Chapter 9: Sustainable environmental infrastructure and flood risk

Closed27 Jul, 2022, 09:00 - 1 Sep, 2022, 16:30
Material Alteration Reference Number 9.1

Chapter 9
Section: 9.5.1 Water Supply and Wastewater
Page: 315, 3rd paragraph

Amendment:

The water supply and wastewater needs of Dublin are to be met by a series of planned Strategic Water Services Projects designed to enhance the city’s water supply and increase wastewater treatment capacity in compliance with the Urban Waste Water Treatment and Drinking Water Directives. The phased upgrade of the Ringsend WWTP Project and Greater Dublin Drainage Project remain critical waste water infrastructure investment priorities in the short-to-medium term, whilst the Water Supply Project for the Eastern and Midlands Region (EMR) is identified as a critical longer term project to ensure resilience and security of supply. This project is due to be implemented under the IW National Water Resources Plan – Framework Plan (2021) which outlines how Irish Water intends to maintain the balance between the supply from water sources around the country and demand for drinking water over the short, medium and long-term. (The next phase will be the preparation of Regional Water Resources Plans (RWRP), which will in turn inform future capital investment and operational plans.){This Framework Plan is supported by the Draft Regional Water Resources Plan: Eastern and Midlands (RWRP-EM) which will inform future capital investment and operational plans in Dublin city.}
 

Material Alteration Reference Number 9.2

Chapter 9
Section: 9.5.2 Urban Watercourses and Water Quality
Page: 318, 3rd paragraph

Amendment:

The Council has a role to play in co-ordinating and tracking the implementation of {current, Draft and future 3rd cycle} RBMP measures at regional and local level, and in making sure they are fully considered throughout the physical planning process to ensure alignment between the Development Plan, WFD and RBMP. It is anticipated that forthcoming Section 28 Guidance on WFD Assessment and Sustainable Urban Drainage will assist planning authorities in addressing these water quality considerations as part of the planning and development decision-making process. {In the interim, regard will be had to the Government’s best practice guidance document, Nature-based Solutions to the Management of Rainwater and Surface Water Runoff in Urban Areas (December 2021)}.

Material Alteration Reference Number 9.3

Chapter: 9
Section: 9.5.2 Urban Watercourses and Water Quality
Page: 322, Objective SIO9

Amendment:

Objective SIO9: Planning for (Nature-based Water Management){Surface Water Management}

To undertake (Rainwater) {Surface Water} Management Plans for each river catchment and as part of this, include a study of relevant zoned lands within the city in order to ensure that sufficient land is provided for nature-based {surface} water management {, SuDS and green infrastructure}.

Material Alteration Reference Number 9.4

Chapter: 9
Section: 9.5.3 Flood Management
Page: 323, last paragraph on page

Amendment:

In 2013, the OPW published the Irish Coastal Protection Strategy Study (ICPSS) which provided strategic coastal flood and erosion hazard maps for the national coastline. {This was updated by the Irish Coastal Wave and Water Level Modelling Study (ICWWS) 2018, and the National Coastal Flood Hazard Mapping, 2021.} (This) {These} stud(y){ies} (has) {have} informed local authority assessment of potential hazards associated with future development, (has) {have} guided decision making on local coastal planning and development, and (has) {have} facilitated the development of appropriate plans and strategies for the sustainable management of coastlines. {Regard will also be had to the forthcoming recommendations of the Government’s Inter-Departmental Group on Coastal Change Management.}

Material Alteration Reference Number 9.5

Chapter: 9
Section: 9.5.3 Flood Management
Page: 324, Policy SI13

Amendment:

Policy SI13 Minimising Flood Risk

To minimise the flood risk in Dublin City from all other sources of flooding as far as is practicable, including fluvial, {coastal,} reservoirs and dams, (and) the piped water system {and potential climate change impacts}.

