MOTION: Councillor T. Gilligan
That the manager abandons all permeability routes in the plan
CE Report:
The proposed motion seeks to abandon all permeability routes within the Clondalkin Local Planning Framework boundary. The purpose of permeability routes within the Plan is to identify the optimal location of such routes to achieve the aims of safety, relieve congestion, provide healthier travel options, reduced emissions, in line with national, regional and local policy, with the opportunity of creating these permeability routes to undergo additional public consultation at a later stage.
National and Regional Policy
The proposed network of permeability links aligns with National and Regional policy statements in prioritising active travel and pedestrian movements within urban areas, increasing public transport usage, enabling a reduction in congestion, creating safer streets for all road users and delivering a reduction in emissions from vehicles helping to achieve our climate targets.
“We want to make sure that we provide good public transport, cycling and walking infrastructure, so people are less reliant on their cars, and we can cut congestion. We have already committed to an additional 500,000 public transport and active travel journeys daily by 2035. Policies need to be better aligned to achieve more ambitious targets for modal shift, involving building supporting infrastructures.”
Government of Ireland, 2019 Climate Action Plan
The National Planning Framework (NPF) is the Government’s high-level strategic plan for shaping the future growth and development of Ireland prior to 2040. Permeability is seen as one aspect in creating healthier communities, with healthy places creating economic value by appealing to a skilled workforce and attracting innovative companies. Under National Strategic Outcome (NSO) 7 ‘Enhanced Amenities and Heritage’, it states ‘implementation of planning and transport strategies for the five cities and other urban areas will be progressed with a major focus on improving walking and cycling routes, including continuous greenways networks and targeted measures to enhance permeability and connectivity’. The role permeability plays in increasing active travel and creating healthier communities is emphasised in its importance at National level.
The National Transport Authority (NTA) provide national policy in their publication ‘Permeability: Best Practice Guide’. As provided for within the guidance, permeability links provide tangible local economic benefits to the wider economy, benefits public transport operators, achieves better public health and promotes social interaction.
In the context of decisions to be made on this Variation (LPF) and the policy outlined above the provisions of Section 13(7) of the Planning and Development Act 2000 as amended are noted;
‘In making a variation under this section, the members of the authority shall be restricted to considering the proper planning and sustainable development of the area to which the development plan relates, the statutory obligations of any local authority in the area and any relevant policies or objectives for the time being of the Government or any Minister of the Government.’
The Transport Options
To support the preparation of the Clondalkin Local Planning Framework (LPF), a Local Transport Plan (LTP) was completed using the ABTA (Area Based Transport Assessment) process, which ensures that the assessment of transport demand and its associated impact play a central role in informing the relevant policy documents, in this case the Clondalkin Local Planning Framework. Essentially, the function of a local transport plan is to ensure the integration of land use and transport planning as a key consideration within the Plan preparation process.
The LTP having assessed a range of options available to relieve traffic congestion and improve public transport usage in the village (bringing with To amend the route between Floraville Avenue and Round Towers GAA club grounds identified in Figure 5.9 as a Priority Permeability Route to a Secondary Permeability Route to allow for its considered review over time. it associated environmental and health benefits). Having engaged in three rounds of public consultation, the last of which dealt specifically with the transport options for the plan, a package of low level intervention recommendations emerged and informed the suite of measures which were written into the draft Local Planning Framework which is now under consideration. This package of measures includes the permeability routes identified in the Local Planning Framework.
The recommendations of the LTP have been integrated into the Local Planning Framework in the way considered most appropriate to enable delivery of the overall framework. Not all of the recommendations from the Local Transport Plan feature in the Local Planning Framework. This is primarily to allow the detail of measures to be considered at detailed design stage and to facilitate public consultation leading to that point.
