Submission on the Dublin City Development Plan
Submission on the Dublin City Development Plan February 8, 2022
Senator Marie Sherlock
Hello,
We welcome the breadth and depth of the City Development Plan and wish to acknowledge the enormous efforts of the councillors, officials and Lord Mayor Alison Gilliland in ensuring that Dublin has a vision and a plan for how it will develop.
We do believe though that the Plan can be further strengthened and we ask that serious consideration be given to the recommendations below.
1. Tackling the issues associated with Build to Rent Development
Recommendation: The policy of targeting Build to Rent development within the Inner City must be abandoned.
We welcome the proposed changes to the unit mix in Inner City apartment developments. However, including a policy of facilitating the provision of Build to Rent specifically in the Inner City fails to recognise that many people live their whole lives in the Inner City.
These people deserve plans which provide good-quality, sustainable housing that allows their communities to grow, rather than an emphasis on solely short-term accommodation as provided by Build to Rent developments. Unless it is changed, this policy will lead to long term damage to the cohesiveness of the communities of the area.
In addition, there is an ambiguity is the plan with regard to the area encompassed by the north inner city. Policy QHSN38 defines the Inner City as “within the Canal ring”, while the Glossary defines it as being bounded on the northside by the North Circular Road.
2. Supporting and Expanding Our Cultural Venues
Recommendation: There must be concrete commitments to the development of the long overdue Parnell Quarter. Given previous disappointments, it is vital that a timeline for the development of the Quarter is set out in the Development plan.
As a Senator based in Dublin Central, I strongly welcome the emphasis on creating a new cultural cluster within the North Inner City. This area is the heart of our city, overflowing with historical significance, and deserves sustained and visionary investment to create one of the State’s premier cultural hotspots.
The long-overdue expansion of the Abbey Theatre (CU06), the delivery of a new City Library and a poetry centre in Parnell Square (CUO7, CUO8) and the creation of a new performance space for traditional music and dance for Na Píobairí Uilleann (CUO47) are all to be welcomed.
It is good to see such an emphasis on providing permanent homes for new and existing museums within Dublin as a vital addition to our shared cultural life. The commitments to identifying viable locations for a Museum of Dublin (CUO1), a Dublin Fire Brigade Museum (CU02), a Dublin Music Resource Centre and Museum (CUO3) and a Cultural Forum for Dublin (CUO5) are very welcome.
I would suggest the addition of a new Museum of Transport and Science be added to this list, with a potential location at the old Bus Éireann building in Broadstone.
3. Prioritising the 1916 Visitor Centre and Moore Street Redevelopment
Recommendation: A clear commitment, including timelines for delivery, must be included for the Moore Street redevelopment.
One of the most significant parts of the entire Plan is the redevelopment of Moore Street and the surrounding areas to provide a 1916 visitor centre and restored historic streetscape (CUO7). However, this is a commitment that has been a long time coming and we have serious concerns around Dublin City Council’s capacity to deliver the project without much firmer deadlines.
The Moore Street restoration and redevelopment represents a vitally important investment in the culture and heritage not only of Dublin City, but of the entire island of Ireland.
We need to see concrete commitments within the Development Plan as to the exact timeframes for delivery of this hugely ambitious project. A clear statement of intent with measurable targets for delivery is needed if this plan is to receive the top priority it deserves.
4. Creating a Vibrant Night Time Economy for Workers
Recommendation: We need a clear statement of intent that Dublin should be a liveable city for all workers, with decent pay, rights and conditions for all night time economy workers.
In our original submission to the City Development Plan in February 2021, we stressed the absolute necessity that “any major change to the night time economy must be accompanied by a proper consideration of worker’s rights,” and this is currently missing from the draft Plan.
Pub and club workers are some of the most exposed workers in the country to low pay, unsociable hours and difficult working conditions. If we are to extend the number and availability of clubs in Dublin, as we surely must, then the attitude to worker’s rights in this sector must also be strengthened.
We are calling for the Plan to commit to an increased focus on the rights, pay and conditions of night time economy workers as part and parcel of the proposed suite of changes, including where necessary an enhanced rate of pay of 1.5 times regular wages for workers in pub or club premises during late night or early morning shifts.
Our original submission also called for the Plan to “prepare for a new night-time landscape, one which includes the potential for longer opening hours, more relaxed licensing restrictions, and a greater all-round focus on the night-time economy”.
