And their Secretary's reply - not for the faint hearted. This is the land where the enemy is always a "fascist" and our friends don't give a "dog turd" for the environment.
Letter to Patricia McKenna, the best of our MEPs, who - perhaps because of the election campaign chaos - didn't see our letter to her or the copy of the appeal we sent her or the copy of the appeal we sent to the Green Party Headquarters. Then she went to a meeting with Ballymun Regeneration about FIE's intervention without contacting us for our side of the story, writing to us saying she was "surprised" to hear at this meeting of our complaint to Europe. We have since discovered that she herself asked Minister Bobby Molly for an EIA a year ago! Put this one down to the chaos at election time?
WHY WE WON'T MEET THE DEVELOPERS? BECAUSE THEY WON'T GIVE US THE DOCUMENTS WE ASKED THEM FOR.
Letter from the Programme Manager with the Community Action Programme Ballymun
Estates on the Edge: the Social Consequences of Mass Housing in Northern Europe, [Anne Power, Macmillan, 1977, 1999]
Social Housing in Ireland: A Study of Success, Failure and Lessons Learned [Tony Fahy, Ed., Oaktree Press, 1999]
Coming shortly: The Slow Death of Great Cities? urban abandonment or urban renaissance [Anne Power and Katharine Mumford, the Joseph Roundtree Foundation, 1999]
Read the Northside People's review of the just published "Social Housing in Ireland". "In the week that the Government spent £23 million on one house in Dublin, a major new study paints a picture of near social collapse in south Finglas."
The Northside People reviewer is no fool: "The study concludes there is a need for the Government to provide continuing support to local authorities in their efforts to develop effective housing management practices. Current funding also needs to be looked at as there is too much bias towards capital expenditure as a means of solving problem estates."
Entitled 'Social Housing in Ireland: A Study of Success, Failure and Lessons Learned', the research study was carried out by the Economic and Social Research Institute, NUI Maynooth and University College Cork for the Katharine Howard Foundation and the Combat Poverty Agency. It explores the living conditions and quality of life in seven urban local authority housing estates in Ireland, including Finglas South.
Estates on the Edge: the Social Consequences of Mass Housing in Northern Europe. [Macmillan] Anne Power is Professor of Social Policy and Administration at London's prestigious London School of Economics and Politics. Edited quotes:
On the origins: "A self-fueling cycle of political ambition, political credibility, and political targets fed the boom in building. In Britain, they built 5,000,000 units in 30 years. It was a movement akin to a forest fire."
On why it failed: "The estates underlined the new fractures in societies, as well as reaffirming the stubbornness of recurring slum problems. Old slums were gradually being replaced and their endemic problems of bad living conditions, poverty, disorderly behaviour, crime, unemployment, and so on, were expected to go with them. The recurrence of deep social problems in relatively new social housing areas was unforeseen and alarming."
"Slums had always been the consequence of three factors - poor people, poor buildings, and poor management. Poor and unpopular social housing proved to be no exception."
On the solutions: "All five countries launched rescue programmes before problems or solutions were universally agreed."
"The social and organizational systems of modern large estates require constant intervention, supervision, and management, precisely because they were artificially imposed and lacked the more 'natural' free-flowing forms of organizations of smaller, more organic, more harmonious communities. In that sense, they are the most extreme form of urban development."
On the reason society cares at all: "The underclass is the living doubt in the prevailing values which will eat into the texture of the societies in which we are living."
And read about Anne Power in the Irish Times of 12 January, 1998:
'It was Irish "estates", such as Ballymun's high-rise housing, which alerted her to the existence in the world of "ghettos" without race. Until she examined the social conditions on Irish housing estates, Ms Power believed that racial issues were the prime cause of the varying degrees of stigmatisation suffered by the residents of estates throughout Europe and in US cities such as New York.
In the Republic, however, Power saw for the first time white people of similar background to the rest of society being stigmatised in an even worse way than people of colour and "foreigners" were in other countries. She came to the conclusion that it was the very fact of living on a particular estate which created the stigma.
In the same way as blacks were cordoned off in the US, Ireland is cordoning off white people with low skills who can't compete in the modern economy. The Irish case illustrates that it is the economy rather than race which creates ghettos," she believes.'
