Fairview Residents’ Association
c/o 39 Windsor Avenue,
Fairview
Dublin 3
5 September 2000
Planning Department
Bárdas Átha Cliath
Block 4
Civic Offices
Wood Quay
Dublin 8
Objection to the proposed development on Richmond Avenue.
Dublin Corporation ref. 2553/00
Dear Sir / Madam,
Fairview Residents Association hereby objects to the proposed development of 4 three to five storey apartment blocks as proposed by Mr. Jerry Beades.
Our objections are based on
1. Density and Open Space
2. Traffic Congestion and Safety
3. Absence of a local area development plan
4. Water & sewage supply
5. Historic sites
We have held a public meeting on this application. The developer attended
this meeting. Issues that arose during these meetings were
· Density
· Traffic
· Privacy for existing residences bordering the site
· Security
· Amenity
· Child safety
The developer took no real account of the issues raised at this meeting.
We note that the developer has not submitted an Environmental Impact Statement (EIS) in respect of this proposal. It is our belief that an EIS is appropriate for a development which would so fundamentally alter the neighbourhood amenity.
We believe that Dublin Corporation has a unique duty of care in respect
of development in historical areas of the city such as Fairview. Factors
such as
· the absence of a local area development plan
· high density developments
· the lack of public open space (throughout the area)
· traffic congestion
· lack of public transport services
· the uncertainties of DPT project
are such that very careful consideration needs to be given to the nature
and scale of any development on this site.
Density, suitability and open space
It is becoming clear that extremely high-density developments such as this
proposal does not lead to the costs of housing being more affordable for
owner-occupancy. At least this is true when high-density comes to mean low
quality. We contend that the Fairview area itself, as it is now, is a model
of the high-density development required to ensure that housing in Dublin
becomes more affordable but in keeping with Dublin’s character. The
local housing stock is terraced with small gardens. Both the 100 year old
houses in Inverness Road and Melrose, Waverley and Lomond Avenues and the
recent developments such as Melrose Court & Bushfield Square are models
of high density, affordable housing.
The proposed development is not at all in keeping with the area.
The permission granted does not enhance the urban fabric in Fairview by seeking innovative dwelling types suggested in par. 5.6.1 of RDDG3/99.
There has been an under provision of public open space in our areas over the years. Indeed the DPT project will remove a large section of the available open space in Fairview Park for a period of some years, thus further reducing available open space. This development does nothing to redress this. The developer does not intend that Dublin Corporation will take the development in charge. This hardly indicates that a higher density policy leading to housing becoming more affordable in this area.
The extremely high density of this proposal is not matched by a higher standard of residential amenity, neither within the Richmond Avenue area nor in the neighbourhood as a whole. We ask that Dublin Corporation now give physical expression to its policies of new parks by insisting on high quality public and communal open spaces on all developments in our area.
Without such measures being applied immediately, we do not see Dublin Corporation can redress what the City Development Plan stated "... the quality of the public domain varies greatly and is frequently poor north of the river"(p.1). The longer these issues are ignored, the more likely it is that inner suburbs like ours will begin to need the same kind of attention as that which the public authorities are giving to the Inner City.
We ask Dublin Corporation to use its power to force contributions to create more accessible and usable public open space in our area. If Dublin Corporation can apply levies for traffic lights etc., we do not see any reason why the same cannot be done in respect of open space.
The extremely high density proposed is not matched by a higher standard of residential amenity, neither within the site nor in the neighbourhood. This is required by par 5.7.2 of your own Residential Density Guidelines.
This development would add to the existing deficit in public open space in this area. It is reasonable that some additional public open space be provided as part of these developments. This is called for by par 5.7.5 of RDG/99. We do not regard apartment balconies, footpaths, car parking, private common areas (e.g. staircases, corridors) or roof areas as contributing to accessible public open space. It is unacceptable that such amenities are not provided for by this proposal.
We draw your attention to par 3.3.1 of these Guidelines"…In residential areas whose character is established by their density or architectural form, a balance has to be struck between the reasonable protection of the amenities and privacy of the adjoining dwellings, the protection of established character and the need to provide residential infill…". Clearly this development does not strike a suitable balance for this area.
The density is excessive. We do not think that the permission granted gives adequate protection to the established character of this area. This contrasts very poorly with the quality of civic design evident in the Marino estate and Fairview. No real effort is being made to maintain the amenity and integrity of the area. Indeed this development – by opening Richmond Avenue to Inverness Road, would destroy this integrity.
Traffic Congestion and Safety
The traffic generated during construction and afterwards is not acceptable
on either of the possible access roads to the proposed site (Richmond Avenue
and Melrose Avenue). Both roads are very narrow and are already filled to
capacity, in common with all roads in the area. Existing developments north
of our area (e.g. Beaumont Hospital, Dublin Airport, housing in North Dublin)
has increased volumes of traffic on Philipsburgh Avenue.
The only safe play area for children in this area is the small cul-de-sac at the bottom of Inverness Road. This is precisely where the development proposes a new access road. Increasing traffic on this access road will make this very dangerous for children.
The main entrance to the proposed development will be from Inverness Road – this will cause severe traffic problems in this already congested area (as the Corporation pipe layers on Inverness Road can testify). The consequences of granting a vehicle entrance at this point would add a significant volume of traffic to an already over-stretched road network. As there will be an exit from the development onto both Inverness Road (new) and Richmond Avenue (existing), the effective construction of a new through road is a real possibility. Indeed there is no justification for an entrance on Inverness Road other than for emergency access which is only required due to the proposal to arch the Richmond Avenue entrance.
