TTDP SUBMISSION IN RESPECT OF AN BORD PLEANALA REF PL.06F.PA0037
TRANSITION TOWNS DONABATE/PORTRANE SUBMISSION IN RESPECT OF AN BORD PLEANÁLA PLANNING APPLICATION, REG. REF. PL06F.PA0037, WHICH COMPRISES OF A STRATEGIC INFRASTRUCTURE DEVELOPMENT FOR THE PROPOSED NATIONAL FORENSIC MENTAL HEALTH SERVICE (NFMHS) HOSPITAL AT ST. ITA’S HOSPITAL, PORTRANE, COUNTY DUBLIN.
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CONTENTS
1.0 INTRODUCTION
2.0 CONCERNS OVER AMOUNT OF UNNECCESSARY TREES BEING FELLED
3.0 CONCERNS OVER THE RIGHT OF WAY EXTINGUISHING
4.0 CONCERNS OVER CONSTRUCTION TRAFFIC HAZARD TO COMMUNITY
5.0 CONCERNS OVER LACK OF COMMUNITY GAIN
6.0 CONCERNS FOR ST. ITA’S WALLED GARDENS
7.0 RECOMMENDATIONS TO AN BÓRD PLEANÁLA
8.0 APPENDIX
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1.0 INTRODUCTION
1.1 TRANSITION TOWNS DONABATE PORTRANE
Transition Towns Donabate Portrane (TTDP) is a voluntary not for profit organisation working in the locality of Donabate Portrane since 2009, primarily focusing on raising awareness and sustainability around local food, local economy and local energy. We facilitate small scale projects within the community using local economy, education, culture and heritage to create positive change for all members of the community in as sustainable and inclusive a manner as possible.
1.2 TTDP AND THE PROPOSED NATIONAL FORENSIC MENTAL HEALTH HOSPITAL
TTDP is cognizant of the long history of Mental Health provision at Portrane dating back over 100 years with St. Ita's forming the heart of the Portrane and greater Donabate community, offering employment and a social hub to the area throughout this 100 year history. TTDP supports the location of the proposed new National Forensic Mental Health Hospital (NFMH) in this current planning application, acknowledging this history and culture. We believe the location of the NFMH at St. Ita’s Portrane will be a positive development for the locality, with the redevelopment of the St. Ita’s complex bringing about renewal to the area as a whole. We believe the proposal will bring positive benefits for the economy and social life of Portrane and Donabate. TTDP as a community organisation recognises that the location of the NFMH at Portrane is both sustainable from a cultural and heritage perspective. Given that St. Ita’s Hospital was formally an Asylum for the Mentally ill and was constructed and run as a Psychiatric Hospital up until earlier this year (2014), there is a long local culture and history which gives a sympathetic and supportive community and therapeutic location for the new NFMH.
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Notwithstanding this support, we at TTDP do have serious concerns regarding the proposals and we would specifically ask An Bórd to address the following topics which we have concerns about and have identified and elaborated on further in this submission in the following chapters;
1. The unnecessary felling of too many trees 2. The extinguishing of rights of way 3. The lack of community gain 4. The Walled gardens at St. Ita's
5. The construction traffic hazard
TTDP recognises that the location of NFMH at Portrane will bring about a sizeable benefit to the local community both during and post construction. TTDP recognises this opportunity for the community and therefore wants to see this development of the NFMH done in a manner which is sustainable, knitting tightly with the local economy and community of Portrane and Donabate. In this way long term maximum benefit can be achieved, creating a whole and inclusive community, where the treatment of mental illness is done as an inclusive and holistic project involving the community and the HSE working together as they have done throughout the 100 year history of the provision of Mental Health care at St. Ita’s Portrane.
The NFMH project will define Portrane and Donabate for the next 100 years and it is imperative that An Bórd ensures that the project is done in a manner that respects the existing community, its specialist heritage and culture and its desire to see the delivery of the NFMH in a fair and sustainable manner for the next 100 years.
