ENVIRONMENT ISSUES IN CONSULTATION

INTRODUCTION
These comments do not attempt to address the details of all the environmental issues regarding Regeneration.  The intention is to provide some awareness on relevant environmental issues which should be taken into account in the consultation process in the regeneration.  Certain environmental issues are covered by European Directives and are a matter of law.  It goes without saying that these must be adhered to, not only for the benefit of the standard of living of residents in the new Ballymun, but also to prevent delays through objections and European investigation.  Some issues require detailed research, for example drainage and sewerage capacity.  This is the responsibility of Ballymun Regeneration Limited.  
However an attempt is made to provide some principles for consultation and action on issues separate to house design.  It should be noted that as a matter of basic let alone best practice no area or aspect of the regeneration is beyond the need for consultation with the community of Ballymun.  In this regard public meetings should also address environmental matters in addition to, and not separate from, house designs.
Regarding environmental issues, regard should be had to comments by a European Court Justice Stein,
‘the precautionary principle is a statement of commonsense and has already been applied by decision-makers in appropriate circumstances prior to the principle being spelt out. It is directed towards the prevention of serious or irreversible harm to the environment in situations of scientific uncertainty. Its premise is that where uncertainty or ignorance exists concerning the nature or scope of environmental harm (whether this follows from policies, decisions or activities), decision-makers should be cautious’.
However ‘green issues’ do not exist in isolation but are part of an interdependent whole.  Therefore the approach adopted here is holistic.  It is not intended to look at pure environment issues only but rather to address other issues of the environment – social, economic, cultural, physical etc.  The quality of the environment has a circular and cumulative effect on the perception of residents of an area.  While the regeneration of Ballymun presents particularly difficult logistic problems, proper consideration and planning of every salient issue will give the programme its best chance of success.
Finally, the comments presented here do not account for issues which may have already been examined and for which programmes/measures are in place.  These proposals present issues which may identify gaps in the consultation process.  Consultation on any of the issues presented below could follow the guidelines presented in the accompanying Three Phase Model of Consultation.
1.  MASTERPLAN
The Masterplan acknowledges that it is subject to change over time as details become worked out.  These changes must be monitored and reported on so that residents are kept up-to-date and so that no ‘surprises’ occur for residents of particular areas within the estate.
Given the changes that have occurred since the introduction of the original Masterplan, it is important to prepare a new phasing model which would inform residents of the time scale for completion of the regeneration.

2.  SEWERAGE
Several problems exist in Ballymun with the current sewerage disposal provision, notably in Balcurris.  Problems have also been experienced in Sillogue.  The construction of the North Fringe Sewerage pipe may go somewhat towards addressing these problems.
The quality of sewerage disposal provision within existing estates which link into the main line sewer needs to be examined, particularly in Coultry.  The increase in population facilitated by the construction of an additional 1200 (40%) private units over and above the 2820 needed to re-house residents in flats, together with all the commercial developments will have a significant impact on demands on the sewerage system which intuitively will be in excess of a 50% increase.  A thorough investigation must be carried out.  Thereafter plans need to be drawn up which will address the deficiencies that exist.  
Investigations, carried out by independent sewerage engineers, must adopt a sound methodology and should yield

•	Current and past data to determine trends (although there may be difficulties with discovering past data),

•	Projections for the increased demand on the sewerage system resulting from the increase in population into the area and which takes account of industrial use of the system,

•	Statistical analysis of the data,

•	Proposed solutions.

The Report of this investigation should be reported to the Housing Task Force and the Estate Forums for the purposes of reassuring residents.  
Proposed repairs to the sewerage system in the Timber Clad estates should be carried out as soon as possible.  This would be an important confidence building measure.  Finally, all EIS’s should account for the cumulative impact of proposed developments on the sewerage system in Ballymun (all EIS’s should be prepared by an independent environmental expert and should conform to European Directives 85/337/EEC and 97/11/EC).

3.  DRAINAGE 

This issue of drainage in Ballymun cannot be overemphasised.  BRL itself was surprised (!) to hear that residents in Coultry had problems with poor drainage in their gardens.  Sillogue is subject to regular flooding during winter.  Poppintree Park is mostly marshland, as is Balcurris.  These problems have a number of roots.  In particular Ballymun is the locale of the headwaters of a number of rivers, including the Wad, Santry, Naniken and Claremont rivers.  Each of these drain through Ballymun.  

