Greystones Oral Hearing

I am making my submission today as an elected representative, a Green Party councillor on Wicklow County Council who is very concerned about the proposed Public Private Partnership development for Greystones Harbour and North Beach. I do not believe the proposed development constitutes the proper planning and sustainable development of the Harbour and North Beach area. In my written submission to the Board I touched on a range of specific planning concerns I have about the proposed development. In my oral presentation today I intend to limit myself to a number of general points that I wish to make about the development. Some of the points I raise are broader than strictly planning issues. I hope the Inspector will indulge me and I will try to make my points as relevant and as succinct as I can.

These points are as follows:

(i) The proposed development will largely urbanise what is currently an unspoilt and undeveloped public amenity, widely used by the residents of Greystones and the wider population, and will undermine the architectural heritage character of Greystones which is central to the town’s sense of identity

(ii) The proposed development does not have public support and indeed other similar proposals for the development of the harbour area which Wicklow County Council has considered over the years- including the Gubay proposal - were consistently opposed by the people of Greystones

(iii) The use by Wicklow County Council of the mechanism of a Public Private Partnership to progress this development is not appropriate as there is little in the proposed development that constitutes ‘necessary public infrastructure’

(iv) The coastal protection works being proposed are inadequate

(v) The road infrastructure around Greystones will not be able to cater for the traffic generated by this proposed development, and, if planning permission is granted, it will undoubtedly lead to a compelling pressure for a new road over Bray Head

(vi) Neither Wicklow County Council nor the private consortium Sispar provided the elected representatives who voted for the proposed development with necessary and accurate information about the estimated costs of the scheme and the likely profits that will accrue to the developers, claiming that this is “commercially sensitive information”

(vii) There was a failure on the part of Wicklow County Council to properly consider alternatives to the proposed development for the Harbour and North Beach area in an open and transparent fashion

(i) Urbanisation of an unspoilt public amenity

My first point today is that the proposed development will largely urbanise what is currently an unspoilt and undeveloped public amenity, widely used by the population of Greystones and beyond. The open and unrestricted access which any member of the public has at present to the harbour itself, to the grey stony beach and to the uninterrupted views of the sea and of Bray Head are all highly prized aspects of living in this seaside town, a town that has begun to experience a rapid process of urbanisation over the past decade. The Regional Planning Guidelines for the Greater Dublin Area place Greystones within its Metropolitan Area. Only yesterday the elected members of Wicklow County Council agreed to put a new Settlement Strategy for Wicklow out on public display in which the 2002 population for Greystones of 11,913 is anticipated to increase to an Indicative population of 17,679 by 2010 and a maximum population of 22,000 in 2016. The accommodation of this enlarged population by the town of Greystones will necessitate its continuing urbanisation. This inescapable process of urbanisation would appear to reinforce the importance of retaining Greystones harbour and beach area as relatively undeveloped public amenities that can provide residents with a direct experience of the coastline in its natural state. Indeed, in the Tourism and Recreation section of the Wicklow County Development Plan 2004-2010, under Development Control Objectives, Section 5.1.1 Recreation Development in Amenity Areas the Plan says:

“The Council will promote and encourage the recreational use of coastline, rivers and lakes for activities such as game fishing, boat sailing etc. Where such recreational uses involve the development of structures or facilities, the Council will ensure that the proposals will respect the natural amenity and character of the area, listed views and prospects onto and from the area in question. Where possible, such structures should be set back an appropriate distance from the actual amenity itself and should not adversely affect the unique sustainable quality of these resources”

While acknowledging the degraded state of the harbour itself and the desirability of improving the club facilities at the harbour, I would suggest that any decision to urbanise a large part of this area in order to fund the necessary harbour restoration works is a disproportionate response on the part of Wicklow County Council, the local authority and must be questioned closely. I listened with interest to some of the presentations made last week by the architects who drew up the scheme and they made no attempt to disguise the fact that what is being proposed by the Harbour and North Beach scheme is the urbanisation of the area. The presentation by John O’Mahony of O’Mahony Pike Architects stated on page 5 that the proposed development presented the opportunity to “reconnect the neglected harbour area to the commercial heart of the town”. Further on he stated, “the opportunity is presented for the town to re-engage with the seafront at an urban level”. In describing the proposal to extend the alignment of Trafalgar Rd northward, he spoke of “firmly routing the new development within the urban form of existing Greystones”. Later on, Peter Dikhuis of Broadway Malyan Ltd spoke of “the need to create a new urban quarter” in the Harbour and North Beach Area.