2.0 CONCERNS OVER THE AMOUNT OF UNNECCESSARY TREES BEING FELLED
TTDP recognises that the HSE along with Fingal Co Co have created a variation to the Fingal County Council Development Plan 2011-‐2017 in order to facilitate the location of the NFMH at St. Ita’s Portrane. It also recognises the work done in feasibility studies which have led to the chosen site location of the NFMH at this location and TTDP recognises that as a result of the 4
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construction there will inevitably need to be the felling of trees to allow for the proposed NFMH construction. This is normal and standard practice during construction projects and TTDP recognises this.
However notwithstanding this, TTDP would ask An Bórd to request that the HSE come back with a revised proposal around the felling of the number of proposed trees, which is currently proposed in the region of just under 1,000 number trees, a large number of which are over 100 years old.
The grounds of St. Ita's are currently an Area of Conservation within the Fingal Co Co development Plan and prior to the Variation to the Development plan to allow the location of the NFMH at this site, the site was zoned as High Amenity Lands, because of its natural beauty and flora and fauna due to in a large part the existing trees and forests within the grounds of St. Ita’s.
TTDP would urge An Bórd to condition instructions around the felling of trees so that the HSE should as a minimum be required to adhere to the following measures to negate the felling of so many trees
1. Ask the HSE to set back the proposed security boundary fence around the NFMH by one metre or two in places, which would as a result negate the need to fell the majority of these trees. The HSE has not demonstrated the absolute need for the security fence in its chosen location. The redesign of the location of the security boundary fence with the specific design intent of minimising the felling of trees would not seriously injure the proposed design, while saving a large proportion of the trees. TTDP contends that with imaginative and considerate design of the location of the fence in relation to the trees around the site we feel that a large number of trees could be saved. 2. Require the HSE to employ an independent arborist to supervise the felling of all trees so that they are felled correctly, without any encroachment and ensure no additional unnecessary felling of any additional trees during the construction of the project, which 5
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is a common occurrence. The proposed replanting should be supervised by the same arborist to ensure that it takes place in accordance with the plan.
3. Require the HSE to make all of these felled trees available to the community of Portrane/Donabate as a part of the community gain that is due to the community for this project, specifically for the loss of this amenity. There is a long history of locals from the community recycling fallen trees from within the complex of St. Ita's for fire wood and one can be sure that it was members of the Portrane community that planted and maintained them until now, so why not give the community back a resource that has always been and should ultimately be theirs. Otherwise it is likely that these up to 1,000 trees will become an additional price that the local community must pay. If the HSE is to demonstrate its ‘gain’ elements to the community, what better way than by giving back to the community what has always been theirs, through such a condition? As part of the give back of these trees to the community there are other imaginative ways that some of the felled trees to be donated back to the community could be utilised such as providing street furniture, sculptures, furniture for the schools and other public buildings on the peninsula made from the hardwood trees. The employment of local artists and carpenters to make this furniture and art would show that the forestry resource has lived on in the community.
The conditioning of these requests by An Bórd on the HSE, would improve the design and fit of the new NFMH in its new location, these conditions would cause less disruption to the existing site, and existing community and these conditions would also give back to the community something real and tangible, at the same time making the construction project more sustainable and inclusive in the long run by means of a very small but symbolically very big gesture.
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3.0 CONCERNS OVER THE RIGHT OF WAY EXTINGUISHING
TTDP accepts that the location of the proposed NFMH will cause disruption to the existing public rights of way through the St. Ita’s complex due to the new NFMH being constructed in the middle of the path of the existing rights of way. These existing rights of way are a well established and much loved and much used amenity by local members of the community for walking on a daily basis. They bring those members of the community who would have otherwise no interaction with the St. Ita’s complex into a close appreciation of the area through the use of these rights of ways for walking.
TTDP is concerned that if the existing public rights of way are formally extinguished by Fingal County Council -‐ in accordance with Section 73 of the Roads Act 1993 – this will remove the legal right of the community to pedestrian access through the site. The HSE/applicant is not proposing to provide new legal pedestrian public rights of way. The community is being asked to accept a promise made in a planning application; a promise which has no legal basis. The planning application states that “alternative / replacement public access routes through the St. Ita’s Hospital complex will be open to the public prior to the closure of the sections of the existing public access routes through the St. Ita’s Hospital complex”, TTDP finds it difficult to believe given how the site will be under construction, that this will be complied with as it will not be a priority of the NFMH Development Team. TTDP requests that the HSE/applicant is conditioned to formally create new legally binding rights of way which the community have a right to as opposed to an inference that they will be provided as part of the planning application which is not legally enforceable, which could ultimately lead to this right being taken away from the community easily enough if the HSE/applicant were to take that action at a later date.