It is welcome to see that the current draft does indeed include a greater focus on the needs and potential of Dublin’s night time economy. This is especially relevant in the wake of research from Give Us The Night which reports an 84% decrease in Irish nightclubs since the year 20001.
In particular, we welcome the commitment to supporting new clubs and music performance venues (CUO30, CUO31, CUO35), the expansion of evening-time activities within the city (CU20, CU22) and the ambition to make Dublin a pilot for the creation of a Night Time Advisor and stakeholder committee as called for in the National Night Time Economy Taskforce Report 2021 (CU21).
5. Significantly Expanding Artistic and Cultural Space
Recommendation: There needs to be clearer targets for direct purchase and support for acquisition of space for new cultural and artistic work within the city.
A greater emphasis on the Council facilitating or directly purchasing properties for new cultural and artistic use would be a timely intervention in the battle for cultural space within our city. Dublin City Council can and must move beyond its current envisaged role as a broker between land-owners and artists or cultural workers; it must scale up its direct involvement in the provision of artistic, cultural and community space wherever possible.
More detail would also be welcome on the planned pilot project for provision of artist live-work space (CUO28) including targets for the number of artists involved and a deadline by which the conclusions of the pilot will be fed back to the Council. In particular, the inclusion of an investment or property acquisition target under CUO41 would be most welcome in terms of ensuring increased public ownership and facilitation of artistic and cultural spaces.
The recent community campaign against the redevelopment of the Cobblestone pub has highlighted the decades-long hollowing out of cultural spaces within Dublin. The past two decades have seen countless unique spaces turned into indistinguishable hotels and offices at the expense of the cultural life of our city.
It is welcome to see that the current draft of this Plan calls for a number of actions which could reduce and possibly reverse this squeezing out of cultural space. Supports for existing artistic spaces impacted by closure during the pandemic (CU13), temporary use of sites and buildings for artistic and cultural purposes (CU16, CUO25), plans for local cultural audits (CUO26) and requirements for new developments to incorporate community, arts and cultural uses (CU14, CUO22, CUO23) are a good start, as is the Council’s commitment to providing more spaces for artist studios and artists live-work spaces within the city (CUO27, CUO28).
However, given the scale of the cultural crisis facing Dublin, more concrete action will be necessary to preserve and expand artistic and cultural provision within the city. We would welcome clearer targets for delivery of artistic work spaces above and beyond the aspirations of the current draft, including through a designation of areas in which these efforts will be focused (as is done for Dublin 2 and Dublin 8 regarding the audio-visual sector).
6. Supporting Local Volunteers
Recommendation: This Plan must recognise and support the hard work of the voluntary arts sector.
The current draft does not address the voluntary arts sector, where local groups and organisations organise events and festivals for the benefit of their communities on an unpaid basis.
These groups need financial support from Dublin City Council as well as access to venues, and they should be acknowledged as significant contributors to the cultural life of the city.
7. Promoting Irish Culture and Gaeilge
Recommendation: We need Dublin City Council to take much more of a leading role in protecting and promoting the Irish language, especially through direct commitments as to the funding and support which will be provided in the lifetime of this Plan.
We would welcome some more detail on the important commitment to support “initiatives to establish Irish language network areas” within Dublin City (CUO45). This is a commendable goal, but ideally this is an area in which Dublin City Council would seek to take a leading role in addition to supporting organic community-led development of Irish-language areas. The establishment of clearer targets in terms of investment and outcome goals in this area would be hugely informative and give added weight to the Council’s commitments towards protecting and promoting the Irish language.
As Labour Party spokesperson on Gaeilge, I welcome the commitments to protecting key venues and cultural facilities involved in the expression of traditional music, song and dance (CUO48) and would request that this definition be expanded to include spaces used by groups dedicated to the promotion and protection of the Irish language.
We also strongly welcome the draft Plan’s focus on supporting the Irish language as part of our identity, and in particular the emphasis on Gaeilge as a living language within Dublin City. The Plan rightly identifies that there are more people using Irish in their daily lives within the capital than in any other part of the country, and that more must be done to facilitate citizens to engage with their city through the first language of the State.
As already mentioned, we commend the proposed extension of Na Píobairí Uilleann to provide a new cultural and performance space within the North Inner City for traditional music and dance (CUO47). If possible, further detail including a timeline for delivery of this project should be included in the City Development Plan.