To break through the high 100 year old boundary wall would also damage irreversibly the architectural integrity & pattern of the housing to the north of the development.
All traffic from the proposed development will flow onto roads, which are heavily used by school children.
In addition, events at Tolka Park (nearby) and Croke Park also give rise to congestion in this area. Both are expanding, without any provision for off-street car-parking or improved public transport in this area.
There are no plans for cycle lanes in our area. There are no plans to improve public transport in this area. The level of service deteriorates daily and this is obvious at times other than normal weekday commuting peak hours.
Traffic is now the major source of air pollution in the Dublin area. (See pars. 1.3-1.6 and 1.10 of Recommendations. Review of the Existing Air Quality and Proposals for Additional Monitoring of Traffic Related Emissions in Dublin City. Dublin Corporation. Office of the Director of Traffic. March 1998).
An area-wide traffic-calming scheme is currently being implemented in the neighbouring Marino area. The East Drumcondra area is next in line for traffic calming. Clearly traffic in the area is already excessive and needs to be calmed, not increased. This development would make a nonsense of these plans.
Local Area Development Plan
The proposed development is not part of a coherent area-wide local development
plan. This is required by the Guidelines on Residential Density and is part
of the City Development Plan approved by Dublin Corporation in March 1999.
Local or Area Action Plans (par 4.2 of Residential Density Guidelines issued in September 1999 -RDG/99) are important in setting the framework for the achievement of integrated and balanced communities. At present, Dublin Corporation has no local area plan for this district. Nor does it have any budget allocated for such a plan(see Dublin Corporation Report to the Planning and Development Committee. Item 2228. 3 Feb 1999).
We ask you to note the way in which this area is being subjected to development without any consideration for the Residential Density Guidelines, the policies set out in the Dublin City Development Plan and good planning. The Development Plan proposed "the development of a local planning consultation and participation framework through which local plans will be prepared". This has not yet happened. There is no timescale given for their completion in our area nor are we aware that any budget has been allocated for this purpose.
If this or similar permissions are upheld or granted without substantial alteration, the result will be considerable disamenity in this area.
It is not at all clear that this pattern of residential development will lead to an improved supply of affordable housing in a socially balanced way. It is just as likely to lead to the need for the same kind of expensive measures now being applied in large parts of Dublin. These include direct public subsidies in the form of tax incentives (e.g. Temple Bar, IFSC, Docklands) and direct public expenditure (e.g. HARP project, Ballymun Regeneration). As incentives result in the loss of commercial rates, it is far from clear that our local authorities have kind of funding needed to redress the imbalance that past policies have given rise to.
The absence of an approved local area development plan makes this and other developments in this area unacceptable. Where can teenagers and young people hang about, play, work off excess energy etc.? Where can older people stroll away from traffic noise and pollution? Where can parents of younger children meet casually while their children play in well-designed play areas?
It is intolerable that decisions be made on a proposal-by-proposal basis, each of which seems to be taken in isolation. Why react to market developments with little apparent regard to what keeps urban areas lively and attractive for people of all ages and status? Decisions taken in such conditions can have very long term effects and may even have to be reversed e.g. Ballymun, the Harcourt St. rail line, proposals to reopen a rail-line to Navan via Dunboyne, the reinstallation of the second track from Clonsilla on the Kilcock-Barrow Street line, tax incentives for some Inner City areas, setting up special development bodies for parts of the city (e.g. Docklands, Temple Bar).
In the absence of a local development plan for our district, we object
to this proposal for Richmond Avenue on the grounds that these extremely
high density developments do not
· appear to making housing more affordable for owner-occupancy
· make a positive contribution to our area, particularly in terms
of enhancing good urban design, regardless of the standard of any single
proposal
· enhance the existing spatial hierarchy, given the under-provision
of public open space in this area
· have public area designs that are guided by the best principles
of passive surveillance to encourage a safe sense of place and to discourage
anti-social behaviour
· have a top quality design approach to the grading from public to
private areas.
The Fairview and Marino areas are already a high-density area, which has many unique features in respect of open space. The overall tenor of the physical space is relaxing to walk through and pleasing to the eye. Marino is a Dublin Corporation development of the 1920s and 1930s (and before).
Water Supplies
Water pressure is already unsatisfactory in this area. Coupled with the
permissions already granted and the extreme density of this proposal being
considered, this will deteriorate further.
We understand that sewage for the area is also inadequate. This is certainly borne out by the frequent calls from the residents of Richmond Estate for shore clearance works.
Historic Site
In our view, the proposal does not take sufficient account of the nature
of the historic buildings surrounding the development. These include Tom
Clarke House (31 Richmond Avenue) and uniquely, houses on both Richmond
Avenue & Inverness Road in which James Joyce lived. We are very worried
about the future of Tom Clarke House in particular, which is right in the
middle of this development. Which involves the construction of a two-storey
underground car-park & thus an enormous amount of excavation.
The housing stock neighbouring the development is in the region of 100 years old. If this development is granted in any way, the developer should enter a substantial bond to guarantee against damage and be required to carry out surveys of nearby houses before & after construction.
We know that that Dublin Corporation does have high standards. We ask that it continue to inspire itself by considering attractive developments for which it was responsible. We insist that the Corporation hold private developers to these high standards.
Le meas,
Pádraig de Burca
On behalf of Fairview Residents’ Association
. . 