Material Alteration Reference Number 9.6

Chapter: 9
Section: 9.5.3 Flood Management
Page: 324, Policy SI14

Amendment:

Policy SI14 Strategic Flood Risk Assessment

To implement and comply fully with the recommendations of the Strategic Flood Risk Assessment prepared as part of the Dublin City Development Plan 2022-2028, {including all measures to mitigate identified climate change and flood risks, including those recommended under Part 3 (Specific Flood Risk Assessment) of the Justification Tests,} and to have regard to the Flood Risk Management Guidelines (2009), as revised by Circular PL 2/2014, when assessing planning applications and in the preparation of statutory and non-statutory plans.

Material Alteration Reference Number 9.7

Chapter: 9
Section: 9.5.3 Flood Management
Page: 324, Policy SI15

Amendment:

Policy SI15 Site-Specific Flood Risk Assessment

All development proposals shall carry out, to an appropriate level of detail, a Site-Specific Flood Risk Assessment (SSFRA) that shall demonstrate compliance with:

  • The Planning System and Flood Risk Management, Guidelines for Planning Authorities, Department of the Environment, Community and Local Government (2009), as revised by Circular PL 2/2014 {and any future amendments}, and the Strategic Flood Risk Assessment (SFRA) as prepared by this Development Plan.
  • The application of the sequential approach, with avoidance of {highly and less vulnerable} development in areas at risk of flooding as a priority {and/ or the provision of water compatible development only}. Where the Justification Test for Plan Making and Development Management have been passed, the SSFRA will address all potential sources of flood risk and will consider residual risks including climate change {and those associated with existing flood defences}. The SSFRA will include site-specific mitigation measures, flood-resilient design and construction, and any necessary management measures (the SFRA and Appendix B(4) of the above mentioned national guidelines refer). Attention shall be given in the site-specific flood risk assessment to building design and creating a successful interface with the public realm through good design that addresses flood concerns but also maintains appealing functional streetscapes. {Allowances for climate change shall be included in the SSFRA.}
  • {On lands where the Justification Test for Plan Making has been passed and where a small proportion of the land is at risk of flooding, the sequential approach to development will be applied, and development will be limited to Minor Development (Section 5.28 of the Planning System and Flood Risk Management).  There will be a presumption against the granting of permission for highly or less vulnerable development which encroaches onto or results in the loss of the flood plain.  Water compatible development only will be considered in such areas at risk of flooding.}
Material Alteration Reference Number 9.8

Chapter: 9
Section: 9.5.3 Flood Management
Page: 325, Policy SI16

Amendment:

Policy SI16 Site-Specific Flood Risk Assessment

Proposals which may be classed as ‘minor development’, for example, small-scale infill, extensions to houses and small-scale extensions to existing commercial and industrial enterprises in Flood Zone A or B, should be assessed in accordance with the Guidelines for Planning Authorities on the Planning System and Flood Risk Management and Technical Appendices (2009), as revised by Circular PL 2/2014, with specific reference to Section 5.28 and in relation to the specific requirements of the Strategic Flood Risk Assessment.  {This will include an assessment of the impact of climate change and appropriate mitigation.} The policy shall be not to increase the risk of flooding to the development or to third party lands, and to ensure risk to the development is managed.

Material Alteration Reference Number 9.9

Chapter: 9
Section: 9.5.3 Flood Management
Page: 325, Policy SI18

Amendment:

Policy SI18 Protection of Flood Alleviation Infrastructure

To put in place adequate measures to protect the integrity of flood alleviation infrastructure in Dublin City and to ensure new developments or temporary removal of any flood alleviation asset does not increase flood risk, while ensuring that new flood alleviation infrastructure has due regard to nature conservation, natural assets, open space and amenity values(.){, as well as potential climate change impacts}.

