Report on Pre Draft Public Consultation. Navan Local Area Plan 1 Johnstown/Athlumney

Transcription

1 Report on Pre Draft Public Consultation Navan Local Area Plan 1 Johnstown/Athlumney June 2010

2 1.0 INTRODUCTION 1.1 Preparation of a Local Area Plan for Johnstown/Athlumney (Navan Local Area Plan 1) The Navan Development Plan was adopted on the 2 nd and 3 rd of November 2009 by Meath County Council and Navan Town Council respectively and is the primary instrument available to the Planning Authority to ensure that future development in Navan takes place in a planned, co-ordinated and sustainable manner over the coming years. A number of framework plan areas and this local area plan (LAP) area were designated in the Navan Development Plan. This LAP relates to lands at Johnstown/Athlumney adjoining and including St. Martha s College to the south east of the town. The area lands extend to 35 hectares and in accordance with the Navan Development Plan land use zoning map is intended to accommodate community, educational, residential and recreational facilities. 1.2 Legislative Background and Requirements The purpose of this document is to report on the outcome of the pre-draft consultation phase as set out under Section 20(1) of the Planning and Development Act, Section 20(1) states that a planning authority shall take whatever steps it considers necessary to consult the public before preparing, amending or revoking a local area plan including consultations with any local residents, public sector agencies, non-governmental agencies, local community groups and commercial and business interests. 2.0 PRE-DRAFT CONSULTATION PHASE The non- statutory pre-draft consultation phase comprised of the following: 1. Preparation and publication of a strategic issues paper for the LAP area which give a broad overview of the main issues that arise in the area encompassed in the LAP and to indicate options and possible solutions to these issues. The purpose of this document was twofold; to notify the general public and interested parties of the intention of Meath County Council/Navan Town Council to prepare the LAP and to consult the public. The document was on display at the following locations: Meath County Library/Navan Branch Library, Railway Street, Planning Department Meath County Council, Abbey Mall, Abbey Road, Navan Town Council, Watergate Street, Johnstown Shopping Centre, Bailis, 2. A number of local community groups and organisations including residents associations were directly issued with a copy of the strategic issues paper, which included details of how to make submissions to the Planning Authority. The list of groups is detailed in Appendix 1 of this report. The pre-draft consultation phase commenced on the 22 nd March 2010 and concluded on the 19 th April A total of 20 written submissions were received during the display period of the strategic issues paper; 17 of these related to the preparation of the draft LAP and 3 related to environmental screening documents. The statutory phase of the LAP process will commence with the publication of the Draft Local Area Plan and there will be an opportunity to make statutory submissions when the Draft Local Area Plan is published. 1

3 3.0 ENVIRONMENTAL SCREENING 3.1 Strategic Environmental Assessment A local area plan must contain information on the likely significant effects on the environment of implementing the plan. A Strategic Environmental Assessment (SEA) is not mandatory for this LAP as the plan area would cater for a population of less than 10,000. A screening exercise was carried out to assess the likely impacts that the implementation of the plan would have and the screening exercise indicated that SEA was not necessary. The screening document was sent to the relevant prescribed bodies; the Minister for the Environment, Heritage and Local Government; the Minister for Communications, Marine and Natural Resources; and the Environmental Protection Agency. The Department of the Environment, Heritage and Local Government made a submission regarding the SEA screening report which detailed the nature conservation and architectural heritage recommendations of the Department as follows: Nature Conservation: The submission notes the SEA prepared in advance of the draft LAP which concluded that SEA is not necessary. It notes that the LAP area consists of mainly agricultural land with extensive hedgerows and mature trees and containing St. Martha s College. A river/stream crossing the LAP area is a tributary of the River Nanny. Downstream, the River Nanny estuary and shore is designated as a candidate Special Protection Area. It is stated that depending on how the lands are developed there is potential to impact negatively on the natural heritage, particularly from the planned riverside walk and the removal of hedgerows and trees. Architectural Heritage: It is stated that the new LAP could have a significant effect on the architectural heritage of the locality. It is architectural heritage which should be taken into account in Strategic Environmental Assessment (SEA) rather than protected structures or Architectural Conservation Areas (ACAs) as set out in the SEA screening report. The development of a plan continues until the formal adoption and until that time options, including those relating to the treatment of the architectural heritage of the locality, are available and therefore subject to SEA. It is stated that new development should enhance the local environment and contribute to creating a place of distinction. The development of an architectural framework for the area to guide future development can help ensure good quality urban design which will enhance the public realm. The contribution of the built heritage of the area to its local sense of place and identity may assist in this. The new plan should attempt to make use of all features of built heritage merit in the locality to engender an evolving new identity as a familiar and recognisable place. It is stated that this goes beyond taking into account the existence of protected structures or ACAs. The Environmental Protection Agency made a detailed submission which referenced the SEA screening document and a range of information which should be taken into account in preparing the LAP. The submission notes the position of the Planning Authority in respect of the need for Strategic Environmental Assessment (SEA) of the proposed LAP. It advises that any future variation to the Plan should be assessed to determine if it would have significant effects on the environment. It states that in proposed the plan, adequate and appropriate infrastructure should be in place, or required to be put in place, to service and development proposed and authorised during the lifetime of the Plan. In particular, adequate and appropriate waste water treatment, water supply, surface and storm water, transport, community services and amenities and waste management should be planned and phased to address any current problems or deficits and to reflect predicated increases in population. The submissions refers to the responsibilities and obligations of the Council in relation to environmental legislation noting that it is a matter for the Council to ensure that the requirements of national and EU environmental legislation are complied with. The LAP should 2

