COMHAIRLE CONTAE ÁTHA CLIATH THEAS
SOUTH DUBLIN COUNTY COUNCIL
MEETING OF DEVELOPMENT PLAN MEETING
Thursday, June 17, 2021
MOTION NO. 42
MOTION: Councillor V. Casserly, Councillor K. Egan, Councillor S. O'Hara
''The Greenogue and Aerodrome Business Parks at Rathcoole/Newcastle, Clondalkin Industrial Estate and Fonthill Industrial Estate are large industrial campuses comprising a mix of largely warehousing and manufacturing facilities, providing potential for new jobs or any displacement of jobs from the Naas Road or Tallaght REGEN lands over the coming years. Other smaller industrial estates throughout the County can also offer space for employment throughout the lifetime of the plan.'' (Ref Chapter 9- Economic development and Employment. Section 9.1)
Motion: ‘To rezone the land outlined in red on the attached map, (extending to 129 acres), from its current ‘RU’ Objective, (to protect and improve rural amenity and to provide for agriculture), to Objective ‘EE’, (to provide for enterprise and employment related uses) to allow the existing industrial estate to expand.’
REPORT:
This motion seeks to rezone 129 acres of land from ‘RU’ Objective (to protect and improve rural amenity and to provide for agriculture), to Objective 'EE', (to provide for enterprise and employment related uses) at Greenogue. The rationale for re-zoning is to allow the existing industrial estate to expand. A response to this is set out under the heading of: Land Capacity, Flood Risk, Aviation Safety and Environmental considerations.
The Draft Plan includes a land capacity analysis under Section 2.6.8 of Chapter 2 setting out the availability of zoned land for employment purposes. Based on the assessment carried out there is potential for 31,824 jobs on existing zoned undeveloped land. The need during the lifetime of the Plan amounts to 18,336 jobs and thus there is sufficient zoned land to meet the projected need without considering further land.
From the perspective of Flooding, the subject lands comprise parcels of land which have been identified as being Flood Zone A (1 in 100-year flood) and Flood Zone B (1 in 1000-year flood) within the Strategic Flood Risk Assessment carried out as part of the review process of the County Development Plan. In this regard the Planning System and Flood Risk Management Guidelines for Planning Authorities, 2009 (FRM Guidelines) set out the following:
The planning implications for each of the flood zones are:
Zone A - High probability of flooding. Most types of development would be considered inappropriate in this zone. 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, and where the Justification Test has been applied. Only water-compatible development, such as docks and marinas, dockside activities that require a waterside location, amenity open space, outdoor sports and recreation, would be considered appropriate in this zone.
Zone B - Moderate probability of flooding. Highly vulnerable development, such as hospitals, residential care homes, Garda, fire and ambulance stations, dwelling houses and primary strategic transport and utilities infrastructure, would generally be considered inappropriate in this zone, unless the requirements of the Justification Test can be met. Less vulnerable development, such as retail, commercial and industrial uses, sites used for short-let for caravans and camping and secondary strategic transport and utilities infrastructure, and water-compatible development might be considered appropriate in this zone. In general however, less vulnerable development should only be considered in this zone if adequate lands or sites are not available in Zone C and subject to a flood risk assessment to the appropriate level of detail to demonstrate that flood risk to and from the development can or will adequately be managed.
The provisions of the Flood Risk Management (FRM) Guidelines are clear in regard to zoning proposals for such lands with section 4.23 setting out the following: “Having prepared a Strategic Flood Risk Assessment and mapped flood zones as part of its development plan review process and any more detailed flood risk assessments as necessary, situations can arise where a planning authority will need to consider the future development of areas at a high or moderate risk of flooding, for uses or development vulnerable to flooding that would generally be inappropriate as set out in Table 3.2. In such cases, the planning authority must be satisfied that it can clearly demonstrate on a solid evidence base that the zoning or designation for development will satisfy the Justification Test”.
The proposal set out in the motion is not supported by any Justification Test which clearly demonstrates the use of the subject lands for enterprise and employment. In addition, the FRM Guidelines clearly set out that less vulnerable type development should only be considered within Flood Zone B if adequate lands or sites are not available in Zone C (Low probability of Flooding) and subject to a flood risk assessment to the appropriate level of detail to demonstrate that the flood risk to and from the development can or will be adequately managed.
From an aviation perspective, the proposed rezoned area lies fully within Casement Aerodrome’s Security Zone. Furthermore, given the Transitional Surface, rising at a 1 in 7 slope from the edge of the flight strip and with existing surface level of the lands, there is insufficient headroom for the height of typical industrial type development at the nearest boundary of the site to Casement Aerodrome.
It is also worth noting that from an environmental perspective that the proposal would lead to potential negative environmental impacts through:
- potential erosion of rural amenity and landscape character;
- loss of agricultural land;
- loss of local biodiversity; and
- conflict with operational constraints at Casement Aerodrome;
Having regard to the above issues relating to the quantum of existing zoned lands, the extent of the flood zones within this area and the potential for a cumulative flood impact on adjoining lands, alongside the lands proximity to Casement Aerodrome’s security zone and the implications of same in regard to building heights and the identified impacts on the natural environment it is considered that the proposal put forward to zone the subject lands for new enterprise and employment development is not appropriate and therefore it is recommended that the proposed motion is not adopted.
RECOMMENDATION: It is recommended that this motion is not adopted.