SUBMISSIONS ON MATERIAL ALTERATIONS DRAFT PLAN 2024-2030

Material alteration 2 (Table 2.5)

This Material Alteration made in response to Submission 140, Recommendation 1, made by the OPR.

“Provide a clear core strategy which sets out: population and housing growth; the area (ha)of land zoned New Residential (A2 and A3 zonings): Existing Residential and Mixed Use land with residential development potential; and the housing yield from such lands, including Existing Residential and Mixed Use, using density standards consistent with the Compact Settlements Guidelines”

The request for housing yields from lands must relate to the yields to be achieved during the life of the Plan up to 2030 and not to lands that may eventually provide completed dwellings. The requirement for housing completions during the Plan Period is 2704 (2448+ 291 shortfall of completions to Q2 2023).

An analysis of the figures for housing yields contained in the table on the map showing potential capacity of Phase1, Phase2, and Mixed Use along with the table on the map showing estimated capacity of lands zoned Existing Residential was made. We set out below in tabular form our estimates of the number of housing completions expected from these lands within the plan period.

TABLE 1 Estimated Capacity of Phase1. Phase 2 and Mixed Use Lands.

Sites Zoned A2 Phase1

R1 Extant permission: improbable that it will be developed within the Plan Period 0

R2 Current application for 205 dwellings servicing and flooding concerns? 205

R3 Permission for 45 dwellings 45

R4 Mount Avenue. 50% completed up to 2030? 600

R6 Mount Avenue. 50% completed up to 2030? 175

R7 Bothar Moal. Subject to decision to rezone as Strategic Reserve 0

R11 Permission for 183 dwellings 183

R14 Land proposed for rezoning. See our submission below. 0

Total 1,208

TABLE 2 Estimated Capacity Existing Residential

Sites Zoned A1 Existing Residential.

1 Small site Low density 5

2/3 Subject to flooding and policy objective INF21 0

4 Permission for 82 dwellings. Expired 12/24 ? 82

5 Permission for 15 dwellings 15

6/7 No applications made on these sites 0

8 Permission for 52 units 52

9 On going development approx. 100 units remaining 100

10 On going development 250

11 No application 0

12 Permission for 80/I bedroom units single occupancy. Not family homes.? 80

13 No application 0

MUI Mixed Use: An application for 300 university bed spaces did not proceed. (See note below) 0

Lands Zoned New Residential Phase 2: are not available for development until rezoned Phase2 0

Total 584

Our total estimate of housing completions on the above lands in the Plan Period is 1792 a shortfall of 912 units on that required in the Core Strategy.

Another factor that has to be taken into account are delays due to external events such as the disruption caused by Covid resulting in a shortfall of 291 completions up to Q2 2033 which now has to made up. There are many foreseeable events which are likely to disrupt the building industry in the coming years such as climate change, shortage of labour, disruption to supply of materials following on expected trade wars with America and another viral attack. All lands which can guarantee a supply of housing within the Plan Period should be brought forward for development subject to compliance with all planning requirements.

It is clear from the above analysis that some of the lands zoned Phase 2 and available for development should be brought forward at this stage. The problem is that applications received for the development of these lands would be refused, even if they meet all planning requirements, on the basis of their zoning. We propose that a new clause, to provide for this concern, be inserted into Table 2.5 as follows.

“ Applications for development on New Residential Phase2 lands, capable of being developed, shall not be refused permission based on zoning considerations only subject to compliance with Clause 2.4.5(Phasing of Residential lands) and having regard to the Core Strategy”

All of the above figures are reflected in a revised Table 2.5 as follows

Settlement Dundalk A1 Existing Residential Phase 1 Phase2 Mixed

Lands with potential

to deliver housing 30.9 ha 90.3 ha N/A See notes below

within the Plan Period

Potential Capacity 584 units 1208 units 0 0

Development of lands zoned Phase 2 can only happen if rezoned under 2.4.5.

Inclusion of family housing completions in Mixed Use zone is highly speculative and should be discounted for now.

Material Alteration 131 Rezoning Phase2 lands to Phase 1

The proposal is to rezone over 2ha of lands presently zoned Phase 2 to Phase 1. The land is located directly south of lands zoned Phase 1 (R11) with permission for 183 houses. While work has commenced on the site it is certainly not 75% complete. The proposal to rezone the lands contravenes Section 2.4.5 of the Draft Plan and Section 13.21.7 of Louth County Council Development Plan 2021-2027 as it does not meet any of the 2 criteria to enable the lands to become available for development which is effectively what the rezoning would achieve. The reasons given by the CE in their report for the rezoning of the parcel of land “-- an Infill location which forms part of same field within which permission was granted---------which would have the benefit of the existing entrance and services-------in the interest of orderly development and to enable the lands to be built out at the same time as the surrounding lands.” It describes the situation pertaining to land parcel 8 at Hamilton zoned Phase 2 but without the constraints imposed by 2.4.5. which was refused a request for rezoning. There has to be a priority system established for the rezoning of all Phase 2 lands.

This brings in the bigger picture of the treatment of the rezoning of Phase 2 Lands. Certain Phase2 lands, for example our lands at Hamilton can demonstrate (details already provided in Submissions 4 and 14 on the Draft Plan) that they meet with all the requirements for their development. Our lands are classified as Tier 1 in the current County Plan, they meet all the requirements of Section 2.4.5, they comply with all the requirements for compact development within the Blackrock Neighbourhood and a recent report (05/12/2024) from Uisce Eireann indicates that the development of the lands to accommodate 190 units is feasible under conditions which are acceptable to our developer. As demonstrated in our submission on Material Alteration 2 above it is likely that the release of suitable Phase2 lands will be required if the Core Strategy requirement for housing completions is to be achieved. The process for this to take place must be streamlined to avoid delays and wasteful appeals to An Coimisiun Pleanala. Genuine applications for planning permission should not be refused on account of Phase2 zoning only where all other requirements are met. See our proposal in this regard above.

Material Alteration 113 (Pharmacies)

Include McQuillan Pharmacy and Allcare Pharmacy both in Blackrock Village in Table 13 Appendix 5

Material Alteration 115 (Places of Worship)

Include St Oliver Plunkett Church Blackrock, Encounter Fellowship Church Blackrock, St Furseys Church Haynestown in Table 16 Appendix 5.

Proposed Material Alterations to the Draft Dundalk Local Area Plan 2024-2030 - Aighneachtaí

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