APPROPRIATE ASSESSMENT SCREENING REPORT · Draft Naas Road Local Area Plan 2012 - 2018 Natura...

Draft Naas Road Local Area Plan 2012 - 2018 Natura Impact Report

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TABLE OF CONTENTS

PAGE

1.0 INTRODUCTION 4

1.1 TERMS OF REFERENCE 4

1.2 OBJECTIVES OF THE HABITATS DIRECTIVE 5

1.3 METHODOLOGY FOR APPROPRIATE ASSESSMENT 5

1.3.1 GUIDANCE 5

1.3.2 STAGE 1 – Screening for Appropriate Assessment 5

1.3.3 STAGE 2 – Appropriate Assessment 6

1.3.4 STAGE 3 – Assessment of Alternative Solution 6

1.3.5 STAGE 4–Imperative Reasons of Overriding Public Interest (IROP) 6

1.3.6 DATA COLLECTED AND CONSULTATION CARRIED OUT FOR ASSESSMENT 6

2.0 DESCRIPTION OF THE LAP AND ITS POTENTIAL IMPACTS ON NATURA 2000 SITES 8

2.1 DEFINING THE ZONE OF INFLUENCE OF THE LAP 8

2.2 DESCRIPTION OF THE LAP 8

2.2.1 Location 8

2.2.2 Characteristics of the Plan 9

2.2.3 Relationship Between the LAP and Natura 2000 Sites 10

2.2.4 Interaction with Other Plans/Projects and Cumulative Effects 13

3.0 APPROPRIATE ASSESSMENT SCREENING – STAGE 1 14

3.1 INTRODUCTION 14

3.2 SCREENING OF NATURA 2000 SITES WITHIN ZONE OF INFLUENCE OF THE LAP 14

3.3 AA SCREENING CONCLUSIONS 20

4.0 APPROPRIATE ASSESSMENT - STAGE 2 20

4.1 POTENTIAL IMPACTS OF LAP ON NATURA 2000 SITES 20

4.2 SUMMARY OF IMPACTS AND MITIGATION MEASURES 22

4.3 AA CONCLUSION 32

5.0 REFERENCES 34


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APPENDICES

APPENDIX A SCREENING OF ALL LAP POLICIES 35

APPENDIX B CONSERVATION OBJECTIVES AND QUALIFYING INTERESTS FOR ALL NATURA 2000 71

SITES SUBJECT TO AA

APPENDIX C COVER LETTER FROM SCOTT CAWLEY 78


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1.0. INTRODUCTION

Dublin City Council is currently preparing a draft Local Area Plan (LAP) for the Naas Road

under the Planning and Development Acts 2000 (as amended). The purpose of this Natura

Impact Report is to assess potential impacts of the proposed LAP on Natura 2000 sites

(Special Areas of Conservation and Special Protection Areas). Please note that a separate

Strategic Environmental Assessment (SEA) Screening report was prepared in tandem with

this report. This Natura Impact Report refers only to potential impacts that may occur to any

Natura 2000 site as a result of the implementation of the Local Area Plan.

Under the EU Birds (2009/147/EC) and Habitats (92/43/EEC) Directives, member states are

required to designate areas in order to protect certain habitats and species. These sites are

known as Special Protection Areas (SPA) and Special Areas of Conservation (SAC).

Collectively these sites are referred to as Natura 2000 sites. Any plan or project that is likely

to have a potential impact on a Natura 2000 site must undergo an Appropriate Assessment

(AA) to determine impacts, and where necessary, devise appropriate measures to prevent or

minimise any such impacts.

1.1 Terms of Reference

The requirements for an Appropriate Assessment are set out in the EU Habitats Directive,

Articles 6(3) and 6 (4) which state:

Article 6(3) of the Habitats Directive states:

“Any plan or project not directly connected with or necessary to the management of the

[Natura 2000] site but likely to have a significant effect thereon, either individually or in

combination with other plans or projects, shall be subject to appropriate assessment of its

implications for the site in view of the site's conservation objectives. In the light of the

conclusions of the assessment of the implications for the site and subject to the provisions of

paragraph 4, the competent national authorities shall agree to the plan or project only after

having ascertained that it will not adversely affect the integrity of the site concerned and, if

appropriate, after having obtained the opinion of the general public”

Article 6(4) of the Habitats Directive states:

„‟If in spite of a negative assessment of the implications for the site and in the absence of

alternative solutions, a plan or project must nevertheless be carried out for imperative

reasons of overriding public interest, including those of a social or economic nature, the

Member State shall take all compensatory measures necessary to ensure that the overall

coherence of Natura 2000 is protected. Is shall inform the Commission of the compensatory

measures adopted. Where the site concerned hosts a priority natural habitat type/or a

priority species the only considerations which may be raised are those relating to human

health or public safety, to beneficial consequences of primary importance for the

environment or, further to an opinion from the Commission , to other imperative reasons of

overriding public interest‟‟.


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1.2 Objectives of the Habitats Directive

The Habitats Directive promotes a hierarchy of avoidance, mitigation and compensation

measures to be addressed.

Firstly, a plan should aim to avoid any negative impacts on Natura 2000 sites by

identifying possible impacts early in plan making, and writing the plan in order to avoid

such impacts.

Secondly, mitigation measures should be applied during the AA proves to the point

where no adverse impacts on the site(s) remain.

Thirdly, under a worst case scenario a plan may have to undergo an assessment of

alternative solutions. Under this stage of the assessment, compensatory measures are

required for any remaining adverse effects, but they are permitted only if a) there are no

alternative solutions and b) the plan is required for imperative reasons of overriding

public interest (the IROPI test). European case law highlights that consideration must be

given to alternatives outside the plan boundary area in carrying out the IROPI test. It is a

rigorous test which plans are generally considered unlikely to pass.

1.3 Methodology for Appropriate Assessment

1.3.1 Guidance

This Natura Impact Report has been prepared with regard to the EU‟s guidance document

„Assessment of plans and projects significantly affecting Natura 2000 sites, Methodological

guidance on the provisions of Articles 6(3) and 6(4) of the Habitats Directive 92/43/EEC

(2001) and the National Parks and Wildlife Service (NPWS) document „Appropriate

Assessment of Plans and Projects in Ireland – Guidance for Planning Authorities (2010).‟

Appropriate Assessment is an assessment of the potential effects of a proposed plan in

combination with other plans and projects on one or more Natura 2000 site. Key stages in

the process are set out below, as per European and Irish Government guidance (EC 2000,

EC 2001 and DoEHLG 2010). Stages 1 and 2 relate to Article 6(3) of the Habitats Directive,

and Stages 3 and 4 relate to Article 6(4).

1.3.2 Stage 1 – Screening for Appropriate Assessment

In compliance with the procedures set out under „Managing Natura 2000 sites, the

Provisions of Article 6 of the Habitats Directive 92/43/EEC the Screening for an appropriate

Assessment is undertaken through the following stages:

(i) Description of the Proposed Planning Scheme

(ii) Identification of Natura 2000 sites potentially affected

(iii) Identification and description of individual and cumulative impacts likely to result from

the Planning Scheme

(iv) Identification and description of individual and cumulative impacts likely to result from

the Naas Road Local Area Plan


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(v) Assessment of the significance of the impacts identified on the integrity of protected

sites and

(vi) Recommendation for the preparation, or not, of a Stage II Appropriate Assessment

1.3.3 Stage 2 – Appropriate Assessment

Stage 2 of the process is the Appropriate Assessment. This stage considers whether the

plan or project alone or in combination with other projects will have adverse effects on the

integrity of Natura 2000 sites, and includes any mitigation measures necessary to avoid,

reduce or offset negative effects. The proponent of the plan is required to submit a Natura

Impact Report, to identify and characterise possible implications for site integrity in view of

the sites conservation objectives, talking account of cumulative effects.

1.3.4 Stage 3 – Assessment of Alternative Solutions

This stage examines any alternative solutions or options that could enable the plan or

project to proceed without adverse effects on the integrity of a Natura 2000 site.

Demonstration that all reasonable alternatives have been considered and assessed, and

that the least damaging option has been selected, is necessary to progress to Stage 4.

1.3.5 Stage 4 - Imperative Reasons of Overriding Public Interest (IROP)/Derogation

This is the main derogation process of Article 6 of the Habitats Directive and examines

whether there are imperative reasons of overriding public interest (IROP) for allowing a plan

or project that will have adverse effects on the integrity of a Natura 2000 site to proceed in

cases where it has been established that no less damaging alternative solutions exist.

An assessment of compensatory measures is required where, in the light of an assessment

of Imperative Reasons of Overriding Public Interest (IROPI), it is deemed that the project or

plan should proceed.

Each stage of the AA determines whether a further stage in the process is required. If, for

example, the conclusions at the end of Stage 1 are that there will be no significant impacts

on Natura 2000 sites, there is no requirement to proceed further.

1.3.6 Data Collected and Consultation carried out for this Assessment

This NIR has been informed by relevant information contained in the following documentary

sources:

Dublin City Development Plan 2011 -2017

Dublin City Development Plan 2011 -2017 Environmental Report

Dublin City Development Plan 2011 -2017 Natura Impact Report

Dublin City Biodiversity Plan 2008 - 2012

National Development Plan

National Spatial Strategy


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Regional Planning Guidelines for the Greater Dublin Area

Greater Dublin Strategic Drainage Study – Regional Drainage Policies – Technical

Document – Vol. 2 New Development , Dublin City Council , March 2005

Greater Dublin Strategic Drainage Study – Regional Drainage Policies – Technical

Document – Vol .3 Environmental Management , Dublin City Council , March 2005

Strategic Environmental Assessment of the Greater Dublin Strategic Drainage Study

2008

Eastern River Basin District Basin Management Plan 2009-2015

Other relevant plans and guidelines

Websites consulted include:

National Parks & Wildlife Service (internet) available from www.npws.ie

EU Water Framework Directive (internet ) Available from www.wfdireland.ie

Eastern River Basin District Project (internet) Available from www.erbd.ie

Environmental Protection Agency (internet) Available from www.epa.ie

Geological Survey of Ireland (internet) Groundwater Public viewer www.gis.ie

As part of the Draft LAP statutory consultation, the NPWS will be provided with a copy of the

Draft LAP and this NIR for comment. Any comments/amendments necessary to either the

Draft LAP or the NIR as a result of NPWS feedback will be incorporated into the final LAP.

Site surveys of the study area were carried out in parallel with the preparation of this NIR.

These include site walkover surveys by the Area Team on 9th February and 1st March 2012

,and investigative water quality sampling carried out on 21st June 2011. In addition Aebhín

Cawley (Scott Cawley Ltd, independent peer reviewer of this NIR walked the site on 13th

June 2012).

Who carried out the assessment:

Reviewed by:

The Planning Department, Dublin City Council,

June 2012.

Maryann Harris (Senior Executive Parks

Superintendent, April 2012) & Aebhín Cawley

(Scott Cawley Ltd., independent peer reviewer

of this NIR). (see Appendix C for cover letter)

Level of Assessment Completed Desktop Screening Study

Site surveys of the study area were carried out

in parallel with the preparation of this NIR.

These include a number of walkover surveys by

Area Team in 2011 and on 1st March 2012 and

investigative water quality sampling carried out

http://www.npws.ie/

http://www.wfdireland.ie/

http://www.erbd.ie/

http://www.epa.ie/

http://www.gis.ie/


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by DCC on the 21st June 2011. In addition

Aebhín Cawley (Scott Cawley Ltd, independent

peer reviewer of this NIR walked the site on 13th

June 2012).

Where can full results of the assessment be

accessed and viewed

Will be on public display with Environmental Report

and Local Area Plan

2.0. DESCRIPTION OF THE LAP AND ITS POTENTIAL IMPACTS ON NATURA 2000 SITES

2.1. Defining the Zone of Influence of the LAP

The Zone of Influence (ZoI) is the „effect area‟ over which changes could give rise to

potentially significant impacts. The ZoI over which significant impacts may occur will differ for

sensitive ecological receptors depending on the pathway for any potential impacts, as well

as the specific nature of different habitats/species (e.g. ability to move/disperse or absorb

impacts).

In accordance with guidance from the Department of Environment, Heritage and Local

Government (2010) a distance of 15km was used as a starting point for identifying potential

impacts. It was found that this 15km distance was more than adequate for capturing all

potentially significant impacts within the ZoI of the LAP.

Hydrological linkages (e.g. rivers, groundwater flows) between impact sources and aquatic

habitats and species often result in impacts occurring at significant distance from the source

of impact. The distances over which water-borne pollutants are likely to remain in sufficient

concentrations to have a significant impact on receiving waters is difficult to quantify and

highly site-specific. Evidently, it will depend on volumes of discharged waters, concentrations

and types of pollutants, volumes of receiving waters, and sensitivity of receiving waters. As a

precautionary measure, the distance over which surface water discharges could have a

significant impact on the marine receiving waters is considered to be up to 15km.

In order to understand the ZoI for this LAP in the context of Appropriate Assessment, it is

useful to explain the hydrological interconnectivity between the LAP area and surrounding

areas. The River Camac runs through the LAP lands and this is a tributary of the River

Liffey which flows into Dublin Bay. There are a number of Natura 2000 sites within Dublin

Bay that therefore are hydrologically connected to the LAP area. These Natura 2000 sites

are located some distance downstream from the LAP area (between 8km and 11km) yet fall

within its identified potential zone of influence.

2.2. Description of the LAP

2.2.1 Location

The Naas Road LAP area is located some 6km south west of Dublin‟s City Centre, and

immediately east of the administrative area of South Dublin County Council. It occupies a

strategic location on a gateway point into the city and provides good public transportation

links to the wider metropolitan areas including Dublin City Centre and Dublin Airport.


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2.2.2 Characteristics of the Plan

The Naas Road LAP area comprises approximately 100ha of land and is located some 6km

south west of Dublin‟s City Centre.

