Plan Reference Number ABP 305828, From Crekav Trading GP Limited for 177 Dwellings and Other Developments at Baily Court Main Street and Balscadden Road, Howth, Dublin 13.

Re: Plan Reference Number ABP 305828, From Crekav Trading GP Limited for 177 Dwellings and Other Developments at Baily Court Main Street and Balscadden Road, Howth, Dublin 13.

Dear Secretary,

On behalf of myself and a large number of constituents in Howth Town and housing estates throughout the Howth/Sutton Peninsula, I wish again to submit the following objections and observations on the above proposal, which so closely resembles ABP Plan 301722-18 submitted last year. A well-attended public meeting has again shown the concerns and opposition of Howth and Dublin Bay North constituents to this revised higher-density plan for the three receiving sites between Main Street and Balscadden Road, Howth, Dublin 13.

In a nutshell, my constituents believe that the density of Plan 305828 is perhaps over treble the sustainable density of this location and there is great regret that a much-needed replacement hotel facility is not part of the proposal. They are also shocked at the proposed massive disruption to the life of Howth town and peninsula at the construction stage, at the grave dangers to existing homes from the deep excavation of 78,000 square metres of the sandy ice age moraine to the south of Main Street and Abbey Street and at the proposed ongoing significant increased traffic and on-street parking which will be certainly generated by the proposal and which will seriously add to ongoing traffic congestion in Howth and in the Peninsula. My constituents also note that Plan 305828 and another Crean/Marlet plan (Plan PL06F.304637 for 512 apartments) for the old Techrete brownfield site at the entrance to Howth town totally contravene recommended density in the Core Strategy for Howth in the 2017/2023 Fingal County Development Plan.

In a little more detail, the deep opposition of my constituents and myself to ABP (SHD) 305828 include the following key concerns:

The Proposed Density and Height Constitute Serious Overdevelopment of this 1.55 ha. Site

Howth people and our visitors have long wanted an appropriate and sustainable development at the old Edros Sports Centre Site and on the Baily Court Hotel site. Over the past 10 or 12 years, residents hoped that a new hotel and commercial/shop units might occupy the Baily Court site and that a well-designed low-density housing development with some commercial facilities would be planned for the long derelict Edros site. Indeed, the ‘Planning Report’ by Tom Phillips and Associates details 20th century proposals for the sites in question. Plan F07A/1349/PL (06F.227972) for a 64-unit circular apartment development from Pierse Construction was approved by Fingal County Council (this proposal at what is now referred to as Site C was subsequently overturned by An Bord Pleanála).  Aspects of this plan, for example the pedestrian street from Abbey Street to Balscadden Road, are present in the current proposal. The design of that earlier proposal seems greatly superior to the Crekav plans but the key difference is that Crekav is trying to almost treble the density approved by Fingal in 2006/2007 (and objectors at that time felt that a lower density of perhaps 35/40 apartments would have been more appropriate). Of course, in 2014 and in line with the traditional density of the receiving environment, Fingal granted approval for just 17 houses and 6 apartments at the same site. The argument in the Tom Phillips ‘Planning Report’ against lower densities at the site is based on a spurious reading of the current County Development Plan, and a complete lack of understanding of the ACA and SAAO for Howth Town and Peninsula.

Likewise, the so-called Cluxton Lands (Site B) had a permission from around 2006 (F06A/1897/PLO6F.224372) and FO6A/1897/E/ for just 6 detached houses entered from Balscadden Road. A later plan F15A/0545/PLO6F.246183 (refused by Fingal County Council) proposed a development of 9 three-storey dwellings, also with access from Balscadden Road. The much longed for development of a new hotel facility at the Baily Court/Royal Hotel site of course has not yet happened. But in 2013, Plan 13A/0110/PLO6F.242595 was granted by Fingal and An Bord Pleanála. That proposal was for a four-storey mixed use development including 4 retail/service units for the centre of Howth Town and with 7 apartments overhead and 22 car parking spaces. (I note in the original Crekav ‘Planning Report’ that Fingal Planning officials are said to have objected to what seems to have been a lower density circular design echoing the Pierse Construction proposals of a decade ago).