The clear acknowledgement that the existing harbour and beach area is being urbanised and transformed into a new urban quarter appears to bear out some of the concerns expressed by the Department of the Environment in its submission to the Board on the EIS for the proposed development. In its submission the Department stated: “The proposal seeks to site a large-scale urban development with a new harbour and harbour-related uses next to a Victorian village at the edge of a small existing harbour”. The submission goes on to say that the Harbour area has a distinct character and that the predominant form in the harbour area is the two-storey house. It emphasizes the prominence of the Harbour in relation to the town of Greystones because of the orientation of the Victorian terraces and streets towards it and notes that the area contains many protected structures. It points out that the new Harbour scheme does not build upon the existing urban design but establishes a separate character – what the Department refers to as “a wholly distinct new quarter”.

I want to suggest that the proposed large four- storey commercial/apartment blocks exceed in scale anything in this Victorian town and that furthermore the difference in character between the established town and the proposed new quarter will have a very negative effect on the architectural heritage character of the town. I am no expert in architectural matters but I am aware that there is a trend towards amongst some contemporary architects towards the juxtaposition of modern and traditional design in what is considered to be an interesting blend. However, I would argue that the Victorian and Edwardian character of Greystones architecture is central to the town’s sense of identity and that the addition of this very modern urban maritime quarter will greatly disturb and detract from that identity. It is important to remember that the proposed site is of a very significant size -approximately 27 hectares, including 28 acres of reclaimed land and there will certainly be a disparity of mass and intensiveness between the existing town and the proposed new development.

So to conclude my first point Inspector, I believe that the proposed PPP development of the Greystones Harbour and North Beach area will transform what is currently a undeveloped, unspoilt and highly valued public amenity area in a growing town, albeit an area that has been neglected in terms of maintenance and investment to date, into a built up, urban quarter which will include both residential and commercial development. Furthermore the very modern design of this new urban maritime quarter will undermine the town’s architectural heritage character, which is central to the town’s sense of identity. The combined effect of the loss of a valued undeveloped public amenity area and the undermining of the town’s sense of its own identity amounts to quite a serious, and, I would contend, negative impact of the proposed development on the residents of Greystones.

(ii) Lack of public support for the proposed development

This allows me to move on to the second argument I wish to make in opposing this proposed development, and that is the clear lack of public support for the scheme.

Inspector, if it were the case that despite the impacts I mention, the town’s residents welcomed the proposed development as a way of addressing the problems that affect the harbour area, then the Board would obviously have to give serious consideration to this fact when making its decision. On the basis of the canvassing I have done in the town to elicit people’s views about the proposed development, the packed public meetings I have attended opposing the development, and the several thousand local objections to the proposed development of the Harbour and North Beach Area that were lodged with the Board, I have good grounds for believing that a majority of the town’s residents are opposed to the scale and design of the proposed scheme. The obvious question to ask is how the proposed development got as far as being submitted to the Board for approval, given the fact that it is not supported by a majority of the town’s population. I hope to clarify today how the people of Greystones have consistently opposed plans for the large-scale development of the Harbour and North Beach area since they were first mooted and how this opposition has been expressed whenever opportunities for public consultation were provided by Wicklow County Council. As far back as 1997 Wicklow County Council presented proposals by Albert Gubay for large-scale marina and housing development at Greystones Harbour, which was subsequently rejected at a public meeting attended by 800 local residents. A subsequent survey covering over 1,000 local houses found 92% of residents were opposed to the concept of high-rise development at the harbour being used to fund a marina.

In response to this Wicklow County Council set up a Harbour Think Tank whose objective was to arrive at a consensus on what scale of development would be acceptable to all interest groups. Consultants retained by Wicklow County Council presented a number of proposals to the Think Tank over a 4-year period. At no point in the 4 year process did the Community give any indication that it had changed its views regarding high-rise development at the harbour. At no point was the Think Tank asked to make a final decision on the option to be pursued. At a meeting in 2003 Greystones residents were told that Wicklow County Council had made a decision on the plan that was to be pursued for the Harbour and North Beach Area. In a variation to the 1999 Wicklow County Development Plan, the elected members of Wicklow County Council had voted 13 for and 8 against a development plan for the Harbour and North Beach area that was very similar to the one that had been rejected by the people of Greystones 6 years previously. Indeed as one of the councillors that refused to support that variation, I pointed out a the time that councillors were voting to increase the number of apartments from 220 to 375 in the absence of any real financial information that would justify the need to increase the number of apartments as proposed by the council officials.