TTDP request that An Bórd also conditions that the new rights of way be constructed in 7
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their entirety prior to the extinguishment of the existing rights of way.
4.0 CONCERNS OVER CONSTRUCTION TRAFFIC HAZARD TO COMMUNITY
The proposed construction of the NFMH as set out by the HSE/applicant proposes to drive its construction traffic through the Hearse Road/R126 over the Railway Bridge entering into Donabate Village, through the village of Donabate, passing the Beaverstown Road (which controls access to the Educate Together School) past the access road to the Donabate Post Primary School, past the graveyard, past the Portrane Boys and Girls National Schools, then through the Portrane Road entering into the St. Ita’s Demesne to the construction site. It then proposes to return out the same way. This is a one road town with only one road in and out once one enters the village of Donabate on the way to Portrane.
The existing community is already poorly served by the existing road infrastructure and this has been recognised in the proposed Donabate/Portrane Local Area Plan already, with a new road proposed from the Hearse R126/to the Portrane Road to help alleviate this and allow for a second route. This new road is not built or planned to be built any time soon and the village/community and schools are currently working the existing road network to its maximum. At times of high volumes such as school times, evening rush hour the village and its roads are bumper to bumper and realistically the existing road network, not upgraded can handle no more.
The construction of the NFMH is a proposed 2 ½ year project, with construction traffic proposed to generate thousands of truck deliveries to the site through the existing road network. The HSE/applicant has indicated it will manage the times of traffic flows to minimize disruptions to the busy periods to help to negate the hazard.
This proposal as set out will as a result guarantee that the villages of Portrane and Donabate will be permanently at maximum traffic capacity at busy times with the schools/rush hours to work with existing traffic and then on top of which it is planned to take up the slack times with 8
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a full flow of construction traffic from the construction traffic from the proposed NFMH.
In summary the HSE/applicant proposes to drive all the construction traffic through the village, past the three schools which is all a one road access in and out which will result in a permanently clogged traffic network within the community and village of Portrane/Donabate.
TTDP feels that this current proposal is unsafe to the local residents, is unsafe to the local children and it will destroy the amenity of the area and we ask An Bórd to condition that the HSE/applicant deals with its construction traffic in a more appropriate, sustainable and local friendly way. TTDP understands that the construction traffic is requisite to the construction of the NFMH, however the proposal to run the traffic as proposed is not the only option and TTDP recommends that the Bórd conditions the HSE/applicant to create an alternative route as set out in the following map and description which would vastly lessen the burden on the current road network of Donabate and Portrane, while at the same time allowing the project to proceed without too much additional cost in proportion to the overall project brief.
TTDP requests An Bórd to make the following two conditions in relation to traffic management to alleviate the burden of this traffic on the community of Donabate Portrane as follows;
1. The traffic entering into the peninsula from the M1/R132 should be forced to use Turvey Avenue on the way IN and traffic leaving the NFMH site should be forced to use the Hearse Road/R126 on the way OUT. This would alleviate the traffic on the main R126 access by halving the traffic caused by the proposal. It would also allow users to predict the traffic and not be held to ransom by the construction traffic for the two years plus that the project will be constructed.
2. Fingal County Council own the lands indicated in the attached map, which stretch from the New Road, Donabate north to the St. Ita’s Demesne complex. The HSE/applicant should be required to create a haul road/temporary construction road from the New Road to the construction site over these Fingal County Council lands for the duration of the project for the sole purpose of rerouting the access of the construction traffic to 9
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the site. This would have the effect of removing the construction traffic from the villages of Donabate Portrane and away from the three schools. This is a very easily achieved solution that would bring about a serious improvement to the amenity of the local community during the construction phase. The last time the HSE/applicant developed at St. Ita's Demesne complex in 2006/2008 when it constructed the Knockaman Complex, it constructed a Haul Road to take traffic away from the Portrane Avenue, and so it is also therefore a solution the HSE/applicant has used in the past at this location. We have included a map which shows the Fingal Co Co lands outlined in blue, the NFMH location outlined in red and we have shown a possible route for a haul road, which would redirect the traffic from the entire village, the schools and the graveyard below.
