Response to the 'Final Report to Dublin City Council Meeting 5th December 2011'

Below is the text of our response to the ‘Final Report to Dublin City Council Meeting 5th December 2011’ issued by Dublin City Council (DCC) on 2nd December 2011.

The letter can be downloaded here in pdf format.

To: All City Councillors

We are disappointed to read the latest report issued by DCC in relation to the Clontarf Flood Defence scheme. DCC on the one hand acknowledge the overwhelming public opposition while on the other are recommending to Councillors that the plan be proceeded with.

We are dismayed and frustrated at the apparent intransigence of DCC to accept the views of the people of Clontarf and the wider Dublin area on this controversial issue.

It confirms our view that the information sessions were simply an exercise in 'optics' and that DCC did not have any real intention of taking on board the views of the public. We are relying on our elected representatives to take the opposite view on Monday night and we would like to thank the parties and councillors that have already pledged their support.

The CRA/CBA group reserves the right to make a more detailed response to this report at a future date but in the meantime would like to make the following high level points by way of a preliminary response:

• DCC place great emphasis on the 'alternative scheme' proposed by the CRA/CBA. In our letter to DCC on 18th November 2011 (see appendix 2 of their report), we clearly stated we are not proposing an alternative scheme and nor could we. Our references to option 1 of the Haskoning report (which was included as an option in their EIS) were mainly to show that other alternatives had been proposed but had not been fully consulted upon. No wonder there is some confusion on the heights. Our reference to option 1 eventually led DCC to admit that the heights detailed in the their Environmental Impact Statement (EIS) were wrong, thus further undermining the credibility of the planning process. Also, if Option one was ‘never developed beyond outline design stage' why was it put forward at all? It is disappointing that DCC are recommending proceeding with this plan despite it being underpinned by a flawed EIS.
• Correspondence with the CRA is produced by DCC as evidence that the CRA were aware of the full details of the scheme. We wish to clarify that CRA never received any notification from DCC of this planning proposal. None of the original information sessions took place in Clontarf. One took place in Marino, which is not Clontarf, and the other was at the interpretive centre on North Bull Island which is uninhabited. Why did DCC not conduct an information session at a Clontarf venue? DCC accepted at a north central area meeting in October last that communication was poor between officials and CRA. It accepted full responsibility for this.
• The reference to the flood scheme by the CRA in a letter date January 2011 was in relation to the original flood scheme which the CRA had been briefly consulted upon in 2005/2006 but which had much lower heights of between 0.6m and 1.2M. This further shows the weakness of the public consultation process.
• The report does not address the scoring mechanism (see slide 16 of a DCC presentation dated 21st October 2011) that was used to assess the various options presented in the Haskoning report. In a letter dated 22nd October 2011, we asked for as much detail as possible in relation to this but nothing of significance has been forthcoming that would explain the scores arrived at.
• The report is dismissive of the safety concerns raised by residents during the public information sessions. While, the sea side of the berm/wall may be lit well, this will be of no major help if the passive surveillance is not maintained. For the most part, at darker times of the day, this passive surveillance is offered by passing motorists. Even berms that can be overlooked by men and women of average height cannot be overlooked by motorists.
• We welcome the fact that this report which is addressed at elected officials acknowledges that the option chosen was a cheap option and other options would not score as high on a cost/benefit test. At the recent information sessions there was a distinct reluctance on the part of DCC officials to admit this to members of the public.
• The report closes with the statement "there are therefore no alternative options which can protect Clontarf..." and then in the next sentence is it stated that "the amended proposal is the only feasible option that can be achieved in the short to medium term".  We believe these statements to be ludicrous. Of course there are other options. We believe that this will indeed emerge in any new consultation process. The existing defences include the sea wall, the width of the prom itself, the uphill gradient on certain sections of the prom, and the wall alongside the road. Any new plan needs to look at how these existing defences can be enhanced and then needs to consider what new supplementary defences are needed. The current plan which is, in effect, to build a new primary defence is crude in the extreme. There are also more innovative technologies that are emerging that could be used on the sea side of the sea wall to mitigate the risk. These also need to be looked at. Finally, we also believe that the 'one size fits all' approach for the entire 3km stretch is potentially flawed given the fact that one end of the stretch is subject to wave action while the other isn't. Also, the flood risk differs greatly along the stretch given the known flood history in Clontarf.
• CRA/CBA is neither being obtuse nor obstructive in this process, but simply wants an all-inclusive planning process that ensures that an acceptable Flood Defence system takes account of the wishes of the public.

We are urging you as an elected official to reject the current plan tomorrow (Monday) night in order that the flood defence scheme can go back to the full public consultation that it needs in order to produce an outcome that is more acceptable to the users of this valuable amenity.

Thank you for your attention in this matter.

Deirdre Tobin
Chairperson
Clontarf Residents’ Association

4th December 2011