The plan builds on the vision for the Naas Road lands Strategic Plan (2009), and is intended

to provide for the proper planning and sustainable development of the Naas Road area for a

duration of six years, from adoption in 2012 until 2018, unless amended.

The plan consists of a written statement, accompanying maps and a Strategic

Environmental Assessment (SEA) Report.

The Naas Road LAP area sits within a hierarchy of land use plans and is intended to provide

a localised and focused planning framework for the sustainable regeneration and

development of the Naas Road Area, an outer urban area of Dublin City, within the context

of the Dublin City Development Plan 2011 -2017, the Regional Planning Guidelines for the

Greater Dublin Area 2004 – 2016 and the National Spatial Strategy 2002 – 2020. All of these

policy documents support brownfield urban regeneration and the minimisation of suburban

sprawl. Planning and development issues of a regional and strategic nature, including, for

example, wider wastewater treatment capacity, are assessed at a higher level of the

planning hierarchy.

The Naas Road Lands LAP is part of the overall core strategy as set out in the Dublin City

Development Plan 2011 - 2017. As part of this core strategy, Dublin City Council will

prepare area specific plans for the key developing area (KDAs) and Key District

Centres(KDCs), using appropriate mechanisms of local area plans and schematic master

plans. The local area plans will be prepared for areas subject to large scale developments

within the lifetime of the plan. Table 3.4 and Table 3.5, of Section 3.2.7 of the Dublin City

Development Plan 2011-2017 sets out a schedule of the local area plans/statutory plans to

deliver the core strategy. These have been taken into consideration when assessing the

cumulative impact of this LAP.

The Dublin City Development Plan 2011 – 2017 designates 9 key developing areas, one of

which is the Naas Road Lands. Table 3.3 of section 3.2.3 of the Development Plan gives

estimated capacity of the key developing areas. In total over the 9 KDAs, an estimated

31,680 new housing units are proposed, and 1,629Ha of zoned commercial/employment

lands. The estimates under the core strategy for the Naas Road Lands are 2100 housing

units and 63 Ha of zoned commercial/employment lands.

In terms of the AA, the cumulative impact of other plans and projects must be taken into

consideration, when assessing the LAP. It should be noted that an Appropriate Assessment

and Strategic Environmental Report was undertaken for the Dublin City Development Plan

2011-2017. Each of the Local Area Plans will be carrying out their individual Appropriate

Assessment and Strategic Environmental Assessment screening reports, but for the purpose

of this report regard will be had to all projects and plans of relevance.


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2.2.3 Relationship Between the LAP and Natura 2000 Sites

The individual elements of the draft plan have been identified that may impact on Natura

2000 sites. These are described below.

Waste Water Discharge

The foul drainage for the Naas Road Local Area Plan drains to two separate catchments.

Most of the area is connected to the Grand Canal Tunnel catchment with a small area at the

northern end connected to the City Centre catchment. Both catchments ultimately discharge

to the Regional Waste Water Treatment Plant at Ringsend. The drainage network in the

Naas Road Lands is a partially separate system in which foul sewage, together with some

surface water is carried by an individual system of sewers to the Grand Canal Tunnel sewer

and the balance of the surface water is collected in an independent system of surface water

sewers ultimately discharging into the River Camac.

It is considered that the surface water runoff and foul drainage from the subject lands may

have indirect impacts on water quality in Dublin Bay, in that the current drainage network

results in unnecessary contamination and treatment of surface waters, in that the combined

sewer overflows discharging to the River Camac are frequent spillers and have a negative

impact on the river, which would ultimately have a potential adverse impact on the structure

and function of the habitats of Dublin Bay.

In 2010, the Environmental Protection Agency granted a Discharge Licence to Dublin City

Council under the Waste Water Discharge (Authorisation) Regulations (2007). Dublin City

Council must comply with the conditions of this discharge licence. The ultimate objective of

this licence is to restrict discharges from the wastewater network into rivers and water.

The Naas Road LAP, in common with the rest of the City and a large portion of surrounding

council areas, is served by the Regional Waste Water Treatment Plant at Ringsend. At the

time of preparing this LAP this facility is operating at its design capacity. Dublin City Council,

is currently finalising proposals to increase capacity of the plant at Ringsend from 1.7 million

PE (population equivalent) to 2.1 million PE, with a target completion date of 2015. At

present the Ringsend Plant does not have capacity to accommodate the redevelopment of

all the LAP lands.

The LAP makes a commitment that any significant development in the LAP area will not be

permitted at the Naas Road Lands until the upgrade of the Ringsend Treatment Plan is

completed. Development can and will only be permitted where capacity is available, and will

be on a phased basis.

Surface Water Management

An extensive surface water drainage network discharges to the River Camac and a

significant number of combined sewer overflows also discharge to the river and its

tributaries. Within the city area, the catchment draining to the River Camac and its

tributaries extends from the River Liffey at Heuston Station to Rathfarnham and Walkinstown

and from Cherry Orchard to Whitehall and Terenure, making it a very extensive catchment.


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The Greater Dublin Strategic Drainage Study identifies numerous deficiencies within the

catchment and makes recommendations for the upsizing of sewers, addressing the issue of

combined sewer overflows and improving flood defences.

It should be noted however, that the GDSDS study is under review and will likely be revised

during the lifetime of the plan.

In keeping with the Greater Dublin Strategic Drainage Study (2005), Sustainable Drainage

Systems (SuDS) techniques will be incorporated into new developments. The drainage

strategy for any new development in the LAP will also take due cognisance of the objectives

of the FloodResilenCity Project, which promotes an integrated approach to flood risk

management. This project promotes „Awareness, Avoidance, Alleviation and Assistance‟

when considering pluvial flood management.

As part of the implementation of the local area plan, Dublin City Council will seek to remove

the storm water runoff from the combined system. In some cases, this will require new

surface water pipes to be constructed. All new development in this area will be expected to

manage surface water in accordance with modern sustainable principles to minimise peak

flows in the system, for example, green roofs or rainwater harvesting. All planning

applications shall be required to submit a surface water drainage plan which will include

proposals for the management of surface water within sites, and runoff rates from sites,

protecting the water quality of the River Camac and retrofitting best practice SuDS

techniques on existing sites where possible.

Water Quality

Recent years have seen the adoption of a number of EU Directives, transposed into Irish

Law which seek to protect and improve water quality. The EU Water Framework Directive

(2000/60/EC) aims at improving water quality, and applies to rivers, lakes, groundwater,

estuaries and coastal waters. Member states must aim to achieve good status in all waters

by 2015 and must also ensure that status does not deteriorate in any waters. The ERDB

Project in one of eight river basin districts established in Ireland arising out of the legal

requirements of the Water Framework Directive. The Eastern River Basin District plan sets

out series of targets for improvements in river water quality to bring it to good status by 2015

across the wider Greater Dublin area which makes up the catchment of the Liffey, Tolka,

Dodder, Boyne, Avoca, Vartry Rivers and a number of smaller rivers in this geographical

river catchment area.

The River Camac enters into the functional area of Dublin City Council at the Old Naas Road

and makes its way to the River Liffey at Heuston Station, Islandbridge via a series of natural

open channels, man-made channels and culverts. The Robinhood Stream, the Galblack

River (including the Blackditch and Gallanstown streams) and the Walkinstown Stream all

discharge to River Camac.

Water quality samples are taken from the River Camac on a monthly basis as part of the

routine river sampling programme carried out by Dublin City Council on all of the reportable

rivers. The samples are analysed for a comprehensive suite of parameters and non-

compliances are noted. Both Operational and Surveillance Monitoring are also carried out

on the reportable rivers in accordance with the requirements of the Water Framework


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Directive. Results taken from the River Camac indicate the presence of gross pollution in the

River Camac during periods of rainfall. The samples taken by Dublin City Council were all

from surface water pipelines flowing into the River Camac or from the actual River Camac

itself. Essentially this should be a surface water network but is obviously seriously

contaminated with wastewater flows.

Dublin City Council face a number of challenges in implementing the measure identified in

the River Basin Management Plan. It is a legal requirement to meet good status by the

designated deadlines (2015, 2021, or 2027).

Under the officially adopted River Basin Management Plan, the River Camac has „Bad

Status‟ and this must be improved to Good Status by the end of 2027. The implementation

of the Programme of Measures developed as part of the River Basin Management Plan is

aimed at achieving this improvement in status. Status is determined on the basis of

physicochemical, ecological and hydromorphological parameters and is determined on a one

out/all out basis (i.e. a failure to meet the criteria for one of these parameters results in an

overall failure to meet Good Status).

The GDSDS states that each Local Authority must develop a works programme for the

management of overflows in networks, which would include a monitoring programme leading

to the development of a detailed capital works programme.

The Local Area Plan provides the opportunity to improve water quality alongside continuing

control measures such as Trade Effluent Discharge Licences which require discharges to

surface water to not compromise water quality. As part of the GDSDS recommendations, it

was recommended that a large scale misconnection survey (both domestic and non-

domestic properties) should be carried out by Dublin City Council

Climate Change

Climate Change will result in a rise in sea levels, and also lead to more flooding especially in

the Naas Road Area, which would increase surface run off into the River Camac. A flood

risk assessment has been carried out as part of the draft Naas Road LAP(see Appendix 1),

and mitigation measures have been put in place, and restrictive policies for developing in

High Risk Flood Areas.

Invasive Species

Japanese Knotweed is known to occur within the LAP lands in Lansdowne Valley Park.

This species can spread rapidly via watercourses as it can successfully establish itself on

river banks when fragments of the plant fall into the water and are carried downstream.

Construction work at sites that contain this species are at risk of spreading this species to

downstream sites/habitats either via adjacent watercourses or by transporting the material

off-site by road. Any construction works at sites where Japanese Knotweed occurs and

which is located along watercourses which are connected to downstream Natura 2000 sites

could pose a risk of spreading this species to these sites.


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2.2.4 Interaction with Other Plans/Projects and Cumulative Effects

Other Dublin City Council Local Area Plans

In terms of the settlement strategy, the Regional Planning Guidelines (RPG) for the

metropolitan area includes a strong policy emphasis on the need to gain maximum benefit

from existing assets such as public transport and social infrastructure, through the

combination of consolidation and increasing densities within the existing built footprint of the

city. Dublin City in this regard lies within the metropolitan area and the RPGs give direction

to Dublin City as the gateway core for high densities, brownfield development, urban

renewal and regeneration. The development plan in this regard incorporates these principles

in a settlement strategy which priorities the inner city, key developing areas, key district

centres and strategic development and regeneration areas. The plan designates 9 key

developing areas, 1 of which is the Naas Road Lands. In the Dublin City Development Plan

2011 -2017, table 3.3 of section 3.2.3 gives estimated capacity of the key developing areas.

In total over the 9 KDAs, an estimated 31,680 new housing units are proposed, and 1,629Ha

of zoned commercial/employment lands. The estimates under the core strategy for the Naas

Road Lands are 2100 housing units and 63 Ha of zoned commercial/employment lands.

The cumulative impact of these plans must be taken into consideration, when assessing the

AA in terms of the cumulative impact of the surface water runoff and waste water discharge.

It should be noted that an Appropriate Assessment and Strategic Environmental Report was

undertaken for the Dublin City Development Plan 2011-2017. Each of the Local Area Plans

will be carrying out their individual AA, and SEA screening reports, but for the purpose of this

report regard will be had to all projects and plans of relevance.

Naas Road Development Framework Study - May 2010 – South Dublin County Council

South Dublin County Council have produced Framework Plan for the Naas Road lands,

2010, which adjoin the Dublin City Council administrative area.

The aim of the Naas Road Development Framework is a flexible, long term strategy that has

the ability to respond to change over a range of issues, topics and scale. One of the key

purposes is to set our strategic objectives and priorities as guiding principles to inform such

things as how they use land, set out new roads networks, and what the area might look like

in the future.

The key elements of the Framework are the maintenance of the existing Green Belt between

Clondalkin and Tallaght; the consolidation of most new development east of the M50, with

mixed uses focused around the existing Red Cow Luas stop, a proposed new Luas stop

between Red Cow and Kylemore as well as the creation of a new „green corridor‟ and new

road links east of the M50. A central element of the scheme is a change to the character of

the Naas Road, especially from the existing Nangor Road/Long Mile Road junction in a city

bound direction. In terms of phasing of this plan (2010 -2016) this would see the

transformation of the Naas Road area starting around the crossing of the Long Mile Road.

This area is closest to the area currently planned by DCC for the Local Area Plan. It is also

at the intersection of the transformed Naas Road and the newly planned linear park. In terms


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of the first phase this would see approximately 5,300 residential units. This plan when it

goes ahead will be the subject of a Strategic Development Zone, and will have to prepare its

own Appropriate Assessment. No SDZ designation has yet been sought by South Dublin

County Council from the DoEHLG.

In terms of the drainage network in South Dublin, this is largely broken down into two areas,

the area draining to the Grand Canal Sewer and the area draining to the Dodder Valley

Sewer. The area draining to the Grand Canal Sewer is served by the 9B Sewer and is

broadly in the area of the Naas Road. The area south of the Naas Road drains to the Dodder

Valley Sewer. South Dublin have planned works in these two catchments which will provide

for future development and reduce the frequency of overflows to receiving waters by the

provision of additional pipelines, pumping stations and detention tanks.

The cumulative effects of the Naas Road LAP draft in combination with South Dublin‟s plan,

would result in extra loading on the Ringsend Treatment Plant. However as the lands in

South Dublin have not yet progressed to being the subject of a either a draft or adopted

statutory plan, it is not be considered by this AA. The current South Dublin County Council

Development Plan 2010-2016, included a policy, (WD2) which states „that development shall

be preceded by sufficient capacity in the public wastewater treatment plants and appropriate

extensions in the existing public wastewater collection systems.‟

3.0. APPROPRIATE ASSESSMENT SCREENING – STAGE 1

3.1 Introduction

The first stage of the appropriate assessment process is screening which identifies the likely

impacts on European Sites of a plan or project either alone or in combination and considers

whether these effects are likely to be significant.