8. Better Multilingual Cultural Infrastructure
Recommendation: The Plan should list the language groups that will be prioritised for greater facilitation in access to cultural infrastructure.
We strongly welcome the commitment towards multilingual community infrastructure within Dublin City (CUO44). While we would not want to set a limit on the language groups which may expect to benefit from such a policy, perhaps a clearer identification of which languages will initially be prioritised for greater cultural access would be useful in terms of ensuring tangible results.
In addition to Irish speakers, we must make much greater efforts to open our cultural life to those speaking Polish, French, Lithuanian, ISL and other common household languages in Dublin.
9. Providing Better Air Quality within Dublin City
Recommendation: All main traffic arteries into the city centre must be monitored for air quality. It is not acceptable that two key arteries, Drumcondra Road and Phibsborough Road, are not currently monitored. It is not sufficient, as per the draft Plan, that the Dublin City ambient air quality monitoring network would simply be “maintained”.
Recommendation: More concrete measures for improving air quality and reducing emissions must be included in the Plan to include consideration of traffic low emissions zones and congestion charges in certain areas.
Air quality is a key concern in the city, particularly in the Inner City. High traffic volumes into the city lead to a deterioration in the air quality of the area, which makes it even more important to address the promotion of active travel and sustainable, affordable home heating solutions in the city.
The poor level of air quality in parts of our city is, along with housing, one of the greatest challenges that must be headed off in Dublin right now before it gets worse. Initiatives such as low emission zones should be considered. However, at the heart of any action must be supports for the least advantaged in our city who are, on average, the most exposed and the least able to take on the cost of mitigating actions.
Ultimately, the improvement of air quality must be accompanied by serious consideration of how we incentivise cycling, bus use and sustainable, affordable home heating solutions in households in our city.
10. A Comprehensive Plan for Drumcondra
Recommendation: It is vital that the new local area plan/village improvement plan covers all of the Drumcondra area.
We very much welcome the commitment to develop a local area plan/village improvement plan for Drumcondra and it is important to acknowledge that this is a breakthrough for an area that is part of three different local electoral areas and two local authority management committees. However, clarity must be provided as the extent to which the LAP/VIP will encompass all of the Drumcondra area.
11. More detail is needed for all other proposed LEIPS and LAPs
Recommendation: More detail needs to be included in the LAPs and LEIPs for areas and there should be formal recognition in the development plan for substantial local community input into the LEIP/ LAP process.
We welcome the commitments to provide Local Area Plans (LAPs) and Local Environmental Improvement Plans (LEIPs) for a number of areas within the constituency, as well as the inclusion of Phibsborough as a Key Urban Village and Drumcondra and Stoneybatter for Village Improvement Plans.
However, we note that there is very little in the way of actual proposals within the term of the Plan for a lot of these areas, such as Cabra and the Navan Road: vibrant, clearly-defined communities with a strong sense of identity which deserve detailed and carefully thought-through local plans.
In addition, it must be accepted that there should be substantial local community input into the LEIP process in particular.
12. Preserving Corpus Christi Parish Hall as a Civic Amenity
Recommendation: Corpus Christi Parish Hall should be re-zoned as Z15 (Community and Social Infrastructure).
The Corpus Christi Parochial Hall, Homefarm Road, Drumcondra, Dublin 9, D09 W18 is an important community amenity for Drumcondra and is vital that it is made an express objective of the city development plan to retain it as such.
We ask that two amendments are made to the City Development plan:
- That it be expressly clarified within all maps and text of the City Development Plan that Z15 Community and Social Infrastructure zoning applies to the Corpus Christi Parochial Hall building and its frontage consisting of parking and side/front gardens. The building is located on Home Farm Road, Dublin 9.
- That it is an express objective of the City Development plan to protect and retain the Corpus Christi Parochial Hall as an important and necessary community amenity in Drumcondra.
The retention of this important amenity is vital for the use by people of all ages and backgrounds in the local community including the pupils of Corpus Christi Girls National School (CCGNS).
Section 14.7.14 of the Plan sets out the importance of community and social infrastructure in the city under Z15 zoning:
Such facilities are considered essential in order to provide adequate community and social infrastructure commensurate with the delivery of compact growth. It is the policy of the council to promote the retention, protection and enhancement of the city’s Z15 lands as they contribute to the creation of vibrant neighbourhoods and a sustainable well connected city.