The Wad River rises in Poppintree at the road between the housing estate and the IDA industrial estate. When the Poppintree estate was built, the construction of the houses was constrained by the presence of these branches of the Wad River.  This River flows down through Ballymun and along the southern end of Poppintree Park before flowing off along Ballymun Road to the Tolka River.  Two of the branches of the Wad flow around and enclose Coultry Park.  The 8 storey flats on Coultry Road mark out the banks of one of these branches.  Also flowing through Poppintree Park is the Claremont Stream which joins the Wad River.  Both of these streams have been culverted.  The culverts prevent the river from expanding naturally and also prevents water from entering the culverts in places.

After heavy rainfall, the Wad River, into which rain water drains, backs-up in the drainage pipes (which are inadequate) and flooding occurs around the drainage shores. Sometimes entire stretches of access roads are flooded. In addition to this, the construction of the houses in the 1960’s resulted in localised subsidence that occurred later and so rain tends to gather in ‘hollows’ around some of the houses. This results in residents being unable to leave their houses.  In some cases residents reported floodwater rising to the level of their external doors.  Where rainwater is unable to drain off into the culverts – usually on green space- the land becomes water logged.  

It should be noted that climatic trends show a consistent increase of rainfall over the last 20 years (Dublin Airport Met. Station) and this trend is likely to continue.  In 1962 654.2mm of rainfall was recorded and in 1998 832.4mm of rainfall was recorded.  These facts are curiously absent from the climate data presented in the Masterplan Environmental Appraisal and prepared by CODEMA with advice from Muir & Associates.

Since Ballymun is the location of the sources of these streams, any construction on the lands there must provide for adequate drainage in order to prevent flooding at a later date.  Suggestions have been made during planning appeals for the increase in the quantity of excess floodwater which will arise as a result from the increased hard surface due to developments.  However it is clear that a full and proper investigation of drainage must be carried out (similar to sewerage above), reports issued to the Housing Task Force and the Forums, and suitable measures adopted in consultation for the amelioration of excess flood water.  

The ‘suggestion’ of ‘attenuation ponds’ is far too vague to be worthy of appraisal.  However measures researched and proposed should account for some increase in rainfall above current levels.  Clearly defined measures must be adopted before work begins on access roads and new housing areas.  Proposals to replace the existing pipes should do so by increasing the size of the pipes rather than replacing them at current capacity.  It is clear that there may be insufficient space to present an aboveground solution to this problem.  A local underground solution may be too costly.  It is possible that action may need to be taken beyond the confines of Ballymun to solve the problem.  Again, EIS’s should account for the cumulative impact of proposed developments on the drainage system in Ballymun.  
Finally, one sewerage engineer reported that the Wad River would facilitate an over-flow mechanism for the planned North Fringe Sewerage Scheme in Ballymun.  This is worrying considering the course of the Wad to the Tolka River.  This issue may need to be addressed to Dublin Corporation for alternative proposals.
 
4.  WATER SUPPLY AND WATER PRESSURE

Water resources in Dublin are becoming increasingly limited and it is only a matter of time before water charges are introduced (tenants should be informed of this).  This may have some effect in limiting demand on water in Ballymun.  However the increase in the number of houses and the increase in population have implications for water supply and water pressure.  BRL estimates (Environmental Appraisal of Masterplan) that there will be an increase in of 11% from 4400m3/day to 4900m3/day (actually 11.4%) in the required water supply.  This is hard to reconcile with the demand resulting from the provision of an estimated 1200  additional private houses representing an additional 40% of units to be replaced (2820) and all the other commercial developments. The assumptions underlying the estimate of 11% must be reviewed.

A full investigation and report is urgently needed. Contrary to BRL views expressed in the Environmental Appraisal of the Masterplan, how this is addressed is very much a matter for BRL and not Dublin Corporation alone.  If problems are likely to occur as the regeneration comes ‘on stream’, tenants should be forewarned to prevent adverse reaction.  The Task Force and the Forums should receive copies of these reports.  Current usage, projected population increase and resultant overall demand must be included in reports.  

