FINGAL DEVELOPMENT PLAN 2017 - 2023

SUBMISSION BY HOWTH/SUTTON COMMUNITY COUNCIL15th May 2015

CONTENTS Page

1. INTRODUCTION 1

2. CROSS CUTTING THEMES - PLANNING FOR THE FUTURE 2

3. SETTLEMENT STRATEGY - WHERE ARE WE GOING TO LIVE? 4

4. PLACEMAKING & COMMUNITIES – TURNING SPACE INTO PLACE 7

5. INFRASTRUCTURE AND MOVEMENT - GETTING WHERE WE WANT TO GO 11

6. ECONOMIC DEVELOPMENT - A GOOD PLACE TO WORK? 16

7. GREEN INFRASTRUCTURE - SPACE TO LIVE AND BREATHE 19

8. NATURAL HERITAGE - ENHANCING OUR QUALITY OF LIFE 21

9. CULTURAL HERITAGE - ENRICHING OUR LIVES 23

10. IMPACTS ON THE ENVIRONMENT - PROTECTING OUR ENVIRONMENT 25

11. CONCLUSION X

For information contact:

Charles Sargent, Chairperson, Howth/Sutton Community Council

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Howth/Sutton Community CouncilThe Old CourthouseHarbour RoadHowth

Howth/Sutton Community CouncilThe Old CourthouseHarbour RoadHowth

1. INTRODUCTIONThe Howth/Sutton Community Council, which represents many local organisations, interest groups, and community-minded individuals, welcomes this opportunity to work closely with the Planning and other County Council departments, combining our local knowledge with the technical expertise of County Council staff and consultants in order to produce the best possible Development Plan for the protection and improvement of the Howth Peninsula and the immediate Sutton hinterland. We suggest that this Development Plan be guided by the need to preserve the environmental and historical aspects of the Howth Peninsula which are a huge asset to Fingal, while meeting the social and recreational needs of residents and stakeholders alike. The Development Plan must include specific objectives to preserve and enhance the following:

The glorious and largely unspoilt mountain, cliff and other walkways

The traditional village and fishing harbour of Howth

Access to & from Dublin City - the greatest population density in the country

Employment opportunities in tourism, recreational and marine-related activities

We suggest that Fingal’s vision of the Howth/Sutton area should take all the above into account, and we repeat the description of Howth from Fingal Co Council’s own publications:

“Dublin has one of the most spectacular settings of any European capital. Howth is arguably the brightest jewel in that setting. Its beauty has been celebrated by travellers and artists over the centuries. Distant sea views, large skies and heath land above sea cliffs are the characteristic landscape elements of the peninsula.”

“The Howth Peninsula possesses some of the finest scenery in Ireland. What makes the area especially valuable is its close proximity to Dublin. The potential of Howth was a playground for the people of Dublin was first exploited a century ago by the Great Northern Railway. The company built a tramline to The Summit and a cliff walk around the headland.”

“The very special character of Howth is reflected by multiple environmental designations, which cover a large part of the area. In 1999 Fingal County Council made a Special Amenity Area Order (SAAO) for Howth. It is the Council’s intention, in partnership with the local community, to develop the recreational resources of the peninsula and to ensure that its natural amenities are conserved and enhanced”.

The conservation and enhancement of the natural amenities of Howth, together with the architectural heritage of the built environment, call for delicate and special treatment for the Village area. When a painting is a masterpiece, a cheap, gaudy and badly designed frame does not enhance it. The same applies to Howth.

The SAAO Buffer Zone was designed to provide an appropriate frame for the SAAO area itself. Regrettably, to date Fingal planners have neglected to recognise this and have approved some disgraceful developments in this so-called protected buffer zone. We contend that, had there been an official FCC vision for Howth which provided planners with guidelines on what developments should be allowed, much better decisions would have been made in the past.

This vision for Howth should encompass all areas of the Peninsula.

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2. CROSS CUTTING THEMES - PLANNING FOR THE FUTUREThe Development Plan will be underpinned by the principles of sustainable development, climate change adaptation, social inclusion and high quality urban design.

Sustainable Development – refers to ‘development which meets the needs of today without compromising the ability of future generations to meet their own needs’. The principle of sustainable development will be embedded in the objectives of the Plan by promoting and encouraging the integration of economic, environmental, social and cultural issues to ensure the needs of all communities are met. Sustainable development principles will be further strengthened by the requirement for separate environmental assessments of the Plan. These assessments are legal requirements to ensure a high level of protection of the environment.

Climate Change Adaptation – evidence shows that the climate is changing, and human activity is influencing this change. Rising sea levels, more intense rainfall events, flooding and drought are happening now. While future events and impacts are uncertain, adaptation to potentially adverse effects is vital in order to reduce the impacts of climate change and increase our resilience to future events. National targets aim to cut emissions by at least 20% by 2020, targets for 2030 are under review. The main areas where reduced carbon emissions can be achieved are energy, land use planning, transport, waste management and biodiversity.

Social Inclusion – social inclusion is about the wellbeing of individuals, families, social groups and communities. Creating a more socially inclusive society by alleviating social exclusion, poverty and deprivation is a major challenge. Steps that can be taken towards this include the provision of community infrastructure and improving access to information and resources. Social inclusion will be a key concept underpinning the Plan.

High Quality Design - good design makes places more attractive to those living, visiting, and working there and to those planning to set up business. High quality design in our towns, villages and countryside improves our quality of life and will be promoted by encouraging its integration into every aspect of the Plan.

The Howth/Sutton Community Council would like the following views to be considered for incorporation into the Fingal Development Plan 2017 - 2023:

2.1 Lessons from the recent collapse of the economy relevant to planning in the Howth/Sutton area

The outrageous planning decisions of the Celtic Tiger era, which would have seen high-rise apartment developments on the Baltray Park / Techrete site permanently change the nature of the Howth area, were developer-driven. The long-term future of the local economy will rely on attracting tourism to a relatively unspoilt heritage town and to wonderful natural surrounding area, not on local spending by residents of tower blocks.

