COMHAIRLE CONTAE ÁTHA CLIATH THEAS
SOUTH DUBLIN COUNTY COUNCIL

MEETING OF CLONDALKIN AREA COMMITTEE

Wednesday, May 18, 2022

MOTION NO.3

MOTION: Councillor S. O'Hara

That this Area Committee put a temporary moratorium on the planning application for high-density type accommodation in locations of Aviation Significance (dark grey area on the map) given the significant interventions by the Dept. of Defence in relation to the New Development plan, copy attached, and the intention to increase the level and type of military aviation activity in and around Casement Aerodrome. It would be my recommendation that a specific guidance document in relation to developments with the areas of Significant aviation Risk be developed to guide planners in relation to what is permitted with specific attention being given to developments directly beneath the take-off surface as this is the area of highest risk from an aircraft crash perspective.

REPORT:

The Council has no remit to put in place the type of moratorium suggested in the motion. There are procedures in place through the existing planning legislation and through planning policy in the current Development Plan 2016-2022 and in the Draft Development Plan 2022-2028 to take account of airports. This policy includes measures to ensure safety on the ground and in the air, security measures where related to Casement and measures around noise.

All planning applications are subject to the Planning and Development Acts and associated Regulations. Article 28(1) of the Regulations sets out the instances where notice to certain bodies on planning applications are to be referred. In relation to airports notice is given under Article 28 (1):

“(h) where it appears to the authority that the development might endanger or interfere with the safety of, or the safe and efficient navigation of aircraft — to the Irish Aviation Authority,

 (i) where it appears to the authority that the development might interfere with the operation and development of a licensed airport, whose annual traffic is not less than 1 million passenger movements — to the airport operator”

As Casement is a military airport it is not under the control of the Irish Aviation Authority (IAA). However, the Planning Department refers planning applications to the Department of Defence rather than the IAA where the application may endanger or interfere with the safety of, or the safe and efficient navigation of aircraft. 

Also, the Department for Defence monitors planning applications through the publication of the planning lists and makes submissions where it considers necessary.

The decision to refer a planning application to the Department of Defence is influenced by the planning policy on airports and Casement Aerodrome in particular.  This policy is contained in chapters 7 and 11 of the current Development Plan and is set out in considerable detail.  The policy and objectives in the Development Plan include clarity on where planning applications will be referred to the Department and the IAA. This includes development underneath the Approach Surfaces / funnels, any proposed development exceeding the Ordnance Datum (OD) height 45 metres above the level of the aerodromes, development within the Inner Zone and within the aerodromes Security Zone.  All of these different zones are set out in the relevant Development Plan maps, including the obstacle limitation surfaces which includes approach surfaces, transitional surfaces, inner horizontal surfaces and the conical surface.  It is a matter for the Department of Defence to respond to any referrals and their response will form part of the assessment process.

In relation to Development Plans, at all times in the preparation of the current Plan, previous Development Plans and the Draft Plan the relevant agencies / Department of Defence have been consulted and encouraged to make submissions and engage with the Planning Authority.

As part of the review of the County Development Plan, significant effort has been made in the Draft Development Plan 2022-2028 to simplify the technical detail involved for the benefit of the public and planners. This resulted in a simplified map for Areas of Significance for Airports. This is in addition to the technical detail and to a new section titled ‘What is Important in Assessing a Planning Application’.

The Draft Plan is still undergoing the adoption process and as such, has no remit in the determination of planning applications until such time as it comes into effect.  The current Development Plan 2016-2022 is the relevant plan for the assessment of planning applications.

The Department of Defence made two submissions to the Draft Development Plan and the Plan was amended, as appropriate, to reflect the issues raised in their submissions.  No submission was made by the Department at the current Material Amendment stage of the Plan process.  It is noted that the attachment on noise with this motion relates to policy in the UK and to specific grants which are not applicable to Casement. In relation to the attachment detailing fighter jets, it is not clear what the purpose of this attachment is, but the Development Plan contains policy on identified noise zones.

Policy and Objectives included in the Draft South Dublin Development Plan 2022-2028 relating specifically to Casement Aerodrome (this is in addition to more detailed policy and objectives on Obstacle Limitation Surfaces, Public Safety Zones and to Noise Zones for all airports which impact on South Dublin and to mapping of relevant obstacles, noise zones and public safety zones)

Policy IE8: Casement Aerodrome Safeguard, having regard to the requirements of the Department of Defence, the current and future operational, safety and technical requirements of Casement Aerodrome and facilitate its ongoing development for military and ancillary uses.

IE8 Objective 1: To ensure the safety of military and other air traffic, present and future, to and from Casement Aerodrome with full regard for the safety of persons on the ground as well as the necessity for causing the least possible inconvenience to local communities.

IE8 Objective 2: To maintain the airspace around Casement aerodrome free from obstacles to facilitate aircraft operations to be conducted safely, as identified in the Development Plan Index map and outlined in Chapter 13 Implementation and Monitoring.

IE8 Objective 3: To implement the principles of shielding in assessing proposed development in the vicinity of Aerodromes, having regard to Section 3.23 of the Irish Aviation Authority Guidance Material on Aerodrome Annex 14 Surfaces (2015) (See Chapter 13 Implementation and Monitoring).

IE8 Objective 4: To prohibit and restrict development in the environs of Casement Aerodrome, where it may cause a safety hazard. (See also Policy IE13 Public Safety Zones, and Chapter 13 Implementation and Monitoring).