The Broadstone Together Submission to the Dublin City Development Plan 2022 - 2028

The Broadstone Together group explicitly supports all material alterations suggested under Material Alteration Number 1.8

The Broadstone Together group explicitly supports all material alterations suggested under Material Alteration Numbers 3.7, 3.10, 3.15, 3.20, 3.24 and 3.28

The Broadstone Together group explicitly supports all material alterations suggested under Material Alteration Numbers 5.6, 5.7, 5.8, 5.9, 5.17, 5.18, 5.25 and 5.26

The Broadstone Together group explicitly supports all material alterations suggested under Material Alteration Number 7.1, 7.3, 7.4, 7.11, 7.14 and 7.18

The Broadstone Together group 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 Numbers 12.5, 12.20, 12.24, 12.35 and 12.36.

The Broadstone Together group explicitly supports all material alterations suggested under Material Alteration Number 14.12

The Broadstone Together group explicitly supports all material alterations suggested under Material Alteration Number Appendix 3.2

Motion MOT-01602 requests that Phibsborough is added to Section 4.5.1 as:

Chapter 4 Section: 4.5.1 Approach to the Inner City and Docklands Page: 139, Policy SC1 To amend the following: SC1 Consolidation of the Inner City To consolidate and enhance the inner city, promote compact growth and maximise opportunities provided by existing and proposed public transport by linking the critical mass of existing and emerging communities such as Docklands, Heuston Quarter, Grangegorman, {Phibsborough,} Stoneybatter, Smithfield, the Liberties and the North East Inner City with each other, and to other regeneration areas.

In their response to this motion, the CE mentions that "Phibsborough is an urban village and is considered to form part of the inner suburbs rather than the inner city.".

The CE furthermore refers to the definition of the "inner city" given in the Glossary:

“Inner city (see also city centre): The inner city is bounded on the northside by the North Circular Road, Phibsborough Road, the Royal Canal, North Strand Road and East Wall Road, and on the southside by the South Circular Road, Suir Road, the Grand Canal from Dolphin Road to Grand Canal Street Upper, Bath Avenue, Londonbridge Road, Church Avenue and Beach Road (See Map K)."

A number of conflicting errors are being made by the CE here. Phibsborough comprises three neighbourhoods: Shandon, Broadstone and Mountjoy. While Shandon indeed lies outside the inner city bounds, Broadstone and Mountjoy certainly do not and lie entirely within these bounds along the Phibsborough Road and Royal Canal Bank. Map K indeed confirms this, as does an independent Neighbourhood Mapping Project by the Dublin Inquirer (see image below indicating the boundaries of Phibsborough as per 28 separate submissions).

Furthermore, the CE's recommendation appears to indicate a lack of awareness of where Phibsborough is located. The alteration recommended by  the CE states is as follows:

It is the recommendation of the CE to agree the motion with amendments. For clarity, amendment to Chapter 4 Shape and Structure of the City, Section: 4.5.2 Approach to the Inner Suburbs and Outer City as part of the Metropolitan Area, page 139, first paragraph to read:
The inner suburbs comprise the established suburban communities {, largely,} located outside of the canal belt {e.g. such as Phibsborough,} and the outer city refers to the newly developing areas on the fringe of the city administrative area including Clongriffin-Belmayne, Ashtown-Pellestown, Park West and Cherry Orchard.

Phibsborough is not "largely located outside the canal belt". It is in fact entirely located within the canal belt. The adjacent area outside the canal belt is Glasnevin, not Phibsborough.

In the current draft Development Plan there is significant ambiguity about what urban area Broadstone and Mountjoy are part of. While they are considered by the CE to be part of the Phisbsborough KUV, they are also a part of the inner city as per the Development Plan's definition.

A compromise solution would perhaps be to make the following material alteration:

Chapter 4 Section: 4.5.1 Approach to the Inner City and Docklands Page: 139, Policy SC1 To amend the following: SC1 Consolidation of the Inner City To consolidate and enhance the inner city, promote compact growth and maximise opportunities provided by existing and proposed public transport by linking the critical mass of existing and emerging communities such as Docklands, Heuston Quarter, Grangegorman, {Broadstone, Mountjoy,} Stoneybatter, Smithfield, the Liberties and the North East Inner City with each other, and to other regeneration areas.

In Table 13.1, the "Capacity" and "Area" of SDRA 8 is incongruous with the equivalent values in Table 2.8 of Section 2.3.1, Chapter 2.

Table 13.1 should be amended as follows:

The Broadstone Together group welcomes the material alteration to remove the inner city as a location to facilitate the provision of Build to Rent. However, in the interest of promoting diverse typologies in all of Dublin, BTR should not be explicitly concentrated in the remaining locations:

The following text should be entirely removed from Section 5.5.7 page 184-185:

{BTR should be concentrated in areas of high intensity employment use, within 500m of major public transport interchanges  and within identified Strategic Development Regeneration.}

The following text should be entirely removed from Section 5.5.7 page 186:

• (Within the Inner City (i.e. within the canal ring)).  
• Within 500 metre walking distance of a high employment area i.e. more than 500 employees per hectare.
• Within 500 metres of major public transport interchanges (e.g. Connolly Station, Tara Street Station and Heuston Station), and
• Within identified Strategic Development Regenerations Areas.

The Broadstone Together group objects to including Build To Rent residential under Permissible Uses for Z14 zoning.

The Broadstone Together group objects to the changes introduced in Material Alteration Number Appendix 1.5

This clarity should not be included.