Opportunities and purpose of Priority, Secondary and Strategic Permeability Routes
The LPF has categorised the proposed permeability links into Priority, Secondary and Strategic permeability routes. As set out in chapter 5 of the LPF in the text, objectives and Tables 5.4, 5.5 and 5.6, the different category of permeability routes / links helps to make clear their purpose. These are as follows:
Priority links have been identified in the LPF in Figure 5.9 and are explained in Table 5.4. They are focused on creating safer routes to schools to try and provide better options for children and parents / guardians to get to their schools without having to use the car. It is recognised that this will not be possible for all parents, but it is based on the evidence provided in Table 5.3 that the top ten origin-destination trips originating within the Plan area are from residential areas towards schools. Any reduction in these trips would help relieve congestion in the village, with priority measures also creating a safer space for children to get to school by walking or cycling.
It should be noted that there is a recommendation in the CE Report to amend the Priority Permeability route between Floraville and the GAA club to a Secondary Route as follows:
To amend the route between Floraville Avenue and Round Towers GAA club grounds identified in Figure 5.9 as a Priority Permeability Route to a Secondary Permeability Route to allow for its considered review over time.
This is not to diminish its importance in providing greater accessibility to the schools on New Road, but rather to recognise that it would have to be delivered alongside the route from Monastery Road to the GAA grounds. It was also recommended within the CE Report that this latter route be amended, as follows:
To amend the route between Monastery Road at Round Towers GAA grounds and Knockmeenagh Lane identified in Figure 5.9 as a Priority Permeability Route to a Strategic Permeability Route to better reflect its potential for longer term delivery.
The CE recommendations recognised the concerns raised at these permeability routes by local residents and given the timelines that will likely be required to effect consultation and delivery of these links a change from priority routes to a secondary route and strategic route categorisation was recommended.
Where the motion relates to the removal of the priority permeability routes it takes away the opportunity to improve access to schools by shortening the distance needed to walk or cycle and / or by taking away the opportunity to provide safer travel options. It increases the likelihood that children will continue to be driven to school, continuing the existing congestion issues around school times. It also takes away the opportunity to help normalise walking and cycling to school where that is possible.
Secondary links are also shown in Figure 5.9 and detailed in Table 5.5. These routes have been identified as benefiting walking and cycling movement, helping to connect places within and around the villages. While their delivery would be beneficial to help with general accessibility, they have not been identified as priority routes as they generally do not directly facilitate shorter and / or safer access to schools. The exception to this is in the recommended changes to the categorisation of the Floraville route into the GAA lands and into the GAA/SIAC lands from Monastery Road and Knockmeenagh as outlined above.
The identified Secondary Routes allow for greater added value to the overall network, improving the linkages by further connecting the existing, priority and strategic routes in a way that allows even greater movement options throughout the plan lands.
Strategic links are identified to be delivered in the longer term as opportunity arises. Any such opportunity would generally only arise on foot of a planning application on the lands concerned. For example, as part of back land or infill development within the village centre or as part of the development of the Ninth Lock Framework site, to ensure that links through the site from the village towards the train station and elsewhere are integrated into the development. This is reflected in the proposed new objective as recommended in the CE Report, intended to make absolutely clear the purpose of the Strategic Permeability Routes, specifically those within the village centre:
New Objective: To support the potential for strategic permeability routes within the existing village area, only where the opportunity arises as part of proposed redevelopment and / or the consent of the relevant landowners and subject to any proposals undertaking the appropriate environmental and archaeological assessments.
The parameters for development of the Ninth Lock Framework site make clear the requirement for permeability within that site, reflected in Figure 5.9 by the identification of strategic permeability routes.
Where the motion relates to the removal of the Strategic Permeability routes it would impact on the ability to ensure links are created through the new development site at the Ninth Lock Framework Site for example or should new development opportunities come forward within the village centre. As shown on Figure 5.9 and in the development parameters for the Ninth Lock site in Chapter 8, the strategic routes ensure access towards the Village and Clondalkin Park, also facilitating better access from the existing residential areas around the village and the site itself to the New Nangor Road and the train station at Clondalkin Fonthill. This helps facilitate access to public transport (bus and train), improve general safety for road users and those using footpaths and helps to reduce congestion.