But the density envisaged in the effectively massive blocks in Plan ABP 305828 is astonishing given the highly sensitive environment of the Martello Tower and adjoining lands between Main Street and Balscadden Road. The 171 apartments and 6 duplexes represent an astounding 114 units plus to the hectare, or more than 46 units to the acre. These densities seem even too high for a Strategic Development Zone (SDZ) and a new urban zone such as Hansfield or Adamstown or even for the North and South Fringes of Dublin City and Fingal respectively. Indeed, the densities at The Coast in the South Fringe are planned at a significantly lower density than at the Baily Court/Edros site. The public who I represent are fearful, of course, that both 2016 planning legislation and ‘Rebuilding Ireland’ are being used as a pretext for unsustainable densities and heights in another phase of the developers ‘boom bust’ cycle.  Of course, the programme of speculative uncontrolled building which produced 400,000 plus (and often defective) homes in 2004 to 2008 has left a trail of structural, fire safety and insulation difficulties for residents who purchased their homes before the crash. The developer’s officials who reported to a large meeting in Howth Yacht Club in 2018 seemed to say that initially Crekav sought 123 units in these 3 locations. But even that density is far too high and does not deliver the homes and services which Howth actually needs.

The Proposed Height and Scale of ABP 305828 Seriously Damages the Character of Howth Town

The height of Block C and Block B are also particularly striking.  Block C is effectively a 5-storey structure (plus the basement) with Block B 4-storeys high.  Inevitably, even in the excavated Cluxton and Edros sites, these heights are out of character with the centre of Howth Town and will seriously impinge on existing households and businesses.

The Conroy Crowe Kelly Architects and Urban Designers Report have a range of photomontages showing the major visual impact of the height of the new buildings proposed for Sites A, B, and C, and the reference to other sites in the UK and Europe have little relevance to the unique visual legibility of Howth town. The height of Block A soars above the Health Centre and the historic Howth library. The more characteristic height of Block M simply does not prepare the viewer for the towering height and mass of Block B which with Block C is closely reminiscent of massive high apartment blocks in the North/South Fringe and in other high density new urban regions. The use of the height of the Martello Tower and some homes in Asgard Park as reference points in the cross-section drawing on Page 29 of Conroy Crowe Kelly’s Architects Report cannot disguise the profound height and mass impact of Blocks B and C on Main Street and environs and on Balscadden Road and all current buildings located there.

Block C will tower over Abbey Street (even from its ground floor) and negatively change forever the pleasant walkway up to the Martello Tower from the town. The ‘café corner’ at Block C looks like a typical streetscape in high-density districts of Clongriffin and The Coast. The photomontages also show a major new built skyline from the ocean near Howth Harbour. In fact, Balscadden Road will completely lose its quasi-rural character under Plan 305828 and it is nonsense to write (as on Page 42 of Conroy Crowe Kelly) that ‘on the Balscadden elevation, the building steps back into the landscape and retaining walls.’ Indeed, Block C is monumental in every direction.

The attempt by Conroy Crowe Kelly in the Architects and Designers Report to show that they are complying with conditions of the earlier Plan 301722 granted by An Bord Pleanála in Appendix 3 is futile. The Board’s decision was fundamentally flawed. A few reductions in roof ridge heights, a change to light coloured bricks, open access to the new street and plaza, EV charge points, additional replacement trees, etc., are simply tiny revisions to an unwelcome scheme which is now significantly more massive and intrusive than even plan ABP 301722 in 2018.

The Design of Plan ABP 305828 is Badly Flawed and Does Not Address the Needs of the Receiving Environment.

