20th February 2021The Dublin City Planning OfficerMr. John O’HaraDublin City CouncilCivic Offices, Wood QuayDublin 8, D08 RFRe. pre-draft consultation phase as part of the preparation of the Dublin City Development Plan 2022 - 2028 Dear Mr. O’Hara,I welcome the opportunity to take part in the pre-draft consultation phase as part of the preparation of the Dublin City Development Plan 2022 - 2028. As we live use the lessons learnt from the COVID_19 pandemic to inform a new Development Plan that better assists in providing housing for all, and that tackles the climate and biodiversity crises than previous plans. I suggest that the Plan should be shorter than the previous Plan and should be fully costed. It should also identify who will deliver the Plan’s objectives where that is outside the Local Authority’s control.My suggestions are as follows. Theme 1: Shaping the City: Height and DensityDespite the over-ruling of height guidance by Government guidelines, it is crucial that the Planning Authority sets out its rationale and rules for height and density in the city. It should set both minimum and maximum heights and densities for different locations relative to accessibility by sustainable transport modes and give clear guidance on heights and floors on all. For instance, it is wasteful to allow one floor high food outlets on precious sites alongside Quality Bus Corridors. Greater clarity on heights and densities will reassure nearby residents and boost investor confidence. The urban planning of Catalonia in Spain could inform this work. A presumption of six floor high construction is appropriate at locations well-served by public transport. This is the maximum height that can allow a parent to see and communicate with a child on the ground outside. It also is relatively accessible by emergency services and can be allow stairs access should lifts fail. Taller buildings should be also facilitated, but in locations that are carefully chosen in terms of their impact on the streetscape, and their accessibility by extremely high levels of public transport access. Compared to our continental counterparts Dublin is not particularly sunny and is both damp and windy. This means tall buildings can be particularly detrimental in terms of exacerbating high winds and overshadowing their surroundings.The Planning Authority should pinpoint locations and sites for high buildings within the city, and review the many locations identified in the current plan. It should demand an exceptionally high design standard for such buildings and ensure that they are the subject of design competitions. The pandemic has also shown the importance of providing generous courtyards in apartment buildings, and adequately sized balconies. These provisions should be ensured in the Plan.The Plan should adopt the ‘15-minute city’ approach espoused by Sorbonne professor Carlos Moreno.It should provide more encouragement of mixed-use development both throughout neighbourhoods and within individual buildings. Such developments should seek a lively mix of uses on the ground floor in the form of vibrant ‘plinth’ uses at street level with generous floor-to-ceiling heights. It is appropriate to provide a significant increase in housing within the inner city to reduce long-distance commuting to city-centre workplaces. The Living City scheme should be under the control of a named and readily contactable public official whose mandate is to coordinate planning, disability, conservation, and other issues under the local authority’s remit. The scheme must also be more actively promoted by the Council. The rezoning of old industrial lands for higher density development should be encouraged, and such areas should be the subject of Local Area Plans that provide detailed master-planning and guidance on open space and street layouts following the latest guidance for the design of urban streets and roads (DMURS). Theme 2: Climate Action: Climate and BiodiversityThe Planning Authority should ensure that any new construction reaches a Passive House standard, as is the case in the neighbouring Planning Authority of Dún Laoghaire-Rathdown.The most sustainable buildings are generally the ones that already exist. Should Planning Permission be sought for demolition a full-life cycle analysis should be carried out to determine the impact on greenhouse gas emissions of such a development. The presumption should be against demolition.The carbon content of construction materials should be considered in determining Planning Applications and low-carbon building materials should be encouraged within the written statement of the Plan. Theme 3: Quality Housing and Sustainable NeighbourhoodsThere is a crisis of affordability and availability of housing. Many key sites in the city are being developed for student housing, hotels, and co-housing with limited tenant tenure. All these uses are transient and deter social cohesion and housing affordability if they are prioritised above other uses. The Plan should determine the housing mix required at a micro-level within individual electoral districts and on key sites. Guidance from the UK such as the City of Edinburgh’s Student Housing Guidelines provides valuable lessons in ensuring student housing does not dominate an area, and this could inform Dublin City’s next Development Plan. (https://www.edinburgh.gov.uk/downloads/file/24492/student-housing)The Local Authority should ensure that vacant or under-used sites within its one jurisdiction are developed for public housing using the ‘Vienna Model’ of affordability over the course of the six-year plan. Underdeveloped lands (such