Importantly, the inclusion of these strategic routes in the plan supports the Development Management process and gives clarity to future developers, ensuring the delivery of links between the Village and strategic public transport infrastructure such as the Fonthill Railway Station and the Red Cow Luas Stop. They will also ensure residents of the village and new residents of future development can access amenity areas such as Corkagh Park and Clondalkin Park without the necessity of driving from their homes in the north or east of the LPF area.
Existing Permeability Routes
As well as identifying permeable routes throughout the LPF boundary, permeable routes currently exist which benefit those travelling towards schools, work or for leisure. For example, routes through Clondalkin Park already provide links towards St. Johns Road, Cherrywood and Boot Road, providing additional movement options, improving travel times, improving safety and reducing congestion within the village. Existing routes provide a blueprint for how new routes could add value to an overall walking and cycling network demonstrating how new routes might enhance access to the village and surrounding areas.
If all the proposed permeability measures were removed, as put forward by the motion, the impact would significantly limit movement options within the LPF area and further afield and reduce the potential positive impact of the suite of measures for the village and wider area put forward in the LPF.
Consultation
Recognising that there are local concerns at individual links within the LPF area, objectives within the LPF make it very clear that consultation will be undertaken prior to the any openings.
These measures have been built into the objectives of the LPF as follows (underlining for emphasis):
SM4 Objective 1: To support the permeability routes and links identified in Figure 5.9 and Table 5.4, subject to further consultation, which will enable quicker and safer access to schools, shops, places of work and social interaction in a pedestrian and cycle friendly environment.
SM4 Objective 2: To ensure that proposed permeability links are designed in line with the NTA’s best practice guidance and in such a way as to reduce the potential for anti-social behaviour, providing wide and inviting openings which are well lit
SM5 Objective 1: To deliver the identified priority permeability routes, subject to local consultation, to facilitate improved connections to schools, increasing the safety of children currently using active travel and providing improved options for children and their parents / guardians currently travelling by car to switch to walking or cycling.
SM5 Objective 2: To encourage permeability improvements in general, including those identified as secondary permeability links, at suitable locations following appropriate consultation, throughout the Plan area.
SM5 Objective 4: To engage with the community prior to any formal Part 8 or related process to facilitate consultation on proposed new links and their design.
Summary
While concerns have been expressed to some routes in submissions, these must be balanced with the need to try and improve the wider environment for walking and cycling in Clondalkin, facilitate improved public transport, improve general safety for those using the roads and footpaths and helping to resolve the real congestion issues in Clondalkin. The LPF includes permeability routes as one of a package of measures which in conjunction with each other will begin to achieve change. This change is dependent on delivering the whole package of measures. The removal of one will make the others less effective.
In addition, the inclusion of these links can create a more attractive village for those living in and visiting the surrounding areas and will make Clondalkin a more attractive location for businesses and services.
Further consultation prior to any implementation and design of proposed permeability links will allow for examination of issues raised in submissions around anti-social behaviour, access issues, safety, and environmental concerns. To reiterate, the purpose of what is included in the Plan is to identify the optimal location of permeability routes to achieve the aims of safety, relieve congestion, provide healthier travel options, reduced emissions, in line with national, regional and local policy, with the opportunity of creating these permeability routes to undergo additional public consultation at a later stage.
CE Recommendation:
No Change to the draft LPF (Variation no. 1).
Advisory Note: Initial Screening for SEA for the Motion
This proposal would not provide the most evidence-based framework for development and has the potential to undermine sustainable development and proper planning - with potential for associated unnecessary adverse environmental effects on various environmental components. Taking this into account, SEA would be likely to be advised as being required.
Initial Screening for AA for the Motion
No AA issues; Stage 2 AA not required.