COMHAIRLE CONTAE ÁTHA CLIATH THEAS
SOUTH DUBLIN COUNTY COUNCIL

South Dublin County Council Crest

MEETING OF DEVELOPMENT PLAN MEETING

Tuesday, March 01, 2022

MOTION NO. 28

MOTION: Councillor B. Lawlor, Councillor K. Egan

This motion refers to Chapter 9 Economic Development and Employment, page 308 of the CE's report, submission SD-C195-257 Motion: To rezone this site from RU to EE.submitted by Cllr Kenneth Egan and Cllr Brian Lawlor

REPORT:

This motion seeks to rezone lands from RU to EE, on lands north of Greenogue Industrial estate. 

While the submission referenced is SD-C195-257, the motion clearly relates to submission no. SD-C195-169, see accompanying maps to motions. 

Enterprise and Employment 

The Draft Plan under EDE1 Objective 3 seeks to ensure that there is sufficient supply of zoned and serviced lands at suitable locations in the County to accommodate a range of enterprise and employment development types and to promote growth by strengthening the integration between employment, housing and transportation. 

Under Section 2.6.8 Employment Lands, an analysis of available lands which have potential to generate jobs was undertaken as part of the preparation of the Draft Plan. The purpose of this analysis was to ascertain whether sufficient employment lands are zoned to provide for the projected additional workforce for the Plan period up to 2028. Based on the analysis, there is a total capacity, excluding REGEN lands, to develop 624 hectares to facilitate further employment. This would more than meet the projected employment growth of 18,336 jobs over the Plan period set out in Section 2.6.8 of the Core Strategy in the Draft Plan. 

Submissions received from the OPR and the EMRA welcomed the evidence-based approach that has informed the strategy in the Draft Plan and considered the lands zoned for employment uses to be compliant with the RSES Guiding Principles for the Dublin Metropolitan Area and employment land and consistent with RPO 4.3. 

Objective CS5 Objective 4 sets out the commitment to monitor employment lands within the County. However, the Council does recognise that trends in the wider economy can quickly impact on employment lands, and as such the Council considers it will be important to monitor this situation. For this reason, an objective has been recommended for insertion into the Draft Plan to read: 

To ensure, that as part of the two year statutory review of the 

Development Plan, an evidence-based analysis of employment lands will be undertaken and should there be evidence for the need for further employment zoning within the lifetime of the Plan, a Variation to the Plan will be immediately initiated informed by: 

Flooding 

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”.  

As set out above, the Planning Authority is satisfied that there is no need for further employment lands in the County at this time. Therefore, the need for the zoning of these lands to EE has not been justified and hence the zoning of the lands fails the Justification Test as described in Section 4.23 of the OPW Guidelines, as it relates to Development Plans. It is also noted that the Camac River is the subject of a Flood Alleviation Study underway since 2019 by South Dublin County Council, Dublin City Council and the OPW and solutions to the existing catchment-wide flooding problems are not yet identified. Any further development in this area would be premature pending the outcome of this assessment. 

Having regard to the above issues relating to the quantum of existing zoned lands, the extent of the flood zones within this area, potential for a cumulative flood impact on adjoining lands and downstream it is considered that the proposal put forward to zone the subject lands for new enterprise and employment development would be premature and contrary to section 48 Guidelines and therefore it is recommended that the proposed motion is not adopted. 

CE Recommendation:  It is recommended that this motion is not adopted.