Irish Times writer Kathryn Holmquist points out that "the 1996 ministerial report on the heroin epidemic concluded that one of the greatest needs on troubled estates was for more sport and recreation facilities for youths. The previous government earmarked £20 million for this purpose. The current Government reduced this to £1.25 million in the recent Budget, while giving £20 million to the GAA for Croke Park and lowering tax rates in a way which favoured the better off. Independent TD, Tony Gregory, believes that the Government's refusal to grant the funding 'destroyed the one hope that a lot of communities had of getting something that would help the drug problem'. He agrees the Government can get away with such inaction as long as estates remain stigmatised, marginalised and ghettoised and the politically correct turn a blind eye."
The Slow Death of Great Cities? urban abandonment or urban renaissance [Anne Power and Katharine Mumford, the Joseph Roundtree Foundation, 1999]
Inner areas of Manchester and Newcastle - decline, abandonment, demolition that no matter how massive in nature somehow never elimates the problem, which spreads like a cancer as the blight infects the atmosphere and fear drives people in adjacent streets away. Zero value. Negative equity.
The authors identify way forward as well. In our overall review we hope to relate them to the recently announced (1 July, 1999) Irish grants for housing mangement initiatives and the conclusions of Social Housing In Ireland.
Infringement of Environmental Impact Assessment Directive 85/337 in urban development in Ireland
We write to ask you to examine the procedure used to assess the proposed redevelopment of Ballymun in north Dublin by Dublin Corporation in view of the fact that no Environmental Impact Assessment has been prepared for this development.
This development is part of the newly introduced integrated area plans (IAPs) for six areas within the Dublin Corporation authority's jurisdiction - Ballymun, Inchicore/Kilmainham, O'Connell Street, the north-east inner city, Liberties/Coombe, and the HARP (Historic Area Rejuvenation Project) area extending westwards from O'Connell Street to Collins Barracks) and that tax concessions are being provided for these developments.
The Ballymun development currently houses 20,000 people in high rise buildings constructed in the 1960's. It the stated intention to demolish these buildings and rehouse the residents. A Master Plan was drawn up and subject to an "environmental appraisal", the Irish authorities stating that this was sufficient examination.
The first phase of this redevelopment is comprised of 11 sites represented by 11 separate planning applications to the local authority. [Dublin Corporation Planning Register No: 3661 - 3665 of 98; 3726-3730 of 98; 2704 of 98; and others.] In total these applications comprise 750 housing units covering approximately 48 acres and with an estimated cost of IR£ 275 million.
We believe that the proposed development is of a scale and nature to require an Environmental Impact Assessment, notwithstanding the fact that each individual application may be beneath the threshold requiring such an assessment.
We would be most grateful if the European Commission would examine the facts of this case and determine if the local authority's recent notice of intention to grant permission for these applications without an environmental impact assessment is an infringement of the European Environmental Impact Assessment Directive 85/337.
Comment on Ballymun Regeneration First Phase Housing Environmental Impact Statement
It is beyond the resources of the appellants to assess and if need be to appeal all the applications which relate to the notices of intention to grant planning permission relating to the largest urban renewal in the history of the State - and perhaps in Europe.
Nonetheless, it is undeniable that each single application contributes to the demand on the infrastructure of the entire project just as each single project contributes to the diminution of the established amenities of the area that might, by piecemeal and subsequent applications, be eroded unnoticed.
We concentrate in this submission commenting on the Environmental Impact Statement on the first of 8 sets of applications by expanding on the two areas covered in our original appeals on Ballcurris and Poppintree projects - drainage and open spaces (see 4 and 5 below), and making some comments on other clear inadequacies in the EIS.
2. We have not received all the EIS documentation.
The following appendices to the EIS are missing:
1. Environmental Appraisal of the Ballymun Masterplan in the Dublin Corporation Area.
2. Public Consultation.
3. Maps of Extinguishment of Public Rights-of-Way under 1993 Roads Act.
We wrote to An Bord Pleanála about this on 27th September, asking for this documentation and time to consider it. We have not yet received a response.
3. The Environmental Impact Statement submitted is inadequate to comply with Directives 85/337/EEC and 97/11/EC.
The EIS submitted covers only the First Phase Housing under the Masterplan. The EIS is inadequate in that it does not consider the entirety of the development proposed. It should cover the entire Masterplan.