A key question which is asked by constituents is why Crekav and its agents held no consultation whatsoever with the people of Howth Town and with Howth social, business and cultural interests before embarking on any proposal for this site. People ask why there were not presentations by the proposers at local venues and why realistic models of the proposed development (or alternatives) were not produced and displayed at a venue such as the Old Court House on Harbour Road. Any such consultation would have revealed grave concerns with the design of Plan ABP 305828 (as with earlier Plan 301722). The Conroy Crowe Kelly Architects and Urban Design Report goes on at length about ‘permeability’, ‘legibility’, and something called ‘serial vision’ for the Howth ‘Village Core’. But the incredibly massive Block C (on less than 1 hectare), Block B which is facilitated by the removal of a huge sandy portion of Howth Hill and Block A do little or nothing to enhance the character of Howth Town (beyond the long proposed pedestrian street). Indeed, the key ‘serial vision’ seems to be the developer’s vision of massive multi-million supernormal profits if this latest proposal is approved.

I have carefully examined the photomontages in the Landscape and Visual Impact Assessment report by Murray and Associates and of course in the Conroy Crowe Kelly Architects document itself. These visualisations cannot diminish the reality that the design of the new development will tower over Main Street and Abbey Street and dramatically change the receiving environment forever. Much is made in these Crekav reports of the so-called integrating design of Block A, but this will be a huge intrusion into Main Street in a style which seems to add little in design terms to the streetscape. As I mentioned above, the design of Block A, Block B and the massive Block C seem merely to echo the hackneyed design motifs of districts of the North Fringe and West Dublin Strategic Development Zones and add little to the architectural character of Howth.  While the pedestrian street linking the town and Balscadden Road is welcome, it is still unclear, despite the commitment in Appendix 3 of Conroy Crowe Kelly, if this street and the new small plazas will ever be taken in charge as public streets and spaces.  The amount of amenity open space for the new residents is also deplorable and in the worst traditions of poor high-density developments.

Profound Negative Structural and Drainage Impacts on Howth Town.

There were gasps of amazement at a large public meeting I attended on the earlier Plan 301722-18 when the representative of the developer seemed to report that truckloads of sandy soil would be removed from Howth Hill daily for six months. This was said to be necessary to remove the embankment of higher ground to facilitate the construction of Block B and to presumably excavate the basement car park with 112 spaces in Block C. The immediate concern for residents is that the terrain at this site is composed of sandy soil from Ice Age eskers and other formations.  Fears have been raised over the years at the danger of major soil movements at Balscadden Road, Abbey Street and Harbour Road with potential catastrophic results for residents and businesses in these locations. For this reason, earlier planning applications for this area were changed or heavily conditioned to allow for this district located on the unique topography of Howth.

Howth Town residents’ fears on this matter have a recent historic basis. Seven years ago, after a period of intense rainfall, the soil and ground formation at nearby St. Mary’s Abbey and graveyard underwent a major collapse and movement out into Harbour Road. Many graves and coffins were disturbed, and Fingal County Council had to carry out major restoration works, including the provision of a fortified boundary wall at Harbour Road. So, the disturbance of terrain at the Baily/Edros site has huge negative implications for the existing receiving population. The level of disturbance and additional traffic with excavated soil and rock continuously passing through Howth Town and Sutton Cross over a long period is also greatly disturbing to my constituents. (Even a plan to remove the soil by sea through Howth port or to use the removed materials for a sustainable purpose in the Howth Peninsula itself would be preferable to the nightmare of 6 months or more of trucks trundling in and out of Howth).

Reference to soil movements and flooding in Howth town illustrates another huge reason why the high density ABP 305828 should not be approved. Over the past few decades there have been many instances of flooding at the Bloody Stream, the Gray’s Lane Stream and other small rivers and tributaries in Howth. A key element in these floods is the very steep topography of Howth whereby streets ascend quickly to several hundred metres above sea level and the main roads such as Thormanby Road and Carrickbrack Road have very steep gradients.

In early August 2015, a major thunderstorm caused a series of flash floods right across the peninsula. Cascades of water poured down Thormanby, Balkill, Balscadden and other Howth roads and estates like Thormanby Woods were badly flooded. A major impact of this flood was located directly in front of the Baily Court Hotel where a large water pipe collapsed and severely damaged Main Street and the adjoining Abbey Street. That destructive flooding event underlines the unique location and fragile topography of Howth.