The screening stage requires a review of all Natura 2000 sites that could potentially be

subject to impacts. This NIR has identified that the zone of influence of the plan is no greater

than 15km from the LAP boundary area, based on an examination of links between the plan

and the Natura 2000 network. All Natura 2000 sites within 15km of the plan have been

screened. (See Figure 1). This process has identified which if any of these sites should be

included in Stage 2 of the AA.

3.2 Screening of Natura 2000 Sites within Zone of Influence of the LAP

Each Natura site within a 15km distance of the LAP boundary has been reviewed to

establish whether or not the plan is likely to have a significant effect on the integrity of the

site as defined by its conservation objectives. The qualifying interests of each Natura 2000

site were identified and set out in Table 2. The sensitivities and threats to individual

qualifying interests were assessed with reference The Report on Status on Habitats and

Species in Ireland (NPWS 2008). The potential threats are summarised into the following

categories:

1) Direct Impacts – refers to habitat loss or fragmentation arising from land-take

requirements for development or agricultural purposes. Direct impacts can also be as

a result of a change in land use or management e.g. removal of agricultural practices

that prevent scrub encroachment.


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2) Indirect and secondary impacts –which do not have a direct cause and effect

relationship and are potentially more challenging to assess, ensuring that all the

possible indirect impacts of the plan in combination with other plans and projects

have been established. Deterioration in water quality for example can occur as an

indirect consequence of development which in turn changes the aquatic environment

and reduces its capacity to support certain plants and animals. The introduction of

invasive species for example can also be defined as an indirect impact, which may

result in the transfer of alien species from one area to another.

3) Disturbance to fauna can arise directly through the loss of habitat (e.g. bat roosts) or

indirectly through noise, vibration and increased activity associated with construction

and operation of developments or other activities.

Figure 1 – All Natura 2000 sites within a 15km buffer zone


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Tables 1 and 2 list all Natura 2000 sites within a 15km distance of the LAP boundary area as well as their qualifying interests. Table 1- List of Natura 2000 sites within 15km of Naas Road LAP

1 Downloaded from www.npws.ie are dated 18

th July 2011

Site Code

Site Name Distance (km) from LAP boundary

Qualifying Interests of Natura 2000 Sites1

Special Areas of Conservation*

000206 North Dublin Bay 11.3 Km north east

[1140] Mudflats and sandflats not covered by seawater at low tide [1210] Annual vegetation of drift lines [1310] Salicornia and other annuals colonizing mud and sand [1330] Atlantic salt meadows (Glauco‐Puccinellietalia maritimae) [1395] Petalophyllum ralfsii [1410] Mediterranean salt meadows (Juncetalia maritimi) [2110] Embryonic shifting dunes [2120] Shifting dunes along the shoreline with Ammophila arenaria ("white dunes") [2130] * Fixed coastal dunes with herbaceous vegetation ("grey dunes") [2190] Humid dune slacks

000725 Knocksink Woods 15 Km South east [7220] * Petrifying springs with tufa formation (Cratoneurion) (91EO) Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno‐Padion, Alnion incanae, Salicion albae).

002122 Wicklow Mountains

10.3km South [1355] Lutra lutra (3130) Oligotrophic to mesotrophic standing waters with vegetation of the Littorelletea uniflorae and/or of the Isoëto‐Nanojuncetea [3160] Natural dystrophic lakes and ponds [4010] Northern Atlantic wet heaths with Erica tetralix [4030] European dry heaths [4060] Alpine and Boreal heaths (6230) Species‐rich Nardus grasslands, on siliceous substrates in mountain areas (and submountain areas,in Continental Europe) [7130] Blanket bogs (* if active only) [8110] Siliceous scree of the montane to snow levels (Androsacetalia

http://www.npws.ie/


17

Table 2 - List of Natura 2000 sites within 15km of Naas Road LAP

Site Code

Site Name Distance (km) from proposed development

Qualifying Interests of Natura 2000 Site2

Special Protection Areas**

004006 North Bull Island 11.0 Km north east

Light-bellied Brent Goose (Branta bernicla hrota) [A046] Shelduck (Tadorna tadorna) [A048] . Teal (Anas crecca) [A052] Pintail (Anas acuta) [A054] Shoveler (Anas clypeata) [A056] Oystercatcher (Haematopus ostralegus) [A130] Golden Plover (Pluvialis apricaria) [A140] Grey Plover (Pluvialis squatarola) [A141]

Knot (Calidris canutus) [A143]

Sanderling (Calidris alba) [A144]

2 All SPA qualifying interests obtained from www.npws.ie are dated 16

th April 2012.

alpinae and Galeopsietalia ladani) [8210] Calcareous rocky slopes with chasmophytic vegetation [8220] Siliceous rocky slopes with chasmophytic vegetation [91A0] Old sessile oak woods with Ilex and Blechnum in the British Isles

001209 Glenasmole Valley 8.3Km South (6210)Semi-natural dry grasslands and scrubland facies on calcareous substrates (Festuco Brometalia)(*important orchid sites) (6410)Molinia meadows on calcareous, peaty or clavey-silt-laden soils (Molinion caeruleae) (7220)Petrifying springs with tufa formation (Cratoneurion)

(Conservation Statement 2009)

000210 South Dublin Bay 9.2Km east (1140)Mudflats and sandflats not covered by seawater at low tide

http://www.npws.ie/


18

Dunlin (Calidris alpina) [A149]

Black-tailed Godwit (Limosa limosa) [A156] Bar-tailed Godwit (Limosa lapponica) [A157] Curlew (Numenius arquata) [A160] Redshank (Tringa totanus) [A162] Turnstone (Arenaria interpres) [A169] Black-headed Gull (Larus ridibundus) [A179] Wetlands & Waterbirds [A999]

004024 South Dublin Bay/Sandymount Strand/River Tolka Estuary

8.7 Km east Light-bellied Brent Goose (Branta bernicla hrota) [A046] Shelduck (Tadorna tadorna) [A048] Teal (Anas crecca) [A052] Pintail (Anas acuta) [A054] Shoveler (Anas clypeata) [A056] Oystercatcher (Haematopus ostralegus) [A130] Golden Plover (Pluvialis apricaria) [A140] Grey Plover (Pluvialis squatarola) [A141] Knot (Calidris canutus) [A143] Sanderling (Calidris alba) [A144] Dunlin (Calidris alpina) [A149] Black-tailed Godwit (Limosa limosa) [A156] Bar-tailed Godwit (Limosa lapponica) [A157] Curlew (Numenius arquata) [A160] Redshank (Tringa totanus) [A162] Turnstone (Arenaria interpres) [A169] Black-headed Gull (Larus ridibundus) [A179] Wetlands & Waterbirds [A999]

004040 Wicklow Mountains 10.3 km south Merlin (Falco columbarius)

[A098]

Peregrine (Falco peregrinus)

[A103]

*Candidate Special Areas of Conservation are designated under the EU Habitats Directive

(92/43/EEC) for the protection of certain habitats and species as listed in the Directive. ** Special Protection Areas are designated under the EU Birds Directive (79/409/EEC) (as amended) for the protection of birds as listed in the Directive.


19

There are no Natura 2000 sites within the LAP area, however there are indirect links to some Natura 2000 sites, as the River Camac runs through the LAP lands and this is a tributary of the River Liffey which flows into Dublin Bay. There are a number of Natura 2000 sites within Dublin Bay that could be indirectly affected due to the hydrological connection and downstream location of these sites from the LAP area. These sites are North Dublin Bay SAC, South Dublin Bay SAC , South Dublin Bay/Sandymount Strand/River Tolka Estuary SPA, and North Bull Island SPA. Only these sites are considered to have the potential to be significantly impacted by the LAP. Tables 3 and 4 below summarise the results of AA screening process which identified the Natura 2000 sites for which potential impacts could arise. Full details of the AA screening of the LAP are included in the Appendix A.

Table 3 – Potential for impacts from the Naas Road LAP on Natura 2000 cSAC sites

(sites for which potential impacts are possible are in highlighted rows).

Site ID Site Name Direct

Impacts

e.g.

Habitat

Loss

Indirect

Impacts e.g.

alteration to

the

hydrological

regime

Surface or

ground water

contamination

Disturbance

to Qualifying

Interest

habitats or

species

AA

required

000206 North Dublin Bay

No Yes Yes Yes Yes

000725 Knocksink Woods

No No No No No


No No No No No

001209 Glenasmole Valley

No No No No No

000210 South Dublin Bay

No Yes Yes Yes Yes

Table 4 – Potential impacts of Naas Road LAP on Natura 2000 cSPA sites

Site ID Site Name Direct

Impact

s e.g

Habitat

Loss

Indirect

Impacts e.g

alteration to

the

hydrological

regime

Surface or

ground

water

contaminati

on

Disturbance

to qualifying

interest

habitats or

species

AA

required

004006 North Bull Island

No Yes Yes Yes Yes

004024 South Dublin Bay Sandymount Strand/River Tolka Estuary

No Yes Yes Yes Yes


20


No No No No No

3.3 AA Screening Conclusions

The AA screening process has identified that there is potential for significant impacts (in the

absence of mitigation) to the following four Natura 2000 sites in Dublin Bay;

North Dublin Bay SAC

South Dublin Bay SAC

North Bull Island SPA

South Dublin Bay/Sandymount Strand/River Tolka Estuary SPA

Potential impacts to these four sites are taken forward for detailed assessment in this NIR. All other

sides are not further considered as likelihood of significant impacts on these arising from the LAP has

been ruled out due to the lack of any source-pathway-receptor link between these sites and the LAP.

4.0. APPROPRIATE ASSESSMENT – STAGE 2

4.1 Potential Impacts of LAP on Natura 2000 Sites

Direct Impacts

As the proposed LAP is approximately 8.7km from the closest Natura 2000 sites in Dublin

Bay, there will be no direct impacts on any Natura 2000 site.

Indirect Impacts

The Naas Road LAP lands has hydrological connection to Dublin Bay, as the River Camac

is a tributary of the River Liffey, which ultimately discharges into the Dublin Bay. The

wastewater from the Naas Road lands currently discharges to Dublin Bay. Impacts on

Dublin Bay may arise indirectly through contamination of the water resources which affect

the habitat and invertebrate species, which the birds depend on. The main threat to water

quality is nutrient enrichment of the water (eutrophication). In accordance with the

requirements of the Water Framework Directive and the associated national regulations the

Environment and Heritage Service (EHS) and the Environmental Protection Agency (EPA)

have compiled registers of Protected Areas. The register consists of an inventory of

protected area sites representing the protected area categories

The EPA has classified the Broadmeadow and Liffey estuaries as eutrophic (nutrient

enriched). Eutrophication has been linked to discharges from Waste Water Treatment Plans

at Swords and Ringsend respectively. Despite the problems above, the outer Broadmeadow

estuary shows little evidence of impaired water quality and Dublin Bay itself is currently

classified as non eutrophic. In the GSDSDS report it is noted that the water quality of Dublin

Bay remains high.

Indirect impacts on the water quality of Dublin Bay, through waste water (foul and surface

water) discharges will be avoided by only discharging to the network when there is available

capacity in the Ringsend. Development in the LAP will be on a phased basis, along with the


21

other LAPs; and permission will only be granted in accordance with capacity being available.

The upgrade is due for completion by 2015.

Water supply for the Naas Road area is part of the Dublin Region Water Supply which is

sourced from the Liffey, Dodder and Vartry rivers and is an integrated network covering

Dublin City, and adjoining counties. Currently across the region supply and demand for high

quality drinking water is finely balanced and this will remain the case in the short to medium

term pending the delivery of a number of projects to increase production, storage and

delivery capacity. Projects being implemented include pipe renewal across the region to

reduce leakage as well as demand management measures to encourage water

conservation while the provision of a suitable long term new supply source for the Dublin &

mid-Leinster area is being investigated.

Construction Impacts

During the construction phase of developments there is the potential for an increase in

siltation and runoff which contain polluting substances, from construction sites which could

enter the River Camac and ultimately discharge to the River Liffey and Dublin Bay.

Appropriate mitigation measures and robust construction methodologies will ensure no such

significant impacts on Natura sites occur. The development of the Naas Road lands will

cause an increase in vehicular traffic around the LAP area. Construction on this site will be

on a phased basis and may take up to and beyond 10 years.

However given that no Natura site occurs within the LAP boundary it is considered that there

will be no impact on any Natura 2000 site.

Japanese Knotweed is known to occur within the LAP lands within Lansdowne Valley Park

and at other locations. This species can spread rapidly via watercourses as it can

successfully establish itself on river banks when fragments of the plant fall into the water and

are carried downstream. Construction work at sites that contain this species are at risk of

spreading this species to downstream sites/habitats either via adjacent watercourses or by

transporting the material off-site by road. Any construction works at sites where Japanese

Knotweed occurs and which is located along watercourses which are connected to

downstream Natura 2000 sites could pose a risk of spreading this species to these sites.

Operational Impacts

Provided the waste water treatment systems operate effectively there will be no significant

adverse impact on the water quality of Dublin Bay. The site is adjoining the LUAS tram line

and a QBC, and occupies a strategic location on a gateway point into the city, providing

good public transportation links to the wider metropolitan areas including Dublin City Centre

and Dublin Airport. This will maximise the use of public transport and will be supported by

an increase in number of and quality of cycle lanes in the LAP area.

Dublin Bay is under on-going pressure from increasing levels of urban development. The

main issues in Dublin Bay are water quality due to increasing levels of discharges to Dublin

Bay. The Naas Road LAP has already taken this into consideration in the LAP development

in terms of policies for surface water drainage systems, attenuation on site, green roofs,

green infrastructure network, flood resilient design construction in high risk flood zones, etc.