The Environmental Appraisal carried out and submitted as an appendix to the EIS on the first phase is also not an adequate EIS of the full redevelopment project. It is limited in geographical area to the Dublin Corporation area whereas the entire plan includes substantial development in Fingal County.
The Bord is obliged to carry out EIA of the entire regeneration project. It has not been supplied with the necessary EIS. All our further comments are made without prejudice to our reliance on this fact at any future date. Aside from it's inadequacy in terms of its overall scope, the EIS contains many instances of inaccurate or insufficient information, some of which we refer to below.
Appeals like this by the residents of Ballymun and the neighbouring estates and the consequent public disharmonies might indeed never have been required had there been a full Environmental Impact Statement and a rigorous Environmental Impact Assessment from the first. Our intervention in the planning process is to help alert the planning authorities to what we must term a break down in the planning system.
The appellants would like to clearly state that they are aware of the great need for the regeneration of Ballymun and the many false dawns endured by these residents. The appellants are entirely in accord with the policy of the Government and the applicant, Ballymun Regeneration Ltd., to complete the "virtuous cycle of economic regeneration".
Finally, while we have no doubt that An Bord Pleanala is well aware of the laws governing Environmental Impact Statements, we attach a letter from the European Commission to the Irish Authorities in relation to the Environmental Impact Assessment Directive and "project splitting" at Ballymun, specifically highlighting the issues of drainage and open spaces.
3.1 The Environmental Impact Statement fails to meaningfully consider alternatives.
3.2 Consultation in relation to alternatives.
Many tenants are unhappy with the manner in which the decision was made to demolish the flats, effectively without consultation. Only when the decision had been made to demolish all the flats was a form of "consultation" started. However, this was not a participative consultation process, as described in the attached observation from Robert Guillemot, our co-appellant.
A process which
¬? does not enable the consideration of alternatives by the community, and
¬? does not consider alternatives or additions proposed by local residents
is not consultation.
A good example of the latter is the issue of allotments, referred to below.
In this case what has been described as consultation has been a collection of techniques aimed
¬? primarily at seeking public support for the proposals, and
¬? secondarily at collecting data (allegedly) demonstrating such support.
The last time the tenants of Ballymun were consulted in a meaningful fashion was by survey, by Craig Gardner in 1993, and we enclose a copy of that report to inform the Bord's consideration of the issue.
3.4 Failure to consider impacts of alternatives
The social, economic and environmental impacts of the various alternatives have not been addressed.
The assessment of the project remains wholly insufficient to give any reasonable certainty that the development, if permitted, would not endanger the health and safety of the residents by way of inadequate infrastructure, particularly through inadequate surface drainage which is not detailed in any drawings and which relies on conditions precedent for these applications. The Wad River and the Wad River Diversion are part of the city wide drainage network excoriated by the Director of Ballymun Regeneration Ltd. (in a letter attached as an Appendix to our original Balcurris appeal) as "clapped out" and "past their sell by date". These drains are inadequate to cater for the additional surface water generated by the development with consequent negative impacts on many other residential developments adjoining these applications and on residents beyond the boundaries of the development site in clear contravention of the EU Directive on Urban Waste Water.
Surface water treatment is a vital consideration at Ballymun. Not only is the area traditionally a marsh land with springs rising at Balcurris but the proposed development will double the hard standing area and so substantially increase the flow of surface water that otherwise would have been reabsorbed directly into the ground.
This doubling effect is not true of sewage or of the water supply. The new Ballymun will be no more or less thirsty than the old, and its residents will produce no more sewage, regardless of the quality of the architecture.
Surface water is critical at Ballymun and the Environmental Impact Statement submitted for this application actually reduces the amount of information available in the original Environmental Appraisal as to how the developer proposes to mitigate this impact of the development.
At least the Environmental Appraisal accepted that the demolition and reconstruction at Ballymun was a single project, however inadequately they addressed the concerns of residents and interested parties. The EIS now submitted restricts 10.2.2. (Characteristics of the Development, Predicted Impacts and Mitigating Measures) to the first 13 applications - one of eight sets of individual applications that will make up the regeneration of Ballymun detailed in the Ballymun Masterplan.
It is not possible to deal with the drainage if the examination is limited to these 13 housing sites. The increase in additional unmitigated surface water discharge to the Wad River is given as a 4% increase for the first 13 applications alone. We are given no idea what percentage this 4% is of the whole increase proposed in the catchment by the eight phases detailed in the Masterplan. Pro rata, overall increase to the Wad River would thus appear be in the order of 32% [4% per phases with 8 phases].