2.2 Other underpinning principles which should be included in the Development Plan for Howth/Sutton

Maximising the tourism potential – preserving the features which tourists will come to see, and assisting local enterprise to provide additional services and added value to the tourist experience.

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2.3 Achieving more sustainable development (encouraging growth while protecting the environment and society) in the Howth/Sutton area through the Development Plan

Concentrate housing development on infill and brownfield sites, while preserving the green spaces and visual aspects across the Howth Peninsula.

2.4 Helping to address the problems of climate change, in Howth/Sutton in the areas of energy, planning, transport, waste management and biodiversity

Learn from recent flooding and subsidence events – increase awareness of the forces of nature (particularly storm waves and heavy rainfall) on the coastline and hilly slopes of the Peninsula. Consider building coastal defences which provide additional amenity facilities (roads and/or pedestrian access); and providing storm channels to take excess rainfall safely downhill without undermining roads, walls and buildings.

2.5 Encouraging a more socially inclusive society in Howth/Sutton

Given the age profile of the population in Howth/Sutton, there is a need to provide more sheltered accommodation for the elderly, both publicly financed and private. This would allow elderly people to remain in the area while allowing them to sell their houses, freeing up perhaps more family size homes.

2.6 Promoting high quality design in Howth/Sutton

The experiences of the Celtic Tiger development disasters in relatively local developments, including the pyrite issues and the Priory Hall fire hazard, have highlighted the need for not only high quality design, but the enforcement of appropriate regulations to ensure that quality design results in quality build. They say that “the road to Hell is paved with good intentions”: quality design (for all development, physical, social and economic) should not only be promoted – it has to be carried through to completion.

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3. SETTLEMENT STRATEGY - WHERE ARE WE GOING TO LIVE?Fingal’s population in the 2011 Census was 273,991 persons, 21.5% of the total population of Dublin. It is likely that the population will rise to over 303,000 by 2016, and by more again during the Plan period. Fingal has a high proportion of young families, and while much of the population increase will be due to births there will also be people moving in to the county. Fingal works within a regional framework which sets out the housing targets considered necessary to accommodate the new population. Over the Plan period to 2023, Fingal will expect to accommodate an additional 41,000 new housing units.

How and where we plan to meet our housing targets must be set out in the Plan’s Core Strategy and Housing Strategy. Fingal currently has a policy of consolidation with the aim of reducing urban sprawl and the inefficiencies associated with dispersed settlement patterns. We need to ensure sufficient housing is available in the right places, with good infrastructure, services and amenities and of a sufficiently high standard, if we are to improve the quality of life for our citizens. We must also provide for the right type and mix of housing to reflect the different requirements of all of our citizens which can change at the different stages of their lives.

Fingal has a diverse housing stock located in a wide variety of areas, both urban and rural. Different towns, villages and rural areas have their own character which influences where people choose to live. Providing an appropriate scale and type of housing development which respects and enhances the character of our urban and rural areas will be a key challenge.

The Howth/Sutton Community Council would like the following views to be considered for incorporation into the Fingal Development Plan 2017 - 2023:

3.1 Ensuring sustainable patterns of settlement and employment in Howth/Sutton

Providing an appropriate scale and type of housing development which respects and enhances the character of the Howth Peninsula is definitely a challenge – as is creating sustainable employment opportunities. Housing development should be concentrated on infill and brownfield sites, to preserve the green spaces and visual aspects across the Howth Peninsula. Tourism growth can be harnessed to provide to local employment growth, rather than any heavy industry.

3.2 Minimum requirements for residential density in Howth/Sutton to help the delivery of social, community and physical infrastructure

The requirement for residential density, particularly on the Howth Peninsula, has to be balanced against the preservation of the amenity & tourist attraction value of the area.

3.3 If we want lower density housing in Howth/Sutton, should we zone more land for residential use and reduce the amount of land available for other uses e.g. amenity, agriculture, etc.?

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The amenity value of open land on the Howth Peninsula IS its selling point, its “family jewels” – no more open spaces should be zoned for residential use.

3.4 Settlements in Howth/Sutton that could absorb greater development

Areas of Howth/Sutton already well served by transport and other services could absorb further development by infill development and by replacing old housing stock on large sites with denser developments.

3.5 Suitable housing types for rural areas of Howth/Sutton

The “rural” areas of the Howth Peninsula afford spectacular views across open heathland and hills to Dublin Bay and the Irish Sea. Suitable housing types in these areas include single-storey bungalows or two-storey buildings nestled into hillsides, not intrusive on the skyline.

3.6 Enabling people to move house within the Howth/Sutton area as their needs change

Given the age profile of the population in Howth/Sutton, there is a need to provide more sheltered accommodation for the elderly, both publicly financed and private. This would allow elderly people to remain in the area while allowing them to sell their houses, freeing up perhaps more family size homes. The provision of affordable housing would also facilitate local young people to leave the parental nest and start out on their own, without having to leave the area.

3.7 Areas in Howth/Sutton more suitable for apartment-type units

Apartment-type units should be located near mass public transport services (i.e. near Dart stations) to reduce the dependence on car use – but not built to inappropriate heights.

3.8 Most important considerations when moving to a new area of Howth/Sutton

Housing development/provision needs to provide young families with locations near schools, elderly people with access to services, and daily city commuters with public transport access within walking distance.

3.9 Building larger new housing estates in Howth/Sutton in phases, and the advantages (if any) this would have

There is no capacity within the Howth/Sutton area to build any more large housing estates.

