Many thanks for your letter of concern over Friends of the Irish Environment's intervention in the regeneration of Ballymun.
I am surprised you did not know about our involvement with the community there and the outcome. I wrote to you about this matter on 13 May in a covering letter to a printed copy of our first joint appeal with a resident of Ballymun on the day which we lodged that appeal. I attach a copy of this letter.
A further copy of the appeal was sent by e-mail to the Green Party National Office on 15 May, 1999.
The Ballymun Forums copied their letter to Friends of the Irish Environment to you on 19 May, 1999. From our point of view perhaps the most disturbing aspect of the case is that you went to your meeting on 26 May in the full knowledge that our representations were the cause of some disquiet without contacting us for our side of the story.
I do not know if the Ballymun Forums have shown you our reply to them outlining the residents position we are supporting and the research we have done to date. I am attaching this, which is also available on our website in the interest of openness, as are all replies we make to representations we receive, including this letter.
Both our fellow appellant, Robert Guillemot 01 8622106, and the spokesperson for the joint residents groups involved, Vincent Magozoli 01 8362712- as distinct from the BRL sponsored Forums - are available to answer any questions you might have.
We are of course acutely aware of the desperate need for rehousing in Ballymun and the many false dawns the residents have endured, but I am sure you would agree that not doing the job properly will only cause the residents more misery in the long run and I urge you to examine the case that we have presented for an Environmental Impact Statement with some care as I know you have the best interests of the residents at heart.
As I said to you in my letter of 13 May, "We know that our appeal will be characterised as vexatious and trivial but there is a matter of great substance contained within with very serious consequences for a great many people."
Something has gone very wrong in the planning process here which we believe also has wide implications for pre-mature development throughout the north Dublin fringe and elsewhere in urban and urban agglomerates throughout Ireland.
Nature of this contribution
Resources to enable particpation.
Friends of the Irish Environment
Disjointed nature of planning
Matters to be covered by the guidelines
Size of Dublin
Economics and local economies
Nature of this contribution
Friends of the Irish Environment make these comments as initial proposals in relation to the drawing up of the guidelines. We see the consultation at this stage of the plan as analagous to the scoping of an Environmental Impact Statement. In that context, our comments are of a general nature and set out some (but not necessarily all) areas to be examined and issues to be addressed in the guidelines. We have not set out a full list of issues to be dealt with but instead some of the issues which we believe might otherwise not be fully addressed and some of the conceptual tools we believe to be of value in addressing them.
We have not gone into great detail on any of them, but instead referrred to publications or other information sources where we are aware of them. Many of these publications give both useful examples and accessible graphics. We believe these would be of considerable value in communicating the guidelines to the decision-makers, who almost without exception, are not professional planners. Although they are advised by planners, all final decisions in relation to planning issues in Dublin are made either by non-professional administrative staff or elected representatives
The only information we have on the process of drawing up the guidelines is the glossy leaflet (undated) entitled "Public Consultation Briefing Document and Questionnaire". We would be grateful for a copy of the document(s) setting out the structure and the process which will be used to draw up the guidelines and the terms of reference for this.
Resources to enable particpation.
In common many many environmental and community organisations, we do not have the resources to fully engage with this kind of a consultation process. We would be happy to participate in greater detail in the future consultation stages of the process, and we would be grateful if you could indicate what resources, if any, will be made available to environmental and community groups to enable them to participate effectively.
Friends of the Irish Environment
Friends of the Irish Environment is a grassroots network of Irish environmental groups and individuals. It was formed in the autumn of 1997 as a loose federation with a core group of persons as a steering committee.
The Friends network brings interested persons from around the country onto its steering committee. A main function of the network is to assist local groups through letters of support and strategic advice of all kinds. Local groups retain their own group names, identities and special interests, while calling themselves "associates" of Friends of the Irish Environment. Agenda 21 is fully endorsed by Friends of the Irish Environment.
oWe support a root and branch reform of Irish planning laws. We believe that the Planning Acts must contain clear, legally binding land use principles based on the concept of sustainable development. We support and monitor the full implementation in Irish law of European environmental legislation, with a particular focus on the environmental impact assessment directive and the habitats directive.
oWe fully support the maintenance of areas of scenic importance in the Irish landscape and the maintenance of traditional economic activities which sustain the population.
oWe support the existing conservation designations and zonings in Ireland, including national monuments, listed buildings, natural heritage areas, special areas of conservation and areas zoned for amenity purposes in local authority development plans.