Nor does the rewritten section 10.2 in the Environmental Impact Statement give satisfactory answers to the concerns expressed in our appeal to An Bord Pleanala based on the section 10.2 in the original Environmental Appraisal.
The "attenuation ponds" of the earlier Environmental Appraisal which our appeal showed had not been designed or located in the development plans have still not been designed or located in the development plans and appear now to be covered by the statement "In addition BRL proposes to incorporate phased attenuation facilities in future open space areas".
Where in the much reduced open spaces of Ballymun are such facilities to be located? What is their design? What effect will they themselves have on the receiving environment?
The original Environmental Appraisal stated clearly that the attenuation ponds were to "neutralize" about 50 hectares of the increased run off. 50% of the balance was to be mitigated by a "design target". What happened to this "design target" - or did it never exist? The remaining 50% of the balance was a "negative impact requiring additional mitigation measures off site".
Both the Environmental Appraisal and the EIS agree that off site "the capacity of the Wad River is not adequate for current inflows and the adjacent areas are regularly flooded" [the same wording is used both in the Environmental Appraisal and EIS].
The revised drainage arrangements still issue into the Wad River and still will result in a doubling of the surface water flow. There is no mitigation involved in moving the exit point for 20 hectares of drainage to a less critical junction of the Wad River when it is the Wad River itself that is inadequate to take the existing flow.
We attach a copy of our letter to the relevant sanitary authority requesting a meeting to clarify the matter. We have had no reply to date. We also therefore refer to our earlier Observation on the appeal by residents to a grant of permission at Poppintree Park in which we stated: "We also draw An Bord Pleanala's attention to the fact that our request to Ballymun Regeneration Ltd. for copies of technical reports relating to infrastructure was refused and that, in spite of repeated requests and our searches of all relevant files of Dublin Corporation including each of the 12 other applications relating to the subject site, we have been unable to find a copy of the Sanitary Engineer's Report for this project."
The development is premature until the city wide system of surface water drainage is brought up to the standard required by the Urban Waste Water Directive and the full proposals for the mitigation measures designed by Ballymun Regeneration Ltd. are made available for public scrutiny.
This EIS has actually REDUCED the amount of information available to assess the project by confining itself in detail only to the first 13 planning applications. Even within this first phases details relating to drainage must be supplied as part of any assessment and can not be left to conditions precedent.
No permission can be given until the proposals outlined in the Ballymun Masterplan have been subject to an EIA and until it can be demonstrated that the city wide drainage infrastructure is capably of taking the increased load without further risk to property and public health through flooding.
5. Open Spaces
The proposed development would contravene the 1993 Dublin Development Plan by eliminating 43 hectares of "residual" public space and extinguishing 56 hectares of the Dublin City Public Parks listed and maintained by the Environment and Culture Department of Dublin Corporation. From our examination of the proposals we believe that there will remain only 26.4 hectares of public space within Ballymun.
If Ballymun Regeneration Ltd. is permitted to proceed with its proposals as detailed in the Ballymun Masterplan, the Environmental Appraisal, and the Environmental Impact Statement the overall amenity space available for the residents of Ballymun will be reduced such as to render the ratio of public space vs. residents a material contravention of the 1993 Dublin Development Plan which requires 2 hectares of open space per 1,000 population. The Development Plan thus would requite 52 hectares of open space for the population of 26,000 where we can find only half of that area - 26.4 hectares.
The EIS as submitted does not quantify the loss to the residents of Ballymun and neighbouring areas of public spaces and Public Parks as a result of the proposed redevelopment of their homes.
Leaving aside for the moments the areas of infill and curtilege which themselves are under increasing pressure throughout North Dublin, two Public Parks are within the boundaries of the proposed Ballymun Regeneration Ltd. development. One - Poppintree Park - is to be reduced from 26.3 hectares to 16 hectares. The other, the part of Sillogue Park that lies within the boundaries of the Ballymun Regeneration Project, is to have the entire area of 40.6 hectares eliminated to be replaced at another location by 8 hectares. It is thus proposed to extinguish 50.9 hectares of Public Park.