Nonetheless, housing can be designed (cisterns, water tanks) to hold less, but nonetheless adequate, quantities of water.  Water recycling should be considered as part of housing design (rain water for car washing/lawn sprinkling etc.) which would reduce main line water demand.

Water pressure in existing households should not be affected after the completion of construction.  Therefore adequate pumping facilities may need to be installed.  This matter should form part of the considerations of the housing design process.  The construction of a water tower is undesirable.

While the issue of recycling excess floodwater would involve considerable cost, it is worth mentioning.  Space for a reservoir in Fingal lands north of Ballymun which would include water purification could be considered.  However, aside from negotiations with the relevant authorities, supply to this drainage system would have to be completely independent of wastewater disposal systems.  

5.  FLORA AND FAUNA

Much of the original flora and fauna has been lost due to developments since the 1970’s and what little remains must be protected.  New fauna should not be introduced into the area.  However a comprehensive programme of planting a variety of hedges, shrubs and flowers should be undertaken.  This would provide habitat environments for some fauna.  Parks are important in this.  

6.  OTHER UNDERGROUND SERVICES AND CONSTRUCTION PHASES
The issue of other underground services is not immediately contentious.  The main concern is the continuity of services during construction.  Where disruption is likely to occur, residents should be informed well in advance of disruption.  Services should not be absent for more than 8 hours at a time without resumption.  Where there is likely to be a prolonged period of disruption (excess of 8 hours), replacement/ameliorating measures must be put in place.  This is particularly important in winter for young babies and elderly people.  Heating and water supply (including hot water) are the main issues here.
In addition to these, planning must allow where possible for the installation of a fibre-optic cable network which would serve both homes and businesses allowing Ballymun the infrastructure for the ICT revolution.

7.  HOUSING DESIGNS AND HOUSING DESITY
The issue of the internal design of houses is largely beyond the scope of these proposals. However it should be noted that the adequacy of housing design, housing space and the quality of materials and finish does affect resident’s perception of their living space, and consequently their pride in their residence.  
The issue of external design affects other residents.  It is natural to expect residents adjoining a particular development to want to have a voice in the external design of housing. This should be facilitated through the Housing Design Committees.  Existing residents must have a real input into external appearance of housing.
Maisonettes should be confined as far as possible to single (i.e. one person) tenants though as far as possible not elderly or disabled people who may have difficulty climbing stairs.  Ground floor units allow families immediate access to garden space for children and provide convenient access for elderly people.
Where it is necessary to house elderly or disabled people above the level of a two storey house elevators must be provided regardless of cost.  In two-unit two-storey houses for the elderly, chair-elevators should be considered.
‘Two-bedroom’ apartments in which the second bedroom forms part of the sitting room are, in reality, a one-bedroom apartments.  These designs in Coultry are below the recommended minimum size for two bedroom apartments.  In one Coultry scheme that portion of the living room which could be separated to form the second bedroom is below the recommended minimum size for a single bedroom.  The alternative to this design is to increase the size of such apartments so that they match the recommended minimum size.  The ‘second’ bedroom should be just that and seperate from the sitting room.
The height of proposed buildings must take account of the experience of Ballymun with tall buildings. Heights in excess of 8 storeys should be avoided as a matter of practice. Building design should take account of this to avoid buildings that have a squat appearance.  Where taller buildings are required (above four storeys) a varied roofscape should be adopted to avoid a monotonous appearance.  In addition, the location of taller buildings must be particularly sensitive to context and avoid negatively affecting resident’s rights to light.

The issue of housing density is significant.  While there have been objections to the construction of houses in some areas, more often the issue is the number of houses planned for particular sites.  The Gateway Scheme is a good example of this.  
The housing density on Site A (the ‘Monos’) is 81.4 Units per Hectare (32.5 per acre) and the housing density on Site B (Pearse Tower) is 156.2 Units per Hectare (62.5 per acre). Total density for both sites is 89.5 Units per Hectare (35.8 per acre).

