plan within the CDP.
Creation of wild spaces with fixed paths when housing developments are sought as part of planning permission.
Proper buffer zoning between rivers and plantation of conifer trees.
Enhance and enforce better protection of trees not only on public lands but private lands where development is sought.

Rivers within the county need to have carefully managed buffer zones including proper investigation to protection where planning permission for development is required.

P.324- The guidance is addressed to a range of EU, national and local decision-makers in different sectors. It is also addressed to planners and businesses who may have varying levels of experience in assessing and integrating ecosystem services in policy and planning. It therefore outlines basic concepts, principles and a generic, crosscutting framework for approaching ecosystem services in the common stages of a decision-making process. Within each decision-making stage, readers can find an overview of (i) entry points and steps for integrating ecosystems and their services, (ii) reflections on aspects that need special attention, and (iii) references to tools and resources and to case studies that illustrate the use of these tools and resources. Due to its broad scope across a wide range of decision-making processes and target groups, the guidance provided in this document remains at a relatively general level. This is also a static document in a field of constantly developing research and practice.

Comment:

It is correct to say on P.324 of the CDP that ‘’planners and business have varying levels of experience in assessing and integrating ecosystem services in policy and planning’’. However the CDP should state that ignorance of environmental law is not a defence for allowing poor and incorrect planning decisions. The text on p324 relating to the EU Habitats directive gives the impression to the reader that a general adherence or best endeavours to be compliant to the Directive ‘’will do’’and I would like to request it is re written.

Chapter 4 Settlement Strategy

Caibidil:

Volume 1 » Chapter 4 Settlement Strategy

Ch. 4 Settlement Strategy

Enniskerry is included in the Dublin Metropolitan area under the The Regional Spatial and Economic Strategy (RSES) for the Eastern and Midland Area.

P.70 of the Draft CDP summerises what this means for Wicklow as follows:-

To realise ambitious compact growth targets of at least 30% for metropolitan settlements, with a focus on healthy placemaking and improved quality of life.
To deliver strategic development areas identified in the MASP, located at key nodes along high-quality public transport corridors in tandem with the delivery of infrastructure and enabling services to ensure a steady supply of serviced sites and to support accelerated delivery of housing.
To increase employment in strategic locations, providing for people intensive employment at other sustainable locations near high quality public transport nodes, building on commercial and research synergies in proximity to large employers, industry clusters and smart specialisation and activating strategic sites to strengthen the local employment base in commuter towns.
Enhance co-ordination across local authorities and relevant agencies to promote more active land management and achieve compact growth targets through the development of infill, brownfield and public lands, with a focus on social as well as physical regeneration and improved sustainability.

Chapter 4 Settlement Strategy

P. 72- ‘’In order for Bray to fulfil its growth potential, lands at Fassaroe to the west of the N/M11 are targeted for new housing and other facilities. The development of a new centre at Fassaroe is largely dependent on the delivery of infrastructure including upgrades to the N/M11 and the delivery of high quality public transport connections to Bray Town Centre and to Dublin City Centre. The Bray and Environs Transport Study, drawn up by the NTA in conjunction with the TII and both Wicklow and Dun Laoghaire Rathdown County Councils sets out a programme of transport interventions and improvement necessary to realise the sustainable development of Fassaroe.’’

Comment:- The Fassore development is the correct and proper planning strategy for north Wicklow. However the CDP makes no mention to the best in class development plan at Cherrywood in the DunLaoghaire Rathdown district. The Cherrywood development builds parkland and other social infrastructures first before building housing units. This strategic type of large development practice should be coped for the Fassaroe development as it will share Cherrywood transport infrastructure investment.

Comment: Enniskerry does not have transport infrastructure to meet the development needs currently zoned for. Lands zoned around Enniskerry are all Greenfield sites and contravenes the strategic guidelines within the RSES to use infill brownfield sites and public land and to locate development at key nodes of high-quality transport corridors.