3.10 Specific housing for the Howth/Sutton area, which may have different standards, to reflect different needs such as those for students, older people, and disabled people

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Given the age profile of the population in Howth/Sutton, there is a need to provide more sheltered accommodation for the elderly, both publicly financed and private. This would allow elderly people to remain in the area while allowing them to sell their houses, freeing up perhaps more family size homes. The provision of affordable housing would also facilitate local young people to leave the parental nest and start out on their own, without having to leave the area.

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4. PLACEMAKING & COMMUNITIES – TURNING SPACE INTO PLACEThe Development Plan has a central role in developing our sense of place, identity and character and helping to provide the type of living accommodation and environment in which to enjoy our preferred lifestyle. There is also clear evidence that good quality public spaces, well designed buildings and a green public realm have a positive effect on economic growth and are therefore important considerations in making the county more attractive to both local and global business.

How places are designed, built and work affects our life choices both now and into the future; our access to public transport, education, community facilities and jobs; where we shop and spend our free time; even influencing whether we feel safe walking down the street. This is not just a consideration in our urban areas but also in our rural areas and villages.

Negative climate change impacts can be reduced by well-designed places and buildings. Carbon emissions can be reduced through, for instance, good physical connections with surrounding areas which encourages walking and cycling and by having easier access to public transport. Open spaces and areas of public realm e.g. streets, parks, squares, can be multifunctional resources capable of delivering quality of life benefits for communities while protecting and enhancing our ecology and biodiversity. The design and management of open space can respect and enhance the character and distinctiveness of an area having regard to habitats and landscape types.

The Howth/Sutton Community Council would like the following views to be considered for incorporation into the Fingal Development Plan 2017 - 2023:

4.1 Facilities which would encourage people to live in the Howth/Sutton area, learning from other examples

The Howth village area has suffered in recent years by the closure of many facilities, such as banks, filling stations, community centres and hotel/function venues – reversing this trend would encourage people to come and live there.

4.2 Accessibility to workplace – its role in choosing where to live in the Howth/Sutton area

The hilly aspect of the Peninsula and its limited public transport service makes many dependent on car transport to go to and from work. Concentrating future development near transport hubs, providing more local employment opportunities, and improving broadband service all have roles to play in improving workplace accessibility.

4.3 Importance of quality green spaces in enhancing the enjoyment of Howth/Sutton

Quality green spaces are essential to the enjoyment of the Howth/Sutton area for residents and visitors alike, from the Promenade at Howth Harbour, through the open greens in housing estates, to the “rural” areas of the Howth Peninsula with spectacular views across open heathland and hills to Dublin Bay and the Irish Sea.

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4.4 Features which make a good open space or park in Howth/Sutton

Open spaces and parks attract a wide spectrum of visitors, and need appropriate features to enhance the visitor experience. Adequate litter/recycling boxes are necessary to encourage people to dispose of their rubbish responsibly; suitable signage can provide information on local views, aspects and local attractions; and public playgrounds provide children with opportunities to burn off their energy without damaging the environment. Around the Howth Peninsula, “open spaces” include the Harbour, the many beaches and coves, the Cliff Path and the mountain heathland with its walks and trails.

4.5 Supporting and encouraging community interaction and integration in Howth/Sutton

Community interaction and integration could be enhanced by the provision of a new Community Centre on the Peninsula, open to all ages and abilities.

4.6 Providing a supportive living environment in Howth/Sutton for people from all walks of life and all stages in their lifecycle

While most of the population of Howth/Sutton are well catered for, the ageing population in the area has resulted in a disproportionately large number of people with dementia. People with dementia are one of the most marginalised, socially excluded and highly stigmatised groups in society. It has been identified that exclusion from communities is all too frequently a consequence of dementia because the person often experiences reduced ability to follow the normal rules of social engagement.

In order to address the exclusion of people living with dementia, a new initiative has emerged on the landscape in the form of Dementia Friendly Communities – this should be adopted to make Howth/Sutton an Alzheimer-friendly area. Essentially, the initiative is about transforming the area into a better place to live for people with dementia.

Key areas for creating a Dementia-Friendly Community in Howth/Sutton:

• The physical environment (signage, orientation, streetscapes)

• Local facilities (shops, pub, Post Office, library, sporting and activity groups)

• Support services (community based services, day care, home care, community based health care professionals)

• Social networks (family, friends, other members of the community)

• Local groups (dementia led initiatives such as Social Clubs, support groups for people with dementia and walking groups)

Activities involved in creating a Dementia Friendly Community:

• Developing educational tools – producing an information product that explains the initiative and how people can get involved. This will create awareness in the broader community and among the various stakeholders.

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• Building the awareness of communities and the actors within them of dementia - Develop and deliver dementia awareness training to key people living and working in the community in order increase understanding of the condition and how to respond appropriately (Gardai, emergency services, business owners, librarians community groups, etc)

• Volunteering - Develop a buddy system and/or citizens’ advocacy services for people living with dementia using community volunteers to provide low key one-to-one support to enable the person with dementia to continue to participate in everyday life

• Creating appropriate environmental factors - Develop proposals on environmental / landscape / barrier removal that are dementia friendly and work with the local authority to instigate practical changes and influence the town planning process

• Enabling the engagement of people with dementia and their families in communities - Develop dementia led initiatives that are inclusive of everyone

• Supporting the person with dementia and their carers to adjust to a diagnosis of dementia – Providing people impacted by dementia with outlets to discuss their diagnosis and adapt to the changes it will bring e.g. family carer training, providing early stage support for people with dementia or providing cognitive stimulation therapy for those newly diagnosed

• Develop a Dementia Friendly Communities Toolkit based on the learning and evaluation of the experience in order to roll out the project in other locations

4.7 Achieving higher densities and creating places where people will want to live and work in Howth/Sutton

Areas of Howth/Sutton already well served by transport and other services could absorb further development by infill development, and by replacing old housing stock on large sites with denser developments.