The Plot Ratio for the total site is given as 0.672. This exceeds the Department of the Environment 'Residential Densities - Guidelines for Planning Authorities' where it states plot ratios for outer suburban areas (of which Ballymun is one) should be 0.35-0.5 for areas close to public transport. Plot ratios for inner suburban areas is 0.5-1.0. Therefore the plot ratio given in the planning application is for an inner suburban area and does not take cognisance of the fact that Ballymun is, both locationally and demographically, suburban.

The Department of the Environment brief was to re-house the population of Ballymun at existing bedspace densities. The existing bedspace density is 115 bedspaces per acre. The bedspace density on site A will be at least 206 bedspaces per acre. At the very least, this will lead to an inequitable treatment of certain tenants compared to those in lower density sites in order to balance the final total bedspace densities.  At worst it indicates that Ballymun will experience the same on other sites once the precedent is set. 
It has been decided that Ballymun will become a town and therefore it will no longer be a suburb in appearance.  This is unfortunate and is bound to negatively affect the quality of life compared to regeneration maintaining a suburban appearance.  The end result is an increase in building densities both for particular sites and for Ballymun as a whole.  However it is possible to provide for regeneration targets while maintaining reasonable densities.  This requires a firm commitment on the final number of new buildings to be built, particularly housing units.  The minimum level of densities possible should be adopted.  There should be no attempt to ‘squeeze’ as many housing units as possible into particular sites either alone or on the basis of some ill-defined ‘viability’.
The emphasis in the provision of housing in Dublin has been on traditional low-densitiy two-storey housing and this has been detrimental to the Dublin environment.  It is clear that there is a need to vary this practice.  However being unique, Ballymun has never enjoyed this type of housing and there is a good argument to be made for exempting Ballymun residents from the need to set the precedent of providing public authority out-of-town family housing at higher densities.
All new housing should be within five minutes stroll of local convenience shops.  The alternative is the re-appearance of van shops after regeneration.  Indeed, as far as possible, provision should be made for the accommodation of van shop businesses.

8.  GRAFFITI
The problem of graffiti will never be overcome entirely.  Education in local schools and a campaign among parents may help to reduce the presence of graffiti.  A permanent ‘Graffiti Wall(s)’ could be considered in a suitable location, say, on the edge of a Park as a focus for graffiti art.   Ultimately account for graffiti must be taken in the design of building finishes.  Certain finishes are easier to clean than, say, bare brick or stone or bare brick or stone could be coated to ensure easy cleaning.  A regular process of reporting graffiti could be established and carried out, say, by a litter warden to the appropriate estate office.
9.  ENERGY
 This is effectively a matter of building design and so is not presented in any great detail here.  Suffice to say that there is little emphasis on the use of alternative energy sources in the regeneration and this is regrettable.  Given that residents in new houses face separate and possibly higher fuel bills, solar energy could present a money-saving alternative to conventional heating sources.  Solar power could be exploited more thoroughly.  Certainly solar power should be considered as an important element in the design of the Business and Technology Park.
10.  WASTE AND RECYCLING  
Demolition of the flats
Confirmation of the demolition of the flats is urgently needed to instil confidence in the original purpose of the regeneration. This should come from the Dublin Corporation City Manager.  
 Planning and preparation should begin immediately for the recycling of waste materials from the demolition of the flats.  Doors and other wooden panels can be chipped.  Metals can be smelted for reuse.   Wiring can stripped and smelted.  Plastic pipes can be reused or recycled. The possible reuse of the concrete panels should be investigated.  If this is not feasible, the panels could be crushed for gravel/foundation material and the steel reinforcing could be sold for smelting.
A safety plan and statement should be drawn up regarding the removal of asbestos linings present in the flats.
Recycling in the new Ballymun
Waste minimisation	
Reuse	
Recycling	
Energy recovery	
Incineration	
Landfill	
 The average Dublin household produces 1.2 tonnes of waste each year of which only 10% is recycled.  There is an upward trend in production of household waste linked partly to growing prosperity.  Waste management strategies have been compiled under the auspices of the Department of the Environment and the Eastern Region Local Authorities which aim at quantifying waste and establishing strategies for the management of waste.  The European Union has established the Proximity Principle for the treatment of waste, namely that waste should be disposed of or treated close to its source of generation.  Landfills are becoming limited.  Incineration would NOT be acceptable under any circumstance due to noxious emission.  Incineration plants are being phased out in some European countries because of this.
EU Hierarchy of Solid Waste Management
Regard should be had to the European Union Hierarchy of solid waste management.  Therefore, as part of the transition programme, residents should be encouraged to minimise waste as far as possible.  Dublin Corporation has produced a booklet on ‘sensible shopping’ aimed at helping the consumer reduce waste quantities.
 Ballymun presents a unique opportunity to establish town-based recycling which could serve the wider north Dublin area.  A recycling centre should be considered as part of the Business and Technology Park.    Not-withstanding proposals for the segregation of waste, it should be 
noted that in some jurisdictions, separation of refuse is a matter of law.  Given that recycling must be market oriented, it is important to note that the value of waste as a resource is inverse to its degree of mixing. The more mixed waste is, the less value it has as a resource.  As far as possible, residents must be encouraged and provided with the means to segregate waste.
Waste Fraction	Percentage	
Glass	6.1	
Paper	16.4	
Plastic	12.8	
Card	4.3	
Metals	3.6	
Organic	33.4	
Rest of Waste	23.4	
Total	100	
 