This EIS refers only to the "loss of public major open public space due to Phase I housing (approximately 9.3 hectares)". We believe the total loss of listed Dublin City Parks areas alone represent a loss of more than times this size - 50.9 hectares, an area more than twice the size of the Botanic Gardens [20 hectares] and more than 10 times the size of Merrion Square [4.75 hectares].
Although the Environmental Impact Statement makes no calculation of the "residual lands" - public spaces not within Dublin City Parks, the earlier Appraisal states that the existing "residual" open space areas comprise approximately 43 hectares. [Receiving Environment 6.2.2]. These too are to be extinguished, giving 93.9 hectares of lost open spaces.
By dividing Masterplan into a series of EIS each of which is concerned only with a small part of the proposal the impact of the development can not be assessed.
Finally, no reference is made to the proposed green field development at Meakestown where a fgreen field site of 37 hectares will be reduced to 7 hectares or to the reduction in size of the public open spaces at neighbouring Santry Woods where 69 hectares acres of public access will be reduced to 29 hectares. No calculations have been made in the EIS as to how these proposal will affect the radio of population to amenity space.
5.1 Poppintree Park
Poppintree Park was "developed in the late 1970s and early 1980s mainly as a sports ground for football, tennis, and basketball". The official publication of Dublin Corporation notes that "the park also has significant tree plantations and is due for substantial redevelopment as part of Ballymun regeneration Project."
Much is made in the EIS of the poor quality of the open spaces at Ballymun. The document states "the lack of development and/or maintenance is due to their design and has been subject to vandalism and underuse," referring to "major public open space areas with no intrinsic landscape or amenity value." These are the very areas that during the initial planning and development of Ballymun were presented to the public as opportunity for landscape and amenity. Indeed the avenue at Poppintree Park, the wooded area at the south east corner, the spacious playing pitches - however ill drained - are proof that Ballymun's landscape and amenities could be as fine as in any European capital.
The public facilities at Poppintree Park include a pavilion with changing rooms of a high standard. There are not made available to the residents through poor management and the adjacent tennis courts are a tribute to poor maintenance. To quote the Craig-Gardner Report mentioned in our initial appeal: "It is as if the authorities have found the scale of the problem overwhelming and have given up altogether."
The "bleak and featureless landscape" and the abandoned facilities are due to management rather than design and the arguments proposed in the EIS to justify their removal are a particularly cruel touch for the "city of false dawns".
The residents are outraged that the "substantial redevelopment" includes reductions of this scale of Poppintree Park. While certain lands (lands now surrounding for example the power pylons which are to be removed from the south east corner of the park) are a necessary price of the redevelopment, danger is focused on the proposal to excise the south west corner of the park, where the trees are most mature and a fine public park entrance is graced by gates relocated from Glasnevin Cemetery. A "stand alone" housing proposal is detailed in the Masterplan beside this location and all the edges of the Park are to be built upon.
Neither the EIS nor the Masterplan nor the Environmental Appraisal gives a breakdown of the locations of the various elements of the mixed housing rightly proposed in the Masterplan. Residents may therefore be justified in their fears that the excised section of their park will because of the quality of its location and convenience to access become part of the private part of the redevelopment and be denied to them.
5.2 Sillogue Park
Sillogue Park, (known locally as the "Naul") part of which comes within the boundaries of the proposed regeneration, is 80.4 hectares of farmland purchased in the early 1970s to provide recreational facilities for the "burgeoning local population". Twenty playing pitches were provided and a nine hole golf course developed. The construction of the M50 motorway in the mid 1990s divided the Park. The golf course was extended on the northern side of the M50 while 46 hectares of playing pitches remained adjacent to Ballymun.
The Masterplan states about Sillogue Park: "A minimum intervention would see the park developed as a properly landscaped amenity park - however this would not greatly benefit the people of Ballymun which suffer currently from an oversupply of poorly developed open space." In view of the proposed reduction in these "poorly developed" open spaces in the same Masterplan, this argument appears almost humorous.
Elsewhere in the Masterplan [M50 page 29] the authors are more piquant and equally illogical. "The loss of such green fields is philosophically undesirable but an inevitable consequence of planning the M50".