4 provide for the inclusion, where appropriate, of the policies and recommendations of the Meath County Development Plan (and associated SEA and appropriate assessment), the Greater Dublin Regional Planning Guidelines and FEMFRAMS. The submission reminds of the obligation to give notice to the Minister for the Environment, Heritage and Local Government and the Minister for Communications, Energy and Natural Resources where appropriate under the SEA regulations. The requirements of Article 6 of EU Council Directive 92/43/EEC (the Habitats Directive) in respect of appropriate assessment are also highlighted and links to relevant information sources are provided. The submission identifies a number of issues which should be addressed in the LAP, including: Appropriate assessment screening; Cumulative effects and in-combination effects of other plans/programmes/projects in particular the Navan Development Plan; Flood risk assessment and management; Landscape character assessment; Adequate protection of designated and non designated conservation sites, ecological linkages/corridors and provision of buffer zones from development; Achievement of water framework directive targets by 2015; Water; Biodiversity; Air, noise and climatic factors; Energy conservation/renewable energy; Transportation; Infrastructure planning; Waste management; Urban waste water discharge licensing; Environmental impact assessment; Strategic environmental assessment Detailed guidance is provided in respect of the above issues. 3.2 Appropriate Assessment Article 6(3) of European Council Directive 92/43/EEC (known as the Habitats Directive) requires competent authorities to undertake an appropriate assessment of any plan or project not directly connected with or necessary to the management of a Natura 2000 site (i.e. sites that are Special Areas of Conservation or Special Protection Areas) but likely to have a significant effect thereon, either individually or in combination with other plans or projects. An appropriate assessment screening was carried out for this LAP which was circulated to the Department of the Environment, Heritage and Local Government. The Department of the Environment, Heritage and Local Government responded with a submission. The submission advises that appropriate assessment should be carried out on a draft plan and not before the draft is prepared. Reference is made to Irish and European guidelines on appropriate assessment. The submission also states that it is important that the appropriate assessment procedure takes place in consultation with the teams working on the draft Plan and SEA. The appropriate assessment should examine the effects of policies, objectives and any indicative maps or zonings, as well as cumulative impacts with other plans and projects both within and outside of the Plan area. In particular the water supply and waste water disposal for the extra population envisaged in the LAP may have the potential to impact on the River Boyne and River Blackwater csac. Data sources for Natura 2000 sites are provided in the submission. 3

5 The draft LAP will be subject to appropriate assessment screening and the comments of the Department will be taken into account in the preparation of the draft plan. 4.0 SUBMISSIONS RECEIVED AS A RESULT OF THE DISPLAY OF THE STRATEGIC ISSUES PAPER This section refers to the submissions relating to the proposed LAP which were received during the public consultation period and provides a summary of each submission and the Manager s comment on each. In total, 17 submissions were received as detailed below. 1. Johnstown Wood Residents Association. 2. Johnstown/Athlumney Community Council. 3. Patrick Donaghy & Co. and Hendrik W. van der Kamp on behalf of Mrs. Catriona Cleary, Alexander Reid, 4. Co-ordination Unit, Department of Communications, Energy and Natural Resources, Elm House, Earlsvale Road, Co. Cavan. 5. Site Acquisition and Property Management Section, Department of Education and Science, Portlaoise Road, Tullamore, Co. Offaly. 6. Declan Brassil & Company Ltd on behalf of the estate of Kathleen Bourke, Johnstown, 7. Johnstown Woods Residents Association 8. Planning and Building Unit, Department of Education and Science, Portlaoise Road, Tullamore, Co. Offaly. 9. HSE Community Care Services, County Clinic, 10. Niamh Cleary. 11. Fiona Gunapala, Cluain na Boinne Residents Association. 12. Peter Kierans, County Meath VEC. 13. Bernard Folan, 4 Birch Avenue, Johnstown Wood, 14. Stephen Little and Associates on behalf of Granbrind Athlumney Ltd., 120 Rathgar Road, Dublin Ciara Murphy, 13 Maple Lawn, Johnstown Wood, 16. National Roads Authority, St. Martin s House, Waterloo Road, Dublin Development Applications Unit, Department of Environment, Heritage and Local Government. 4