 	Sources of household waste in Dublin City
 One of the difficulties for recycling operations is the logistics of securing a regular supply of material.  Therefore it is doubly important that waste is segregated at source. However a reliable collection method must also exist.  This function could be greatly assisted by Dublin Corporation and would allow it to demonstrate its commitment to recycling.  BRL is in a position to lobby the City Manager on this.  However ultimately it may be a matter for local enterprise.  With perhaps the exception of major commercial paper recycling an adequate market for recycled matter does exist.  Daintree Ltd., a Dublin company, for example manufactures a broad range of stationery products from recycled paper and cloth.  However an in-depth analysis of the local supply of recyclable material including from commercial activities, would need to be completed.
Waste Fraction	Percentage	
Paper	65.1	
Glass	1.2	
Plastics	13.6	
Metals	1.9	
Organic	12.6	
Other	3.6	
Composition of Waste from Merrion Square/Fitzwilliam Street
Households may not maintain their own compost heaps for a variety of reasons, mostly health.  However a Garden Centre should be encouraged to locate in a suitable location in the new Ballymun, or perhaps Santry Woods, and this could provide a focus for the recycling of organic matter besides offering other useful garden services to the immediate area and beyond.
(Tables from Dublin Waste Management Strategy)

11.  GARDENS
There is sufficient land in Ballymun to provide gardens for every resident.  This is the preferred option.  It is understood however that the quantity of commercial land uses results in a situation where some units will have ‘private space in the form of balconies’.   In this situation, steps must be taken to ensure that family dwellings all have access to a private garden.  Balconies as private space should be provided only to single (one person) residents where absolutely necessary.  Where a development consists of units in excess of two storeys (e.g. maisonette above a house), resulting in the need to provide balconies, a communal garden should be provided in addition to family-dwelling gardens.
All gardens must be at least the recommended minimum length and no less.  Where there is a conflict between the provision of a garden and the need to maintain way leaves for services, no building should be constructed.  An alternative site should be used for the housing unit that will provide the minimum garden size.