22

In combination effects

The Masterplan for South Dublin County Councils „Naas Road Development Framework

May‟ 2010, which adjoins the Naas Road lands, sets out a vision for the development of the

adjoining lands to the Naas Road LAP. At present this is only a Framework Plan and does

not have a statutory basis. Provided they mitigate any potential adverse effects on Dublin

Bay, there should be no significant in combination effects. Any statutory plan prepared by

SDCC for this area will be required to follow the required AA process.

In summary the main potentially significant impacts of the Naas Road Plan LAP on Natura

2000 sites, alone or in combination with other plans and projects, are as follows:

1) Possible impacts during the construction and operational phases of developments,

which could have potential adverse effects on water quality (e.g release of silt and/or

pollutants).

2) Uncontrolled or untreated surface run-off or discharge of water and other materials

from site operation.

3) Infrastructural Deficiencies e.g. incapacity of municipal wastewater infrastructures to

cater for additional load

4) Spread of invasive species where they are present on construction sites.

4.2 Summary of Impacts and Mitigation Measures

The range of potential impacts described above arise from the specific objectives and

policies set out in the LAP as is described in detail in the Appendix A. Table 5 below lists

each objective/policy which gives rise to a potential impact on Natura 2000 sites and also

lists the specific mitigation measure which has been included in the LAP to address each

impact.

Table 5 – Potential Impacts and Mitigation Measures

Polices have been given codes for the purposes of this table (see Appendix A Screening

Table)

Policy/Objective giving rise to

potential impact on the integrity of the

four identified Natura 2000 sites within

Dublin Bay

Specific Mitigation (Policies) Including

within LAP to address these potential

impacts

Land Use Strategy

LUS1 - To establish new and appropriate land-

uses that support a thriving employment and

residential hub in recognition of the strategic

nature of the plan area as a Key Developing Area,

Key District Centre, Strategic Development and

Regeneration Area, a gateway to the city and its

location along the Naas Road/Rail trans-boundary

Innovation Corridor.

See policies and objectives contained in the Draft

Naas Road LAP: (see appendix A for codes)

GI10 Any plan or project with the potential to give

rise to significant direct, indirect or secondary

impacts on a Natura 2000 site(s) shall be subject

to an appropriate assessment in accordance with

Article 6(3) of the Habitats Directive

GIO12 During construction/redevelopment of any

sites, developers shall ascertain the extent, if any,


23

of invasive species, and shall demonstrate

measures for their control/removal.

IW2 To ensure that development is permitted in

tandem with available water supply, waste water

treatment and network capacity. To manage and

phase development so that new schemes are

permitted only where adequate capacity or

resources exist or will become available within the

life of a planning permission.

GIO4 All proposals should incorporate the principles of Sustainable Urban Drainage Systems (SuDS) in accordance with the requirements and standards of the City Council‟s Environment and Engineering Department – Drainage and Wastewater Services Division IWO5 To require all relevant proposed

developments to carry out a site specific Flood

Risk Assessment in accordance with the

Departmental Guidelines on Flood Risk

Management and Appendix A1 of this plan. The

flood risk assessment shall accompany the

planning application and should be sufficiently

detailed to quantify the risks and the effects of any

residual mitigation/adaptation together with the

measures needed to manage residual risks.

IWO6 All planning applications shall be required to

submit a surface water drainage plan which will

include proposals for the management of surface

water within sites, protecting the water quality of

the River Camac and retrofitting best practice

SuDS techniques on existing sites where possible

Dublin City Development Plan 2011-2017 Policies Si43, SI44, SI45, SI46, SI51, SI52

Dublin City Development Plan 2011-2017

Objectives

SIO72, SIO73,SI)74, SIO75,SIO76

LUS2 - To develop a vibrant mixed-use core

between the Old Naas Road and Long Mile Road,

along Walkinstown Avenue and Kylemore Road

and adjoining sites.. This shall reinforce this

location as a Key District Centre, with retail,

commercial and residential as the dominant land-

uses.



GI10, GIO12, IW2, GI04, IW05, IW06



Objectives


LUS01 In support of the KDC, to encourage a core See policies and objectives contained in the Draft


24

of mixed uses including higher order retailing in

the specified KDC core positioned between Naas

Road and Long Road – incorporating quality public

realm along new access routes.


GI10, GIO12, IW2, GI04, IW05,IW06



Objectives


LUSO2 To promote investment, economic and

employment growth in the area through the

attraction of commercial office development within

the KDC along the main transport routes, whilst

supporting existing industrial enterprises and

employment uses on Z6 lands



GI10, GIO12, IW2, GI04



Objectives


Economic Development & Employment

ED1 To develop the economic renewal and

revitalisation of the Naas Road Lands plan area as

a dynamic and sustainable employment cluster in

a vibrant mixed-use quarter with a distinct spatial

identity.



GI10, WW2, GI04, IW05, IW06



Objectives


ED3 - To promote and enhance the Naas Road

Key District Centre as a significant employment

centre with a compact mixed-use core by

facilitating the required quality and quantity of

commercial, retail and enterprise floorspace and

encouraging the development of the necessary

support facilities such as business services, cafes,

shops and leisure facilities within a high amenity

environment with permeable grain. The greatest

concentration of employment floorspace will be in

the core of the Key District Centre.



GI10, GIO12, IW2, GI04, IW05, IW06



Objectives


ED4 To promote and facilitate the sustainable

development of the Naas Road Key District Centre

by facilitating an appropriate and adequate range,

quality and quantity of retail floorspace within the

mixed-use core of the Key District Centre



GI10, GIO12, IW2, GI04, IW05,IW06

Dublin City Development Plan 2011-2017 Policies


25

Si43, SI44, SI45, SI46, SI51, SI52


Objectives


ED6 To expand the role of the plan area as a

thriving office district in the western suburbs by

facilitating the required quality and quantity of

commercial development with active ground floor

uses in the mixed use core of the KDC along with

appropriately designed high-end enterprise

development along the main arterial routes into

Dublin City Centre



GI10, GIO12, IW2, GI04, IW05, IW06



Objectives


ED7 To promote and facilitate the intensification of

employment uses across all sectors, including the

growth sectors of digital industries, science, green

technologies whilst providing for some lower-

intensity light industrial and employment uses in

the plan area which have a strong relationship with

existing communities in the vicinity by

consolidating and upgrading existing light

industrial units within the Z6 zoning boundaries



GI10, GI012, IW2, GI04, IW05, IW06



Objectives


ED9 To adopt a flexible approach towards

temporary/short-term uses by promoting such

uses on underutilised and/or vacant lands and

buildings as an interim solution to create vibrancy

and employment potential in the short-term whilst

ensuring that such temporary/short-term uses do

not preclude the realisation of the long-term

economic vision of the plan area as a vibrant,

dynamic employment cluster providing for long-

term, sustainable employment uses



GI10, IW2

EDO1 To facilitate the provision of an anchor food

store within the mixed use core area of the Key

District Centre to serve surrounding communities

and also stimulate commercial development in the

vicinity. It is also an objective that any such anchor

will be supported by a range of smaller retail uses

– providing choice and local retail competition, and

contributing to strong active public realm.






Objectives



26

EDO2 In order to achieve the objectives of the

KDC, to seek the sustainable redevelopment of

identified key sites in accordance with Key Site

Framework Strategies and employment generating

land-uses specified therein.



GI10, IW2



Objectives

SIO72, SIO73,SI074, SIO75,SIO76

ED04 – To promote retail and local services

within the KDC, creating a vibrant and

attractive new centre. To protect the retail

character of the KDC, uses such as

bookmakers, amusements and casino centres,

off-licences and takeaways shall be carefully

managed and if necessary, restricted in

number, so that retail remains the pre-

dominant use. Clustering of such uses shall be

avoided. Such uses shall not be located at

high profile locations and or addressing key

junctions within the LAP area.



GI10, IW2



Objectives

SIO72, SIO73,SI074, SIO75,SIO76

Movement and Access

MA1 To provide for a new high quality pedestrian and cycle network within the LAP area which will connect up existing and new communities and redefine the character of the LAP area; including (i) creation of new segregated green routes within the LAP; (ii) improvement and upgrading of existing routes; and (iii) improvement and increased number of pedestrian/cycle crossings on main roads; and (iv) connect into existing and planned networks surrounding the LAP area.

See policies and objectives contained in the Draft Naas Road LAP: (see appendix A for codes)

GI10, GIO12,GI04

GI9 To support and promote Biodiversity and to support the National Biodiversity Plan 2011 – 2016 and the current Dublin Biodiversity Action Plan 2008-2012. (under review)

GI11 To conserve priority species, habitats and natural heritage features identified in the Dublin City Biodiversity Action Plan 2008 – 2012 for priority conservation measures( This plan is currently under review).

GI013 – To replace all trees removed with an appropriate species, where the removal of street or roadside trees is necessary

MA5-To ensure integration between the LAP lands

with initiatives such as „Smarter Travel‟ and

strategic cycle routes connecting between South

Dublin County Council and Dublin City and to

develop improved connectivity to surrounding

communities including Walkinstown, Ballyfermot,

Drimnagh and Bluebell



GI10, GI04

MAO1 -To create a south-east/north-west linkages

from Long Mile Road and Landsdowne Park to the See policies and objectives contained in the Draft Naas Road LAP: (see appendix A for codes)


27

Naas Road and to the Grand Canal to provide

cycling connections to the Canal Way and to

provide direct links through the LAP to the Luas

and bus services on the Naas Road.

GI10, GIO12,GI9, GI11,GIO13

MAO9 To create a through access in Lansdowne

Valley Park, linking Davitt Road in the north with

the Long Mile Road in the South and also creating

a western access link to Drimnagh Castle and

Walkinstown Avenue,

See policies and objectives contained in the Draft Naas Road LAP: (see appendix A for codes)

GI10, GIO12,GI9, GI11,GIO13

Housing

H3 To seek housing at sustainable densities in

order to create the critical mass of persons to

support existing and proposed infrastructure and

services in the plan area and the environs



GI10, IW2, GI04, IW05, IW06



Objectives


HO1 To facilitate the sustainable development of

approximately 2,100 additional residential units in

the plan area



GI10, IW2, GI04, IW05, IW06



Objectives


Infrastructure and Water Management

IW1 To actively seek the funding and delivery of

key infrastructure including water supply and

waste water to enable development in the Naas

Road Local Area Plan.



GI10, IW2, GI04

GIO7 To pilot and test new green infrastructure

installations in the public realm to boost

biodiversity and improve surface water

management on a number of streets within the

LAP area; including the use of permeable

materials for surfaces, planted roofs and provision

of storm water tree trenches.

WW6 – To encourage provision of suitably high

quality strategic telecommunications including



28

fibre optic, broadband links and utilities (inc. gas

and electricity) infrastructure within the plan area.


GI10, GI04








IWO1 To seek the undergrounding of the 11oKV

and 38KV high voltage overhead cabling

traversing the LAP area. The route for

undergrounding the cables will be assessed by

ESB Networks as part of the overall interaction

with the applicants/developers, and in that event

the cost of the undergrounding of the lines

including associated civil works will be borne by

the developers



GI10, GI04,








Green Infrastructure Bio-diversity and Natural

Heritage

GIO2 To implement restoration works in

Lansdowne Valley Park which could include

removal of concrete channel from the river,

reinstatement of natural riverbank vegetation or

perhaps an area of wetland, and continue the

control of invasive species including the removal

of Japanese knotweed as a priority



GI10, GIO12, GI04, GI01, IW03

Development Plan Policy GC7

GIO3 To look into(see note at base) the feasibility

of relocating the existing pitch and putt course at

Lansdowne Valley Park and provide a high quality

pedestrian and cycle route, linking the Grand

Canal (pNHA) along Davitt Road, through

Lansdowne Valley Park, and linking up with the

Long Mile Road. This combined cycle/pedestrian

route should address security, public lighting and

securing of back gardens



GI10, GIO12, GI01, IW03, IW05


GI06 To facilitate the use of Lansdowne Valley in

accordance with the provisions set out in the

Drimnagh Integrated Area Plan (June 2009),

including (i) to create a safe and accessible

heritage park connecting the canal to Drimnagh

Castle (ii) To improve security and passive

surveillance of the park and integration with

adjacent development areas (iii) to protect and

enhance the setting of Drimnagh Castle (iv) to

protect the bio-diversity of the park and Camac

River, and (V) To open up existing or blocked off

connections through Landsdowne Valley Park to

improve connections to Drimnagh Village, and the

recently upgraded cycleway along the Canal and



GI10, GIO12, GI01, GI11, GI9, IW03, IW05



29

the Luas Stop at Blackhorse Avenue.

GI08 To look into the feasibility of de-culverting

sections of the Camac River, when and if sites

come up for redevelopment.



GI10, GIO12, GI04, GIO9 To carry out a study on the feasibility of placing flood management structures in the River Camac in the Lansdowne Valley Park and the creation of a new wetland area/flood alleviation scheme IWO3 To promote the achievement of good ecological status, good ecological potential and good chemical status for the River Camac by 2027 in accordance with the Water Framework Directive IWO4 To implement the programme of measures for the River Camac set out in the Eastern River Basin District ,River Basin Management Plan 2009 – 2015 Development Plan Policy GC7 Applicants shall demonstrate best practice measures to protect the watercourses from soil, silt or other material during construction and in this regard should liaise with the Eastern Regional Fisheries Board (ERFB)

GIO9 To carry out a study on the feasibility of

placing appropriate flood management structures

in the River Camac in the Lansdowne Valley Park

and the creation of a new wetland area/flood

alleviation scheme. Consultation will be carried

out with the National Wildlife and Parks Services,

Inland Fisheries Ireland and other bodies as

appropriate.