6 1 Johnstown Wood Residents Association. The submission expresses concern and disappointment at the manner in which the pre draft strategic issues paper for the LAP was displayed and advertised. It is stated that the consultation period is inadequate for the residents association to consult with residents. It is requested that a copy of the document be delivered to all residents in Johnstown/Athlumney and that the closing date for submissions be extended for at least another 4 weeks. During this consultation process, Meath County Council has endeavoured to raise local awareness of the preparation of the plan and inform people of the opportunity to make submissions/observations to the Council. A notice was placed in the Meath Chronicle advising of the LAP preparation, stating that a strategic issues paper had been prepared and that submissions could be made. The issues paper was available online on the Meath County Council website and at a number of locations around Navan including the Johnstown Shopping Centre. In addition, a number of local community groups and residents associations were directly issued with a copy of the issues paper, including the Johnstown Woods Residents Association. The pre draft consultation stage for this LAP allowed for submissions to be made during a four week period, consistent with the timeframe for other LAPs prepared by Meath County Council. In addition, when the draft LAP is prepared, there will be a six week period during which further submissions can be made on the draft. 2 Johnstown/Athlumney Community Council The submission outlines some background information on the Johnstown Athlumney area, in terms of population and housing and notes that there is a highly successful but limited shopping centre in Johnstown and a small number of shops in Johnstown village. It is stated that the IDA park does not play a central or pivotal role in the community. The submission notes that the Johnstown area is as large as some of the leading towns in county Meath i.e. Kells, Trim, Athboy, Dunboyne without any of the advantages or amenities of these towns. The present school, St. Stephen s, is unsuitable for the present or future generations of children. A number of basic community facilities are stated to be absent from the area including a national primary school, secondary school, community centre, sub Garda station, library out reach centre, Post Office, natural walkways, playground. The Johnstown /Athlumney Community Council is anxious that this land bank is developed in the interests of both the community and landowners. It is accepted that not all of the facilities listed can be catered for in the land bank; they are highlighted however in order to illustrate the absence of basic needs in an ever growing community. It is stated that the LAP must be developed in line with the overall and holistic needs of the people of the area and the mistakes of the past must be rectified for the community of the present and future. As acknowledged in the submission, it may not be possible for all facilities listed in the submission to be provided on these lands. The LAP will assist in enabling the delivery of the facilities specified in the Navan Development Plan. 1

7 3 Patrick Donaghy & Co. and Hendrik W. van der Kamp on behalf of Mrs. Catriona Cleary, Alexander Reid, The submission is made on behalf of Mrs. Catriona Cleary who owns part of the lands in the LAP area and raises a number of issues as follows: 1. Requests that the G1 zoning objective for the lands north of the tree lined avenue and that include the St. Martha s complex is changed to C2 to provide for and facilitate mixed residential and business uses in edge of town locations. It is stated that the St. Martha s College and outbuildings have been used as a primary school since 2003 as facilitated by Ms. Cleary. Discussions between Ms. Cleary and the Department of Education and Science have taken place regarding the possible provision of land for the construction of a new purpose built primary school and have raised the merits of creating an educational campus facility combining a primary school, special needs school and secondary school. It is stated that while the principle to create an integrated educational campus is supported by the landowner, it is not certain whether the Department of Education and Science will continue to provide an educational facility in the existing St. Martha s complex or indeed whether any of the lands located to the north of the tree lined avenue will be required for educational purposes. It is contended that there is little point in maintaining the existing G1 zoning if the Department decides it does not wish to acquire the lands and the alternative C2 zoning is suggested for these lands. It is noted that this zoning objective does not rule out community uses other than school such as community resource centre and health centre. 2. Requests that the lands currently zoned F1 and re-zoned A4. It is stated that the lands in the north east area of the LAP lands could accommodate residential development which would allow a greater number of dwelling houses to be built within the town development plan boundary and achieve the protection of the main nature feature of the stream and valuable trees through the inclusion of a linear park in the residential area. It is stated that recreational for residents can be combined with those of the educational campus by providing sports pitches on lands zoned G1 and through the provision of smaller open spaces throughout the LAP area. 3. Suggests that community facilities should be clustered in and adjacent to the proposed educational campus located on lands south of the tree lined avenue to St. Martha s House. Such an educational campus facility has the support of the Department of Education and Science and will be facilitated by the landowner. It suggests that a community resource centre could be provided as part of the educational campus or as part of the C2 zoning. The former would be in line with the code of practice for the provision of schools as stated in the guidelines produced by the Department of Education and Science and the Department of the Environment, Heritage and Local Government. The landowner, Ms. Cleary, supports the provision of clustered and shared facilities for education and community uses on lands located to the south of the tree lined avenue to St. Martha s House. The zoning strategy for the lands in this LAP is set out in the Navan Development Plan and it is not proposed to re-examine zoning designations at this stage. 2