12.  ALLOTMENTS
Provision should be made for some allotments in the new Ballymun.  Similar schemes have operated successfully in Finglas and there is no reason why some provision cannot be made in Ballymun for the small number of people who would be interested.  Additionally, the NCI could consider running a course in urban-garden agriculture which would equally serve this purpose well.
13.  PLAYGROUNDS
There has been no public meeting to my knowledge regarding the provision of playgrounds in Ballymun despite BRL’s information that a playground strategy group has been appointed. While it is reported that children were involved in helping to identify ‘what works’, the size and particularly the location of playgrounds is important.  So far BRL plans to build playgrounds for two age groups.  The total of 12 playgrounds, each serving approximately 300 children is inadequate and more must be considered.
Regarding the location of playgrounds, it is important to remember the fate of the old playgrounds in Ballymun.  These were removed partly because of the increasing number of insurance claims.  However in many cases, residents adjoining playgrounds campaigned, and in some case threatened court action, to have playground removed due to noise. Therefore a balance needs to be struck between the need for playgrounds in readily accessible areas and the need to avoid building them too close to housing.  Where a site is identified for a playground, ALL the residents in the adjoining area must be informed and their views sought.  Attention must be paid to the final demographic structure of a residential area to ensure that use of a playground is optimised while at the same time ensuring that no area is so far removed from a playground to make the playground inaccessible to that population.  
The likely success of regional playgrounds is questionable.  Children from one part of the estate tend not to cross the estate for youth activities are are unlikely to do so to use a playground (unless accompanied by a parent).  Indeed, they are likely to ‘hang-out’ near existing playgrounds if the age gap between them and the design age group of the palygrounds is not large, or if they have to supervise younger siblings.  Therefore consideration could be given to providing more, but smaller scale playgrounds in forum areas in place of larger regional playgrounds.
Older teens are unlikely to conform to the idea of formal ‘hang-out areas’ and these should be reconsidered.
14.  RIGHTS OF WAY, FOOTPATHS AND CYCLE PATHS
The extinguishments of rights of way must be subject to the consultation process and agreement sought on their removal and replacement, subject to the Bye Laws.
All roads should have a footpath on either side of the road and conform to minimum standard widths and design at least.  The exception to this is where there is no building on one side of a road and a boundary railing or wall is planned. The foundation of footpaths must be stable to prevent slumping in future therefore footpaths should be properly bedded with compacted sand over compacted gravel.  From an aesthetic point of view, footpaths should be paved, rather than have Bitmac or concrete construction.  Provision for drainage must be included in the design of footpaths to prevent flooding and water-logging (gradient to kerbside drainage or other). They should be broken from the road by a grass verge or a line of trees.  Similar provisions must be made for cycle paths (2 lanes on arterial roads).  Dedicated cycle paths must be included in the plans for Main Street separate from the reservation for the Luas.
15.  ROADS, TRAFFIC AND TRANSPORTATION
The Masterplan has divided Ballymun into five separate and identifiable districts or communities.  This necessarily implies that each district should have a clearly recognisable entry and exit point.  Hence the need for access roads.  The difficulty presented by access roads is two fold.  Firstly there is a need for access.  On the other hand there is a need to ensure the safety of residents, especially children, living in communities adjacent to the access roads and limiting  noise and air pollution.  
This issue has a primary importance in those areas likely to be used to access the Poppintree Industrial Estate and the new Business and Technology Park. These areas are Sillogue, Sandyhill and Poppintree.  Since the Main Street is to be a heavily calmed ‘Boulevard’ style development, and is to provide space for the Luas, it is logical that through traffic will use the access roads to by-pass the Main Street.  This is particularly the case with heavy goods traffic travelling to and from the Poppintree Industrial Estate and the Business and Technology Park. In addition, the increase in traffic on Ballymun Road during rush hour will result in traffic using parallel roads to by-pass traffic stops.  This already occurs in Santry and is a concern of residents in Coultry.  It is worth noting that the Masterplan Environmental Appraisal records current traffic on Ballymun Road at 30,000 vehicles per day and envisages the same level of traffic after the development is fully completed.  I would challenge this notion with the proviso that the Luas is developed and routed through Ballymun.  Notwithstanding the Luas, traffic from areas not served by the Luas in North Dublin will add to traffic levels through Ballymun Road as future developments in North Dublin come on stream.
It is recommended therefore that all access roads be heavily traffic calmed to prevent speeding.  Ramps should be of a sufficient number, construction, height and width to force traffic using access roads to slow to 10/20 mph. This may also contribute to more traffic passing the Main Street so contributing to ‘passing trade’.  The situation is less than ideal however the safety of the children in estates adjoining roads is paramount. In particular, where a new road is proposed, consultation between existing residents must take place to ensure that they have a voice in the location of the road.  Attempts to find a middle ground between their concerns and the developer’s needs would reduce delays and increased costs.
16.  CAR PARKS
The Main Street development proposals illustrate the number and location of car parks to be provided adjacent to the Main Street (1788 car park spaces).  There has been no consultation with adjoining residents concerning the provision, size and location of these car parks.
Car Parking proposed includes a 650 Car Park and Ride Facility located between the location of Ceannt Tower and Sillogue Road.  There is a need for a Park and Ride facility, however there are problems with this proposal vis it’s size and location.  BRL states that open spaces facilitate anti-social behaviour but what will this Park and Ride facility be at night except a wide-open space?
The non-residential car parks will consume large amounts of space, be used mostly by people from outside Ballymun, and become a focus of anti-social behaviour at night. Car parking is necessary, however the current plans must be rationalised to provide for a more effective use of the land.  Covered car parks should be the norm, rather than the exception, and could form part of building construction e.g. underground/basement car parking. This would provide a more rational use of space and reduce pressure on housing densities.  Covered car parks could be secured at night so as to reduce the possibility of anti-social behaviour and any charges applying to their use, which would be mostly be people from outside Ballymun, could be invested to repay the costs of construction and maintain the car parks. This would also create a business opportunity for local people. The 650 space Park and Ride facility should be located at a more northerly point in the estate, closer to the Business and Technology Park.  It should be built on more than one level so as to reduce the amount of space it consumes.  
People should not have to look out the windows of their new housing unit and see a car park, and then wonder why their private space is a balcony and not a garden.
All housing units should be provided with a minimum of 1 off-road car park space.  Curtilage parking is unacceptable as a norm except as spare car parking for visitors.  There should be NO introduction of residential parking charges in the new Ballymun.  Disc parking on the Main Street would be acceptable.