Material Alteration Reference Number 9.10

Chapter: 9
Section: 9.5.3 Flood Management
Page: 326, Policy SI19

Amendment:

Policy SI19 Provision and Upgrading of Flood Alleviation Assets

To facilitate the provision of new or the upgrading of existing flood alleviation assets where necessary and in particular, the implementation of proposed flood alleviation schemes, on the Santry, Camac, Dodder, Wad, Naniken, Mayne, Tolka and Poddle rivers as well as Clontarf Promenade, Sandymount {/ Promenade (northwards towards Irishtown Nature Park subject to the outcome of a flood / environmental study),}Liffey estuary and any other significant flood risk areas being progressed through the planning process {to completion} during the lifetime of the 2022-2028 Dublin City Development Plan, with due regard to the protection of natural heritage, built heritage and visual amenities (.){, as well as potential climate change impacts.}

Material Alteration Reference Number 9.11

Chapter 9
Section: 9.5.3 Flood Management
Page: 326, Policy SI21

Amendment:

Policy SI21 Managing Surface Water Flood Risk

To minimise flood risk arising from pluvial (surface water) flooding in the city by promoting the use of natural or nature-based flood risk management measures as a priority and by requiring the use of sustainable drainage systems (SuDS) to minimise and limit the extent of hard surfacing and paving, and requiring the use of sustainable drainage techniques, where appropriate, for new development or for extensions to existing developments, in order to reduce the potential impact of existing and predicted flooding risk and to deliver wider environmental and biodiversity benefits {and climate adaption}.

Material Alteration Reference Number 9.12

Chapter 9
Section: 9.5.3 Flood Management
Page: 326, Objective SIO10

Amendment:

Objective SIO10 OPW Flood Relief Maintenance

To support and facilitate the OPW in its duty to maintain flood relief schemes completed under the Arterial Drainage Acts, 1945-1995, including the schemes ( in Carysfort Maretimo Stream,) {at} River Dodder (Tidal), River Tolka, River Wad (Clanmoyle) South Campshires and Spencer Dock.

Material Alteration Reference Number 9.13

Chapter: 9
Section: 9.5.3 Flood Management
Page: 326, Objective SIO12

Amendment:

Objective SIO12 OPW Catchment-Based Flood Risk

To work with the OPW in the development and implementation of catchment-based strategies for the management of flood risk – including those relating to storage, and conveyance(.){and climate adaption}.

Material Alteration Reference Number 9.14

Chapter 9
Section: 9.5.4 Surface Water Management and Sustainable Drainage Systems (SuDS)
Page: 328, Policy SI22

Amendment:

Policy SI22 Sustainable Drainage Systems

To require the use of Sustainable Drainage Systems (SuDS) in all new developments, where appropriate, as set out in the Greater Dublin Strategic Drainage Study (Vol 2: New Development)/ Greater Dublin Regional Code of Practice for Drainage Works {and having regard to the guidance set out in Nature Based Solutions to the Management of Rainwater and Surface Water Runoff in Urban Areas, Water Sensitive Urban Design Best Practice Interim Guidance Document (DHLGH, 2021)}. Sustainable Drainage Systems (SuDS) should incorporate nature-based solutions and be designed in accordance with the Dublin City Council Sustainable Drainage Design and Evaluation Guide (2021) which is summarised in Appendix 12. SuDS should protect and enhance water quality through treatment at source while enhancing biodiversity and amenity.

Material Alteration Reference Number 9.15

Chapter 9
Section: 9.5.5 Waste Management and Circular Economy Practice
Page: 329, 2nd paragraph

Amendment:

The Government’s Waste Action Plan for a Circular Economy 2020-2025 provides Ireland with a roadmap for waste planning and management and is supported by the {Whole of Government Circular Economy Strategy 2022-2023 which provides a policy framework for Ireland’s transition to a circular economy through new policies and practices. The Draft Circular Economy Bill was published in 2021.}(Government Strategy to comply with EU Waste Directive obligations).