8 4 Co-ordination Unit, Department of Communications, Energy and Natural Resources, Elm House, Earlsvale Road, Co. Cavan. The Department state that they have no comments to make on the LAP, without prejudice to any comments that the Eastern Regional Fisheries Board may have. No Comment. 5 Site Acquisition and Property Management Section, Department of Education and Science, Portlaoise Road, Tullamore, Co. Offaly. The submission notes that the lands adjoining and including St. Martha s College, Johnstown are intended inter alia for the provision of education through an educational campus of 23 acres. It is the Department s preferred approach to establish a primary school, a special school and a 1,000 pupil post primary school in Johnstown. The Department requests that the existing lands zoned educational be retained for that purpose. The draft LAP will be cognisant of this submission, in the context of the overall educational needs for Navan and the specific objectives for this site as set out in the Navan Development Plan Declan Brassil & Company Ltd on behalf of the estate of Kathleen Bourke, Johnstown, The submission is made on behalf of the estate of Kathleen Bourke, Johnstown which owns part of the lands within the LAP area. The lands are zoned G1. The Estate acknowledges the local educational requirements arising in this area. However it wishes to notify Meath County Council that it will not be in a position to release any of the lands for any uses over the lifetime of the Navan Development Plan and the Johnstown/Athlumney LAP. It is considered appropriate to provide notification at this stage in order to facilitate the Council in examining other alternative locations which may be suitable, viable and have a greater prospect of being made available to meet these needs over the lifetime of the LAP. It is stated that the Estate was not aware of the Navan Development Plan review process and consequently did not make a submission at that time. Had they had the opportunity to do so, they would have requested that the unzoned status of the lands be retained. The estate requests that the private dwelling on the lands and its curtilage be dezoned or alternatively rezoned objective A1 to enhance and protect the amenities of established residential communities, to reflect the established, historic and on-going use of that area of land and to ensure that the amenities of the property are appropriately and adequately protected in the future. It is also requested that the narrow strip of land beyond the southern field boundary is dezoned to ensure the protection of the amenities of the dwelling located immediately to the south. In this regard, it is stated that the hedgerow represents a suitable physical boundary which would be appropriate to retain for ecological, landscape and development control reasons thereby rendering the narrow strip on the southern side unsuitable and unusable for development. 3

9 The zoning strategy for the lands in this LAP is set out in the Navan Development Plan and it is not proposed to re-examine zoning designations at this stage. 7 Johnstown Woods Residents Association This submission addresses a number of the topics raised in the strategic issues paper as follows. Community: It is stated that a multi use/multi purpose community hall should be provided in the area. The present lack of suitable community facilities inhibits the founding of sports/community groups and their activities. Community and social facilities should be clustered and central to all existing housing estates in the Johnstown/Athlumney area. The main focus for the residents association, in respect of the most appropriate location for schools, is how the final access routes to the LAP1 lands are determined. It is stated that the location should be accessible from different areas, i.e. Kentstown Road, Johnstown Road in order to reduce the volume of traffic passing through the Johnstown Wood estate which would split the estate in town and put the safety of children at risk. Non vehicular linkages from existing residential areas to community facilities should be prioritised. The dual use of school buildings should not be encouraged as it would negate the need for designated community facilities. Public Open Space & Leisure/Recreational Activities: It is stated that there are minimal public sporting facilities in Johnstown; all current facilities are privately owned. There is a need for outdoor sports fields, courts, tracks, playground, astro turf, skate park etc with adequate ancillary facilities to be developed and managed by Meath County Council/Navan Town Council. Facilities should cater for difference age groups and organisations. It is envisaged that public open spaces would be managed and maintained by the Local Authority which would include active and passive activities with consideration for wheelchair users. The issue of security should be address by An Garda Síochána and use of CCTV with the provision of adequate support and facilities in combination with severe restrictions for pedestrians and vehicular access after dark in particular after sports clubs have ceased training. The stream located within the plan lands should be preserved in its current form and integrated as an amenity feature into the overall scheme. Existing trees should be integrated into the overall scheme through landscape design and protection measures during development. Residential: Proper infrastructural services and facilities must be in place before any further residential uses. Enhancement of Movement and Access Networks: It is stated that these issues can be adequately addressed by the appointment of fully qualified, independent and environmentally aware professionals. Traffic management is of paramount importance and a proper movement framework should be put in place to include traffic calming, speed bumps and other modern horizontal alignment constraints. It would enhance the living environment of Johnstown Wood if full through traffic/school traffic was prohibited. Urban Form: Principles of urban design are quoted from the Urban Design Compendium including places for people; enrich the existing; make connections; work with the landscape; mix uses and forms; manage the investment and designs for change. This is a detailed submission and the comments raised will be considered in the course of preparing the LAP. 4