4.8 Using the Development Plan to ensure that new buildings in the Howth/Sutton area are of high quality design and adaptable for changing family demands

New developments should include a mix of two, three and four bedroom housing units, to encourage a population mix of single young (or elderly) residents; young starter and retired elderly couples; and families with children.

4.9 Using the Development Plan to encourage the creation of vibrant and attractive towns, villages and neighbourhoods in Howth/Sutton

The long-term future of the local economy will rely on drawing in tourists to visit and enjoy the relatively unspoilt heritage town of Howth and the wide-open spaces of the Peninsula, while preserving a very attractive place for locals to live.

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4.10 Designing the built environment in the Howth/Sutton area to have the least impact on our natural heritage and biodiversity

The amenity value of the Howth Peninsula natural heritage and biodiversity IS its selling point, its “family jewels” – no more open spaces should be zoned for residential use. Areas of Howth/Sutton already well served by transport and other services could absorb further development by infill development and by replacing old housing stock on large sites with denser developments. The “rural” areas of the Howth Peninsula afford spectacular views across open heathland and hills to Dublin Bay and the Irish Sea, and provide natural biodiversity; suitable housing types in these areas include single-storey bungalows or two-storey buildings nestled into hillsides, not intrusive on the skyline.

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5. INFRASTRUCTURE AND MOVEMENT - GETTING WHERE WE WANT TO GOIf Fingal is to continue to grow and thrive it must have the necessary infrastructure to accommodate development. Integration between land use and transport services i.e. roads, paths, cycle ways and public transport, will enable efficiencies in public spending and improve our quality of life. It will influence where we choose to live or locate our business and ensure a wider choice in the way we travel by promoting walking, cycling and public transport as an alternative to the private car. In conjunction with a good road and public transport network, an improved, integrated and sustainable transport strategy will support existing and future development.

Managing demand for energy is crucial to meet EU targets for a reduction in greenhouse gas emissions. Encouraging sustainable travel patterns, promoting energy savings and exploring innovative renewable energy technologies can help Fingal to become carbon neutral. The Draft Regional Waste Management Plan 2015-2020 seeks to rethink the approach to managing waste which can be a valuable material resource. It places a stronger emphasis on waste prevention and material reuse, reducing landfill and improving the recovery and generation of energy from waste. The availability of information and communication technology (ICT) to local communities is vital for social and business use. The National Broadband Plan aims to deliver reliable high speed broadband to more areas. There is potential for Fingal to facilitate public wi-fi in towns and villages as well as in public buildings.

As of January 2014, Irish Water is responsible for the provision of public water supply and wastewater services. Fingal will continue to engage with Irish Water to ensure that capital investment decisions reflect our settlement strategy. Fingal, supported by government agencies, will continue to be responsible for surface water and flooding.

The Howth/Sutton Community Council would like the following views to be considered for incorporation into the Fingal Development Plan 2017 - 2023:

5.1 Fingal Co. Council actions needed to protect areas of Howth/Sutton that are at risk of flooding

Flooding in the Howth/Sutton area is caused by three different types of event – each requires specific action to mitigate the effect. Fingal Co. Council can learn much from recent flooding and subsidence events, increasing awareness of the forces of nature (particularly storm waves and heavy rainfall) on the exposed coastline and hilly slopes of the Peninsula.

Heavy rainfall: This is a recurring problem – long-term mitigation measures should include the provision of storm channels to take excess rainfall safely downhill without undermining roads, walls and buildings. The natural processes over millennia created the valleys and gullies from the heights of the Peninsula – building development over the years has blocked the passage of rainwater, which finds its own way to the sea, causing devastation on its path. This sometimes only manifests itself when sections of roadway and footpath collapse into a void caused by underground erosion.

Storm waves: The damage caused by storm waves affects different areas of Howth/Sutton in different ways.

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(a) The soft sand of the Claremont / Burrow Beach area is subject to cyclical deposit and erosion, with a single storm often undoing decades of soft protection (cages and planting to encourage dune creation). Consideration should be given to building a permanent coastal defence in the form of a road or pathway from Sutton to Howth Harbour which would provide additional amenity facilities (vehicle and/or pedestrian access), as well as protecting the buildings along Burrow Road. With more vision, a coastal road could be constructed to link Baldoyle with Howth, bypassing Sutton Cross.

(b) The lower stretches of Strand Road, Sutton are frequently battered by waves driven by south-easterly storms, damaging the sea walls and flooding the roadway and adjoining gardens. Fingal Co. Council has done some work to reinforce the footings of the sea walls, and raised the sea wall levels – but observation of the actual waves during a storm show that the impact of the waves against the walls results in vertical projection of large quantities of seawater, which then land on the road and flow along and across it. This is particularly evident at the Pumping Station location, where it creates a funnelling effect. Raising the wall levels will not keep this water off the roadway – what has proved effective is what has been done along Carrickbrack Road, creating an outer rock barrier where the waves can break onto a green promenade, draining naturally into the ground and back onto the beach. The Carrickbrack Road form of promenade should be extended along Strand Road to the St Fintan’s Road junction, permanently protecting the roadway and creating additional green space amenity.

(c) Similar wave damage happens to the rear gardens of houses of Greenfield Road and Dublin Road Sutton - the Carrickbrack Road form of promenade should also be extended westwards behind the houses south of Greenfield Road and Dublin Road to where the shore meets the Dublin Road, permanently protecting the shoreline and creating additional green space amenity. With more vision, a coastal road could be constructed to link the Dublin Road with Carrickbrack Road, bypassing Sutton Cross.