Councillors also voted at that meeting to exempt the Harbour and North Beach development from any requirement to comply with Part V of the Planning and Development Act 2000, insisting that this would undermine the financial viability of the project. Again this decision was based on notional costs rather than any accurate financial analysis of the proposed development. Approximately 70% of the public submissions that were made to the council at the time in relation to the variation were opposed to it. In 2005 Wicklow County Council put its development out to tender and the project was awarded to Sispar. The PPP proposals were presented as part of a public display in Greystones over two days in late October 2005 and the majority of those who turned up to view the plans voiced their opposition to them. Since then, over 6,000 people have lodged their objections to the proposed development with the Board. Most of the people I have spoken to in the town have expressed the view that while Greystones Harbour badly needs to be restored and refurbished, they favour a much more modest development of the Harbour and North Beach area. It seems to me that the reason why this scheme progressed as far as it has is that the Greystones public representatives on Wicklow County Council prior to the 2004 local elections were completely in favour of the proposed development and voted accordingly. I think we would all acknowledge the limits of representative democracy but certainly there was a failure to properly consult with the residents of Greystones to elicit their views on the proposed development before voting to allow it to progress. In fact given the high level of opposition that was expressed to the original 1997 Gubay proposal for the Harbour area, I believe that there was an onus on local councillors to establish that there was an acceptable level of public support for any subsequent development proposal for the Harbour area, before they voted for it.

To conclude this point therefore Inspector I would contend that, given the significant impacts the proposed development will have on the town of Greystones in terms of loss of the existing amenity and the undermining of the town’s architectural heritage character and sense of identity, the Board should give serious consideration to the high level of opposition to this scheme amongst the residents of Greystones when making its decision on the application.

(iii) Inappropriate use of the Public Private Partnership mechanism

My third point Inspector concerns what I believe to be the inappropriate use by Wicklow County Council of the mechanism of a Public Private Partnership to progress this development. I believe that there is little in the proposed development that constitutes ‘necessary public infrastructure’ with the exception of limited coastal protection works whose likely effectiveness has been questioned by the Department of the Marine in its submission to the Board. I don’t think anybody, even the greatest sailing enthusiast, could describe an international standard marina, desirable as it might be, as “necessary public infrastructure”. As part of the proposed PPP, Wicklow County Council is using the new power conferred on local authorities by Section 227 of the Planning & Development Act, to compulsorily acquire the foreshore in order to allow a private consortium to proceed with residential and commercial development on reclaimed land at the waterfront. The Wicklow County Council/Sispar Public Private Partnership is the first PPP of its type and I believe it will set an undesirable precedent for similar developments around the country. The proposed marina is definitely not necessary public infrastructure as defined under the legislation for PPPs. In the absence of a sufficiently robust ‘necessity test’ to ensure that the public good is being served by the use of such a power by local authorities, there unfortunately is the potential for the misuse of such powers. As the dominant elements of this proposed development include a 6,500 sq metre private marina with 230 berths, new harbour marine- based club facilities and mixed residential and commercial development, I believe the Board should consider both whether the public good is being sufficiently served by this development or whether the Public Private Partnership mechanism is facilitating private developers to maximise their profit by creating a development totally out of character with the rest of the town in terms of its design and density.

(iv) Failure to provide adequate coastal protection

My fourth point concerns the inadequacy of the coastal protection works being proposed. Wicklow County Council as the local authority partner in this proposed Public Private Partnership development has consistently justified this arrangement with the private sector on the basis that there is an urgent need to fund and provide for coastal protection works in the area. The public good, it is argued, will largely be served by the coastal protection element of the development. The development, as the Inspector is aware, will provide coastal protection from the harbour/marina to approximately 250m past the Gap Bridge. The coastal protection scheme designed involves a groyne revetment and programme of beach management using shingle beach nourishment. However in a submission made by the Coastal Zone Management Division of the Department of the Marine on the EIS for the development states in Point no 8, Soils and Geology: “ In relation to coastal protection north of the proposed revetment, it is not possible to offer a definite view on the proposed scheme but it appears to be minimalist and close to a ‘do nothing’ scenario”. This assessment by the experts in coastal protection in the Department is extremely worrying. While a large part of the justification for the Harbour and North Beach development is that it provides for necessary coastal protection works, the experts are saying that the proposed works are close to a “do nothing” scenario. It is important to ask why the local authority is making a significant amount of coastal land, including the foreshore, available to developers to develop lucrative residential and commercial property in return for what appears to be a “do nothing” or non-existent benefit to the community?

(v) Inadequate road infrastructure to support the proposed development

My fifth point concerns the fact that the road infrastructure around Greystones will not be able to cater for the traffic generated by this proposed development, and, if planning permission is granted, it will undoubtedly lead to an irresistible pressure for a new road over Bray Head. Pg 5 of the Dublin Transportation Office’s submission in response to the EIS for this development states: “However, due to the constraining aspects of the site and the lack of multiple access points into the site, the DTO has concerns about the overall scale of the development. The provision of just one access point, which would appear to be catering for all modes, does not seem appropriate for a development of this scale, in a central location within the town. This is likely to accentuate the traffic impact of the development on the road network within the town centre and negatively impact on the pedestrian and cycling environment in an area where this should be a primary consideration. Although it is accepted that the physical constraints of the site may limit accessibility potential, the overall scale of the development should reflect this constraint”. In other words Inspector it would appear that the DTO is suggesting that the existing limits on access to the site should be reflected in a reduction in the overall scale of the proposed development.