10 8 Planning and Building Unit, Department of Education and Science, Portlaoise Road, Tullamore, Co. Offaly. The submission from the Department commences by detailing the information used to calculate educational infrastructural requirements and typical size sites required for various types of school. The submission notes that specific population projections arising from the Plan area are not outlined in the strategic issues paper and states that the Department would welcome the opportunity to make a more detailed submission if this information could be made available. It notes that there is a requirement for four primary schools in the Navan area: St. Stephen s National School and Navan Educate Together National School (currently in temporary accommodation); St. Mary s Special School and Navan Community National School (due to commence operation in September 2010). The Department state that they would welcome any assistance or advice regarding this issue and that it was understood that the Site Acquisition and Property Management Section of the Department of Education and Science were also making a submission in relation to specific site requirements in this LAP. The submission also notes that the Department always requests site reservations to be made as close as possible to community facilities e.g. sports facilities, library so that these can be shared between the school and community. The Department is also open to the concept of multi-campus school arrangements. The submission refers to a number of sources of information and official guidance in relation to identifying school sites, planning for education and the Code of Practice for Planning Authorities and the Provision of Schools. It concludes by stating that the Department would like to meet with the Planning Authority prior to the finalisation of the LAP to discuss these issues with them. The draft LAP will be cognisant of these comments, particularly in the context of the overall educational needs for Navan and the specific objectives for this site as set out in the Navan Development Plan The objectives of the Development Plan propose a multi campus school for Johnstown/Athlumney which is consistent with the advice from the Department. In addition, there are lands zoned for community use and open space and recreational facilities which would facilitate the location of the schools adjacent to community facilities, as requested by the Department. There have been discussions between the officials of Meath County Council and the Department of Education and Science regarding educational provision in this area and it is intended to liaise further with the Department during the preparation of the draft LAP. 9 HSE Community Care Services, County Clinic, The submission notes the statement in the Navan Development Plan that a 1.5 acre site is being considered for reservation in the LAP for a primary health care unit for HSE. It states that in view of recent developments whereby the HSE and the Department of Health have decided that all future primary care units will be on the basis of public private partnerships, 5

11 the HSE will no longer have a need to acquire sites. Nevertheless the 1.5 acre site in Johnstown will be needed by the HSE for the development of a special care unit for disability services. This matter will be considered during the preparation of the local area plan. 10 Niamh Cleary The submission addresses a number of issues as follows: Primary Care Unit: Queries what such a unit entails, how it will impact on the lives of residents in the area, where it would be located and where the pedestrian links are going. It is stated that such a unit should not act as a needle exchange and methadone clinic. There is already a health care unit in Johnstown Village and why is there a need for another one. Recreational Facilities: Facilities should include a playground to cater for all age groups with safety surfaces, a skate park, astro turf pitches and the use of a football club for the community. It is stated that St. Martha s College should be used as a community centre. Trees which are preserved should have wooden seats built around them. Residential and Urban Form: Houses should be semi detached and detached and include bungalows. Height should not exceed two storeys. Every road should have a cul de sac to stop through traffic. Access and Transport Infrastructure: The correspondent does not want access from existing housing estate to the LAP lands. The R15050 should be used as vehicular access. There should be dedicated pedestrian and cycle routes. Cars and traffic should be kept out of the existing Johnstown Wood with links by pedestrian routes only. There should be adequate parking in school groups and a turning circle. The access to the LAP lands should not be from the Supervalu roundabout as it would have a negative impact on the lives of residents and be a risk to children playing in the area. It is stated that the plans on display are unclear and need to be more precise with regard to where things will be. No 9 from the HSE provides information in respect of what health care uses operated by the HSE could potentially be located on the LAP lands, i.e. special care unit for disability services. It is intended that the LAP will address the issues of recreational facilities, urban form, residential development and access and transport infrastructure and the comments expressed on these issues are noted. At this stage of the plan preparation process, specific locations have not been identified for particular uses, beyond the zoning categories and objectives illustrated for the lands on the zoning and objective maps for the Navan Development Plan and the requirements for the LAP lands detailed in the text of the Development Plan. 6