Howth was once an island and became a tombolo a few millennia ago. But like a small island it receives the full rigours of the weather from every direction (and hence the difficulty in maintaining trees in Howth due to the strong ocean winds).  Howth’s sea position and steep topography impose natural constraints on all developments in the peninsula – it is truly a unique coastal location.  The excavations planned and the high density of the 177-unit development will clearly place an intolerable strain on existing Howth residents. There is little or no information in the Crekav documents about how the topography/drainage problems will be addressed. There is a mention of ground structures with an incredible lifespan of only 50 years (subject to ‘regular maintenance’) but no detailed information on how the above problems will be resolved.

There is an insuperable obstacle to giving permission to plan ABP 305828. That is the existence of the Howth Tunnel, a major water pipeline underneath the site. Conroy Crowe Kelly and Crekav seem to have no difficulty in applying for a permission which covers part, if not all, of this pipeline. In another environment inland, a case might be made for such a development. But in the case of Howth and for the reasons outlined above, building a huge edifice over the Howth Tunnel is unconscionable and the consequences may be disastrous even decades from now (long after the developer and Crekav/Marlet have disappeared). Even a much smaller and more sustainable development would have to ensure that the route of the Howth Tunnel is kept clear of major development and retained under amenity open space or streetscape for easy care and maintenance by Irish Water and Fingal County Council.

Constituents Have Grave Concerns about Traffic Access and Egress to the Proposed New Development and about Parking.

One of the most serious flaws with this proposal is the access and egress to this site which has caused concern amongst residents. According to the O’Connor Sutton Cronin and Associates (OCSC) Traffic Impact Assessment, this development for 177 residential units will generate approximately ‘387 additional trips per day’. Of these, approximately 8 arrivals and 37 departures are expected during the AM peak, with 17 arrivals and 10 departures during the PM peak. These figures are surely a gross underestimation and even the nearly 400 additional trips per day are still a significant amount of traffic to add to a town which already suffers from very serious traffic congestion, especially at weekends and rush hours. Sutton Cross junction is very busy especially during those periods and the new traffic from this high-density development will have a significant impact on existing Sutton Cross traffic flows. O’Connor Sutton Cronin and Associates Traffic Impact Assessment’s conclusions that the proposed development’s impact on the junctions in the immediate vicinity ‘is negligible’ and ‘well within normal capacity levels’ has no basis in reality. The assertion on Page 49 of the OCSC report that the impact of the proposed development on Sutton Cross would also be ‘negligible’ is similarly fanciful.

The Traffic Impact Assessment was carried out on March 7th 2019 and therefore this assessment totally fails to encompass the huge number of visitors and tourists who travel to Howth during the summer months. At weekends, Howth’s population increases by a factor of three, four or more.  This generates massive amounts of additional traffic with long queues at Sutton Cross and in and out of Howth town, and this should have been taken into account when completing this assessment.  The above OCSC estimations do not even consider the traffic that will be generated by the retail units and cafe proposed within this development. Within the O’Connor Sutton Cronin and Associates Traffic Impact Assessment, it is stated that these ‘are not expected to be a primary trip generator’ but there is no way of proving this assertion. O’Connor Sutton Cronin and Associates did not account for the traffic generated by these retail units when completing this Traffic Impact Assessment which I think is also a major flaw with this proposal. It is impossible to know how much traffic these units will attract and O’Connor Sutton Cronin and Associates assertion that they do not expect ‘to attract trips from the external road network’ is bizarre.