Rising water levels: There are not many locations around the Howth peninsula which are directly threatened by rising sea levels alone, although some coastal properties are below the level of the road which protects them from high tides (short section of Strand Road, Sutton; Dublin Road, Sutton; and Strand Road, Baldoyle). This can prevent excess rainwater and storm spray from draining back onto the shore when the tide recedes. The low road level of the junction of Strand Road and Carrickbrack Road, Sutton also provides a catchment area for rainwater and sea spray, blocking the road to traffic. Specific studies should be carried out to see if raising the road levels could provide long-term mitigation of these problems.

5.2 Ensuring better management of private waste water treatment systems and private wells to protect groundwater quality in Howth/Sutton

Regulation and active inspection must be used to ensure that private waste water treatment systems and wells do not adversely affect groundwater quality.

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5.3 Promoting and encouraging the use of innovative renewable energy technologies in Howth/Sutton

Although the Howth Peninsula provides considerable opportunity for harnessing wind energy, building wind turbines would destroy the economic value of the tourist attraction of spectacular views across open heathland and hills to Dublin Bay and the Irish Sea. Generating power from rainfall or tidal generators would probably not be economical given scale required, so installing solar panels and/or exploiting geothermal energy on domestic and community buildings should be promoted and encouraged.

5.4 Willingness to pay more for a house designed to have a higher energy rating through incorporation of sustainable technologies

There is general support for designing houses to have higher energy ratings, provided that the extra capital cost can be recouped from energy savings within a reasonable term. Consideration should be given to promoting higher energy efficiency by orienting buildings to maximise solar gain, both into the building itself and through south-facing roof-mounted solar panels.

5.5 Improvements that can be made to the ICT facilities within the Howth/Sutton area of Fingal

In the absence of heavy industry, improvements to the ICT infrastructure will facilitate an increase in web-related employment in Howth/Sutton, including tourism-related activities, by improving online marketing, booking, transactions and feedback.

5.6 Further promoting waste reduction within Howth/Sutton

Waste reduction is already being facilitated by the provision of public recycling banks – these can be further extended and promoted.

5.7 New or improved transport infrastructure required for the Howth/Sutton area

(a) Sutton Cross is a bottleneck junction which causes major backlogs at peak times – particularly at school set-down and pick-up times, as well as at weekends when visitors to the Peninsula add to the traffic volume. Fingal Co. Council signage at the bottom of Strand Road Sutton directs Howth-bound traffic down to Sutton Cross, then instructs them to turn right – effectively blocking other traffic who wish to go straight across or turn left. Because businesses (including Supervalu) are situated at the Cross itself and are destinations in themselves, there is no significant way that “passing traffic” can avoid the area. The only “relief” route, which thankfully is only known to locals, is via Lauder’s Lane, Burrow Road and Corr Bridge – but Burrow Road has restricted width and is currently unsuited to large traffic volumes.

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Solutions to the Sutton Cross problems can be either small, medium or large scale, depending on budget, political will and public acceptance – the junction itself and traffic flows should be examined to determine whether:

i. the approach road lanes could be widened to provide for filter lanes (e.g. Station Road towards Howth, Greenfield Road towards Dublin) ;

ii. access to Supervalu from Station Road should be made entry-only: all exiting traffic to use the main entrance/exit to Howth Road;

iii. a “pull-in” space could be provided for buses in both directions, to avoid blocking traffic;

iv. traffic leaving the main Supervalu car park could be allowed turn left only, using Church Road and Greenfield Road if they wish to head west;

v. a roundabout could be constructed to remove the incidence of cross traffic;

vi. the whole Howth Road / Church Road / Greenfield Road triangle could be made one-way clockwise, creating a single traffic flow with ample space for vehicles to enter / leave driveways, and to set down / pick up passengers.

vii. as part of coastal protection for Burrow Road and Dublin Road / Greenfield Road, a coastal road could be constructed to link Baldoyle with Howth, another to link the Dublin Road with Carrickbrack Road, bypassing Sutton Cross to north and south.

(b) Howth Harbour Road / West Pier junction: A roundabout should be installed at this junction (approximately the diameter of the existing one at Coast Road / red Arches Road Baldoyle, wide enough for double-deck buses to turn). This will eliminate the long traffic bottlenecks and dangerous high-speed “darting” by traffic trying to exit the pier at peak periods.

(c) Station Road Railway Crossing: The Sutton railway crossing gates are closed for too long particularly when incoming and outgoing trains arrive within minutes of each other. The closed time should be shortened as far as possible while maintaining public safety

(d) 102 Bus: This service would provide a very useful public service for DART passengers alighting at Sutton if departure times could be synchronised with train arrival times. The current practice of the bus pulling out as the train arrives makes no sense from an economic, public service or carbon footprint viewpoint – it is a very visible example of wasteful practice.

5.8 Encouraging people in Howth/Sutton to leave their cars at home in favour of walking / cycling or using public transport

The nature of the Howth Peninsula means that many commuters live outside walking distance of Dart stations – so measures must be put in place to facilitate them getting to and from transport hubs. A good round-Peninsula bus service, and adequate free parking in the vicinity of Howth Dart station, will encourage many not to use their cars to travel to Dublin – if costs are as much either way, people

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will continue to use the car. Synchronising bus links with train times would also promote use of both services.

5.9 Best ways to integrate land use with transportation provision in Howth/Sutton e.g. higher density development near public transport, car storage areas

Areas of Howth/Sutton already well served by transport and other services could absorb further development by infill development and by replacing old housing stock on large sites with denser developments.

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6. ECONOMIC DEVELOPMENT - A GOOD PLACE TO WORK?A number of key economic strengths place Fingal in a unique position to encourage and foster employment opportunities. These include its proximity to Dublin City ensuring good access to domestic markets and to the competitiveness of the City-Region. Dublin Airport provides access to national and international markets and is a key economic and employment hub within the county. Fingal has good access to motorways, rail and Dublin Port, as well as water, waste, ICT, power and a young highly educated workforce.