P. 80 Comment:

Enniskerry is designated a ‘Self Sustaining Town’ (Level 4). Not a growth town. The Population Growth forecast for Enniskerry as tabulated on p.80 from a standing population figure of 1877 in 2016 and a target population figure of 1920 by 2031. This is an increase of 43. The development of ‘’Sika Woods’’ at Parcnasillogue constituted 47 dwellings. Further Lands adjacent are zoned for 219 units. Therefore the current area is currently over zoned in this draft CDP and is incontravention to this draft CDP. The draft CDP is more appropriate to zone large areas beside large towns such as Bray (eg the Golflands and Fassaroe), Arklow, Newtown, Wicklow, etc. and therefore lands around Enniskerry and environs should be zoned back to agricultural use to re-install the Greenfield belt that protects biodiversity and architectural heritage.

P.81 - Housing Occupancy Controls As ‘self-sustaining towns’, these settlements should provide housing for people from across the County and region, subject to the provisions of Objective CPO 6.2

Comment: All zoned development in Enniskerry as a ‘Self- Sustaining Town’is catering for an over spill from the greater Dublin metropolitan area and therefore contravenes the above objective.

Chapter 6 Housing

Caibidil:

Volume 1 » Chapter 6 Housing

Chapter 6 Housing

P. 134 ,Key Housing Principles:- In accordance with the NPF, RSES and the Core / Settlement strategies set out in Chapters 3 and 4 of this plan, new housing development shall be generally required to locate on suitably zoned / designated land in towns and villages

The zoning / designation of greenfield land for new housing shall adhere to the following principles:

Application of the ‘sequential approach’ whereby zoning extends outwards from centres, contiguous to the existing built up part of the settlement;

Application of compact growth targets;
Creation of ‘walkable’ neighbourhoods, whereby undeveloped lands within 10 minutes walking distance of the settlement centre and 5 minutes walking distance of any neighbourhood / village centres are prioritised.

6.3 – Key Housing principles and 6.3.1 Sustainable Communities. The CDP states that it is essential to provide high quality places to live and that includes:

Promote the efficient use of land and of energy, and minimise greenhouse gas emissions;
Enhance and protect the green infrastructure and biodiversity;

To support sustainable communities as a principle, the development of walking trails should be integrated into future housing developments that are built on a greenfield site (only where Greenfield is allowed for zoning). In essence this means making it mandatory as part of planning permission that a walking pathway or trail no more than 2 meters wide be allowed along the perimeter of the greenfield site. This will ensure an alternative way to travel and take walkers of the road enhance safety. It will also support future walking routes that can be joined with existing or new walking routes. (tracks and trails), joining other villages or towns. (This will encourage people to walk rather than drive). This small amendment to planning will support all parts of our communities to ensure walking on the road is not required, delivering better safety and enhance our tourism experience.can be linked to future and other walking routes.

Comment:-

The two key principles documented in the CDP are not currently supported in the design and plans submitted by Developers for large scale (SHD) initiatives. In particular trees and hedgerows are not adequately protected and are always compromised to fit in more units. The destruction of our hedgerows in particular is materially damaging biodiversity in the county and both the felling of trees and destruction of our hedgerows are in contravention across multiple chapters in the CDP and in particular CPO 17.14 and CPO 17.16 in Chapter 17 (Natural Heritage and Biodiversity), relating to Sites & Corridors of Ecological & Biodiversity Value.

To support this, it is strongly recommended a Environment / Bio-diversity offer is appointed to ensure full compliance with EU and Irish environmental laws are adhered to before planning permissions are granted.

In relation to permissible design of the landscape on zonzed lands requesting planning permission. A green verge or nature strip should always be included in front of houses and also the perimeter of the site. Current designs passed at planning stage allow house walls to be built up to the edge of the open road. It is poor design and both visually and environmentally.

Enniskerry and Environs

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