In fact it appears that the part of Sillogue Park inside the M50, all of which is within the boundaries of the BRL study area, was omitted entirely from the EIS. In the calculations given by BRL they state there were "43 hectares of major space in the Ballymun Master Plan". By adding to that sentence the qualifying phrase "within Dublin Corporation boundaries" the loss of 46 hectares of the Sillogue Dublin City Public Park was concealed as this area, while within the boundaries of Ballymun Regeneration Ltd., is within the boundaries of Fingal County.
Further, Sillogue Park is listed by the Dublin City Parks Department as containing "wildlife". What is the nature of the "wildlife" in Sillogue Park. The nature and location of this wildlife is not specified in the Masterplan, the Environmental Appraisal, or the EIS which states that "no wild birds or mammals were recorded on these sites". [The Meakestown Environmental Impact Statement suggests that foxes and rats - which are mammals - are present as well a substantial number of birds noted in both the Meakestown and Santry EIS which cast doubts on the accuracy of the Ballymun EIS in relation to wildlife.]
The failure to note any wildlife anywhere else within the Environmental Impact Statement area highlights the importance of any wildlife that might exist within at a location like Sillogue Park. No judgement can be made about the proper planning of Ballymun until the potential loss of biodiversity - if any - and the necessary mitigating measures are subject to an EIS.
The future of the Sillogue Dublin City Public Park has variously been indicated in the Integrated Area Plan in the Masterplan as industrial/residential with the area along Ballymun Road reserved for "Tourist Heritage Leisure" [Masterplan page 11], reinforced three pages later by the "possible leisure complex" on the southern edge (Masterplan 14).
However, the advertisement we attach (which was only recently published) shows that the entire area of Sillogue Park on the Ballymun side of the M50, playing pitches and all, is now to be given over to a Ballymun Business and Technological Park and the developer is required to supply 8 hectares of replacement sports facilities.
There is no mention of the loss of these open spaces in the EIS submitted with this application other than in section 6.2.3 (Characteristics of the Proposal) where it is stated that "Other private developers will have to provide additional public open spaces on their lands."
The proposed 8 hectares is not in addition to the development area. It is to replace 8 hectares of the 46 hectares of a Dublin City Park that is to be extinguished by an industrial development.
Not only can the matter of the overall ratio between residents and open space not be addressed this way, but it is difficult not to feel that the proposed 8 hectare "replacement" for Sillogue Park will be at a greater distance that the existing facilities. Would not proper planning and development require that the amenity facilities be in closer proximity to the residential areas than the industrial park?
5.3 Overall Loss Of Open Spaces
The loss of open spaces at Ballymun due to the redevelopment appear to be the existing "residual" open space areas comprise approximately 43 hectares and the Public City Parks which are to be reduced by 50.9 hectares, giving a total loss of public space of 93.9 hectares and leaving only 26.4 hectares (Poppintree 18.2; Balcurris 5; and Coultry 3.2) to cater for a direct population of 26,000, not even considering the population of adjacent areas which have used these facilities to date.
It is very difficult for our organisation not to feel that the proposed reduction in Public Parks alone would not have been met with the most ferocious outcry if the subject of the proposal had been even a 12 hectare park like Herbert Park in Ballsbridge.
The loss of substantial parts of two Dublin City Parks is far too serious a consequence of the proposed redevelopment to be omitted from consideration on the grounds that there are "too many under utilised open spaces in the Ballymun." Even the smaller areas outside the Public Parks - such as Balcurris - serve purposes not only within the Ballymun community but for much of the population of North Dublin.
We drew the Boards attention to the high degree of maintenance on the pitch at Ballcurris that is maintained by Ballymun United. The Masterplan states "There are two pitches in Balcurris Park, one Gaelic and one soccer. Because of the problem of wandering horses only the soccer pitch is used. Again these soccer pitches suffer from poor drainage which can limit use." [13. Amenity / Play]
But walk on across the two pitches, towards the city, and in some mysterious way the ground changes. It become silky smooth, filled and rolled and fertilised. This is the section of the "park" where Ballymun United train. Ballymun United maintain the ground.
The rest is Corporation ground made worse than useless - nay dangerous - by ill management. although the grounds is unfenced or differentiated in any other manner from the unmaintained open space at this location. It is not socially disruptive misfits on horses that should be blamed - it is the administration in Dublin Corporation who fail to reach standards that are demonstrably viable.
Sillogue Park has 24 pitches, many of them in regular use. The Masterplan points out that many of these pitches are used "by clubs from outside Ballymun", as if that relieves the developers from providing alternative sites when in fact it indicates how crucial the Dublin City Parks of Ballymun are to a very wide catchment area.