Indeed, Howth is a unique location in traffic terms with estimates of 750,000 to one million visitors per annum (these are figures based on Fingal County Council and local tourist surveys). The OCSC study is actually completely useless because it has not examined the massive traffic flows into and out of Howth (and the resulting parking difficulties) in good weather (especially) and on virtually every sunny and weekend day of the year. On several Sundays throughout much of 2019 (as for the past decade), Sutton Cross has been totally gridlocked with backed-up traffic in all four directions for three or four kilometres to Sutton Cross. (Indeed, as Howth residents well know, any Saturday, Sunday or Bank Holiday with good or sunny weather draws crowds to the town, harbour and walkways of Howth from all over North Dublin, Fingal and beyond.)

Thousands of commuters and tourists to Howth also use Sutton Cross daily and constituents feel that this development will have an adverse effect on traffic coming into and leaving Howth (already constituents are calling for new relief roads into and out of Howth). The developer relies heavily on the fact that this development is near to public transport links. However, even if some residents decide to use public transport as part of their commute, it is likely that the majority will still own cars.

O’Connor Sutton Cronin and Associates have proposed that 146 car parking spaces be allocated to this development which will contain 30 three-bedroom units, 103 two-bedroom units and 44 one-bedroom units. This is not even one space per unit. Further to this, 112 are located in the basement of the property, with only eight parking spots provided for on the surface level adjacent to the development entrance, which are said to be for ‘visitors and general public use’. There are a further 26 spaces in a ‘podium car park’ in Block B. I think that the deficient parking spaces on the 0.82 ratio which have been allocated within this proposal are completely inadequate. As 133 apartments are three- and two- bedroom properties, a minimum 2 car parking spaces per unit should be allocated for a three-bed property and 1.5 spaces for two-bedroom properties. The parking density of 0.82 is ludicrous for this location and even one space per residential unit would be a basic essential facility.  O’Connor Sutton Cronin and Associates detail the reasoning behind having so few car parking spaces in the Traffic Impact Assessment. It says that as this development is ‘relatively well served by public transport’ and it is served by both a DART station and bus service that it is ‘wholly appropriate to provide a reduced quantum of car parking at the proposed development’.  Residents fear that this oversight will cause further parking problems and traffic congestion in Howth Town and the surrounding peninsula. There is very little overflow or visitor parking within these proposed plans and the retail units have not been assigned an appropriate amount for customers. Residents are obviously very concerned about this as they fear the cars of new residents and their visitors will be parked on the already narrow streets in Howth Town.  Conroy Crowe Kelly has no way of knowing also how so-called free public car parking in Howth (on Harbour Road and even in the Harbour itself) will evolve in the years ahead. (There have been several proposals already from Fingal County Council and the Department of the Marine for paid parking on Harbour Road, Abbey Street, Main Street, and in the Howth Harbour itself.)

O’Connor Sutton Cronin and Associates’ assertion that this site is near transport links is meaningless, and the allocation of so few car parking spaces for a development that will accommodate at least 300 people is completely inadequate and will have adverse effects on existing residents. The developer also fails to address the huge volumes of traffic Howth gets during the summer period and the thousands of visitors who come to the peninsula every day during sunny weather (visitors as mentioned above are conservatively estimated at up to 750,000 and even 1,000,000 per year!).  O’Connor Sutton Cronin and Associates state that three car parking spaces will also be needed as part of the ‘Car Club’, which means the already inadequate car parking spaces will be depleted further. The ‘Car Club’ is an initiative that hopes to reduce levels of car parking and the developer envisages a shared car service which allows residents to book and rent a car for a day or part thereof. Although any proposal to encourage people to reduce over-reliance on cars is welcome, I think the developer is using this as another way to justify the lack of parking spaces. The clear lack of parking spaces per unit shows that this proposal is far too high a density for this site and the developer needs to go back to the drawing board.