The prolonged closure of the hall to the community and CCGNS (with the loss of PE/Assembly activities with no suitable alternative) has given rise to concerns that it may be converted to an alternative use by its owners.
Section 14.1 of the draft development plan acknowledges that community and social infrastructure must be safeguarded:
The strategic importance of the city’s Z15 (Community and Social Infrastructure) landbank (formerly referred to as “institutional lands”) to the future development of Dublin as a 15-minute city has been reviewed and there will be an increased focus on safeguarding the development of these lands these lands for social and community infrastructure.
Section 14.7.14 of the draft development plan highlights the need to actively protect the current use of the site.
In recent years, Z15 lands have come under increased pressure for residential development. However, protecting and facilitating the ongoing use of these lands for community and social infrastructure is a key objective of the Council. The Council are committed to strengthening the role of Z15 lands and will actively discourage the piecemeal erosion and fragmentation of such land.
However, it is open to the City Council under the draft development plan to permit limited residential/office development under the Z15 zoning:
Limited residential/office development on Z15 lands will only be allowed in highly limited circumstances where it can be demonstrated by the institutional landowners that the proposed development is required to maintain or enhance the function/operational viability of the primary institution on the lands.
Given that Corpus Christi church is the primary institution on the lands where Corpus Christi parochial hall is located, it is possible that such an application for conversion of the hall to alternative use could be permitted. On these grounds we are seeking an express reference to the importance of retaining Corpus Christi parish hall as vital community infrastructure.
13. Promoting Cycling Wherever Possible
Recommendation: The Plan must provide a firm commitment to reducing barriers to cycling everywhere in the city, including by setting definite targets for the roll out of segregated continuous cycle lanes, safety improvement measures, setting targets for reduction of car use and extending the Dublin Bikes network and hours of operation.
Improving the ability of people to cycle in Dublin is essential in terms of meeting our emissions targets, improving the quality of our air, promoting public health and improving road safety.
There is a paucity of ambition to roll out segregated continuous cycle lanes in the draft plan. It is telling that detail on the development of segregated cycle lanes is only proposed for Naas Road LAP in the city.
The City Development Plan must come out as strongly as possible in favour of the promotion of cycling and the removal of all possible barriers which currently prevent people in Dublin from getting on a bicycle.
The Plan must commit explicitly to removing barriers such as kissing gates that block cyclist passage throughout the city, to reduce speed limits to or towards 30km/h wherever possible, to dramatically increase the availability of secure parking spaces for bicycles within the city, and to set real targets for the reduction of car traffic within the city in general and through the Inner City in particular.
The Plan should also support extension of the highly successful Dublin Bikes scheme, increasing the number of bikes available and ensuring the long-overdue extension of the Dublin Bikes network into suburbs such as Drumcondra, Cabra and Glasnevin.
14. Banning For-Profit Homeless Hostels
Recommendation: That Dublin City Council institutes a total ban on private for-profit homeless hostels within the city bounds.
This Development Plan must face up to the issue of Dublin City Council facilitating the development of for-profit private homeless hostels in preference to public and charitable services. The creation and sustaining of a profit-making industry around homelessness in Dublin is deeply unwelcome, especially where this occurs with the effective sanction of Dublin City Council. Solving the housing and homelessness crisis within our city will never be achieved by commodifying basic services for homeless people, especially when there are many worthy but under-resourced charities striving to provide beds and supports for people experiencing homelessness.
Current DCC practice has allowed for-profit hostels to be put in place in areas like the Lower Drumcondra Road without even a semblance of meaningful consultation with the existing community. This facilitates private businesses profiting off a serious social problem with scant regard for the opinions or experiences of the residents of the communities in which they operate.
15. Facilitating Deliveries within an Active City
Recommendation: That the Plan makes reference to the need for innovative thinking around facilitating deliveries of goods within the City.
While the existing Plan makes reference to requirements for loading bay provision around hotels, there needs to be more thinking on how we can facilitate deliveries of goods safely and efficiently within an increasingly active city. As we rightly prioritise the uptake of walking and cycling, and a reduction in private car traffic, we must be mindful of the need to plan for vehicular deliveries to shops and other businesses within the city. Innovative thinking is needed to balance a strong prioritisation of safe walking and cycling and measures to allow a reliable flow of necessary deliveries into areas with high footfall.
Thank you for your attention to the recommendations above.
Best wishes,
Senator Marie Sherlock
Great Western Square,
Phibsborough, Dublin 7