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5.0 CONCERNS OVER LACK OF COMMUNITY GAIN
TTDP would like An Bórd to note that the proposed community gain as set out by the HSE/applicant is effectively miniscule and could be construed as a disrespectful gesture to the local community if taken as literal. This supposed community gain has been represented by the HSE/applicant that the community of Donabate Portrane will gain by having the HSE giving over leases to a soccer club that has played on its site for upwards of 80 years and giving a lease to another club on its lands which was originally swamp land until the same club reclaimed these lands. In other words the HSE/applicant is going to allow two soccer clubs to use lands that it already uses. This cannot be construed as community gain in the context of the relocation of the ne NFMH at St. Ita’s Portrane. TTDP asks that, for the reasons set out below, An Bórd Pleanála disregard the list of items the applicant purports to represent as “community gain” and instead to refer to a list of potential community gain projects which the community has drawn up elsewhere in other community representations made to it and specifically the recommendation made by TTDP in relation to the Walled Gardens at St. Ita’s, further elaborated in the next section of this submission for consideration for conditioning under Section 37 (G) (7) of the Strategic Infrastructure Act 2006 – in the event that the Board decides to grant planning permission. 3.1 COMMUNITY GAIN PROVIDED FOR UNDER THE STRATEGIC INFRASTRUCTURE ACT 2006:
TTDP requests that when the Board makes its decision to grant permission for strategic infrastructure development, the Board may attach conditions in the normal manner. Conditions may include a condition providing for ‘community gain’. Such a condition may require the construction or the financing, in whole or in part, of a facility or the provision of a service in the area in which the proposed development would be situated and which the Board 11
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considers would constitute a gain to the community. TTDP notes that Section 37 (G) (7) of the Strategic Infrastructure Act 2006 states: Without prejudice to the generality of the Board’s powers to attach conditions under subsection (3) the Board may attach to a permission for development under this section— (d) a condition requiring— (i) the construction or the financing, in whole or in part, of the construction of a facility, or (ii) the provision or the financing, in whole or in part, of the provision of a service, in the area in which the proposed development would be situated, being a facility or service that, in the opinion of the Board, would constitute a substantial gain to the community TTDP clearly understands that the Act also states in Section 37 (G)(8): A condition attached pursuant to subsection (7)(d) shall not require such an amount of financial resources to be committed for the purposes of the condition being complied with as would substantially deprive the person in whose favour the permission operates of the benefits likely to accrue from the grant of the permission.
TTDP asks the An Bórd to make a condition on the HSE/applicant in light of the legislation allowing for real Community Gain by way of a financial award for the community alongside the request set out by TTDP in relation to the Walled Gardens at St. Ita’s, see next section.
By virtue of the nature of the relocation of the NFMH at Portrane, its very nature and notoriety is going to define the community of Portrane and Donabate for the next 100 years. The local community of Portrane and Donabate is uniquely placed to welcome and home this new facility and help make it a success. TTDP would ask An Bórd to make this financial contribution/levy for community set at a reasonable figure of 5% of the overall project cost on the basis that, this would not be onerous on the overall project budget, it is a right as set out under the act and it is the right thing to do by the community to help pave the way and welcome the new NFMH community into the community of Portrane Donabate.
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6.0 CONCERNS FOR ST. ITA’S WALLED GARDENS
The walled gardens at St. Ita’s Portrane were constructed in the 1730’s by The Evans Family as part of Portrane House (now demolished), which was the original Portrane Demesne which was subsequently bought for the building of an auxiliary hospital to the Richmond Hospital, which was completed in 1902, now known as St. Ita’s Hospital.
The house was demolished in the 1950’s however, the walled gardens continued to be used by the hospital, with all of the work being carried out by patients when there were upwards of 2000 patients within St. Ita's growing vegetables, fruit and flowers. However in the 1980’s the management decided to opt out of the provision of vegetables/fruit and the walled gardens became derelict and fell in to disuse which is how they currently stand.