as the one-storey high shops that front onto the west side of Moore Street in Dublin 1 in the ILAC centre) should be developed in the short-term. All vacant sites owned by the city should be redeveloped within the lifetime of the Plan. The Plan should not allow windowless habitable rooms and should mandate adequate levels of daylight. The Plan should ensure that any co-housing or student rooms have balconies. There has been a tendency to provide dark and dank courtyards in residential areas in recent years. The Plan should set out minimum standards for daylight in courtyards and living spaces. The Development must set out steps to bring ‘Pre-63’ residential units with poor quality accommodation up to a reasonable standard. Poorer tenants and vulnerable groups such as immigrants are suffering due to low standards and this must be remedied. The Plan should set out timelines for this to happen. Theme 4 The City Economy The Plan should be ensure that economic activity is aligned with climate and biodiversity goals and should not simply pursue ecomic growth as an end in itself. It must recognise that there are natural limits to the planet's capacityIt should plan for less dependence on Foreign Direct Investment, letter-box companies and over-concentration on the Information Technology sector. Sectoral diversification is crucial to a steady-state thriving economy.The Plan should ensure sufficient space is provided at affordable rent foir crafts tpeople and other ‘maket’ and ‘repairing skills. These have a key role to play in areas of deprivation. Regeneration areas must provide mixed uses and work to integrate with the surrounding areas. A particular focus of economic action must be on the needs of immigrant communities. The city should facilitate the provision of small start-up spaces for entrepreneurs through shared workspaces, and indoor and outdoor markets. The city should encourage small plt size economic acrtivites.Tourism policies must facilitate on those who stay for longer periods and should ensure short-stay rentals do not continue to cause difficulties in the housing sector.Theme 5: The City, Urban Villages and Retail: MarketsThe Development Plan should provide strong support for Markets. Dublin may be the only capital city in Europe without an operating central covered market.The Plan should be clear in promoting Market uses for both the Fruit, Vegetable and Flower Markets on Chancery Street and the Iveagh Markets on Francis Street. It should promote and seek to improve the existing street markets on Camden Street, Cumberland Street, Thomas Street, and Moore Streets.It should propose lands for additional outside and covered Markets in other parts of the city. Theme 6: Sustainable Movement and Transport: The most powerful tool available to the Local Authority in terms of climate action in the coming years is its management of the space between buildings and it’s use for transportation and mobility. Safe walking, cycling and public transport must be prioritised.Footpath widening, junction re-alignment and ‘road diets’ can help promote sustainable mobility. The provision of new walking and cycling routes such as the ‘Hamilton Way’ or the ‘Santry Greenway can promote sustainable travel patterns. It should use evidence on emissions to determine the amount of public and private car parking within the Local Authority area and ensure that any new parking spaces have electric charging provided. It should set a gross maximum amount of car parking within the city and establish maximum car parking standards within new developments. Every street within the city that is subject to parking controls should have at least one designated car parking space available for car-sharing.The Plan should use air quality standards as well as other metrics to ensure a sustainable mobility mix in the city. If pollution from vehicles exceeds established standards, then access to the inner city for polluting vehicles should be reduced.The Plan should not permit front gardens to be converted to car-parking, as this removes public on-street parking and reduces green infrastructure, biodiversity, and valuable absorption capacity for rainfall.It should set a target for the reduction of on-street car parking spaces over the course of the plan (perhaps by 3% per year) and their replacement with cycle parking, tree planting and COVID_19 friendly spaces for outside gathering.The Plan should ensure that any future private parking spaces cannot be leased to third parties as such arrangements are encouraging more commuter car traffic into the city centre. The Development Plan should provide a low-emissions vehicle zone for the central business district to incentivise clean travel modes and improve air quality. The proposed plans for College Green are welcome, but the plans for traffic calming of Parnell Square have remained on the drawing board since the last century. The Development Plan should put in place ambitious targets for the reclaiming of public space from the car, and from parking over the lifetime of the Plan. It should put in place ‘road diets’ and reduce the lane width of roads and junctions that date from flawed mid-twentieth century visions of car dominance. As a rule of thumb, half the width of streets in the city centre should be designated for footpath and pedestrian use. In learning lessons from the pandemic, the Planning Authority should provide quality outdoors spaces for socially distanced gathering and provide high standard public seating in all parts of the cavity. The Plan should prohibit any increase in advertising space in the city. It should not allow back-lit