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FRIENDS OF THE IRISH ENVIRONMENT
8 February 1999
Planning Department, Fingal County Council, 46-49 Upper O'Connell St., Dublin 1
Re: Proposed development at Santry Demesne, reference F98A/1273
A chairde,
Friends of the Irish Environment objects to the proposed development at Santry Demesne. Our reasons for objecting are as follows:
1. Santry Demesne constitutes a natural resource of great value to the local community when such areas are increasingly rare in an urban context. The proposed development fails to acknowledge the value of this resource and the fact that the natural environment can not be replaced once it is build upon. The importance of the natural resource was recognized in the 1993 Development Plan as evidenced by the objective of that Plan to bring the (entire) Demesne into public ownership and to examine it for a Special Amenity Area Order. The recent alteration in the plan does not reflect any alteration of the situation on the ground.
Santry Demesne is the only substantial area of land south of the motorway which is available for these recreational uses. To develop it as proposed would cut off thousands of people in the communities to the south and east of the Demesne from the natural environment which is their existing right.
2. Allied to the longstanding local recreational use of the land there are established private and public rights of way across the land.
The EIS fails to acknowledge the existence of these rights of way. The Council is under a legal obligation to protect rights-of-way in performing its functions as a planning authority.
3. The proposed development fails to recognize the potential of the land to contribute to improving the social and economic environment of Ballymun and Santry.
We do not believe that the EIS has fully examined all relevant considerations, in particular in that they have not assessed alternative proposals made by community groups at the time of the recent rezonings of this land. These proposals include a enhanced public park that could incorporate an animal sanctuary, a city farm, woodland crafts, as well as offering scope for community involvement, employment, education and training that relate to a wider cultural identify. The natural resource of the Santry Demesne is suited to community-based and co-operative enterprise, whereas the standard industrial estate model of economic development proposed by the developer often leads simply to large-scale factories whose employees commute to work in an area which remains socially disadvantaged. This is a familiar phenomenon on the Northside of Dublin.
4.(a)The treatment of conservation issues in the EIS is superficial and inadequate, failing to comply with the required legal standard.
4 (b). The developer proposes habitat destruction including largescale treefelling and landscaping in a Natural Heritage Area.
Santry Demesne constitutes an area of considerable natural heritage value. Two areas within the Demesne have been designated as a Natural Heritage Area. Particularly shocking is the proposal to clearfell the woods growing through the lake, in the context of the fact that natural wet woodland habitats are vey rare on a European scale. While it is likely that this habitat, as a regrown rather than "primeval" swamp woodland, may not qualify for the protection of say a priority habitat for the purposes of the Habitats Directive, this habitat and the other protected habitats in the Demesne have not even been characterised in the EIS.
There is reference to the presence of bats, which are protected species, yet there is not survey data relating to their numbers or species. Although wooded areas containing dead wood are of great importance for some endangered insect species, there is no entomological survey in the EIS.
The EIS refers to the Black Wood, which is to be more or less fully destroyed, pointing out the accumulation of a deep natural build up of organic matter on the floor of the thinning woodland. There is no attempt to establish the ecological significance of this observation, nor of the conservation status of this wood identifiable on the oldest maps of the area.
In summary, there is a complete failure to describe the habitats and the species present within those habitats. As a result the EIS fails to assess the conservation importance of these Natural Heritage Areas and inevitably then fails to assess the impact of the proposed development.
We draw the attention of the Council to the fact that the requirements of EU Directive 85/337 are not met simply by the production by the developer of a document claiming to be an EIS. The EIA process requires an assessment of the environmental impact as part of the decision making process, and requires that the decision-making process be informed by that assessment. Should the Council consider granting the proposal, it must satisfy itself as to the environmetnal impact of it before making a decision.
5. The developer proposes a large residential complex in an area well within the airport noise zone.
The noise levels identified in the EIS confirm that this area is by virtue of airport noise, unsuitable as a residential area. The EIS fails to specify the serious negative impact of noise on human health. There is an extensive body of literature dealing with this matter none of which has been referred to.
6. The proper planning and development of the land requires the Council to act in respect of the proper planning and development of all the surrounding area, not just its own territory.
It would appear that the fact that the land lies on the border of Fingal County Council with Dublin Corporation has created a jurisdiction problem. The provision of amenities under a Development Plan is a legal responsibility under the 1963 Planning Act. If the Council reaches a decision to eliminate some of these amenities because they do not wish to be "solving another local authority's problems" then they will have reached a decision by taking into account matters that are not relevant to the proper planning and development of the area. This is an issue which we raised as the rezoning of this land was being discussed.
Yours, etc.,
Tony Lowes, Allihies, County Cork and Peter Sweetman, Bun na nAbhann, Caiseal, Co. na Gaillimhe for Friends of the Irish Environment
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