St Pauls - Object to Planning Before Midnight Tonight!

09 Oct 2017

We've just been informed by the I Love St Anne's Group that the public are able to make submissions in relation to the current planning proposal at St. Paul’s (it deals with only infrastructure elements which should not be in this application as they relate to the housing application which is still only in pre-planning) until just before midnight tonight. They have created a template below which you can copy and paste to use for your own submission. 

Planning application can be found here. 

Re: Objection to Planning Application Reference Number: 3777/17

A Chara,

I am writing in relation to the planning application submitted by Orsigny Limited for development on lands to the rear of St. Paul’s College, Sybil Hill Road, at St. Anne's Park, Raheny, Dublin 5.


To this end, I enclose a cheque for €20, payable to Dublin City Council.


I object in the strongest possible terms to the proposal to build infrastructure intended to facilitate residential development on the St Paul's Playing Fields at St Anne's, for the following reasons:

·       The public notice for this planning application (Reg. Ref. 3777/17) is inadequate, as, similar to the previous planning applications Reg. Ref. 4185/15 (which was mysteriously withdrawn) and Reg. Ref. 3899/15 (which was invalidated) the written description attempts to conceal the true nature of the development. This time any casual observer reading the notice would be led to believe that what is proposed is a sports hall and two all-weather playing pitches and "Cycle parking, boundary treatments and all associated site works and services." However  the "associated site works and services" are oversized for the proposed facilities and alongside the sports hall and all-weather pitches are actually designed to facilitate a major residential development of up to 500 units on these lands which are Zoned Z15 "Institutional and Community" and are historically, geographically, socially and ecologically part of St Anne's Park. As the site notice -either intentionally or by accident- is misleading, the applicant should be requested to reapply with documentation and a notice that advertises the full extent and true nature of the extensive development proposals.

·       The current application requests DCC to make a decision on only a partial, incomplete application that contains oversized service infrastructure such as roads and services -including a massive attenuation tank- that are far in excess of the requirements for a sports hall and one-and-a-half all-weather pitches. The access road shown on the site plan is clearly intended to facilitate hundreds of residential units under a separate planning application, which the public has no access to any information on. The public should be able to view the full scheme at the same time this element of the scheme is under consideration by the planning authority.

Furthermore the status of the road is ambiguous in that it is both within and outside the red and blue site boundary lines. This road and the other oversized services provisions should not be considered or granted without the public having a full overview of an application for all of the lands and be in a position to comment on the scheme in its entirety. Moreover, if the lands are proposed to receive Z1 type residential development, then the proper procedure would be to present an application to the councillors to vote on whether or not  to rezone the lands from Z15 to Z1.

 ·       The application proposes routing a surface water sewer from the proposed sports hall and one-and-a-half all-weather pitches across the public park to discharge in to the Naniken stream. Additional discharge to Naniken, even if attenuated, will exacerbate existing periodic flash flooding occurrences which put the public, flora, fauna and protected follies at risk. The most recent flooding event on May 27th 2017 was exacerbated by the new tidal flood defences at James Larkin Road. These works didn't increase the road culvert size, with the result that any excess surface water cannot exit the park into the sea and instead floods the park and road, damaging habitat and causing a hazard to park and road users. Thus additional discharge to the Naniken stream should not be permitted.

·       The unintended partial redefinition of uses "open to consideration" under Z15 zoning across Dublin was in response to a court case relating to entirely different lands. The amendment to now make non-institutional residential development "open to consideration" under Z15 cannot apply to these lands as the original Z15 zoning was placed on them to protect their established use as education and amenity -and indeed, public parkland. The intensity of educational and sporting use remains (notwithstanding the developers recent attempts to restrict access) and the vital biosphere-related use has been acknowledged by the applicant's own Natura Impact Statement. This and separate independent studies have established that the St. Paul’s playing fields are vital feeding grounds for Brent Geese, the Black Tailed Godwit and the Curlew, all of which are protected/endangered species whose habitat's are protected by national and international law. The St Paul's grassland playing fields are the main staging post for Brent geese feeding and moving inland from the Bull Island.

The applicant's developer-funded  Natura Impact Statement claims that the protected birds will move from the grassland proposed to be obliterated by the all-weather pitch, onto adjoining grassland. However, the four adjoining grass pitches are also proposed to be built on by the same developer!

Removal of the St Paul's grassland pitches, the most intensively used feeding site in the inland network, would represent a significant and negative interruption of the feeding network with detrimental effects on the population.

Thus these grasslands cannot be built on without destroying vital habitats in contravention of the protections of the Dublin Bay Biosphere and national and international bird protection directives.

The current application is being presented to the public without the main generator for it, which is rumoured to be up to 500 apartments/houses on amenity grassland, which would represent a significant community loss rather than a community gain. As a decision to grant prior to the entire scheme being put out for full public consultation would be premature at this time and as the scheme is clearly a sweetener for a large residential development utterly inappropriate for these educational, amenity and biosphere lands, the application should be rejected.


Yours Sincerely