GI10, GIO12, GI04, IW03, IW04 Development Plan Policy GC7

Environmental Sustainability and Sustainable

Design

ES1 Promote and support the Naas Road area as

a mixed use area with new development adding

new housing, commercial and other uses into the

area and to foster a balanced approach to

integrating a wide variety of uses on each street

and block.




Key Sites Chapter 5

RL01 To encourage the sustainable

redevelopment of this key site as part of the

mixed-use core of the Key District Centre

containing mainly office and residential uses with

local scale retail and service uses.



GI10, IW2, GI04


30

MD1 Facilitate the sustainable redevelopment of

this key site with a fine urban grain and a mix of

uses as part of the mixed-use core of the Key

District Centre all at sustainable densities within a

vibrant and interesting environment and

integrating with the wider plan area and the

administrative area of South Dublin County

Council directly adjoining




MDO13 As part of the redevelopment of this site

the 750mm watermain may need to be diverted.

Such a diversion would be at the expense of the

developer(s)



GI10

NSO1 To facilitate the sustainable redevelopment

of this key site with a fine urban grain and a mix of

uses as part of the mixed-use core of the Key

District Centre, all at sustainable densities within a

vibrant and interesting environment and

integrating with the wider plan area



GI10, GIO12, IW2

NSO12 To seek the underground of the 110 KV and 38KV high voltage overhead cabling traversing the LAP area. The route for under-grounding the cables will be assessed by ESB Networks with the applicants/developers, and in that event the cost of the under-grounding of the lines including associated civil works would be borne by the developer(s) and ESB.



GI10, GI04, GI07.

NSO14 As part of the redevelopment of this site

the 750mm watermain may need to be diverted.

Such a diversion would be at the expense of the

developer(s).



GI10,

MDNR01 To develop land uses in accordance with

the accompanying map – framing the Camac

Valley and integrating with adjoining residential

areas. Predominantly residential land uses are

proposed in place of existing industrial lands,

whilst mixed uses and some supporting retail are

sought on the northern side of the site fronting the

N7 road route. New public open spaces will be

provided along the River Camac to support

biodiversity.




MDNR02 To de-culvert that section of the River

Camac on the western side of the site, thereby

providing a new north-south green infrastructure

link and linear park – integrating with other

proposed routes connecting to the wider area



GI10, GIO12, IW2, GI04, GI4, GI5

MDNR03 To resolve key blockages in the existing

Green Infrastructure by expanding Lansdowne

Valley Park and establishing new green routes




31

including ;

a) A new „short-cut‟ east-west route from

Mourne Road in Drimnagh, via

Lansdowne Valley Park, to Naas Road

and Bluebell Luas stop.

b) A link to the south towards Drimnagh

Castle and Long Mile Road

GI10, GI04

GI4 To promote the development of soft

landscaping in public open spaces, where

feasible, in accordance with the principles of

Sustainable Urban Drainage Systems.

GI5 To provide for publicly accessible open

spaces and green infrastructure which contribute

to the amenities of the area and the green

network.

MITIGATION MEASURES

Dublin City Council recognises that the protection and future conservation of designated sites under EU legislation is an important issue for the Local Authority to address, both directly and indirectly. As a result, a comprehensive set of policies and objectives are contained within the Dublin City Development Plan 2011-2017 which are aimed specifically at protecting the rich and diverse natural environment within the City development plan area.

The Naas Road LAP sits within the framework of the Dublin City Development Plan as the

study area is designated as one of nine Key Developing Areas (KDA‟s) to deliver the Core

Strategy of the city plan. Therefore the mitigatory polices and objectives in the Dublin City

Development Plan would also apply to the Naas Road LAP.

Dublin City Development Plan2011-2017 provided specific policies in relation to the

protection and preservation of designated sites under the EU Habitats Directive and the EU

Birds Directive. These policies are as follows:

Policy GC26 To protect flora, fauna and habitats, which have been identified by the Habitats Directive, Birds Directive, Wildlife Act 1976 (as amended), the Flora Protection Order (S.I. no. 84 of 1999), and the European Communities (Natural Habitats) Regulations 1997 (S.I. no. 94 of 1997) Policy GC27 To conserve and manage all Natural Heritage Areas, Special Areas of Conservation and Special Protection Areas identified and designated, or proposed to be designated, by the Department of Environment, Heritage and Local Government. These designations will allow for protection in the event of any approved boundary changes by the Department of Environment, Heritage and Local Government

The following policies, which are set out in the Development Plan, are aimed specifically at

protecting the natural environment within the Dublin City Council administrative area

including LAP area.

Policy GC28 To seek the conservation and management of areas of natural environmental value.


32

Policy GC29 To conserve priority species, habitats, and natural heritage features identified in the Dublin City Biodiversity Action Plan 2008 - 2012 for priority conservation measures. Policy GC30 To have regard to the conservation and enhancement of significant non-designated areas of ecological importance in accordance with development standards set out in this plan. The Dublin City Development Plan also includes additional mitigation measures, in the form

of additional policies and objectives. These additional policies are included in the following

chapters (see also Table 5 Natura Impact Report of the Dublin City Development Plan 2011-

2017):

Making Dublin the Heart of the City Region

Shaping the City

Providing Quality Homes in a Compact City

Greening the City

Connecting & Sustaining the City‟s Infrastructure

Mitigatory policies in the Draft Naas Road LAP and the Dublin City Development Plan 2011-

2017 provide the study area measures to avoid or reduce impact on the Natura 2000 sites.

Numerous other higher-level measures further mitigate potential impacts of the plan. These

measures include EU Directives, National legislation and various guidelines. Principal

among these are the following:

The Habitats Directive (HD): The European Council Directive on the Conservation of

natural habitats and of wild fauna and flora (92/43/EEC) (Habitats Directive)

The Water Framework Directive (WFD): The Water Framework Directive 2000/60/EC

The National Biodiversity Plan (NBP): UN Convention on Biological Diversity 1992 -

National Biodiversity Plan 2011 is as a result of this.

The Wildlife Act (WA): Wildlife Act 1976 and Wildlife (Amendment) Act 2000 (Wildlife

Act)

The Birds Directive (BD): The 1979 European Council Directive on the Conservation

of Wild Birds (79/409/EEC) (Birds Directive)

The Ramsar Convention (R): Convention on Wetlands of International Importance

(Ramsar)

The Bathing Water Directive (BW): Bathing Water Directive (76/160/EEC)

The Urban Waste Water Treatment Directive (WW): (91/271/EEC) (amended by

Directive 98/15/EEC)

S.I. No. 275 of 2010 European Communities (Conservation of Wild Birds (Baldoyle

Bay Special Protection Area 004016)) Regulations 2010


33

4.3 APPROPRIATE ASSESSMENT CONCLUSION

With the implementation of the mitigating policies, the LAP for the Naas Road will not result

in any significant long-term impacts on Natura 2000 sites. Potential source-pathway receptor

linkages with Natura 2000 sites were identified in Dublin Bay, with the potential pathway

being effluent discharge into Dublin Bay via discharge from the Ringsend Wastewater

Treatment Plant into Dublin Bay. This impact was ruled out with the inclusion of the specific

policy that any future development will be dependent on the necessary service infrastructure

being in place and will be subject to the normal statutory planning approval process. Where

the necessary capacity or infrastructure has not been provided, future development will not

be progressed until the necessary upgrades have been completed. The LAP will include the

necessary policy safeguards and standards to ensure that no negative significant

environmental effects will arise singularly or in a cumulative manner. There is a

commitment under the Dublin City Development Plan 2011 – 2017 to which the LAP must be

consistent to „provide additional and improved wastewater treatment capacity by the

upgrading of the Ringsend Waste Water Treatment Plant (Objective S145). The Draft Naas

Road LAP includes a phasing programme which will ensure that development will only be

carried out when the capacity is available at the Ringsend Plant, and also due to the

requirements of Trade Effluent Licences in line with the upgraded operation of the

wastewater treatment plant this will ensure that the water quality of the Natura 2000 sites will

not deteriorate as a result of the development of the Naas Road Lands.

The implementation of the Naas Road LAP, with its specific policies, for surface and foul

waste water treatment, together with the proposed increased capacity of the Ringsend

Treatment Plan by 2015 to cater for effluent discharge, is likely to improve the existing water

quality entering Dublin Bay.

Additional potential source-pathway-receptor linkages with Natura 2000 sites were identified

in Dublin Bay, with the potential pathway being surface water discharge into Dublin Bay

during both construction and operation of new developments in the plan area. These

impacts were ruled out with the inclusion of specific policies requiring that all development

proposals will require assessment as per Article 6 of the Habitats Directive (i.e. screening for

AA and if necessary an actual AA) as part of the consent process, and policies requiring

proposals for the attenuation and treatment of surface water run-off during the operation of

future developments.

The final source-pathway-receptor linkages with Natura 2000 sites in Dublin Bay was the

potential for construction works to spread invasive species in the area downstream into the

sites. This impact was ruled out with the inclusion of a specific policy requiring that all

development proposals will require assessment as per Article 6 of the Habitats Directive (i.e.

screening for AA and if necessary an actual AA) as part of the consent process.

Any in combination effects with the other Local area plans, including the Masterplan for

South Dublin County Council Naas Road Lands, are unlikely to have a potential significant

adverse impacts on Dublin Bay. Since the South Dublin Plan is not yet a draft or adopted

statutory plan, it is not considered in this NIR. This will be the subject of a separate AA

when a new statutory plan is prepared for the area.


34

Therefore it is concluded that with the inclusion of relevant mitigating policies in the LAP

there is no potential for significant effects arising from the Naas Road LAP 2011 plan either

alone or in combination with other LAPs.


35

5. 0 References

In preparing this Appropriate Assessment Screening regard has been had to the following

documents:

National Parks & Wildlife Service (2008) The Status of EU Protected Habitats and

Species in Ireland

European Commission (2000) Managing Natura 2000 Sites. The provision of Article

6, of the Habitats Directive 92/43/EEC

European Commission (2001) Assessment of Plans and Projects significantly

affecting Natura 2000 sites, Methodological guidance on the provision of Article 6(3)

and (4) of the Habitats Directive 92/43/EEC

Department of the Environment Heritage and Local Government (DEHLG) Circular

Letter SEA 1/08 & NPWS 1/08 , dated 15.2.2008

Department of the Environment Heritage and Local Government (DEHLG)

Appropriate Assessment of Plans and Projects in Ireland, Guidance for Planning

Authorities 2009, Updated and published in February 2010

Department of the Environment Heritage and Local Government (DEHLG) Circular

Letter NPWS 1/10 and PSSP 2/10 dated 11th March 2010

Planning and Development (Amendment) Act , 2010


36

Appendix A

Screening of all LAP Policies/Objectives


37

Table 1 Final Habitats Directive Screening of Naas Road Local Area Plan 2012-2018 Policies

Note: Many polices and objectives have been screened out on the basis that a previous overarching

policy/objective deals with the quantum of development, and construction related impacts

Mitigation measures have been put in place for the overarching policies/objectives that have been

screened in.

Policy

Land Use Strategy- Policies

Potential Impact on the integrity of the Identified Natura 2000 sites

Screen In / Out Reason for Screening In / Out

LUS1 -To establish new and

appropriate land-uses that support a thriving employment and residential hub in recognition of the strategic nature of the plan area as a Key Developing Area, Key District Centre, Strategic Development and Regeneration Area, a gateway to the city and its location along the Naas Road/Rail trans-boundary Innovation Corridor.

yes

In

Potential for construction related impacts for any development/construction works due to potential for silt and/or pollutants to enter the surface water network during works

In the absence of knowing where the exact locations are for invasive species, all major development has the potential to spread invasive species by construction work, for any works in areas where invasive species are know to occur

Potential for additional loadings from foul effluent and/or surface waters during operation.

LUS2 - To develop a vibrant mixed-

use core between the Old Naas Road and Long Mile Road, along Walkinstown Avenue and Kylemore Road and adjoining sites.. This shall reinforce this location as a Key District Centre, with retail, commercial and residential as the dominant land-uses.

yes

In


In the absence of knowing where the exact locations are for invasive species, all major development


38

has the potential to spread invasive species by construction work, for any works in areas where invasive species are know to occur


Land Use Strategy- Objectives



LUSO1 – In support of the KDC, to

encourage a core of mixed uses including higher order retailing in the specified KDC core positioned between Naas Road and Long Road – incorporating quality public realm along new access routes.

Yes

In




LUS02 To promote investment, economic and employment growth in the area through the attraction of commercial office development within the KDC along the main transport routes, whilst supporting existing industrial enterprises and employment uses on Z6 lands

Yes

In


In the absence of knowing where the exact locations are for invasive species, all major development


39

has the potential to spread invasive species by construction work, for any works in areas where invasive species are know to occur


LUSO3- To develop a new

sustainable neighbourhood inclusive of residential development at sustainable densities, underpinned by quality social infrastructure all within a high quality public domain

Yes

Out

See Note at top of table.

Economic Development and Employment - Policies



ED1 - To promote the economic

renewal and revitalisation of the Naas Road Lands plan area as a dynamic and sustainable employment cluster in a vibrant mixed-use quarter with a distinct spatial identity.

Yes

In



ED2 - To foster linkages with existing

and emerging employment hubs in the vicinity, including those in South Dublin County Council, developing a critical mass of employment and enterprise clustering as part of the city-region‟s Naas Road-Rail Innovation Corridor .