oWe support the idea that urbanisation should not be at the expense of the countryside; the town-countryside boundary must be maintained. The Irish countryside should not be turned into a suburban subdivision.
oWe support the traditional right of access to the land by the people of Ireland, as well as the right of public access to the foreshore.
oWe support the maintenance of traditional Irish nucleated settlements, including villages, towns and hamlets.
oWe support the retention of agricultural land in agricultural use, and the retention of rural character, including old hedgerows and existing stone walls.
oWe support non-intensive agriculture, with an emphasis on organic farming.
oWe support the rejuvenation of the natural woodlands of Ireland with native species by means of appropriate forest design, to avoid monoculture in order to enhance the landscape and enhance the sustainable use of the woodlands.
oWe also support the sustainable use of the sea, including the maintenance of wild fish stocks.
oWe support owner-occupied and social housing, while opposing investment-led housing.
oWe fully support sustainable tourism that favours keeping revenue in the local community where it is spent. We oppose environmentally and socially destructive tourism projects.
oWe support coalitions of locally owned businesses in order to gain more control of the tourism sector, both economically and environmentally.
oWe also support non-car oriented transport, both public and private: buses, train, community transport, taxis and bicycles.
oWe support small scale interventions in the landscape, as well as the use of traditional materials in residential building.
oWe oppose the introduction of large, centralised out of town shopping centres, and support policies to maintain and enhance the viability of the local, family owned retail sector.
Friends of the Irish Environment welcomes the proposal to draw up Strategic Planning Guidelines for the Greater Dublin Area. However, we note with great concern the largescale rezonings which have taken place recently in the Dublin area and the further extensive rezoning proposed recently in Fingal. These proposals have failed to comply with the basic landuse principles enunciated in the Dublin Transportation Initiative Final Report (1995) and D.T.I. Land Use Planning Report (1995) and the Bacon Report. We believe it is urgent that a moratorium be put on these rezonings and proposed rezonings.
Disjointed nature of planning.
Local authorities in Dublin regularly make planning decisions with no reference whatsoever to the implications for adjoining areas in the jurisdiction of another local authority. Fingal County Council rezoned land in Santry Demesne without even seeing a map of the adjoining Dublin Corporation land to the East, South and West of the Demesne, not to mind considering the relevant zoning and development plan objectives. The same has happened in the current round of rezonings. The guidelines must address this. The current legal provisions in this area are not working.
Matters to be covered by the guidelines
The European Charter of Sustainable Cities and Towns, of which we understand a number of Dublin local authorities are signatories, emphasises the global context within which urban planning must take place:
"We understand that our present urban lifestyle, in particular our patterns of division of labour and functions, land-use, transport, industrial production, agriculture, consumption, and leisure activities, and hence our standard of living, make us essentially responsible for many environmental problems humankind is facing."
In this context, it is essential that the sustainability issues be fully and meaningfully addressed in the guidelines. Aside from the fundamental texts on sustainability, we have found that the report by Friends of the Earth Europe (1995) entitled Towards Sustainable Europe, gives a good basis for this, developing the concept of environmental space as a valuable tool for thinking about sustainability and how to realise it in practice.
Size of Dublin and relationships with the rest of the country.
We believe that Dublin's size is out of all proportion with the rest of the country, and that its overgrowth is having negative consequences both in Dublin itself and elsewhere. It is vital that the degree to which Dublin should grow if at all is addressed in the study, and that the current growth of the city is not taken as a given outside the scope of the guidelines.
Whitelegg (1993) gives a good overview of many of the environmental issues associated with traffic, giving a sound basis for land use and planning policies.
The feed-back relationship between transport and urban form is discussed and analysed effectively by Newman and Kenworthy (1989). Among the clear conclusions are
¬? that fuel consumption, air pollution etc. are linked to density, and also
¬? that fuel consumption etc. are linked to average urban speed.
The second conclusion is important. It is clear that the "free-flowing traffic" goal of much road engineering leads to increased traffic levels involving higher pollutant emissions and fuel consumption rates per capita.
Engwicht(1992) discusses land use issues suggests that urban space can be divided into transport space and "exchange space" - i.e. space used for human (inlcuding commercial, social etc.) interaction. An efficient city uses as little space for transport as possible.