12 11 Fiona Gunapala, Cluain na Boinne Residents Association The submission acknowledges the need for community facilities and schools in the area and records the concern of residents that the road between Cluain na Boinne and the Chestnuts, Johnstown Wood would be opened up to vehicular or pedestrian traffic as this would lead to the Cluain na Boinne estate being used as a through way. It states that anti-social behaviour has been experienced in the area in the past and residents are concerned that opening up this road would increase this. In addition, residents are concerned that the proposed schools could lead to vehicles taking shortcuts through the area. Concern is also expressed regarding an increase in traffic on Metges Road and it is felt that leaving these green areas open poses a risk to children playing on the greens. It is noted that residents have been taking care of the greens and all other issues in the estate out of their own finances since the developer dissolved the company in It is submitted that the residents of Cluain Na Boinne have a constitutional right to the peaceful enjoyment of their homes and they would object to the opening of this road unless Meath County Council take steps to prevent Cluain Na Boinne from being used as a through road. It is submitted that this would not prevent pedestrian traffic around the area as there is a public footpath in place around the estate. The Navan Development Plan objectives map illustrates some indicative access points into the LAP lands and the issue of access, including footpaths, pedestrian access and car parking, will be examined in the course of the LAP preparation. 12 Peter Kierns, County Meath VEC. The submission relates to the proposal to reserve a 12 acre site for the provision of a secondary school. It is stated that this may be too restrictive taking into account the size of building and car parking required, access arrangements, ancillary sporting facilities and that the plans should incorporate a footprint for an extension should it be required. It is recommended that the campus size be revised to 14 acres. The Planning Authority is committed to facilitating the provision of the educational facilities outlined for this area as per the Navan Development Plan and requirements of the Department of Education and Science and other education providers. 13 Bernard Folan, 4 Birch Avenue, Johnstown Wood, The submission welcomes the plan, particularly the provisions for educational and recreational facilities which are badly needed in the area. It states that the development of the primary and secondary schools must be the priority for the area. Strong reservations are expressed in relation to the residential zoning which, at 35% of the area, is considered excessive. It is queried whether there is demand for this type of development. Clarity is requested in respect of the statement in the strategic issues paper that the residential development will play its part in achieving an integrated and balanced community and the 7

13 correspondent does not see this as being a justification for further residential development in the area. It is considered that residential development should not commence until all of the proposed community plans have been delivered. The objective for LAP1, providing that no residential development will be occupied prior to the delivery of the primary school, the special school and the area of public open space is not considered sufficient and should be expanded to include the secondary school, the health care unit and the playing pitches. The residential zoning on the LAP lands is included in the Navan Development Plan which was adopted in November The lands were also zoned for this use in the Navan Development Plan The location of community facilities adjacent to residential areas is seen as an appropriate and balanced mix of uses as it lends itself to convenient access to these community services for residents. The Navan Development Plan specifies some of the facilities which must be provided in advance of any residential development and is also clear that infrastructure must be in place concurrent with any development proposals. The Development Plan lists some of the phasing requirements for these lands which will be adhered to in the LAP. 14 Stephen Little and Associates on behalf of Granbrind Athlumney Ltd., 120 Rathgar Road, Dublin 6. This detailed submission relates to lands in the ownership of Granbrind located in the plan area. It outlines the planning context of the plan area and addresses a number of topics raised in the strategic issues paper as follows: 1. Community: The submission states that Granbrind have recently lodged a planning application for a primary school on lands within their ownership in acknowledgement of the need for a school in the area and the phasing requirement that a school be delivered prior to the occupation of any houses that may be constructed on the residentially zoned land. It is stated that the location of the development has been influenced by local landownership issues and the desire to proceed with residential development on lands within Granbrind s control. It became apparent prior to lodgement that it was going to take further time to deliver a school on the G1 zoned lands which are not within Granbrind s control. The submission invites the inclusion of a specific objective to provide for a school in the location illustrated (site of 2.79 hectares). It is considered that the LAP requirement to provide a primary school and special school could be accommodated in a single building on these lands. 2. Public open space and leisure/recreational facilities: The submission outlines support for the objectives of the open space zoning on the plan lands. The submission queries the policy of the Navan Development Plan which states that public open space shall be provided prior to the occupation of any residential units. It is requested that this be modified to provide the financial means of delivering open space as the policy will not allow the completion of house sales before the open space is delivered and in the current economic conditions it is difficult to see how this will be funded. It is likely that in the current market conditions only small numbers of houses would be built at any one time and that potentially only units would be constructed when the first occupancy occurs. There could also be healthy and safety issues that are likely to arise were the open 8