No

Out

See note at top of table

ED3 - To promote and enhance the

Naas Road Key District Centre as a significant employment centre with a compact mixed-use core by facilitating the required quality and quantity of commercial, retail and enterprise floorspace and encouraging the development of the necessary support facilities such as

Yes

In

Potential for construction related impacts for any development/construction works due to potential for silt and/or pollutants to enter the surface water network


40

business services, cafes, shops and leisure facilities within a high amenity environment with permeable grain. The greatest concentration of employment floorspace will be in the core of the Key District Centre.

during works



ED4 -To promote and facilitate the

sustainable development of the Naas Road Key District Centre by facilitating an appropriate and adequate range, quality and quantity of retail floorspace within the mixed-use core of the Key District Centre

Yes

In




ED5 - To promote and facilitate the

sustainable development of smaller-scale, neighbourhood retail facilities in locations that are locally accessible and conveniently serve businesses and local residential communities on foot or by bicycle. These retail services should provide choice and be in a quality environment to cater for the regular needs of the local communities

No

Out

No potential impacts

ED6 To expand the role of the plan

area as a thriving office district in the western suburbs by facilitating the required quality and quantity of

Potential for construction related impacts for any development/construct


41

commercial development with active ground floor uses. In the mixed use core of the KDC along with appropriately designed high-end development along the main arterial routes into Dublin City Centre

Yes In ion works due to potential for silt and/or pollutants to enter the surface water network during works


Potential for additional loadings from foul effluent and/or surface waters during operation


intensification of employment uses across all sectors, including the growth sectors of digital industries, science, green technologies whilst providing for some lower-intensity light industrial and employment uses in the plan area which have a strong relationship with existing communities in the vicinity by consolidating and upgrading existing light industrial units within the Z6 zoning boundaries

Yes

In





growth of affordable and flexible, small-to-medium sized enterprises, start-up incubator businesses and units and entrepreneurial activity

No

Out

See Note at top of table


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ED9 -To adopt a flexible approach

towards temporary/short-term uses by promoting such uses on underutilised and/or vacant lands and buildings as an interim solution to create vibrancy and employment potential in the short-term whilst ensuring that such temporary/short-term uses do not preclude the realisation of the long-term economic vision of the plan area as a vibrant, dynamic employment cluster providing for long-term, sustainable employment uses

Yes

In



Economic Development and Employment – Objectives



EDO1 - To facilitate the provision of

an anchor food store within the mixed use core area of the Key District Centre to serve surrounding communities and also stimulate commercial development in the vicinity. It is also an objective that any such anchor will be supported by a range of smaller retail uses – providing choice and local retail competition, and contributing to strong active public realm.

Yes

In



Potential for additional loadings from foul effluent and/or surface waters during operation. Potential for additional loadings from foul effluent and/or surface waters during operation.

EDO2 -In order to achieve the

objectives of the KDC, to seek the sustainable redevelopment of identified key sites in accordance

Potential for construction related impacts for any development/construct


43

with Key Site Framework Strategies and employment generating land-uses specified therein.

Yes

In

ion works due to potential for silt and/or pollutants to enter the surface water network during works


EDO3 – To promote the key

economic role of the area as a site for new investment and employment. .

No

Out


ED04 – To promote retail and local services within the KDC, creating a vibrant and attractive new centre. To protect the retail character of the KDC, uses such as bookmakers, amusements and casino centres, off-licences and takeaways shall be carefully managed and if necessary, restricted in number, so that retail remains the pre-dominant use. Clustering of such uses shall be avoided. Such uses shall not be located at high profile locations and or addressing key junctions within the LAP area.

Yes In Potential for construction related impacts for any development/construction works due to potential for silt and/or pollutants to enter the surface water network during works


Movement and Access Policies



MA1 - To provide for a new high

quality pedestrian and cycle network within the LAP area which will connect up existing and new communities and redefine the character of the LAP area; including (i) creation of new segregated green routes within the LAP; (ii) improvement and upgrading of existing routes; and (iii) improvement and increased number of pedestrian/cycle crossings on main roads; and (iv) connect into existing and planned networks surrounding the LAP area.

Yes

In


In the absence of knowing where the exact locations are for invasive species, all major development has the potential to spread


44

invasive species by construction work, for any works in areas where invasive species are know to occur.

MA2 - Increase permeability to

existing public transport routes by providing attractive, legible and direct walking and cycling links to bus and Luas stops.

No

Out


MA3 -To protect the role of the key

strategic roads within the LAP area so that they continue to serve and benefit the City economically, whilst also seeking visual improvements to these routes so that they are more urban in character, and provide better movement for the public bus services utilising them.

No

Out


MA4 -Ensure that sustainable

development within the LAP area is cognisant of the proximity of the LAP area to the City and to existing and future public transport infrastructure and that residential densities, access points, layouts, are compatible with this.

No

Out


MA5 -To ensure integration between

the LAP lands with initiatives such as „Smarter Travel‟ and strategic cycle routes connecting between South Dublin County Council and Dublin City and to develop improved connectivity to surrounding communities including Walkinstown, Ballyfermot, Drimnagh and Bluebell

Yes

In



Movement and Access Objectives



MAO1 -To create a south-east/north-

west linkages from Long Mile Road and Landsdowne Park to the Naas Road and to the Grand Canal to provide cycling connections to the Canal Way and to provide direct links

Yes

In

Potential for construction related impacts for any development/construction works due to potential for silt and/or


45

through the LAP to the Luas and bus services on the Naas Road.

pollutants to enter the surface water network during works

MAO2 - To create new pedestrian

and cycle linkages on an east west axis connecting Robinhood Road through the key sites to Landsdowne Valley , Naas Road and Long Mile Road (see Chapter 5 for details)

No

Out


MAO3 -To seek the delivery of

improved pedestrian and cycle environments, with green infrastructure along Kylemore Road, Walkinstown Avenue and Long Mile Road. New vehicular access points onto the Naas Road cannot be accommodated as this would impact on the strategic role of this important route. (see section 4.8 for further details)

No

Out


MAO4 -To implement pedestrian

infrastructure improvements along the Naas Road to facilitate and increase opportunities for crossing the carriageway.

No

Out


MAO5- To identify funding for key

movement and access enhancements through the 'Sustainable Transport Measures Grants' system and other measures operated by the National Transport Authority with a view to prioritising a number of improvements proposed in this LAP that will interlink with existing projects.

No

Out


MAO6 -To provide good quality end

of trip facilities to encourage walking and cycling such as secure and weather proof bike stands, lockers, showers, changing and drying rooms.

No

Out


MAO7 To ensure that all new routes

whether inclusive of those accommodating traffic shall be designed and constructed in a manner that will facilitate the safe and easy movement of pedestrians and cyclists

No

Out


MAO8 To work with all relevant

providers to facilitate a quality bus, pedestrian and cycling link on a north-south axis (Kylemore Road/Walkinstown Avenue), with orbital capability and associated interchange potential between bus, heavy rail and Luas.

No

Out


MAO9 To create a through access in

Lansdowne Valley Park, linking Davitt Road in the north with the Long Mile Road in the South and also creating a western access link to Drimnagh

Yes

In

Potential for construction related impacts for any development/construction works due to


46

Castle and Walkinstown Avenue. potential for silt and/or pollutants to enter the surface water network during works

Potential to spread invasive species by construction work, for any works in areas where invasive species are know to occur

MAO10 To facilitate works along the

Naas Road that will reduce traffic impact and improve safety for pedestrian and cycle users and facilitate improved linkages. This may comprise landscaping works, public realm enhancement reconfiguration of the carriageway and provision of a direct pedestrian crossing across the Naas Road.

No

Out


MAO11 Car parking provision shall

reflect the accessible nature of the area via public transport both existing and proposed, with the quantity determined in consultation with the Planning Authority through a Transport Assessment prepared as part of the planning process.

No

Out


MAO12 To foster and support a

proactive mobility management approach and a culture of sustainable travel in new and existing developments.

No

Out


Urban Form , Design and Public Realm Policies



UF1 To redefine, through the

progressive creation of smaller plot layouts and implementation of appropriate urban design measures, the existing built fabric of large impermeable sites centred on the Naas Road, and to develop an urban structure that is distinctive and effectively integrated into the wider urban context in terms of street layout and permeability

No

Out

No Potential Impacts

UF2 To promote active and diverse

land-uses at selected locations particularly at ground floor level in the vicinity of the KDC, and to ensure day long activity by encouraging convenient pedestrian access to these uses via new links.

No

Out



47

UF3 Having regard to the planned

delivery of mixed uses on key sites, to ensure clear demarcation between public, private and semi-private realms.

No

Out


UF4 To promote „green‟ public realm

through the incorporation of street trees, vegetation and SuDS measures into new developments(see also Green Infrastructure Chapter)

Yes

Out

Positive Impacts only

UF5 – To minimise the adverse impacts of noise and promote good health for the existing and future residents of the plan area through the effective management of noise in line with the Dublin Agglomeration Noise Action Plan.

No Out No potential impacts

Urban Form , Design and Public Realm Objectives



UFO1 To provide for building heights

on redevelopment sites in accordance with indicative heights set out in the height Strategy (see section 4.5.3 and Map 4.6) .


UFO2 To pursue objectives of key

site framework development strategies to improve urban structure, provide for new and appropriate land-uses and revised building heights


UFO3 To seek the sustainable

development of the Key District Centre focused on an urban boulevard and incorporating quality public realm. Central units at ground floor level fronting public areas shall be of fine urban grain and quality materials.


UFO4 Any landmark buildings will be

characterised by high architectural quality, designed with the specific location/position and land uses in mind.


UFO5 With particular reference to

proposed buildings alongside (and visible from) the Naas Road, these shall demonstrate a degree of design consistency – both in terms of height, general design and materials.


UFO6 To ensure that service

infrastructure provision (water, sewerage, electricity cable ducting, flood risk measures) is planned, phased and provided in a sequential manner that will allow for the realisation of planned layouts.



48

Housing Policies



H1 To encourage and foster the

sustainable development of high-quality, energy efficient residential accommodation in the area as a key component of a vibrant mixed-use area.

Yes

Out

See Note at top of table

H2 To ensure that all new housing

delivers high quality residential environments and protects the residential amenity of existing residential development in the plan area and its environs

No

Out


H3 To seek housing at sustainable

densities in order to create the critical mass of persons to support existing and proposed infrastructure and services in the plan area and the environs

Yes

In



H4 To encourage active ground floor

uses and prevent residential uses at ground floor level facing busy streets to ensure a vibrant streetscape and good residential amenity.


H5 To seek a mix of housing

typologies within residential developments and also in larger mixed use schemes.


H6 To facilitate and encourage the

provision of live-work units to enable people to work from home, particularly artists, small enterprise operators and start-up businesses


Housing Objectives



HO1 To facilitate the sustainable

development of approximately 2,100 additional residential units in the plan

Potential for construction related impacts for any


49

area

Yes

In

development/construction works due to potential for silt and/or pollutants to enter the surface water network during works


HO2 To facilitate and encourage new

residential development in accordance with Development Plan residential quality standards. Specific objectives (including indicative layout objectives) of site briefs shall apply where applicable – see Chapter 5

No

Out

See note at top of table

Built Heritage & Conservation Policies

Potential Impact on the integrity of the Identified Natura 2000 sites?


BH1 To safeguard the character and

setting of heritage sites in the LAP area and to promote the conservation, enhancement and enjoyment of built heritage, in tandem with the regeneration of the area.

No

Out


BH2 Over the period of the LAP, to

realise visual and pedestrian links between heritage sites/structures and the evolving urban form through setting relevant objectives.

No

Out


Built Heritage & Conservation Objectives



BHO1 To enhance the setting of

Drimnagh Castle and to ensure that any development to the west (north of Long Mile Road) is appropriately designed to increase its accessibility from these lands and from nearby green infrastructure.

No

Out


BHO2 To enhance and protect

Drimnagh Castle & Bluebell Cemetery by considering their topography, particularly in relation to the River Camac - when creating linkages and routes within the area and developing their potential as educational and tourist attractions.

No

Out


BHO3 To ensure that future uses of

the former Volkswagen factory (now Mercedes), a Protected Structure, takes place in a manner that


50

respects both the significance of the setting and the scale/design of the protected elements of the building.


BHO4 To protect historic road routes

within the LAP area where appropriate, and to seek that related heritage features such as stone walls or gate pillars, are retained where they have potential to contribute positively towards future development

No

Out


BHO5 To explore the possibility of an

extension to the city centre east-west heritage routes, linking to Drimnagh Castle and incorporating nearby industrial heritage

No

Out


Infrastructure and Water Management


Screen In / Out

Reason for Screening In / Out

IW1 To actively seek the funding

and delivery of key infrastructure including water supply and waste water to enable development in the plan area.

Yes

In

Dual Positive and Negative



IW2 To ensure that development is

permitted in tandem with available water supply, waste water treatment and network capacity. To manage and phase development so that new schemes are permitted only where adequate capacity or resources exist or will become available within the life of a planning permission.

Yes

Out

Positive Impacts only

IW3 To require that all large

development proposals include water conservation and demand management measures

Yes Out Positive Impacts only

IW4 To protect existing

infrastructure by ensuring through consultation with Dublin City Council that buildings and structures will be designed and

No Out Positive impacts only


51

constructed so that they do not compromise the structural integrity of trunk watermains in the area, drainage pipes, gas mains, overhead cables, and other services.

IW5 To seek to improve water

quality and meet the objectives of the Eastern River Basin District Management Plan by ensuring the separation of foul and surface water effluent through the provision of separate sewage networks in any new permission, and ensure the implementation of a stormwater management system in the detailed design of the plan lands, following the principles of Sustainable Urban Drainage Systems (SuDS).

Yes Out Positive impacts only

IW6 To encourage provision of

suitably high quality strategic telecommunications including fibre optic, broadband links and utilities (inc. gas and electricity) infrastructure within the plan area.

Yes In Construction Related impacts

Infrastructure and Water Management Objectives


Screen In / Out


IWO1 To seek the undergrounding

of the 11oKV and 38KV high voltage overhead cabling traversing the LAP area. The route for undergrounding the cables will be assessed by ESB Networks as part of the overall interaction with the applicants/developers, and in that event the cost of the undergrounding of the lines including associated civil works will be borne by the developers


|IWO2 To provide a new HV

substation as part of the redevelopment of the LAP lands to meet the level of demand. A suitable location for this to be provided for in the LAP area.