It is particularly disheartening to read of the vision of Dublin Corporation in the 1970's who purchased some of this land specifically for the "burgeoning local population." Fingal Council states clearly in its analysis of Santry proposal that there are no funds available for the purchase of public lands any more making Dublin Corporation's foresight all the more justified as the population of the area has indeed burgeoned. Not only has it burgeoned within the existing developed area of the city, but the Meakestown Environmental Impact Statement notes that in the adjacent northern "country" areas of Dublin - the Ward and Dubber - the population has grown by 18.7% in the period 1991 to 1996.
The proposed development at Santry adjacent to Ballymun to the East will add 3,500 residents in 1100 further units. The Meakstown proposal under consideration by Fingal County Council will add an additional 2,500 residents in 766 units. In 7.3.3. of the Meakestown EIS, the authors comment "It is likely that the proposed development will result in an increased number of people using the facilities available, and that these facilities will benefit from the additional revenue, It is also likely that the proposed development will spur development of further facilities and services, thus increasing the range of facilities available to the current residents." What they do not say is that the proposed development will also increase the pressure on the existing amenity facilities which are being drastically curtailed at Ballymun and Santry.
The purpose of this submission is to highlight the inadequacy of the Environmental Impact Assessment submitted with the current application. The matter of open spaces available to the community are of critical importance, even to the very limited number of applications before the Board.
The 1993 Dublin Corporation Development Plan states that public open spaces "shall be provided at a minimum rate of 2 hectares per 1,000 population for all types of development." The Population of Ballymun is currently 26,000, giving a public space requirement of 52 hectares. Provision appears to have been made for only 26.4 hectares of open space, exactly half that required by the 1993 Development Plan.
How can it be determined if the regeneration of Ballymun conforms to the 1993 Dublin Corporation Development Plan if the only figure supplied in the EIS is that 9.4 hectares of open space will be removed for these first applications?
An EIS must fully quantify the amount and proposed use of land that is acquired through the extinguishment of any area of a Dublin City Public Parks as well as its effect on the catchments' population.
We would suggest that the developers must supply a detailed schedule of the open spaces for public amenity in relation to the overall project in order to ensure that the development is not, as it appears to be, a material contravention of the 1993 Dublin Development Plan.
6. Air Pollution
The EIS fails to give any meaningful assessment of the current air pollution situation in the area. There is no consideration of traffic-related air pollution issues at sensitive locations, and in fact no information on air pollution measurements at all.
The EIS takes no account of the embedded energy in the existing and proposed buildings. As a result it does not assess the energy consequences of the proposal, although this should have been assessed in comparison with other alternatives.
We believe that fundamental issues have not been properly addressed because the invaluable tool of an Environmental Impact Assessment to examine the overall impact of the demolition and reconstruction of the homes of 26,000 people. Without this examination it is not possible to determine if the proposed development is in accordance with the 1993 Dublin Development Plan. It is not possible to state accurately if the development will through inadequate infrastructure pose a danger to public health. Mitigation measures can not be effective after the development has taken place.
We urge the Board to require a full Environmental Impact Assessment of the proposed regeneration of Ballymun before giving development consent to any part of the project, in accordance with the European EIA Directive and the Irish implementing regulations
Planning Register No: 3661 - 3665 of 98; 3726-3730 of 98; 2704 of 98; and others
We refer to the separate applications for which you have issued notices of intention to grant permission relating to the redevelopment of Ballymun.
We believe that the proposed development is of a scale and nature to require an Environmental Impact Assesment, notwithstanding the fact that each individual application may be beneath the threshold requring such an assesment.
We have registered a formal complaint with the European Commission that your recent notice grant of permission for these applications is an enfringement of the European Environmental Impact Assesment Directive 85/337.
We therefore believe that your notice of intention to grant these planing permissions is legally in error. We would therefore request you not to issue the grants in the event that the decisions are not appealed.
We attach a copy of this complaint and request an urgent reply so that we may further consider out position if necessary.
Friends of the Irish Environment is a network created by conservationists in Ireland in order to monitor the full implementation of European environmental law, to work for changes in the Irish planning laws, and to pursue concerns and cases in both the built and the natural environment based on the principles of sustainable community development.