Chapters 3 and 4 of the OCSC study are gravely deficient. The information on the receiving environment in Chapter 3 simply fails to address the unique character of Howth as a sea-surrounded green lung for nearly 1.5 million Dubliners. The trip generation figures in Chapter 4 (at 188 daily arrivals and 199 daily departures) are perhaps half what might be reasonably expected from almost 200 apartments 17km from the centre of Dublin. The references to traffic in Chapter 4 to Plan PL06E.304637 for 512 apartments at the old Techrete site further emphasise the major additional pressure which will result from two such crass overdevelopments on the street network of the peninsula. Chapter 7 refers to the appalling impact of queues of trucks removing 78,000 square metres of excavated sand and rock from the three sites. Clearly route options 1 and 3 preferred by the developers and his agent would be disastrous for the mobility of the people of Howth and our visitors. It is understandable why Fingal County Council opted for Route 2 (around the east and south of the peninsula in less heavily populated areas and away from the town). Route 3 was approved in the ABP 301722 decision, but the unacceptable scale of Plan 305828 would also impose grave disruption on the Carrickbrack and St Fintan’s areas of Sutton and on Sutton Cross itself.

The Lack of an Environmental Impact Assessment Report.

Altemar originally carried out a very basic Ecological Impact Assessment for the Bailey Court/Edros site. This seems to have consisted of just 3 brief field surveys and only in early Autumn 2017. The EIA listed the designated conservation sites clustered within a few hundred metres of the Baily/Edros site. This litany of conservation areas so close to the proposed development again highlights the unique importance ecologically of this location. A large number of plants and animals are referred to in the Evaluation of Habitats and vibrant plant, animal and bird life is a feature of every open area of the Howth peninsula. Only detailed information is provided on the Herring Gull (Larus Argentatus) population but species like wren, robin, blackbird, blue tit, great tit magpie, jackdaw and rook were observed in the site. The Herring Gull population is increasing and the species is protected but inevitably any development on this site will impinge on the gulls and a much lower density development would also be more appropriate in regard to preserving local flora and fauna. (New residents of any development at the location of course will have to get used to gulls perching on roofs and high vantage points as the species historically has Howth as a key breeding ground and home on Ireland’s east coast.)

But the brief EIA did not reduce the critical need for a full EIAR on this location. Crekav’s ‘Environmental Report EIAR Screening’ is a flimsy document and bases the refusal to submit an EIAR simply on Schedule 5 of the 2001 Planning and Development Regulations. This schedule refers to housing developments of more than 500 dwelling units and areas greater than 2 hectares. But this Crekav development is for 177 housing units and ancillary development in a unique topography and ecological location. The proposal also involves the removal of a huge embankment lower area of Howth Hill which may have disastrous consequences for Howth town.

As such the so-called EIA Screening Exercise is a phony submission where the developer Pat Crean asks himself only certain questions and gives answers to suit himself and his company. Nothing causes concern to the developer in his litany of self-satisfied answers, although several of the questions he poses and glibly answers are the subject of the objections in this submission. At least one sentence in this presentation is factually incorrect, namely the assertion that ‘the site is not hydrologically connected to any protected sites’. The buffer zone of the 1999 Special Amenity Area Order for Howth peninsula includes part of this site. The Environmental Screening Report does admit that the subject lands are located within the architectural conservation area on Main Street and are adjacent to the historic Martello Tower which is a protected structure and has designated protected views from the high amenity area around the Tower. The reference in the report to ‘possible short-term nuisances’ to human beings from noise, truck movements and dirt is simply risible.

The Archaeological Report mentions the adjacent National Monument of St. Mary’s Abbey, the Martello Tower and ‘the presence of medieval pits’ and it is clear that a full archaeological assessment is necessary under a comprehensive EIAR. The conclusion of the Crekav Environmental Report is grievously deficient, and a full Environmental Impact Assessment Report is essential before any development is permitted on the Baily Court/Edros Site. The serious damage the huge proposed excavation may do to the glacial moraine above Abbey Street, Main Street and Harbour Road may have profound consequence for Howth town and the peninsula and result in another public enquiry by the planning regulator and the state.

The Building Lifecycle Report and JV Tierney Engineering Solutions Report Fail to Address Grave Deficiencies of the Proposal.