It is worth noting that the 1997 Buchanan Report commissioned by Wicklow County Council also found that the harbour area was “ill suited to significant extra volumes of traffic”. The report stated: “The increase in flows associated with 350 residential units is felt to be beyond the capacity of the road network and a maximum of 200 units is recommended”. Furthermore the report stated: “In the event of a significant larger marine development being approved, then it is recommended that access be via a suitable junction with the R761 (Bray-Greystones Road) North of Redford”. The possibility that the development proposed for Greystones Harbour and North Beach would lead to the creation of a new road over Bray Head is totally unacceptable from both a political, and a planning point of view. The prospect of a new road across Bray Head is one that in the past has been strongly opposed by the people of Bray and of Greystones. Bray Head and its lower slopes form an important Green Belt between both towns and is zoned Open Space in order to provide it with a strong level of protection against inappropriate development. The achievement of a Special Amenity Area Order for Bray Head has also been a stated objective of successive Wicklow County Development Plans over the past twenty years because the special amenity value of the Head has long been recognised. The elected members of Bray Town Council unanimously approved a Draft Special Area Amenity Order for Bray Head late last year and the Draft Order is currently before Wicklow County Council for its approval. I want to suggest today that the prospect of building a new road over Bray Head in order to facilitate the proposed development of Greystones Harbour and North Beach would be totally in conflict with the current planning objectives for Bray Head and its lower slopes as set out in the current Wicklow County Development Plan. I am aware that a particular landowner on Bray Head has made a submission to an Bord Pleanala stating his willingness to develop an access road across his land on Bray Head, in addition to developing some housing. I would suggest that rather than the Board giving any consideration to the possibility of a new road across Bray Head, it should instead follow the advice of the DTO and reduce the proposed scale of the development in the light of the existing limits on access to the site.

(vi) Lack of financial information concerning proposed development

My sixth point concerns the fact that neither Wicklow County Council nor the private consortium Sispar provided the elected representatives who voted for the proposed development with necessary and accurate information about the estimated costs of the scheme and the likely profits that will accrue to the developers, claiming that this was “commercially sensitive information”. As I have already mentioned, elected members were asked in 2003 to vary the County Development Plan to allow for an increase in the number of residential units permitted on the basis that this increase was necessary in order to make the project financially viable for the private consortium. I do not believe that it was correct for councillors to vote to increase the number of residential units in the development without having access to the necessary financial information to support that decision. I believe that this is something the Board should consider when making its eventual decision on the development.

(vii) Failure to properly consider alternatives to proposed development

My final point concerns the failure of Wicklow County Council to properly consider alternatives to the proposed development for Greystones Harbour and North Beach. As far back as 1987 when it commissioned McCabe Delaney and Associates to carry out a feasibility study for the development of Greystones harbour as a yachting centre, it would appear Wicklow County Council began to abandon its obligation for the upkeep of the harbour in favour of the eventual development of a marina. The Gubay proposal for the development of the harbour was only unsuccessful because of the scale of public opposition at the time, as Wicklow County Council was prepared to support it. Since the formation of the local Greystones Protection and Development Association in 1997, much of its work has been aimed at trying to have Greystones Harbour restored by way of a small-scale development, protecting the character of the Harbour and North Beach area. With the aid of local architects and consultants it prepared its own plans for the harbour area. These plans were costed at around 30 million euros and involved approximately 70 residential units located further back from the harbour area than the proposed apartments in the current application. This sum contrasts with the estimated 300 million euros cost of Wicklow County Council and Sispar’s proposed development. The GPDA presented its plans to Wicklow County Council whose consultants perhaps rather predictably rejected the plans on a number of grounds, including financial viability. In fact the 10 alternative models for the development of the Harbour and North Beach area listed in the back of the EIS submitted to the Board were dismissed by Wicklow County Council without any clarity or transparency about the grounds for their dismissal.

I am suggesting today that the proposed Harbour/North Beach PPP development is inappropriate for Greystones because of its sheer size, very modern design, undoubted impact on the already burdened local road network and the level of public opposition to it. Greystones harbour is a well-used, well-loved beauty spot, though badly neglected and in need of a restoration programme that also addresses coastal erosion and which is sensitive to safeguarding the unique character of the town. I am proposing that a development project, roughly costed at around 30 million euros would cover the restoration of the harbour, build a modest marina for local use and install the necessary coastal protection works. Furthermore, not all of the residential element that is deemed necessary to fund such works need occur at the harbour area but could, as was proposed with the original Gubay proposal, be constructed on land owned by Wicklow County Council elsewhere in the town. Finally, consideration could be given to relocating the large-scale and very ambitious development proposal, which is the subject of this Oral Hearing to a more suitable site along the East Coast.

That concludes my presentation. Thank you for your attention.

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