Fingal has a high quality built and natural environment which is a key factor in attracting employers and highly skilled workers. The Development Plan has a significant influence, through its policy, on the attractiveness of places to employers. Fingal’s diverse economic base is characterised by high levels of Foreign Direct Investment (FDI) in areas such as IT, pharmaceuticals and biotechnology. It also has a strong indigenous business and enterprise culture with the number of start-ups increasing annually.

With a vibrant rural and coastal environment the county is well positioned to benefit from rural based industries and tourism potential. Agriculture, horticulture, a strong food production and distribution sector are key contributors to Fingal's economy, many of which operate at a national and international scale. Large areas of employment zoned, properly serviced and well located development land places Fingal in a good position to attract new business to the county.

However, challenges remain. These include the high, albeit falling, unemployment rate; the proportion of residents travelling out of Fingal to work; retail vacancy rates in some of our towns and villages; changing farming patterns and the need to regenerate existing employment areas. These challenges may ease as the economy recovers. It is essential that every effort is made to provide sustainable levels of employment to match the population increase for the 41,000 new households targeted up to 2023.

The Howth/Sutton Community Council would like the following views to be considered for incorporation into the Fingal Development Plan 2017 - 2023:

6.1 Characteristics and opportunities in the Howth/Sutton area that can be leveraged to attract new employers, highly skilled workers and tourists

The amenity value of open land, coastal cliffs and coves, beaches and water on and around the Howth Peninsula IS its selling point, its “family jewels”. Sustainable employment and work opportunities can be created by setting up more and varied experiences for tourists to enjoy – museums, walks, boat trips, interpretive centres, heritage trails, fishing, diving, bird-watching, seaweed baths, to name just a few.

6.2 Actions to support existing business in Howth/Sutton

One particular business in Howth has the market potential to be a major tourist attraction, but will close eventually unless it can source additional resources. The National Transport Museum, located in the grounds of Howth Castle, has the largest collection of preserved commercial road vehicles in Ireland. It directly attracts visitors to Howth (many of them from overseas) and could attract many more and give employment, if properly developed. It presently relies on a small

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core of active volunteers who keep it open at weekends and public holidays, but this situation cannot last indefinitely. There are no funds available for much needed building repairs or heavy advertising - no official funding for any purpose has been received for five years. Midweek openings for groups can only be arranged on a short notice basis, and long term bookings from travel agents have had to be refused.

With vision and funding, this Museum has the potential to be a major feature of the tourist experience in Howth – some of the items are unique The last tram to run in Ireland before the Luas returned, the oldest electric tram in the world which is almost fully restored, one of only five 1938 Landsverg armoured cars in the world. A GNR Gardiner bus one of three in the world and very much a Fingal item. The exhibition is suitable for all ages and is a mine of social and technical history. Will it remain in Fingal? Hopefully.

Imagine if it could be re-located to the presently derelict Techrete site, with a loop connection to the railway line facilitating delivery of rolling stock? Also imagine a working tram running from the Museum along the Harbour front, along the lines which presently remain buried under the road surface? Howth – the Heritage Town, complete with heritage transport: who wouldn’t want to visit?

6.3 Existing employment areas in Howth/Sutton which could be regenerated, should priority be given to these areas

To be commented.

6.4 Land in Howth/Sutton which could be identified for specific industry sectors or clusters e.g. clean tech, biopharm

To be commented.

6.5 Success to date of rural based economic zonings in the Howth/Sutton area

To be commented.

6.6 Ways in which the Howth/Sutton Food Sector could be promoted better

To be commented.

6.7 Level of priority which agricultural land in Howth/Sutton should be given as an economic asset

To be commented.

6.8 Improving the retail and business environment in Howth/Sutton town and village centres

To be commented.

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6.9 Type and scale of retail opportunities in Howth/Sutton which should be provided, and best locations for them

To be commented.

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7. GREEN INFRASTRUCTURE - SPACE TO LIVE AND BREATHEIt is being increasingly recognised worldwide that our economy and our lives depend fundamentally on nature and natural systems. Nature is now considered a form of capital – natural capital - which we need to protect into the future because it provides us with a multitude of benefits (including food, clean water, clean air and raw materials), and performs important functions such as temperature regulation and flood control.

Our natural capital is contained in networks of land and water including farmland, the coastline, parks, open space, rivers, floodplains, wetlands, woodlands, and nature conservation areas. This resource is a form of infrastructure which we call green infrastructure, and is as important as any other form of infrastructure which benefits our communities. For example, our parks and open space promote health and well-being and help make Fingal a better place to live in. Our green infrastructure enhances opportunities for recreation and tourism, and encourages new business to invest in the county. It plays a critical role in sustaining our food industry.

We must protect, manage and invest in this green infrastructure resource so that it continues to deliver a wide range of benefits. The current Development Plan identifies green infrastructure as a key strategic asset for the county and includes policies for the protection, creation, and management of this resource in an integrated manner by focusing on five key themes: Biodiversity; Parks, Open Space and Recreation; Landscape; Sustainable Water Management; and Archaeological and Architectural Heritage. The next Development Plan can build on this by strengthening green infrastructure approaches into policy, plans and strategy and by seeking to mobilise investment in key green infrastructure projects and places.

The Howth/Sutton Community Council would like the following views to be considered for incorporation into the Fingal Development Plan 2017 - 2023:

7.1 Increasing awareness of green infrastructure in Howth/Sutton and its importance for communities (e.g. health, recreation, environment and heritage) and the local economy (e.g. food and tourism industries)

The long-term future of the local economy will rely on drawing in tourists to visit and enjoy the relatively unspoilt heritage town of Howth and the wide-open spaces of the Peninsula, while preserving a very attractive place for locals to live. Increasing public awareness of the value of this green infrastructure is vital to a sustainable tourism industry.