No Out No potential impact

IWO3 To promote the achievement

of good ecological status, good ecological potential and good chemical status for the River Camac by 2027 in accordance with the Water Framework Directive.

Yes Out Positive impact only

IWO4 To implement the

programme of measures for the River Camac set out in the Eastern River Basin District ,River Basin Management Plan 2009 - 2015

Yes Out Positive Impact only

IWO5 To require all relevant

proposed developments to carry Yes Out Positive impact only


52

out a site specific Flood Risk Assessment in accordance with the Departmental Guidelines on Flood Risk Management and Appendix A1 of this plan. The flood risk assessment shall accompany the planning application and should be sufficiently detailed to quantify the risks and the effects of any residual mitigation/adaptation together with the measures needed to manage residual risks.

IWO6 All planning applications shall

be required to submit a surface water drainage plan which will include proposals for the management of surface water within sites, protecting the water quality of the River Camac and retrofitting best practice SuDS techniques on existing sites where possible


IWO7 - Each of the key sites

identified in Chapter 5 must provide for local recycling facilities. Large retail site must provide a glass recycling facility.


IW08 – To implement, in conjunction with the Health and Safety Authority , the provisions of the Seveseo ii (COMAH) Directive and to have regard to the provisions of the directive and the recommendations of the HAS in the assessment of all planning applications location on or impacted by such sites.

No Out No Potential impacts.

Green Infrastructure, Bio-Diversity & Natural Heritage Policies


Screen In / Out


GI1To seek opportunities to

increase the provision of tree planting on streets within the LAP area to improve amenity, increase opportunities for wildlife and contribute to improvements in air and water quality and water attenuation


GI2 To ensure that in new

residential developments, public open space is provided which is sufficient in quantity and distribution to meet the requirements of the projected population including play facilities for children.


GI3 To support the provision of

community gardens, allotments ,local markets, pocket parks, where feasible and in particular as temporary uses on vacant



53

under utilised or derelict sites in the LAP lands.

GI4 To promote the development

of soft landscaping in public open spaces, where feasible, in accordance with the principles of Sustainable Urban Drainage Systems.


GI5 To provide for publicly

accessible open spaces and green infrastructure which contribute to the amenities of the area and the green network.


GI6 Encourage the development

of podium and courtyard gardens as part of the provision of semi-private and private open space within the LAP area to increase opportunities for biodiversity and the enhancement of the local environment.


GI7 To support and liaise with

South Dublin County Council in relation to their open space strategy proposed in the „Naas Road Development Framework Plan (2010), and to support continuity of linkages across the administrative boundary.


GI8 To recognise the importance of Drimnagh Castle and protect views and vistas, and to improve linkages to the Landsdowne Valley park.


GI9 To support and promote Biodiversity and to support the National Biodiversity Plan 2011 – 2016 and the current Dublin Biodiversity Action Plan 2008-2012. (under review)


GI10 Any plan or project with the potential to give rise to significant direct , indirect or secondary impacts on a Natura 2000 site(s) shall be subject to an appropriate assessment in accordance with Article 6(3) of the Habitats Directive


GI11 To conserve priority species, habitats and natural heritage features identified in the Dublin City Biodiversity Action Plan 2008 – 2012 for priority conservation measures( This plan is currently under review).


GI12 – To protect areas of particular flora, fauna and habitat value that have no specific designation but nonetheless contribute to the environmental and ecological diversity of the area and require recognition as such and for all development to



54

be in accordance with policies GC26, GC28 and GC30 of the City Development Plan

Green Infrastructure, Bio-Diversity & Natural Heritage Objectives


Screen In / Out


GIO1 To continue to implement

biodiversity enhancement plans for Lansdowne Valley Park, Walkinstown Park and Bluebell Cemetery.


GIO2 To implement restoration

works in Lansdowne Valley Park which could include removal of concrete channel from the river, reinstatment of natural riverbank vegetation or perhaps an area of wetland, and continue the control of invasive species including the removal of Japanese knotweed as a prioity.

Yes In

Dual positive and negative

Construction impacts

GIO3 To look into(see note at

base) the feasibility of relocating the existing pitch and putt course at Lansdowne Valley Park and provide a high quality pedestrian and cycle route, linking the Grand Canal (pNHA) along Davitt Road, through Lansdowne Valley Park, and linking up with the Long Mile Road. This combined cycle/pedestrian route should address security, public lighting and securing of back gardens. An ecological survey including a study of rare/protected species shall inform these works.



GIO4 All proposals should

incorporate the principles of Sustainable Urban Drainage Systems (SuDS) in accordance with the requirements and standards of the City Council‟s Environment and Engineering Department – Drainage and Wastewater Services Division


GIO5 To designate Lansdowne

Valley as an outdoor resource centre in light of its varied habitats and potential for learning in a number of disciplines. To this end the Council will engage the interests and energy of the local communities, schools and in particular the educational expertise of the City of Dublin VEC.

Yes out No potential impacts

GI06 To facilitate the use of

Lansdowne Valley in accordance with the provisions set out in the Drimnagh Integrated Area Plan

Yes In Potential for construction related impacts for any development/construction works due to potential for silt


55

(June 2009), including (i) to create a safe and accessible heritage park connecting the canal to Drimnagh Castle (ii) To improve security and passive surveillance of the park and integration with adjacent development areas (iii) to protect and enhance the setting of Drimnagh Castle (iv) to protect the bio-diversity of the park and Camac River, and (V) To open up existing or blocked off connections through Landsdowne Valley Park to improve connections to Drimnagh Village, and the recently upgraded cycleway along the Canal and the Luas Stop at Blackhorse Avenue.

and/or pollutants to enter the surface water network during works

GIO7 To pilot and test new green

infrastructure installations in the public realm to boost biodiversity and improve surface water management on a number of streets within the LAP area; including the use of permeable materials for surfaces, planted roofs and provision of storm water tree trenches.


GIO8 To look into the feasibility

of de-culverting sections of the Camac River, when and if sites come up for redevelopment.

Yes In Dual Positive & Negative impacts &



GIO9 To carry out a study on the

feasibility of placing appropriate flood management structures in the River Camac in the Lansdowne Valley Park and the creation of a new wetland area/flood alleviation scheme. Consultation will be carried out with the National Wildlife and Parks Services, Inlands Fisheries Ireland and other bodies as appropriate.

Yes In Dual Positive & negative

Impacts

Potential for construction

related impacts for any

development/construction

works due to potential for silt

and/or pollutants to enter the

surface water network during

works

Potential to spread invasive

species by construction work,

for any works in areas where

invasive species are know to


56

occur

GIO10 To continue to develop

Walkinstown Park in accordance with objective GC040 of the Development Plan, including (i) remove the derelict tarmacadam surface, (ii) provide for two MUGA pitches,(iii) provide a large diverse playground to meet the recreational needs of the local community, subject to available funding, and (iv) increase the biodiversity landscaping particularly along the river.


GIO11 To support the Drimnagh

Sli na Slainte route from the Grand Canal through the Landsdowne Valley Park as park of the Drimnagh Smarter Travel Plan , and to encourage this route as a new Sports Spine, & Heritage Trail through the Park, linking up with the Grand Canal and wider city green routes, and Drimnagh Castle


GIO12

During construction/redevelopment of any sites, developer(s) shall ascertain the extent, if any, of invasive species, and shall demonstrate measures for their control/removal.


GI013 – To replace all trees

removed with an appropriate

species, where the removal of

street or roadside trees is

necessary


Social & Educational Infrastructure and Culture Policies


Screen In / Out


SE1 Encourage the Naas Road

KDC to become a focal point for the integrated delivery of accessible and multi-functional social infrastructure and community services


SE2 To seek to ensure the

provision of a range of environmentally sustainable social infrastructure and social services in the Naas Road KDC



57

that are accessible, cater for all age groups and serve the existing and proposed communities.

SE3To establish new and

appropriate landuses that assist in creating relationships between one another and support a growing mixed-use community


SE4 To facilitate the provision of

educational facilities in the plan area by way of an integrated approach between the Department of Education and Skills (DES), school authorities and the City Council


SE5 To seek to foster a new

culturally vibrant neighbourhood in the Naas Road lands plan area, linking in with residential areas adjoining, based on a sustainable form of cultural provision founded and managed within the local community


SE6 To encourage the

development of cafes /restaurants/retail facilities along key routes linking cultural facilities

No Out See note at top of table

Social & Educational Infrastructure and Culture Objectives


Screen In / Out


SEO1 Link the plan area, by way

of green routes and sharing of social infrastructure, with the surrounding neighbourhoods


SEO2 To facilitate improved

connectivity to existing schools within and adjoining the plan area through the opening up of new routes, including proposals in site-specific development briefs.


SEO3 To promote innovative

proposals that create a landmark destination within the city for combined facilities of a recreational, leisure and sports nature


SEO4 To encourage vibrancy and

activity in this KDA by facilitating temporary / interim and permanent leisure uses whilst also ensuring the protection of residential amenities. Such leisure uses could include a cinema, theatre, indoor sports facilities and gyms, play spaces,



58

skateboard parks, dance studios, roller discos/ice rinks, etc.

SEO5 Promote and facilitate the

use, including temporary use, of vacant commercial spaces and sites, for a wide range of uses, including cultural uses


Environmental Sustainability and Sustainable Design Policies


Screen In / Out


ES1 Promote and support the

Naas Road area as a mixed use area with new development adding new housing, commercial and other uses into the area and to foster a balanced approach to integrating a wide variety of uses on each street and block.

Yes In Potential for construction


development/construction

works due to potential for silt

and/or pollutants to enter the

surface water network during

works

Potential to spread invasive

species by construction work,

for any works in areas where

invasive species are know to

occur

Potential for additional

loadings from foul effluent

and/or surface waters during

operation

ES2 Seek that new developments

utilise state of the art energy efficiency techniques and best practice technologies to reduce resource consumption of the earth's resources and promote environmental sustainability.


ES3 Through design to enable

opportunities within the form, use mix and orientation of the buildings to maximise solar gain and minimise heat loss.


ES4 Promote the use of

environmentally sustainable technologies and facilities within any development in the LAP area such as the inclusion of CHP (Combined heat and power) units on site, community recycling facilities, grey water collection facilities, green roofs and green walls.


ES5 Given the prevalence of

large sites, seek opportunities within larger block developments to create efficiency in energy consumption both in buildings,



59

blocks and in use of public transport, with future proofing of systems to facilitate district wide schemes in the future.

ES6 Building design will give

careful consideration to the design and arrangement of buildings on a site in relation to the development of a microclimate. New developments should be future proofed to aid in the conservation of energy and to maximize solar gain and renewable technologies.


ES7 All buildings, including

housing units should incorporate flexibility in form and internal design available in the area in terms of size and tenure. Building design and technology used should be flexible and allow for adaptation and for change of use in the long term. A building should not become obsolete on cessation of an activity, but should be capable of facilitating new activities without onerous renovation in order to conserve “embedded energy”.


ES8 Promote the use of

environmentally sustainable

materials in the construction of

any development in the LAP area.


Chapter 5 Royal Liver Business

Park

Potential Impact

on the integrity of

the Identified

Natura 2000

sites?

Screen In /

Out


RLO1 To encourage the

sustainable redevelopment of this key site as part of the mixed-use core of the Key District Centre containing mainly office and residential uses with local scale retail and service uses.



RLO2 To provide for a boulevard

leading to a pocket park and pedestrian and cycling connections through the site to increase connectivity and deliver the green infrastructure network



60

of the LAP.

RL03 To provide for a sustainable

approach to height within the site, with buildings addressing the Naas Road and Kylemore road providing a strong building line with appropriate heights, marked at the corner with a landmark building. Within the site heights will be a sustainable level, appropriate to the uses proposed.


RLO4 Require setbacks to be agreed with Dublin City Council along the main road frontages at Naas Road, along the east side of Kylemore Road to facilitate upgrading of the road to provide for a bus lane, segregated cycleway, greening of the route and footpaths allowing for an attractive and vibrant street environment and to encourage pedestrian and cyclist activity.


RLO5 To pilot new green infrastructure installations in the public realm to boost biodiversity and improve surface water management.


RLO6 Materials used for construction shall have provenance for their durability and weathering qualities and prior examples of their use shall be furnished to the Planning Authority at Masterplan stage. This is of particular relevance to the landmark building


RLO7 In consultation with the HSA, ensure that any new development proposal is compliance with the requirements of Seveso regulations.


RLO8 To ensure that all applications address the following issues regarding water management: a.Prepare a site specific flood risk assessment of the site as part of the first application b. Fully incorporate SuDS in the design of the overall scheme and accompanying masterplan c. Put in place measures to protect water quality, addressing particularly the issues of discharges and runoff, and d. Manage water usages within the site to conserve consumption of treated water and make use of grey water and/or rainwater where suitable.



61

Chapter 5 Motor Distributors Limited Site


Screen In / Out


MDO1 Facilitate the sustainable

redevelopment of this key site with a fine urban grain and a mix of uses as part of the mixed-use core of the Key District Centre all at sustainable densities within a vibrant and interesting environment and integrating with the wider plan area and the administrative area of South Dublin County Council directly adjoining.




MDO2 Require a general height

of between 4 and 6 storeys fronting onto Walkinstown Avenue and Longmile Road, a landmark building of up to 8 storeys at the junction of Walkinstown Avenue and Long Mile Road, 3 to 5 storeys within the core of the site and 4 storeys adjacent to Robinhood Road. The height of new development along Naas Road, directly adjacent to the protected structure, should protect the special character of the protected structure and should be no more than 4 storeys in height


MDO3 Require setbacks along

the west side of Walkinstown Avenue and north side of Long Mile Road to facilitate widening of the road to provide for a bus lane, segregated cycleway and footpath allowing for an attractive and vibrant street environment and to encourage pedestrian and cyclist activity.