The brief paragraph at 3.1.2 on the Crekav Building Lifecycle Report is startling and raises profound concerns for my constituents. An earth retaining wall strategy originally proposed and developed by O’Connor Sutton Cronin Engineers and Gavin and Doherty Geo Solutions (GDG) refers to steel street pile retaining walls. There is reference to an executive summary prepared for this report which ‘outlines how the sheet piles have been designed for a 50-year working life’. The report in appendix 1 goes on to state how this working life can be extended ‘by good housekeeping and regular maintenance’. But given the ongoing legacy of structural, safety and other problems from the pre-crash era, what local resident can have confidence in solutions with only a 50-year working life. They ask if solid safe construction should not result in buildings with secure long-term futures and which don’t endanger other perhaps older buildings and their residents. Indeed, these reports are characteristic of planning applications for commercial buildings with perhaps an intended 50- to 60-year lifespan. But the Baily Court proposal will be occupied for several hundred years  (as with the oldest homes in Howth town and environs).

The light and overshadowing analysis in JV Tierney and Co ‘Daylighting and Sunlight Report’ also seems very basic and formulaic. Even a cursory glance at the Conroy Crowe Kelly’s Architects and Urban Designers Report and Tom Phillips’ Planning Report show that over 30 existing homes and buildings on Abbey Street, Main Street, Balscadden Road and Asgard Park will be profoundly impacted in terms of light overshadowing and access to views of the town and the ocean. In houses marked A to F, the JV Tierney report admits e.g. that ‘it is not possible to quantify a potential loss of sunlight’. No weighting is given to loss of light at other homes because they are said to be ‘heavily obstructed by existing topography’. Site C refers to Asgard Park but clearly Block B will impact at least on ground level on the Asgard cul-de-sac homes. Table C in JV Tierney and Co’s report shows disturbing reductions in sunlight in winter for houses E and F. It’s also striking that in the new development itself the Average Daylight Factor was only 82.9% for Block B and only 82.3% for Block C. So, the conclusions in the J.V Tierney report at (A), (B), (C) and (D) are therefore questionable and need independent investigation.

But neither the J.V Tierney Report, the Building Lifecycle Report, nor the Control of Works within the Howth Head SAC remotely address concerns related to the excavation and construction of such a large and high development at the Baily/Edros site.

The Lack of Consultation with the People of Howth on Plan ABP 305828 Emphasise the Need for an Oral Hearing.

In the documents attached to this application we read of the consultations between Crekav/Marlet and Fingal County Council planners from late 2017 and of Crekav’s responses to conditions imposed by An Bord Pleanála in ABP Plan 301722. These documents also include a Planning Statement of Consistency with local, county and national development plans. But it is the people of Howth and their elected Fingal representatives and elected national representatives like myself who must have a significant input into any proposals for the Baily/Edros site. As I mentioned at the start of this submission, people have longed for a replacement hotel and community facility on the Baily Site plus a reasonable density and height development at Edros and the former Cluxton site (new social housing units at a more sustainable development are also very welcome).  But, Plan ABP 305828 is not that longed for development. On all the grounds I have briefly enumerated above, my constituents remain profoundly opposed to this very high-density development with all the negative structural, traffic, drainage and environmental impacts it will have on neighbouring homes, Howth Town and indeed the whole peninsula. As many other residents have said, even a reported earlier 123-unit and 164-unit developments were far too high density for this receiving site.

It would be best if the assigned An Bord Pleanála Inspector now grants an Oral Hearing so that she/he can hear at first-hand what Howth thinks of Plan 305828 and the almost identical earlier Plan ABP 301722 and what we feel would be a reasonable and sustainable development of the two derelict sites and the Cluxton lands. For that reason, I now call on An Bord Pleanála to grant a full Oral Hearing on Plan ABP 305828 and I formally now request that hearing in the interest of transparency and democratic planning.

Conclusion

My constituents and I are opposed to Plan ABP 305828 on high density, height, poor design, environmental, structural, drainage, traffic and public safety grounds. I hope you will carefully consider this submission and grant an Oral Hearing on this proposal.