14 space provided with the residential lands still predominantly under construction. Two alternatives options are proposed: a. That the delivery of open space be phased in line with the delivery of houses; b. That if the Council wish the open space to be delivered in one phase, that the objective be modified to require the open space prior to the occupation of 200 houses. 3. Residential: The LAP should provide for more traditional suburban type development of detached and semi detached units of 2-3 storeys. Flexibility should be provided to allow terraced or town house styles. Density should be in the range of units. A mix of houses sizes (one bedroom-two bedroom etc) would provide a suitable mix of typologies such that all sectors of society could reside in the development. It is stated that the LAP should be flexible enough to cater for market demand and that in light of the quantity of residential lands in the LAP area, developments should cater for those most likely to be interested in living in this location. The submission notes that the development management process is best placed to address localised concerns regarding overlooking, overshadowing but that the LAP should set out the parameters of good design and identify any particular areas of concern. In terms of design, it is envisaged that the form of adjoining developments will provide the baseline and style for the plan area. With regards to building height, it is not considered that locations for higher buildings should be identified at this time and that buildings would range from 2-3 storeys therefore it would be prudent to allow for up to 4 storeys. 4. Protection and enhancement of built and natural heritage: The submission notes the presence of protected trees in the plan area. It also includes the results of a tree survey carried out on the lands the subject of the planning application for the school which states that several of the protected trees are in poor condition and unworthy of retention. It is stated that their status should be updated and reflected in the LAP. 5. Enhancement of movement and access networks: In respect of traffic calming, the submission states preference for design solutions to the matter rather than measures such as speed bumps and tables. It is requested that the LAP encourages the implementation of best practice through the adoption of a flexible approach to engineering standards on non-distributor roads. In relation to car parking, it is considered essential that parking for housing is provided close to the main entrance of dwellings either within curtilage or in banked parking lots in line with the standards set out in the Navan Development Plan. Residential cycle parking should be provided on curtilage through access to back gardens and secure areas. 6. Urban form: It is stated that development design and high quality urban form can be achieved through the development management process. The development of an irregular shaped parcel of land such as the LAP lands when taken in conjunction with the restrictions of adjoining land uses will necessarily create a series of streets and cul de sacs. The only way to avoid cul de sacs is to develop in a grid formation. The important aspects of urban form to be considered at this time are the principle access and distributor roads; largely defined by the Navan Development Plan. The hierarchy of roads will filter down from these points. 7. Infrastructure: The submission notes that water services infrastructure is in place for the lands. Surface water will need to be attenuated on site to pre development volumes before passing through interceptors and then into the local watercourse. This is a detailed submission which raises matters that will need to be addressed in the preparation of the LAP. 9

15 15 Ciara Murphy, 13 Maple Lawn, Johnstown Wood, The submission states that the provision of a community centre appears to be dependent on additional residential development rather than being a priority along with schools. It states that there is no place at the moment for community groups to meet. While school facilities should be available for community use, they should not be a substitute for a community centre. It is suggested that if St. Martha s is to cease use as a school that it would be suitable for use as a community resource centre and perhaps a health centre. The submission states that this area should have access from the Johnstown Road L5050, Kentstown Road R153 and from the estates to the west and not solely Johnstown Woods as there is traffic congestion in the area already and it is not considered that large amounts of traffic should pass through a residential area. Development should be built so that it can be accessed from many angles but that through traffic won t be accommodated. There is a need for footpaths from Johnstown Village and along the Kentstown Road so that children can walk to school safely which could possibly cut down on the traffic congestion at the school at present. The submission states that the area around the stream should be landscaped to include active and passive recreational facilities. A playground is required urgently as are facilities for older children, e.g. skate ramp, exercise trail, basketball, tennis courts, and adults. Care should be taken to keep as many trees and hedgerows as possible and to keep the topography intact especially beside St. Martha s. It is stated that there may be bats living in the area. The possibility of a third level facility should be considered as part of the plan. The potential for using green energy should be looked at as part of the building process. Ample parking facilities should be provided. Anti-social and security issues may be helped by using cctv or closing off certain areas after dark. Any further housing should be kept to a minimum. Taller buildings would not be a problem if it meant leaving more green spaces. A number of submissions have referenced the need for a community centre in this area at present. This is recognised by the Planning Authority and is to be provided on these LAP lands as per the requirements of the Navan Development Plan. In general, the provision of community and recreational facilities will be a key consideration in the preparation of the LAP for Johnstown/Athlumney. The Navan Development Plan objectives map illustrates some indicative access points into the LAP lands and the issue of access, including footpaths, pedestrian access and car parking, will be examined in the course of the LAP preparation. The possibility of using green energy and generally encouraging sustainability in building construction and design in the LAP area is worthy of examination. 16 National Roads Authority, St. Martin s House, Waterloo Road, Dublin 4. The submission advises that the Authority has no specific comments to make in respect of the proposed LAP. 10