7.2 Where the focus of Fingal’s green infrastructure approach (on the 5 themes set out above) should be

To be commented.

7.3 Best ways to use green infrastructure approaches to provide for high quality new development in Howth/Sutton

Any new developments should fit into, not dominate the land and sea scapes, and not be intrusive on the skyline.

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7.4 Encouraging the use of green roofs, green streets or other green infrastructure approaches (e.g. tree planting) in new or existing development in Howth/Sutton to provide solutions in relation to water management and the need to adapt to the predicted impacts of climate change

To be commented.

7.5 Ways to mobilise additional investment in green infrastructure in Fingal

To be commented.

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8. NATURAL HERITAGE - ENHANCING OUR QUALITY OF LIFEFingal’s rich natural heritage, which goes to make up a part of our green infrastruture, is evident in our countryside, coastal areas, islands, and our rural and urban landscapes. Different landscape types also give each village, town and urban area its own unique identity. As the county grows, we still need to protect and enhance our wildlife and associated habitats, our geological heritage and landscapes.

The current Development Plan and the Fingal Biodiversity Plan have an innovative approach to the protection of our natural heritage through the development of the Fingal Ecological Network. This sets out a spatial framework for nature conservation and management throughout the county.

The approach is based on 4 elements:

strictly protecting the most important nature conservation areas in the county as required by law;

the development of ecological buffer zones around these areas; providing opportunities for nature through the development of conservation

initiatives in nature development areas; and by protecting important movement corridors and stepping stones for wildlife in

the landscape.

The Fingal coastline extends from Sutton to the Delvin River, just north of Balbriggan. It is the single most important natural resource in the county in terms of its high landscape quality, its heritage and amenity values and its economic benefits. The coast is also an ever changing landscape, subject to continuous natural processes of erosion, accretion and flooding. The predicted increase in frequency and severity of storm surges and high tides will put more pressure on our coastal habitats and coastal defences. This will be a major challenge for future management and development along our coastline.

The Howth/Sutton Community Council would like the following views to be considered for incorporation into the Fingal Development Plan 2017 - 2023:

8.1 Providing for development while ensuring that we protect and manage our natural heritage in Howth/Sutton

To be commented.

8.2 The effectiveness of the ecological network approach and its 4 elements, set out above, as a way of protecting nature in Fingal

To be commented.

8.3 In the absence of a National Coastal Policy, developing guiding principles on how we manage coastal erosion and flooding issues in Howth/Sutton

To be commented.

8.4 Relevance of current development setback of 100m along soft shores to avoid any future problems with coastal erosion in the Howth/Sutton area

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To be commented.

8.5 Sensitive use of our designated nature conservation sites along the Howth/Sutton coast as a tourism resource and a source of employment

To be commented.

8.6 Best ways to provide access to and promote the Howth/Sutton geological sites to the general public

To be commented.

8.7 Ways to encourage and support Howth/Sutton landowners to protect and enhance the natural heritage on their lands, particularly those located within the Ecological Network?

To be commented.

8.8 Using the identification of different landscape characteristics to protect the natural heritage and environment of Howth/Sutton

To be commented.

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9. CULTURAL HERITAGE - ENRICHING OUR LIVESCultural heritage gives us a sense of identity and place. It encompasses the monuments, buildings, folklore and traditions that link communities together. The historic story of the people of Fingal is contained within the archaeological sites, monuments, and historic buildings that cover the county. Although the National Monuments Acts 1930-2004 provide for the protection of archaeological sites, monuments, artefacts and shipwrecks and lists them in the Record of Monuments and Places (RMP), our archaeological resource is finite and diminishing over time.

Community Archaeology, such as community digs, pop-up museums, adopt-a-monument, art projects etc., for locals and visitors alike, has helped in terms of pride of place, community integration and economic benefit. There is the potential for even more interpretation of the archaeological resource in Fingal for education, communities and tourism.

The historic, innovative or rare buildings and other man-made structures constructed by previous generations of Fingal inhabitants as homes or places of industry, commerce, defence, leisure or worship form the architectural heritage of the county. Protection and Development Acts 2000-2014 by way of the Record of Protected Structures (RPS) and Architectural Conservation Areas (ACAs). We have a legal responsibility to include a RPS in our Development Plan to protect buildings of special interest or significance. The review of our RPS is currently underway and a separate more detailed consultation process in relation to this will take place over the coming months. Areas or clusters of buildings can also be protected by being designated ACAs.

Our cultural heritage is an important part of what makes Fingal special and is an asset we should protect.

The Howth/Sutton Community Council would like the following views to be considered for incorporation into the Fingal Development Plan 2017 - 2023:

9.1 Buildings and structures of special interest in the Howth/Sutton area that should be added to the Record of Protected Structures (RPS)

The Signal box near Sutton Station is already in the 'listed' category for preservation – this should be added to the Record of Protected Structures (RPS).

9.2 Policies required in the Development Plan to achieve a balance between development pressures and the protection of Fingal’s cultural heritage

Howth Peninsula and Howth Village have many heritage buildings and views, which should be protected from development to maintain the tourism attraction. For example, the view at the site of The Anchorage on Church Street should be listed as a protected view due to the fact it is part of an architectural conservation area – in addition, all views from St. Marys Abbey in all directions listed as protected views. Given that Church Street is the oldest street in Howth, some historical significance should to be given to the street, possibly by including in on a designated tourist trail.

There is a natural stepdown progression from the houses at Harbour View, to two-storey houses on the South of Church St, to the cottages on the North of

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Church Street, and then down to the apartments on Harbour Road . Such natural progression of rooflines should be maintained and that a development would not be allowed which would interrupt that natural progression.

