Submission on the Draft Dublin City Development Plan 2022-2028

The draft Dublin City Development Plan 2022 to 2028 is now open for public submissions (until 14th Feb). Find out below on how to make a submission on the plan and see some of the observations I will be making (which you are free to borrow/amend for your own submission).

What is the Dublin City Development Plan

The Dublin City Development Plan sets out policies and objectives to guide how and where development will take place in the city over the lifetime of the Plan. The current draft plan will cover the six year period from 2022 to 2028.

The current draft Development Plan can be found here.

How do I make a submission

Any submissions need to be received by Dublin City Council by 4.30pm on 14th February 2022.

You can make your submission online. You need to create an account at the submission portal and then add your submissions.

You can also post a written submission to Dublin City Council.

Development Plan Team,
Planning and Property Development Department,
Dublin City Council,
Wood Quay, Dublin 8

Submissions I will be making

Below are the points I’ll include in my submission. Feel free to copy/amend for your own submission. If there’s something you think we’ve missed please let me know.

• Childcare
• Sports Facilities
• Build to Rent
• Controlling the number of hotels
• Active Travel
• Corpus Christi Parochial Hall

Childcare

Chapter 15: Development Standards

Access to local childcare facilities is becoming increasingly difficult for parents. I appreciate that, under the Development Plan, some developments are required to produce a “Community and Social Audit” as part of the planning application. Even given that we have seen large developments in the constituency that:

• simply say that the the area is already suitably well served
• extinguish an existing crèche facility without any replacement

I would ask that the Development Plan be updated to reflect the following:

• Capacity at existing facilities needs to be factored in. It is not sufficient to say that there are a number of childcare facilities in the area if all of them are already running to capacity
• A higher bar needs to be placed on developments that will remove an existing childcare facility.

Sports Facilities

Chapter 10: Green Infrastructure and Recreation

(1) Multiple Use of Sports and Recreational Facilities

Many sports clubs are under pressure with respect to adequate sports facilities. I welcome Policy GI48 in the draft Development Plan to maximise the multiple use of sports and recreation facilities.

I think this policy could be clarified/strengthened by

• Changing the word “encouraging” to “requiring”. Any new sports facilities built on the scarce land in the city should be multiple use.
• Adding a clause to encourage multiple use of existing sports facilities.

(2) Playing facilities for women and girls

I agree with a recent council motion that there should be equal access and availability of playing pitches for men/boys and women/girls and that any future development of both Dalymount Park and/or Tolka Park should ensure that playing facilities for women and girls are properly safeguarded.

(3) Lido

I support the objective “To support the development of a public lido… in the city centre”. I think a reasonable timeline for such a project should be the lifetime of this plan and I think that should be noted in the objective.

Build to Rent

Chapter 15: Development Standards

I welcome the restrictions placed on Build to Rent developments in the draft Development Plan.

I would ask that a standard condition be placed on the 40% build to sell units requiring these units to be sold only to non corporate bodies or Approved Housing Bodies. Without such a condition it is difficult to see how the desired tenure mix will be achieved.

Controlling the number of hotels

Chapter 14: Land Use Zoning

While hotel developments are welcome in the city it is my feeling that certain parts of the city (especially the North Inner City) are being overpopulated with hotels. Dublin City Council itself recently refused permission for a hotel on Capel Street (3609/20) because it was “exacerbating the existing over concentration of hotel developments”. This decision was however overturned by An Bord Pleanála in part because the Dublin City Council’s “decision does not appear to be supported by any specific policy basis or an established density standard for hotels”

In light of this ruling from An Bord Pleanála I would request that the Development Plan include density standards for hotels. It is not clear to me that Policy CEE28 is sufficient in this regard. Without such density standards parts of the city will tend toward primarily tourist use as opposed to a healthy mix.

Active Travel

Chapter 8: Sustainable Movement and Transport

The city is choked with private car traffic resulting in poorer air quality, congestion, and higher emissions of greenhouse gases. I think the Development Plan’s mode share shift should be vastly improved across walking, cycling and public transport. We need to be more ambitious.

Chapter 8: Sustainable Movement and Transport

I note objective SMTO11: Design Standards for Cycle Parking in Developments. These standards need to be updated to reflect that any required cycle space is in a secure space external to the living area and accessible without traversing the living area.

Chapter 7: The City Centre, Urban Villages and Retail

I welcome the objective to reduce street clutter (CCUVO20). Street clutter, while visually disruptive, also can impact the walkability of streets for more vulnerable footpath users. This objective could be extended beyond just poles to include the various cabinets that clutter the street.

I would encourage the council to go beyond consolidation of signs on single poles and to consider wholesale removal of certain classes of signs. For example:

• Directional signage (e.g. signs for the airport, M50, points of interest, businesses) are largely obsolete in an age where handheld navigation aids are common
• Signs that indicate there are traffic calming measures on residential streets. The default should be that such measures exist, each and every street should not need a sign post.

Corpus Christi Parochial Hall

I support the goals of the Corpus Christi Parish Hall Working Group, namely to secure the future of the Hall. First steps in this regard are

• To ensure that the land on which the hall is situated is zoned for community use.
• To include an objective to protect and retain the Corpus Christi Parochial Hall as a community amenity

The working group has produced its own submission in this regard which I encourage everybody to submit.