16 No comment. 17 Development Applications Unit, Department of Environment, Heritage and Local Government. The submission details nature conservation and architectural heritage recommendations from the Department. Nature Conservation: It is recommended that the LAP should include a natural heritage section. The Local Authority should ensure that the LAP does not adversely impact on designated sites or protected species and should ensure that the LAP and any development proposals take into account the need to protect, retain and enhance biodiversity generally as per the National Biodiversity Plan. All designated sites within the Plan area should be listed and mapped. Details are given on protected species. The importance of a number of habitats for biodiversity is outlined, including hedgerows and wetlands. It is advised that any proposals for riverside walks should ensure that the riparian zone is left intact and that inappropriate night lighting which would interfere with bat species is not used. Flood plains should be identified and left undeveloped and the plan should take account of the guidelines for Planning Authorities on the planning system and flood risk management. Adequate water services should be place prior to development and ground and surface waters should be protected from pollution. The impact of any proposed water abstraction schemes on natural heritage should be fully assessed. Information is provided in respect of the potential for negative impacts on biodiversity on designated sites as a result of developments such as walking routes, cycleways, seating, lighting and the loss and mowing of riparian zones and relevant proposals should be subject to appropriate assessment screening. Architectural Heritage: The submission notes that the built heritage of the locality should be taken into account in setting out the LAP. The opportunity exists to give recognition to the value of the architectural heritage component of the existing built environment which would assist in generate a new sense of place within the wide area of Johnstown/ Athlumney. It could be determined if structures of architectural heritage merit exist beyond those already included in the Record of Protected Structures and it should be recognised that that structures of architectural merit, though not included on the Record of Protected Structures, may still contribute to the identity of a locality. The zoning of lands should take into account the former use of the lands or the context within which the land is located and where features exist which form part of the architectural heritage of the locality, the zoning proposal should be sufficiently prescriptive to take this into account. The contribution of features which give identity to an area should be given recognition in the LAP and utilised to encourage development in the plan area. Built heritage features can be used as focal points to incrementally build an identity within the changed setting of recent and future development. Structures of architectural merit can be incorporated in new localised layouts to have a continued or new use and may present an opportunity for such structures to have a viable and continuous future while contributing to the sense of identity and underpinning the evolving sense of place in the locality. 11

17 The LAP should place an emphasis on setting standards for the quality of the design of all new structures within the plan area. New structures can enhance the character of existing items of architectural heritage where the quality of design is complementary and may itself in time be recognised as constituting elements of the architectural heritage of the locality. The Planning Authority recognises the importance of nature conservation and architectural heritage. The provision of an appropriate architectural design framework for this area will be an important consideration in this LAP. As stated in the submission, the bulk of the LAP lands are greenfield, in agricultural use. The issues raised in relation to biodiversity and nature conservation will be taken into consideration in the preparation of the local area plan. 12

18 Appendix A List of persons and organisations who were informed of the preparation of the Navan LAP1 Johnstown /Athlumney Spatial Policy Unit, Department of the Environment, Heritage & Local Government. Minister for Enterprise, Trade & Innovation Department of Communications, Energy & Natural Resources. Department of Education and Science Office of Public Works Central Fisheries Board ESB Head Office National Heritage Council National Roads Authority. Development Applications Unit, Department of the Environment, Heritage & Local Government National Parks and Wildlife Service, Department of Environment, Heritage & Local Government Health Service Executive Department of Arts, Sports & Tourism Bord Gais Eireann Environmental Protection Agency Bus Eireann Eastern Regional Fisheries Board National Transport Authority Bord Failte An Taisce Offaly County Council An Bord Pleanála Irish Rail Commissioners of Public Works Dublin Regional Authority Kildare County Council i

19 Fingal County Council Louth County Council Department of Finance Forfas Dublin Airport Authority Cavan County Council Border Regional Authority Westmeath County Council Udaras na Gaeltachta Local Community Groups and Organisations Supplied with the Strategic Issues Paper Johnstown/Athlumney Estate Forum, c/o Aaron Reid, 4 Alder walk, Athlumney Wood, Johnstown Woods Residents Association, c/o Therese Honda, 14 Maple Lawn, Johnstown Wood, Millbrook Residents Association, c/o Collette Monaghan, 165 Millbrook, Johnstown. Boyne View Residents Association, c/o Finian Murray, 133 Boyne View, Johnstown, Carne Hill Residents Association, c/o Rodney Ring, 46 Carne Hill. Zion Youth Club, c/o Sandra Oked, 163 Millbrook, Johnstown, Cllr. Jenny McHugh, Principle, St. Stephen s National School, ii