I attended Leave No Trace training on beaches and dunes on Bull Island on 6th May.
Although three Biodiversity officials from Fingal were there, unfortunately nobody from Operations managed to attend this time. (The Area Committee agreed in 2024 to my proposal that the Council would investigate the possibility for communities in the Howth/Malahide Area and Council officials to participate in training for communities on beaches and dunes for climate adaptation, but it seems this wasn’t followed up.)

I found the training to be excellent and I have written to the Director of Services firstly to recommend that all dealing with beach management, both in operative and supervisory roles, benefit from similar training. 

I also point out that we face issues with the imminent start of the bathing season and associated mechanical raking, seeking a meeting on the beach as soon as possible to discuss these. These include the following:

On the same day as the training, I received a response at the Area Committee in follow-up to the meeting in February with two local residents about erosion issues. I note the reference to staying 2m away from the foot of the dunes. The photo below shows dune grass trying to grow on an area in front of the dunes which is in places up to 30m deep. We should be ensuring that raking is kept 2m away from any location where dune vegetation is trying to grow. The location of the ropes should support this.

The ropes have stretched and hang to the sand even where the dune hasn’t grown up around the posts. The sand has built up leaving many posts and some stretches of rope submerged. The posts and ropes need to be relocated accordingly.

Concrete bases for the lifeguard hut seem to have been installed on the same day as the training. This was done by cutting into the foot of the dune. Below are two photos, one from 7th May, and one from 13th. You can see that blown sand has already, by 13th, covered the most windward of the concrete pads. (You can also see the scouring in front of the most leeward of the pads.)

Overall this is an area where the dune system is building up sand. The idea of concrete foundations is entirely unsuitable to the location. I suggest the lifeguard hut should be well above the sand level on a foundation of poles into the beach. (The same principles apply to the foundations being used for bins.) The question of Appropriate Assessment under the Habitats Directive for the work done needs to be addressed.

New positive signage should be installed on the rope posts. Here’s an example shown at the training. 

At the eastern end of the beach, sand-trap fencing (chestnut palings) should be installed to catch sand and facilitate dune recovery and growth.

The Area Committee response said

“The seaweed is then deposited approximately 1 meter in front of the dunes at various locations along the beach. This seaweed (a) acts as a natural fertiliser for Maram Grass growth promotion, whose roots are essential for the stabilisation of sand dunes, and (b) to act as an anchor point to encourage sand deposition, the precursor of new dune formation.”

I am informed by people who walk on and pick litter on the beach every day that the seaweed is not spread along the front of the dunes as would be required for this to work but is mounded at one location far from where the public uses the beach.

I’m very concerned by this element of the Area Committee response:

“Beach raking removes debris, often perceived to be unsightly, making the beach more attractive for visitors, tourists and families. The improved aesthetic appeal positively impacts tourism and community well-being, contributing to a positive perception of the coastal area.” 

The Area Committee response seems not to recognise the presence of voluntary litter picking on the beach and to overestimate the degree of work required outside of the most busy periods. In addition, it is worth comparing the cost of improved beach management with the expense currently being incurred in Portrane to address coastal erosion.

I have asked for this site meeting to be organised as soon as possible, and definitely before any beach raking starts.

The Land Development Agency which bought the undeveloped land at Stapolin last year has opened a public consultation (archived) in relation to its proposals to amend the existing planning permission for the part of the Stapolin area which will include the permanent access to Clongriffin train station. The consultation includes drop-in events at Racecourse Community Centre today and next Wednesday from 5 to 8 pm.

The information supplied to date is quite general but the LDA have made a detailed proposal to Fingal County Council in the Large Scale Residential Development process, which unfortunately isn’t publicly available. I have asked them for these document and submitted a request to them under the Access to Information on the Environment Regulations.

The Council Executive have put proposals on public display for parking charges on Harbour Road Howth. The proposal is to charge €1.70/hr, with a 3 hour time limit. The large car-parking areas at the Harbour are managed by the Department of Agriculture, Food and the Marine, who have previously indicated that they would cooperate with Fingal in regulating parking. However, they’re not involved in the current proposal.

I have submitted a response to the consultation. It goes into detail on

• the need to cooperate with the Department / Harbourmaster in developing an integrated scheme,
• the need to extend the scheme over the areas currently affected by excessive parking demand or which will suffer from displaced car parking
• the need to address safety issues and improve conditions for people walking in Howth.

The proposal currently on display was brought to the Area Committee in early March. Feedback was given by councillors but this isn’t reflected in the proposal. The meeting can be watched at https://fingalcoco.public-i.tv/core/portal/webcast_interactive/1064576/start_time/120000?force_language_code=en_GB.

