Save Our Seafront
c/o 91 Lower Georges Street
To: Planning Department
Dun Laoghaire Rathdown County Council
1 Feb 2018
Dear Sir/ Madam
Planning Application D17A/1135
Former Western Marine Site, Bulloch Harbour, Dalkey, Co. Dublin.
We wish to make the following observations on the above site:
- The proposed plans for the quay-side development is utterly out of character with the other housing along the quay and indeed in the wider area.
- SLO 22 in the County Development Plan states that any residential development “shall have regard to the special nature of the area in terms of height, scale, architecture and density of built form.” The proposed development certainly contravenes this part of the SLO
- SLO 22 also insists that any residential development “shall form part of a mixed-use scheme which will include commercial marine-based activity and public water based recreational uses.” The planning application is 75% residential with only 25% dedicated to commercial. This is a far too heavy proportion of residential in what is supposed to be a “mixed use scheme”
- There are minimal details of the commercial plans in the proposal. While the units are allocated a specific purpose, the viability of these units is when parking is limited and access for deliveries and for clients is questionable and leads one to suspect these units are there purely to comply with the SLO and are not a serious part of the proposal.
- The potential for the developer to apply for a change of use of the commercial buildings in the coming years and for the whole development to become residential has been made more likely by recent changes to planning regulations which allow commercial buildings that have been left idle for a year to be changed to residential without having to apply for planning permission.
- The harbour is a key part of the heritage of Dalkey and the surrounding area. The heritage, architectural, cultural and historic features of the area will be negatively affected by the scale of the development.
- The rocks at the rear of the proposed development are a vital part of the harbour and are a key amenity. Existing public views of the rocks will be blocked. While the developer has committed to maintaining public access to these rocks, it is questionable as to whether he has the power to do so as there is currently a right of way to these rocks.
- Bulloch Harbour is visited and used by thousands of Dubliners, tourists and fishermen, community groups and watersports groups especially during the summer, bringing much needed business to Dalkey and the area in general. This out of context development will undermine the unique nature of the harbour and change the whole character of it. This will deter people from visiting what is an important public amenity.
- While there are currently private homes and private spaces in the harbour, the harbour community and the different small businesses that operate there mean that public access to the harbour is central to it. This development will effectively privatize and commercialise a whole section of the harbour and undermine the current public access.
- Parking facilities for visitors will be reduced by the increased parking requirements of the proposed private housing and commercial activity.
- The visual impact and the overall effect of the development is contrary to the County's coastal heritage plan: “It is Council policy to promote features of the County's coastal heritage where these contribute to the character of the area”. (Policy AR7: Protection of Coastline Heritage).
- The development is also contrary to the Council policy on Beaches “It is Council policy to promote the use of certain beaches for amenity and recreational use. The areas traditionally used for bathing in the County include Bulloch Harbour. Public access to beaches will be provided” (22.214.171.124 Policy LHB10: Beaches).
- The County Development Plan also includes a commitment to a Masterplan for Bulloch Harbour. It is contrary to proper planning and sustainable development to give permission for a development in an area, for which a Masterplan is planned, in advance of such a Masterplan.
- Most importantly, Bulloch Harbour is a vital amenity for residents, visitors and tourists, and a key amenity area for South Dublin. The development would injure the amenity value for the thousands of current users – for sailing, swimming, scuba diving, wind and kite-surfing, bird watching, sea scouts, walkers and other recreational users. The future of the Harbour should be decided by the Council in the interests of the public, and not in the interests of private, restrictive development.
- The plan has not taken into account the regular overtopping that occurs at Bulloch Harbour in stormy weather. This is not a rare event. Regularly waves hit the area that is proposed for the 3 houses and would exceed the height of the proposed homes. The impact of building on this area that is so prone to this overtopping has not been adequately assessed by the developer.
The proposed development is contrary to proper planning and sustainable development and should be refused.
Save Our Seafront