changing digital ads that tend to dominate outdoor spaces. The recent granting of permissions for such installations at bus-stops have significantly damaged the public realm. The Plan should propose and support the post of Head of Design who can co-ordinate the efforts of the Environment and Transport; City Architects; Planning and Development; and Parks Departments. This could help ensure a new standard in terms of place-making and urban design is achieved for the public realm. This could address the mishmash of poorly designed signage, street furniture, lighting and paving in the city, as well as lead on ensuring Development Plan policies are rolled out across all Local Authority Departments. Theme 7: Green and Blue Infrastructure The Planning Authority should be reluctant to provide 100% site coverage for development. It should ensure that adequate green, open, or wild space is left in any development. Furthermore, it should move beyond the simple metric of ‘green space’ and insist on minimum standards for grassed area, tree planting, wild space for nature, and play space for children in the Plan.More ambition on green infrastructure is required, particularly in areas that have a deficit of such facilities such as East Wall and other parts of the inner city. The Plan could mandate urban forest plantings on sites and green areas that are somewhat sterile. Tree planting should focus on providing more mature native trees with generous tree pits (perhaps measuring three metres by one metre) with mixed planting in an approach that encourages biodiversity and sustainable drainage. The tendency to place trees in containers or pots should be avoided. It is the plant equivalent of intensive care! Tree roots deserve to be in the ground, and tall, large trees should be encouraged in public spaces.The Plan should ensure that the felling of any tree whose trunk is over twenty centimetres wide at one metre over the ground should involve consultation with residents within one hundred metres of the location. It should maximise opportunities for residents to access and recreate in the canals, rivers, and sea. It should identify places where improved access is required, and where improvements for bathing and water recreation can be made. It should seek to ‘daylight’ many of the rivers and streams that are currently culverted such as the Poddle and Bradogue Rivers and should not allow water bodies to be covered over. Theme 8: Built Heritage and ArchaeologyThe Planning Authority should place any buildings that are more than a century old on the list of Protected Structures. The Council’s reluctance to provide greater protection to heritage is at odds with best practice in other jurisdictions. The Planning Authority should use the Plan to codify an obligation on the Local Authority to provide emergency maintenance works to Protected Structures that are deteriorating and endangered. The Plan should prioritise improvements to Protected Structures that are currently disfigured by advertising including older railway bridges and Protected Structures within Architectural Conservation Areas such as O’Connell Street and environs.All buildings that are deemed of Regional Importance or higher within the National Inventory of Architectural Heritage should be placed on the Record of Protected Structures.The Plan should propose a small marker or plaque on or beside any building in the city that is pre-1700.Theme 9: CultureIt should ensure adequate affordable cultural space is provided and should ensure that the development of larger developments in particular cross-subsidies the provision of and running costs of such spaces. Night-time cultural uses should be incentivised, but a balance must be stuck between such uses and the needs of residents. In Temple Bar and in Dublin’s so-called cultural quarter between Grafton Street and South Great George’s Street an over-supply of late-night bars is deterring residential occupation. Other Issues not Covered AboveEnsuring Children’s views are heardThe Planning Authority should ensure that children’s voices are heard and used in writing the plan. It is noted that the online submission form appears to preclude the participation of children under the age of 16, thus forcing them to make hard copy submissions. This would appear to be at odds with obligations in the Planning and Development (Amendment) Act 2010. The inclusion of children’s voices can lead to a more progressive approach to mobility, as well ensuring that the provisions of space for play is better prioritised. Communicating the PlanThe online version of the 2016-2022 Plan is a significant dis-improvement on its predecessor. The new Plan should be readily accessible online with links on each chapter that bring the viewer to the relevant section. The mapping, particularly online could do with substantial improvements, such as the use of map titles that refer to the areas covered as opposed to the letters A, B, C, etc. The appendices to the plan should also be easily accessible online. It is disappointing that the Pre-Draft Plan Consultation Strategic Issues Paper contains few, if any metrics on the success or failures of the current Plan and it may be appropriate to ensure the provision of such metrics on an annual basis going forward. A plain language of the plan as well as a large print version should be available. The Planning and Development Department must work with express in accessibility and information technology to ensure this is achieved. I wish you well in your work in preparing the Plan. Sincerely,Ciarán CuffeCiarán CUFFE, MEP for Dublin Link to submission here.