These gardens are the oldest structure on the whole site and although they have no architectural merit, the walled gardens are important historically, culturally and for heritage reasons as they are a link going back over 350 years to the original Evans House and way of life.
As set out in the introduction, Transition Towns Donabate Portrane works to create small scale local community projects around food, economy and heritage. Back in 2010 TTDP identified the Walled Gardens at St. Ita’s Portrane as being an ideal site to create a community garden project for the facilitation of small scale economic activity around food. We have included a document published by TTDP in 2010 as an awareness leaflet around the gardens, which sets about explaining TTDP vision and plans in the Appendix.
Before the announcement of the relocation of the NFMH to the St. Ita’s site, initial discussions with the HSE were positive around making available these lands to the community as a community garden. TTDP also met with Fingal County Council and has the full backing of the council in this regard, with motions passed by Fingal County Council at chamber level calling 13
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upon the HSE to enter into negotiations with TTDP to bring the walled gardens at St. Ita’s back into community use.
In Sept 2012, the HSE wrote to TTDP indicating that it had the intention of incorporating the walled gardens into its proposal for the new NFMH and that there was ‘knot weed’ present and therefore as TTDP could not afford to eradicate this weed and that the HSE had plans for the walled gardens, then TTDP had no hope of creating a community resource at this location, we have included copies of the correspondence received from the HSE in this regard in the attached Appendix.
6.1 WALLED GARDENS AND APPLICATION PL.06FPA0037
The HSE/applicant as part of this planning application has now made its plans available and the following points set out where the walled gardens are mentioned or references made by the HSE/applicant within the planning application for the walled gardens as follows; The proposal as it currently stands on the Overall Site Development Plan shows that the HSE/applicant has no future plan for the walled gardens, other than to note some derelict buildings within the gardens, see NFMH Contextual Layout below.
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The proposal as it stands states on the Site Contextual Plan detailed on the previous page that there is an area to the south of the NFMH earmarked for further expansion, but this does not include the walled gardens
The proposal as it currently stands on the Development Plan Area A Site Plan shows the red line for the development of the new NFMH almost 50 metres from the walled gardens with the walled gardens clearly not included in its proposal, therefore demonstrating that the HSE/applicant has no clear plan for the gardens as previously stated in correspondence to TTDP in May 2012, see map on the next page. The proposal within the written documents as it stands indicates that the wall of the garden in places is unstable and the HSE/applicant merely suggests knocking it down, which the applicant has buried deep within the planning report
On page 135 of the EID Vol II – The potential for renovation of the walled gardens was mentioned by Fingal Co Co and it was highlighted by FCC this mitigation be prioritised for the rehabilitation of the walled gardens. In response the Design Team noted that it would ‘likely’ be a long term project for the patients of the NFMH.
Page 32 Planning Statement says (STRATEGIC ENVIRONMENTAL ASSESSMENT OF THE 15
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DRAFT VARIATION) 7 it is recommended that priority is given to rehabilitation of the walled garden as an amenity feature to contribute meaningfully to the concept of re-‐
use and conservation of the available facilities. This should include consideration of the potential heritage value of the apple trees contained within.
Page 47 Planning Statement says -‐ Management of the Orchard and Walled Garden 32 The principal mitigation measures proposed for the walled garden and orchard is some remedial pruning of the extant fruit trees to ensure their longevity and to take some samples of the fruit or genetic material from the trees to determine if they are traditional Irish fruit tree varieties. 33 The areas of rank grassland within the walled garden should be mown twice annually and a general site tidy up of debris, broken glass, damaged greenhouses, etc. should take place.
34 The large stand of Japanese knotweed along the ditch at the base of the walled garden should be controlled and eventually eradicated through herbicide applications as described in the Invasive Species Management Plan for St. Ita’s.
Page 65 -‐ Planning Statement says 7) While it is not proposed to rehabilitate the protected structures comprising the walled garden as part of the present development proposal, the rehabilitation of the original apple trees contained within has been incorporated into the Biodiversity Management Plan, as submitted as part of this planning application. The HSE is however committed to rehabilitating the walled garden as an amenity feature, as part of a patient therapy programme in the near future (which will require separate planning consent) to contribute meaningfully to the concept of re-‐use and conservation of the available facilities.