Material Alteration Reference Number 9.16

Chapter 9
Section: 9.5.5 Waste Management and Circular Economy Practice
Page: 330, 1st paragraph

Amendment:

The {current} Eastern Midlands Regional Waste Management Plan 2015–2021 (EMRWMP) provides a strategic vision and framework for the prevention, reduction and management of waste in a safe and sustainable manner and the development plan is required to take account of the requirements of the plan. Waste streams are viewed as a valuable material resource and landfilling discouraged in favour of higher value waste recovery options, such as the generation of energy from municipal waste. The plan sets strong targets on waste prevention, re-use, recycling and segregation, all to be achieved through active enforcement of waste policy/ legislation and the promotion of reuse, repair and resource efficiency activities. (The EMRWMP is under review with a new plan due to be published in 2022.) {A National Waste Management Plan for a Circular Economy is due to be published in late 2022 and will replace the existing Regional Waste Management Plans.}

Material Alteration Reference Number 9.17

Chapter: 9
Section: 9.5.5 Waste Management and Circular Economy Practice
Page: 331, Policy SI27

Amendment:

Policy SI27 Sustainable Waste Management

To support the principles of the circular economy, good waste management and the implementation of best practice in relation to waste management in order for Dublin City and the Region to become self-sufficient in terms of resource and waste management and to provide a waste management infrastructure that supports this objective. {To support opportunities in the circular resource efficient economy in accordance with the National Policy Statement on Bioeconomy (2018).}

Material Alteration Reference Number 9.18

Chapter 9
Section: 9.5.5 Waste Management and Circular Economy Practice
Page: 331, Policy SI28

Amendment:

Policy SI28 Sustainable Waste Management

To prevent and minimise waste generation and disposal, and to prioritise prevention, recycling, preparation for reuse and recovery in order to {develop Dublin as a circular city and} safeguard against environmental pollution.

Material Alteration Reference Number 9.19

Chapter: 9
Section: 9.5.8 Noise Pollution
Page: 336, SI40

Amendment:

Policy SI40 Dublin Airport Noise Zones and other Noise Plans

To take account of the Dublin Airport Local Area Plan (2020) and Noise Action Plan for Dublin Airport 2019-2023 as part of the development management process in order to (protect noise sensitive development){ensure the protection/ prevention of noise sensitive uses within this zone} whilst facilitating the continued operation of Dublin Airport; and to develop similar appropriate plans for areas adjacent to Dublin Port.

Material Alteration Reference Number 9.20

Chapter 9
Section: 9.5.12 Energy Utilities
Page: 341, 2nd and 3rd paragraphs

Amendment:

Gas and electricity are the energy utilities which have traditionally heated and powered Dublin City, which is identified as a major energy demand centre. The development of low carbon, resilient, reliable and indigenous energy sources and networks is recognised as very important to supporting the social and economic development of (the city) {Dublin}, especially if {the city} (Dublin) is to fulfil its role as a digital connectivity hub which attracts high technology industries. Support for decentralised and indigenous energy sources such as the Dublin district heating project will have an important role to play in achieving this objective alongside small scale/ community investment in solar and other domestic scale renewables. {In the short to medium term, it is prudent that existing electricity generation capacity needs to be retained in order to ensure security of electricity supply. Any potential impact of large energy users will be assessed against this need.} 

The Council will support energy utility providers in their efforts to {to deliver,} reinforce and strengthen existing (utility infrastructure and) {electricity and natural gas} transmission/ distribution {grid infrastructure,}(networks) {electricity interconnection and electricity storage in order to ensure security of electricity supply and support the growth of renewable electricity generation. The Council} will {also} support new infrastructure projects and technologies with particular emphasis on renewable, alternative and decentralised energy sources, and those which are less carbon intensive in line with the Electricity and Gas Networks Sector Climate Change Adaptation Plan (2019) {and Shaping our Electricity Future - A Roadmap to achieve our Renewable Ambition (2021)}.

 

Please refer to the submission attached. Also includes issues relating to Chapter 2, 5, 12, 13, 15, Appendix 1 and Volume 7 SFRA. 
Please see the attached nature conservations from The Dept of Housing, Local Government & Heritage.
Please see attached submission
The District 7 Community Alliance explicitly supports all material alterations suggested under Material Alteration Number 9.14
The Broadstone Together group explicitly supports all material alterations suggested under Material Alteration Number 9.14