COMHAIRLE CONTAE ÁTHA CLIATH THEAS
SOUTH DUBLIN COUNTY COUNCIL
MEETING OF DEVELOPMENT PLAN MEETING
Thursday, February 04, 2016
MOTION NO. 164
MOTION: Councillor E. Higgins
As per our discussions at the last round of Development Plan debate, that lands at Moneenalion Commons at Baldonnell retain an 'EE' (enterprise) zoning; and that a Specific Local Objective should further be applied to these to require preparation of a site specific Flood Risk Assessment and Mitigation Strategy, prepared by a qualified person(s), to be submitted with any proposal for development on these lands.
Map supplied same as at last Development Plan meeting:http://membersnet.sdublincoco.ie/Content/Meetings/Documents/45024_Motions_45024a.pdf
Co Sponsored by: Cllr. Kenneth Egan & Cllr. William Lavelle
REPORT:
The Chief Executive acknowledges the motions received and the submissions from prescribed bodies and the public in relation to the ‘EE’ zoning of lands at Baldonnell. The Chief Executive agrees with the submissions from the prescribed bodies and motion to reconsider the zoning of these lands and recommends a Rural (RU) zoning for the area.
Identification of Flood Risk
As part of the County Development Plan and SEA process 2016-2022, a Strategic Flood Risk Assessment (SFRA) to inform the Draft Plan was carried out for the County, with a further specific report on flood risk also carried out subsequently due to the lands located at Moneenalion Commons being identified in the County study as having a potential risk. Additionally, the Eastern CFRAM study mapping identifies the area as having a potential risk. The foregoing studies incorporate the best available data and provide an evidence base on flood risk in the County. The studies identify a significant portion of the site (see attached map showing the subject area and the flood risk mapping) in question as being in Flood Risk Zone A, with ‘a high probability of flooding’.
Flood Risk Guidelines
The Guidelines for Planning Authorities on Flood Risk Management (2009) advises in relation to Flood Zone A that ‘most types of development would be considered inappropriate in this zone’ and that ‘development in this zone should be avoided and/or only considered in exceptional circumstances, such as in city and town centres, or in the case of essential infrastructure that cannot be located elsewhere’.
These 'exceptional circumstances' require all parts of a Development Plan Justification Test to be met ‘on a solid evidence basis’. It is considered that on the basis of the information currently available to the Planning Authority, this cannot be met in respect of the subject lands i.e. this is because the Planning Authority is not satisfied that ‘it can be demonstrated on a solid evidence base that the zoning or designation for development will satisfy the Justification Test.’
Section 4 of the Flood Risk Guidelines relates specifically to "existing, undeveloped, zoned areas at risk of flooding" and Sections 4.26 & 4.27 state that “future flood risk assessments required to support the development plan process may highlight existing, undeveloped areas which, on their own merits, were zoned for development in previous development plans but which new information indicates may now, or in the future, be at risk of flooding”. The Flood Risk Guidelines advise that in the these cases “planning authorities should reconsider the zoning objective” and following this reconsideration, “may decide to:
- Remove the existing zoning for all types of development;
- Reduce the zoned area and change or add zoning categories to reflect flood risk;
- Replace the existing zoning with a zoning or specific objective for less vulnerable uses;
- Prepare a local area plan informed by a detailed flood risk assessment to address zoning and development issues in more detail; and/or
- Specify, in exceptional circumstances and where the criteria of the Justification Test have been met, design of structural or non-structural flood risk management measures as prerequisites to development in specific areas, ensuring that flood hazard and risk to other locations will not be increased or, if practicable, will be reduced.
Given the extent and sporadically dispersed location of the flood risk zone A on the lands in question, it is considered that removal of the existing employment zoning as the lands are undeveloped is the most appropriate course of action, in line with the 'precautionary approach', which requires planning authorities to consider possible future changes in flood risk including the effects of climate change. The intensive development of this area will displace the flood zone and may impact on the residents of existing dwellings downstream.
The DECLG Planning Policy Statement 2015, reiterates the Key Principles that should be used as a strategic guide to implementing proper planning and sustainable development of urban and rural areas and state that planning must be plan-led and evidence based. This follows on from the 2010 Planning Act, which requires an evidence based ‘Core Strategy’ as the basis for all County Development Plans.
The Chief Executive recommends that the subject lands at Baldonnell be zoned for Rural ‘RU’ in the Chief Executive’s Report. This recommendation is based on evidence and information detailed in specifically commissioned reports prepared by independent consultants for the County Development Plan and the OPW produced Eastern CFRAM.
Recommendation
It is recommended that the motion be adopted