The HSE/applicants arborist concludes his report stating ‘The restoration of the old orchards in the walled garden (this could be part a general rehabilitation of the garden involving patients, voluntary groups, community allotments etc.)’
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6.2 TTDP RECOMMENDATIONS TO AN BÓRD PLEANÁLA IN RELATION TO THE WALLED GARDENS AND COMMUNITY GAIN
If HSE/applicant has a ‘supposed’ future plan to further develop the walled gardens at a later date, TTDP asks that An Bórd instruct the HSE/applicant to make this clear in this application as this ‘possible’ proposal for the gardens is a most pertinent and relevant point that should be clearly indicated in this application in the plans attached to this application and the descriptions as set out, given the very nature of the proposed development. It can be clearly seen from the correspondences received from the HSE in relation to the walled gardens before the planning application was prepared and that following on from the planning application as now presented that the HSE does not have a real or viable plan for this valuable walled garden at this time or for a realistic plan or vision into the future other than to knock its 350 year old walls instead of repair and renew them.
The HSE has been a very poor custodian of the St. Ita’s complex, allowing it to fall into disrepair without any clear vision to renew it. It has no history in the previous 20 years of protecting the walled gardens. The HSE is ultimately a deliverer of Health Care. The HSE is not a Property Manager; it is not a listed buildings guardian, its main focus is the delivery of health care and as a result, it will never have the budgets or the inclination to care for the campus as well as it should be.
TTDP as part of the local community has a real and tangible vision for the walled gardens at St. Ita's and has done for a number of years. It has a history of delivery on projects with a track record of obtaining funding from grant funding bodies. It has the support of Fingal County Council on this project. Even the HSE’s own arborist recommends allowing a community group project at the site. It seems that everyone other than the HSE can see the merits of allowing a local community group like TTDP to deliver a real community gain at this currently run down disused derelict site.
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TTDP sees the walled gardens as an opportunity for the HSE to work in tandem with the local community, and if its intention in years to come is to use the local community to facilitate a work program for its patients in their community rehabilitation back into the general populace, TTDP would be more than delighted to help facilitate this as part of a partnership agreement around the walled gardens.
TTDP asks An Bórd to condition it that as part of the ‘community gain’ aspect of the grant of the application that the HSE/applicant must enter into negotiations with TTDP, the intention of which would be to bring the walled gardens back into community use through a shared space between the community and the HSE as per the vision and desire that the local community of Portrane Donabate has for the walled gardens.
7.0 RECOMMENDATIONS TO AN BÓRD PLEANÁLA
TTDP supports the location and development of the new NFMH at St. Ita’s Portrane, notwithstanding this support we have serious concerns and we recommend that An Bórd specifically deals with these concerns in order to make the new NFMH development;
Safer During Construction
More sustainable during construction and on completion
More inclusive during construction and on completion
Ultimately more successful for the community and the residents of the NFMH
TTDP specifically calls upon An Bórd to make the following conditions on the HSE/applicant to achieve these goals;
1. Re-‐design the location of the perimeter fencing to minimize the felling of trees and give to the community of Portrane Donabate the trees that cannot be saved as a part of the community gain
2. Regularise the legal position guaranteeing any rerouted rights of way through the St. Ita’s complex prior to any work to these existing rights of way
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3. Re-‐route the construction traffic away from the village, schools and graveyard via a temporary haul road across Fingal Co Co lands
4. Give a community gain which is commensurate to the effort and amenity that the local community will give as a result of the NFMH, at a value of no less than 5% of the overall cost of the project
5. Give the community through TTDP the opportunity to create a shared space at the walled gardens as part of the community gain
TTDP asks An Bórd Pleanála to give due and proper consideration to the points and recommendations made here if it sees to grant the permission to the HSE/applicant the development of the new NFMH at the St. Ita’s complex at Portrane.
For and behalf of
Transition Towns Donabate Portrane
Joseph English
The Quay
Portrane
Co. Dublin
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