It is vital not to forget the large and growing role which freight transport plays in overall transport volumes. The concept of food miles, developed by the Wuppertal Institute, (see Whitelegg,1997) is a useful technique to reveal the growing contribution of freight traffic to total transport volumes. The need to reduce freight volume-distances must be addressed as part of urban planning. As such, the facilitation of mixed uses and local production for local consumption is essential. After the Great Earthquake in Lisbon, the new planned district Baixa was laid out and different areas allocated to various uses. For example, the tanneries were beside the leather-workers, who were beside the book-binders, who were beside the printers, etc. The meticulous transport-reduction policy, based on common-sense, seen here on an micro-scale provides a good example of how effective planning can reduce the need for freight transport
Urban food production is a core issue in sustainability. Issues to be addressed in Dublin include
¬? The extent to which urban land in private gardens or public open space is effectively unused, and could more profitably be used for productive purposes which would retain their green character.
¬? The importance of protecting the horticultural industry in North County Dublin, and encouraging its revival and expansion.
Urban agriculture issues tie into transport, as indicated above. It also increases food quality and security, particularly for the disadvantaged, and strengthens local economies. As well as the recent UNDP report (Smit et al., 1996), an excellent starting-point for information is the City Farmer website (ref.below) which contains or links to information on all aspects of urban agriculture including planning issues. Garnett (1996) addresses the British situation. Dublin's low density pattern of settlement allows great possibilities for the kind of growth in urban agriculture which Smit et al. document as a defining feature of cities all over the world in the last 20 years.
The guidelines should include means to ensure the long-term protection and compatible use of green belt land in Dublin for recreation, forestry, horticulture, etc. as appropriate, and any necessary changes to legislation should be proposed.
The guidelines must emphasise the importance of reafforesting urban land. We refer to conference proceedings in relation to urban forestry (Collins, 1996).
We are sympathetic to the recommendation in the Bacon report that urban densities be increased, and refer to work by Newman and Kenworthy (1989) quoted above. However, in this context we would emphasise the importance of addressing the issue of the amount of space given over to roads and parking (see Engwicht, 1992) in addressing urban density. We emphasise also that unpaved space in Dublin serves important functions in improving the quality of the built environment and has great potential for urban agriculture and urban forestry. Higher density should be first at the expense of road and parking space rather than at the expense of open space (especially as a prime purpose of it is to reduce private motor vehicle use).
Economics and local economies.
It is vital that the issues of the role of planning in strengthening local economies, particularly in the poorer areas of Dublin be addressed. Douthwaite's book Short Circuit (1996) does not go into planning issues in any great detail, but discusses many of the kind of local economic initiatives which the planning guidelines should seek to favour and facilitate.
The guidelines must address the fact that Dublin is using as much water as it can extract from its catchment without environmental degradation (in fact, possibly already too much).
The guidelines must address the issue of provision for horses in the city. Keeping horses is a long-standing aspect of Irish culture which knows no class or cultural boundaries. Planning in Dublin has failed to make any provision for horses in urban areas, (whereas it has done everything possible to provide for motor traffic for example). The guidelines should address the possibilities for making sensible provision. We suggest the matter be discussed with the horse-owners' associations in various parts of the city. We are aware of the association in Ballymun, and of the horse centre being set up in Ballyfermot
City Farmer website: http://www.cityfarmer.org
Collins, K., 1996, Proceedings of the Second National Conference on Urban Forestry, Limerick
Douthwaite, R., 1996, Short Circuit: strengthening local economies for security in an unstable world, Lilliput Press, Dublin
Dublin Transportation Initiative, 1995, Final Report and Land Use Planning, Stationery Office, Dublin
Engwicht, D., 1992, Towards an Eco-city: Calming the traffic, Envirobook, Sydney
Friends of the Earth Europe, 1995, Towards Sustainable Europe The Study, Friends of the Earth, Brussels
Garnett, T., 1996, Growing food in cities,A report to highlight and promote the benefits of urban agriculture in the U.K., National Food Alliance, London
Lowe, Marcia, 1989, The Bicycle: Vehicle for a small planet, Worldwatch Paper 90, Worldwatch Institute, Washington D.C.
Newman, P., and Kenworthy, J., 1989, Cities and Automobile Dependence, an International Sourcebook, Gower, Aldershot
Newman, P., Kenworthy, J., and Robinson, L., 1992, Winning back the Cities, Australian Consumers' Association, Marrickville
Smit, J., Ratta, A., and Nast, J.(eds.), 1996, Urban Agriculture: Food, Jobs and
Sustainable Cities, Habitat II Series, United Nations Development Programme,
Whitelegg, J., 1993, Transport for a sustainable future the case for Europe, Bellhaven, London
Whitelegg, J., 1997, Critical Mass, Pluto Press, London