I have submitted a number of motions to amend the proposed Variation, informed by the responses to the public consultation on the Variation. They reflect the following:

I support the bringing forward of the development of the Dunsink lands and Iarnród Éireann’s proposal that higher densities should apply near rail stations.

The Council made some important decisions in the last County Development Plan process, to rezone brownfield employment-only sites for mixed or residential use. This approach was good and it should inform our response to this Variation.

Unfortunately the Executive has decided to recommend the rezoning of Green Belt land rather than brownfield sites. I consider that this advice is contrary to national, regional and local policy, and contrary to proper planning and sustainable development.

I support the proposals in two of the submissions for residential or mixed use zoning on land currently zoned only for employment uses. One is the brownfield former Wavin site in Balbriggan identified in this submission, the other is land to the west of Navan Road Parkway railway station (some, but not all, of the land identified in this submission.) The Balbriggan site is 9.65ha and the Navan Road Parkway site is 18.7ha. Taking account of the national guidelines, these parcels could be expected to accommodate over 500 units and 1700 units respectively. Those density estimates are very approximate; actual densities would depend on whether residential-only or mixed use zonings are applied, and would be subject to detailed analysis of specific local impacts and capacities. My motions seek the initiation of a variation process to change the zoning of these pieces of land, a process which would include consideration of those issues.

The Settlement Capacity Audit, undertaken before the draft Variation was proposed, underestimated the current settlement capacity of the county. It omitted 1511 housing units on brownfield sites currently used as car parks in Blanchardstown and Santry for which planning permission has been granted, and the Kellystown Local Area for which the Local Area Plan indicates indicates between 1065 and 1610 units. Taken together, the total underestimate is between 2500 and 3000. There is more detail on this in my submission to the public consultation.

My motions are as follows:

I made an observation to the NTA’s consultation, in support of the carriage of pets on public transport.

I have made observations on an application for 1,350 housing units at Belcamp. The area was to have a Local Area Plan but that requirement was irresponsibly removed from the Fingal Development Plan in 2023. I previously made a submission on an application on this site which was later withdrawn.

Although close to the existing urban area, this site, unlike most of the zoned land in Fingal, lacks easy access to public transport. Supplying public transport to the site is a central challenge which hasn’t been adequately addressed. An east-west route through the site should be protected for light rail, as I have argued since 2007.

I received a response on Friday 23rd to my queries of 9th January. It shows that important sites with permission for housing or zoned for housing have been omitted from the Settlement Capacity Audit. This includes 3 sites (Blanchardstown and Santry) with existing planning permissions amounting to 1511 units, and one Local Area Plan area (Kellystown) where the Council intends to seek Part 8 approval for the access road this year, with capacity for between 1000 and 1500 units.

I have made a submission to the public consultation with the following recommendations:

• The bringing forward of the Dunsink development is welcome and appropriate. This land is well sited and it really didn’t make sense to defer its development.
• The proposals to rezone green belt and agricultural land should be dropped. A number of the proposed sites were considered and rejected for rezoning in the development of the 2023 Development Plan. The Green Belt zoning has always been intended as a permanent zoning and the proposas to eat into green belt land undermine the proper planning and sustainable development vision for the County. In addition there are grave concerns about flooding and public transport access which haven’t been investigated as they should have been.
• In the light of the over-calculation mentioned above, it is not necessary to find other lands for zoning to replace these rezoning proposals.

I have put more details on the calculations below.

A Variation to the County Development Plan has been proposed by the Council Executive and is out for public consultation until 29th January.

It is in response to a direction from Central Government to increase the housing targets for the County. It is proposing to bring forward the zoning of land at Dunsink which I strongly support. However, it also includes a number of scatterred rezoning proposals eating into the green belts around towns in Fingal, which have been established planning policies for decades.

The total additional zoning proposed would be for 5000 housing units, based on a Settlement Capacity Analysis which appears to have omitted some important sites zoned for housing including sites which have existing planning permissions. This is because the Settlement Capacity Analysis is based on the Residential Zoned Land Tax and land with existing permitted uses is excluded from the tax even if it has residential planning permissions.

I have written to the Council officials about the calculations, asking for some more details.

Subsequent to An Comisiún Pleanála reopening it’s consideration of the appeal on the demolition and replacement of Deer Park Hotel, I have made observations on additional submissions from the applicant, based on the three issues in my appeal: sustainability of demolition, pedestrian access, and the proposed additional road.