No Out No potential Impacts

MDO4 Facilitate landuses that introduce active frontages and enliven the streets along Walkinstown Avenue and Long Mile Road and along priority pedestrian routes running through the site. Such uses may include local services such as retail, cafes, restaurants, leisure, cultural and community uses, reception areas to commercial areas above and other complementary active uses. Design of all units at street level



62

should have a strong urban edge, convey openness and contribute to vibrancy in the public realm.

MD05 Require the provision of a flexible and publicly accessible facility for community and cultural uses. Dublin City Council will, in consultation with local stakeholders, identify suitable uses for the facility. The form, size and other details of this space shall be designed in consultation with Dublin City Council and will become part of the resources of Dublin City Council to support community and cultural activities in the city


MDO6 Require the provision of a pocket park/performance space in any redevelopment of this site. The form, size and other details of this space shall be designed in consultation with Dublin City Council and will become part of the resources of Dublin City Council to support community and cultural activities in the city


MDO7 Retain the Volkswagen premises (protected structure ref. 5792) as a landmark and formal entry point to the city and ensure the enhancement and protection of the special interest and character of the structure in any refurbishment, adaption or reuse; regard to be had to Dublin City Council‟s upcoming guidelines on protection and refurbishment of buildings of the late twentieth century once published.


MDO8 Improve views of the Volkswagen Premises (protected structure ref. 5792) from the Naas Road by incorporating a strategically placed pedestrian access point into the northern boundary treatment of the site, incorporating a redesign of landscaping and an appropriate lighting scheme. This pedestrian point should allow for easy access to nearby bus stops and the Kylemore Luas stop.


MDO9 Provide for a predominantly pedestrian and cyclist-orientated environment at street level. The majority of car parking shall be provided at basement or at under-croft levels provided such under-croft parking does not undermine the objective to provide for active street frontages. A limited amount of



63

well-designed car parking shall be facilitated at surface level subject to good design, integration with the street and broken up with landscaping and/or street furniture.

MDO10 Provide for a clearly defined arrangement of public spaces which integrate into the emerging pedestrian / green routes and cycle network for the plan area and beyond and that increases permeability throughout the site by incorporating clearly defined east-west and north-south pedestrian and cyclist-friendly routes through the site framed by buildings on both sides and containing active street level uses along these pedestrian routes allowing for passive supervision.


MDO11 Provide for a boulevard traversing the core of the site in an east-west direction integrating with the boulevard to be provided on that key site to the east of Walkinstown Avenue (the Nissan site). This space shall accommodate pedestrian, cyclist and vehicular movement but will be so designed so as to prioritise pedestrian and cyclist movement. This boulevard shall incorporate street art, furniture and planting, SuDS and shall be an attractive space for relaxation. The boulevard shall be overlooked by residential units on some upper levels and fine grain neighbourhood-level retail units, cafes, cultural uses and other complementary uses at ground floor levels.


MDO12 Assist in promoting modal shift to sustainable modes of transport by enhancing connections between the site and the Kylemore Luas and Dublin Bus stops by reserving road space for a setdown for buses on Walkinstown Avenue, by incorporating new pedestrian access points in boundaries of the site and provide for enhanced pedestrian crossings over the Naas Road, Walkinstown Avenue and Long Mile Road.


MDO13 As part of the redevelopment of this site the 750mm watermain may need to be diverted. Such a diversion

Yes In Potential for construction related impacts for any development/construction works due to potential for silt


64

would be at the expense of the developer(s)

and/or pollutants to enter the surface water network during works

MDO14 To ensure that all applications address the following issues regarding water management: a)Prepare a site specific flood risk assessment of the site as part of the first application b)Fully incorporate SuDS in the design of the overall scheme and accompanying masterplan c.)Put in place measures to protect water quality, addressing particularly the issues of discharges and runoff, and d) Manage water usages within the site to conserve consumption of treated water and make use of grey water and/or rainwater where suitable.


MD15 To retain existing mature trees and planting on this key site, in particular those trees along the site‟s northern boundary and that tee line location in the southern section of the where feasible and appropriate

Chapter 5 Former Nissan Site/Site onto Longmile Road


Screen In / Out


NSO1 To facilitate the sustainable

redevelopment of this key site with a fine urban grain and a mix of uses as part of the mixed-use core of the Key District Centre, all at sustainable densities within a vibrant and interesting environment and integrating with the wider plan area.




NSO2 Require a general height of

between 5 and 6 storeys fronting onto Walkinstown Avenue, Longmile Road and Naas Road.



65

Two landmark buildings of up to 10 storeys, one at the junction of Walkinstown Avenue and Long Mile Road, and one at the junction of Walkinstown Avenue and Naas Road.. Heights ranging from 3 – 6 storeys within the core of the site

NSO3 Require setbacks to be

agreed with the Planning Department) along the main road frontages at Naas Road, along the east side of Walkinstown Avenue and north side of Long Mile Road to facilitate widening of the road to provide for a bus lane, segregated cycleway and footpath allowing for an attractive and vibrant street environment and to encourage pedestrian and cyclist activity.


NSO4 Facilitate landuses that

introduce active frontages along the Naas Road, Walkinstown Avenue and Long Mile Road, and priority pedestrian routes running through the site. Such uses may include local services such as retail, cafes, restaurants, leisure, cultural and community uses, reception areas to commercial areas above and other complementary active uses. Design of all units at street level should have a strong urban edge, convey openness and contribute to vibrancy in the public realm.


NSO5 Require the provision of a

flexible and publicly accessible facility for community and/or health uses and a crèche in any redevelopment of this site to serve the needs of the residents in the area


NSO6 Provide for a pedestrian

and cyclist focused environment at street level. The majority of car parking serving commercial schemes shall be provided at basement or at under croft levels provided such under- croft parking does not undermine the objective to provide active street frontages. A limited amount of well-designed car parking shall be facilitated at surface level(particularly within residential areas) subject to good design, integration with the street and broken up with landscaping and/or street furniture.


NSO7 Provide for a clearly

defined arrangement of public spaces which integrate into the

No Out No potential impact


66

emerging pedestrian/green routes and cycle network for the plan area and beyond and that increases permeability throughout the site by incorporating clearly defined east-west and north-south pedestrian and cyclist-friendly routes through the site framed by buildings on both sides and containing active street level uses along these pedestrian routes allowing for passive supervision

NSO8 Provide for boulevards

traversing the large site in an east-west and north-south direction integrating with the local green links running through the site and integrating in with the boulevard to be provided on the key site to the west of Walkinstown Avenue (the Motor Distributors site). This space shall incorporate street art, furniture and planting, SuDS and shall be an attractive space for relaxation. The boulevard shall be overlooked by residential and commercial on upper levels with ground levels dominated by l retail units, cafes, cultural and/or community uses and other complementary uses.

Yes

Out Positive impacts only

NSO9 Assist in promoting modal

shift to sustainable modes of transport by enhancing connections between the site and the Kylemore Luas and Dublin Bus stops by providing for new pedestrian access points in all three boundaries of the site and providing for enhanced pedestrian crossings over the Naas Road and Walkinstown Avenue.


NSO10 To green and improve the

major road arteries surrounding this key site i.e. Naas Road, Walkinstown Avenue, Long Mile Road to include wider footpaths, additional tree lines (incorporating native species), soft landscape zones, additional pedestrian crossing points, and off road cycle routes.


NSO11 To pilot and test new

green infrastructure installations in the public realm to boost biodiversity and improve surface water management within the site, such as the provision of storm water tree trenches and permeable paving for parking areas.


NSO12To seek the underground

of the 110 KV and 38KV high Yes In Potential for construction



67

voltage overhead cabling traversing the LAP area. The route for undergrounding the cables will be assessed by ESB Networks with the applicants/developers, and in that event the cost of the undergrounding of the lines including associated civil works would be borne by the developer(s) and ESB.

development/construction works due to potential for silt and/or pollutants to enter the surface water network during works

NSO13 To provide a new HV

substation within the site, integrated with the undergrounding of cabling to meet the level of demand.


NSO14 As part of the

redevelopment of this site the 750mm watermain may need to be diverted. Such a diversion would be at the expense of the developer(s).


NSO15 Local recycling facilities

must be provided for on this key site. For large retail stores , a glass recycling facility shall be provided.


NSO16 To ensure that all

applications address the following issues regarding water management: a.Prepare a site specific flood risk assessment of the site as part of the first application b. Fully incorporate SuDS in the design of the overall scheme and accompanying masterplan c. Put in place measures to protect water quality, addressing particularly the issues of discharges and runoff, and d. Manage water usages within the site to conserve consumption of treated water and make use of grey water and/or rainwater where suitable.


Chapter 5 Muirfield Drive /Naas Road


Screen In / Out


MDNR01 To develop land uses in

accordance with the accompanying map – framing the Camac Valley and integrating with adjoining residential areas. Predominantly residential land uses are proposed in place of existing industrial lands, whilst



68

mixed uses and some supporting retail are sought on the northern side of the site fronting the N7 road route. New public open spaces will be provided along the River Camac to support biodiversity.



MDNR02 To de-culvert that

section of the River Camac on the western side of the site, thereby providing a new north-south green infrastructure link and linear park – integrating with other proposed routes connecting to the wider area

Yes In

Dual Positive and Negative



MDNR03 To resolve key

blockages in the existing Green Infrastructure by expanding Lansdowne Valley Park and establishing new green routes including ;

a)A new „short-cut‟ east-west route from Mourne Road in Drimnagh, via Lansdowne Valley Park, to Naas Road and Bluebell Luas stop.

b) A link to the south towards Drimnagh Castle and Long Mile Road


MDNRO4 To accommodate

access for the majority of vehicular traffic for the new area via the existing entrance position at the Muirfield Drive/N7 junction.


MDNR05 That a masterplan is

submitted with the first phase of development outlining the design approach to be adopted for developing the lands and how each phase can be integrated in future applications


MDNR06 To ensure flood risk

considerations are adequately considered in the design of the linear park and protect the Naas Road and adjoining properties from increased flood risk.



69

MDNR07 To retain and enhance

existing planted areas and mature trees positioned along the Naas Road near the existing entrance to Muirfield Drive and to integrate them into any new development.


MDNR08 To ensure that all

applications address the following issues regarding water management: a. Prepare a site specific flood risk assessment of the site as part of the first application b. Fully incorporate SuDS in the design of the overall scheme and accompanying masterplan c. Put in place measures to protect water quality, addressing particularly the issues of discharges and runoff, and d. Manage water usages within the site to conserve consumption of treated water and make use of grey water and/or rainwater where suitable.


Appendix 1 – Flood Risk Assessment


Screen In / Out


FRA1 All planning applications,

for proposed development within the LAP area should include a site specific flood risk assessment (FRA)


FRA1A Risk to other

development

If the development does not result in increased discharge to foul or surface-water sewers, then it can be confirmed in the FRA that the development does not cause an increased flood risk to other areas. Note that since the publication of the GDSDS, it has been a requirement that surface-water discharge rates are limited to green-field rates for the development, so compliance with this requirement for all pluvial event results in compliance with flood risk management guidelines for surface-water discharge. This requirement is best achieved by properly incorporating SUDS techniques into the development.

If the development does result in increased discharge rates to



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sewers, then the developer may be required either to confirm that there is adequate capacity in the local network to cater for the increased flows without surcharge of the system or to propose a flood management solution to cater for the additional flows.

FRA1B Risk to the development

itself

The FRA should address risks from all sources, including but not limited to coastal, fluvial and pluvial sources, possible flooding from sewer surcharging and flooding from groundwater.

Incorporating storage within the development to cater for surface-water falling within the development for up to the 100-year pluvial (with climate change factor of a minimum of 10% applied as appropriate).

Designing floor levels. A precautionary approach should be taken of the 100 year fluvial flood level plus a minimum of 10% increase in rainfall intensity plus 300mm freeboard.

Designing basements and basement access to prevent ingress of water from groundwater sources or pluvial or fluvial flood events. Reference should be made to the DCC policy on basements as set out in the GDSDS Regional Drainage policy – Volume 6 – Basements. In particular, internal drainage must discharge from a level that is no deeper than 1.5m below ground level. This may require pumping in some cases.

Designing outfall manholes and connections to sewers such that the risk of flooding from backup from sewers is minimised. This may require the installation of non-return valves.

For small-scale development such as change of use, or small scale refurbishments, existing risks from all sources need to be identified and controlled where possible:

Demountable flood barriers might be proposed at ground floor



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entrances.

Existing outfall manholes and connections to sewers should be raised such that the risk of flooding from sewer surcharge is minimised. This may require the installation of non-return valves, or reconstruction of existing outfall manholes.

For small-scale development such as change of use, or small scale refurbishments, existing risks from all sources need to be identified and controlled where possible:

Demountable flood barriers might be proposed at ground floor entrances.

Existing outfall manholes and connections to sewers should be raised such that the risk of flooding from sewer surcharge is minimised. This may require the installation of non-return valves, or reconstruction of existing Outfall manholes.


FRA2 Permission will not be granted for development where it is deemed that an inappropriate level of flood protection has been provided for.


FRA3 Provision for safe, dry emergency access/egress routes should be made from all development (especially basements or semi-basements), both new and existing. These routes should enable pedestrians to safely evacuate properties during flood events.


FRA4 Consideration should be given to the appropriate use of flood warning and flood evacuation procedures for all development sites at risk from flooding and this should be discussed with Emergency Plan Division of Dublin City Council.



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Appendix B

Conservation Objectives and Qualifying Interests for all Natura 2000 Sites Subject to AA


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75


76


77


78


79


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Appendix C

Covering Letter from Scott Cawley


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APPROPRIATE ASSESSMENT SCREENING REPORT · Draft Naas Road Local Area Plan 2012 - 2018 Natura...

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Transcript of APPROPRIATE ASSESSMENT SCREENING REPORT · Draft Naas Road Local Area Plan 2012 - 2018 Natura...