The local cultural heritage should be promoted through museums (small and large) and interpretive centres – Howth already has a Transport Museum (although desperately in need of financial support); it has capacity for a Maritime Museum (on the West Pier?), and perhaps a heritage museum could be located at the top of Church Street on the site of what was formerly known as the Big Blue restaurant. This museum could have a café, and could be used to promote the heritage trails in the area and to give people a sense of the history of Howth - it would also help to re-direct tourists up from the harbour towards the heart of the village, enabling it to regain its former position as the focal point of Howth, bringing more business to shops, restaurants and pubs located there.

9.3 Changes to existing Architectural Conservation Areas (ACAs) in the Howth/Sutton area and/or identification of new ones

To be commented.

9.4 Improving awareness around archaeological sites and monuments in Howth/Sutton

To be commented.

9.5 Encouraging the use of vacant or derelict historic buildings in the centres, particularly on the main streets, of Howth/Sutton, and of farmhouses, outbuildings, old mill complexes etc. on the Howth Peninsula

To be commented.

9.6 Ways to better promote the archaeological and architectural heritage of Howth/Sutton to attract tourism

To be commented.

9.7 Public support for the development of community archaeology, as described above, in Howth/Sutton

To be commented.

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10.IMPACTS ON THE ENVIRONMENT - PROTECTING OUR ENVIRONMENT The impact of Development Plan objectives on the environment must be assessed as part of the process of preparing the Plan. This assessment informs the direction of the Plan and ensures that our built environment responds to the sensitivities and requirements of the wider natural environment. Three separate but related assessments will interact and inform each other and the policies of the Development Plan.

Strategic Environmental Assessment (SEA) is a systematic evaluation of the likely significant environmental effects of implementing the Development Plan before a decision is made to adopt it. It is required by Directive 2001/42/EC, referred to as the SEA Directive. There is an iterative process between the Development Plan making process and SEA which will result in all objectives and policies being assessed against their environmental impact to produce a robust plan.

Appropriate Assessment (AA) is required under the Habitats Directive 92/43/EEC. Its purpose is to ensure the protection of flora and fauna sites within the Natura network. Fingal has a number of these sites, almost all along the coast, in the form of Special Areas of Conservation and Special Protection Areas. The AA of the Development Plan must conclude definitively that the Plan will not negatively effect the integrity of a Natura site. The AA is separate to the SEA but they inform each other and the Development Plan.

Flood Risk Assessment (FRA) must be integrated into the planning process allowing for a more strategic approach to adaptation to climate change and flood risk management. In planning for development we must be aware of areas at risk of flooding and avoid these where possible. Government guidelines 'The Planning System and Flood Risk Management' require a Flood Risk Assessment to be undertaken at an early stage of the plan making process.

The Howth/Sutton Community Council would like the following views to be considered for incorporation into the Fingal Development Plan 2017 - 2023:

10.1 Key environmental considerations for Howth/Sutton

From Fingal Co. Council’s own publication:

“Dublin has one of the most spectacular settings of any European capital. Howth is arguably the brightest jewel in that setting. Its beauty has been celebrated by travellers and artists over the centuries. Distant sea views, large skies and heath land above sea cliffs are the characteristic landscape elements of the peninsula.”

“The Howth Peninsula possesses some of the finest scenery in Ireland. What makes the area especially valuable is its close proximity to Dublin. The potential of Howth was a playground for the people of Dublin was first exploited a century ago by the Great Northern Railway. The company built a tramline to The Summit and a cliff walk around the headland.”

“The very special character of Howth is reflected by multiple environmental designations, which cover a large part of the area. In 1999 Fingal County Council made a Special Amenity Area Order (SAAO) for Howth. It is the Council’s intention, in partnership with the local community, to develop the recreational resources of the peninsula and to ensure that its natural amenities are conserved and enhanced”.

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10.2 The importance of the environment in Howth/Sutton to our quality of life

The long-term future of the local economy will rely on drawing in tourists to visit and enjoy the relatively unspoilt heritage town of Howth and the wide-open spaces of the Peninsula, while preserving a very attractive place for locals to live.

10.3 Areas of the Howth/Sutton area that are particularly sensitive to development

All of the area covered by the Special Amenity Area Order (SAAO), the coastline, and the sea surrounding the Peninsula, including Sutton Creek. The open heathland, particularly in the East Mountain area, should be granted National Park status, protecting it from any further development and enhancing its value as a tourist attraction.

10.4 How environmental policies can address climate change in the Howth/Sutton area

To be commented.

10.5 Ways to deal with the increased likelihood of river and coastal flooding in the Howth/Sutton area

Learn from recent flooding and subsidence events – increase awareness of the forces of nature (particularly storm waves and heavy rainfall) on the coastline and hilly slopes of the Peninsula. Consider building coastal defences which provide additional amenity facilities (roads and/or pedestrian access); and providing storm channels to take excess rainfall safely downhill without undermining roads, walls and buildings.

10.6 Ways to manage development in existing Howth/Sutton settlements which are at risk of flooding

The lower stretches of Strand Road, Sutton are frequently battered by waves driven by south-easterly storms, damaging the sea walls and flooding the roadway and adjoining gardens. Fingal Co. Council has done some work to reinforce the footings of the sea walls, and raised the sea wall levels – but observation of the actual waves during a storm show that the impact of the waves against the walls results in vertical projection of large quantities of seawater, which then land on the road and flow along and across it. This is particularly evident at the Pumping Station location, where it creates a funnelling effect. Raising the wall levels will not keep this water off the roadway – what has proved effective is what has been done along Carrickbrack Road, creating an outer rock barrier where the waves can break onto a green promenade, draining naturally into the ground and back onto the beach. The Carrickbrack Road form of promenade should be extended along Strand Road to the St Fintan’s Road junction, permanently protecting the roadway and creating additional green space amenity.

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