17.  TRAFFIC AND TRANSPORTATION
It should be recognised that the increase in traffic through Ballymun will result not only from the regeneration and the subsequent increase in population, but also from developments in North Dublin.  The Bacon reports have recommended the construction of 17,000 new houses on the plains of North Dublin.  This will result in increasing levels of traffic entering Ballymun at rush hour.  
As mentioned above, access roads should be heavily calmed to prevent excessive speeding and rat-running. Traffic filter lights on the Main Street should be timed to ensure that traffic is not stopped for long periods.  The Main Street must be heavily planted to help absorb CO, SO2 and CO2 emissions. Materials and finishes on Buildings fronting onto Main Street should take account of the corrosive effects of SO2 on stone, brick and concrete.  It may be worthwhile negotiating a later or earlier start to school in the Comprehensive Schools in the morning to ensure the safety of children crossing Ballymun Road in the morning.
Changes have occurred to the Luas plans to provide for a metro-type service.  Ballymun should retain the Luas aspect of the plans rather than a metro service.  The new Ballymun Civic Square is a preferred stop for the Luas.  However this idea does conflict with objection to the location of the 650 car park space Park and Ride facility.  A smaller Park and Ride facility could be considered close to the Civic Square.  The Luas stop would be roughly half way along the length of the Main Street, in the centre of the commercial development, close to the shopping centre, and the Civic Square would provide more space for Luas users embarking and disembarking.  Ground Floor commercial development could also be encouraged to this side of the Main Street.  In the interim, Dublin Bus should be encouraged to improve its bus service to Ballymun.
18. NOISE, AIR POLLUTION AND DUST.
Increased noise will form part of the new Ballymun both during and after construction.  During construction, noise must not exceed to 60Db within the perimeter of construction works including background noise.  Construction equipment must be fitted with silencers where appropriate and kept in good working order.  Construction times should be limited to normal working hours to prevent inconvenience to residents.  Monitoring of safety and environment standards should take place in consultation with the relevant Fora.
After construction, noise will be apparent in the increased traffic (which will occur nonetheless) and from the presence of workspace units.  Each of these workspace units will be subject to existing laws.  However given the proximity of planned work space units to residential units, the building construction of these units should be particularly sensitive to their use and take this into account to alleviate excess noise above the levels expected in residential areas.
Roads should be heavily tree lined and traffic calmed to limit not only noise but also to help limit the spread of pollutants.  It should be noted that too small a number of trees will not only negate the desired effect but may also lead the death of the planted trees since there is a limit to the quantity of pollutants trees can absorb in a given time period.  Attention is also drawn to the fact that there are European Union Directives (80/779/EEC, 85/203/EEC, for example), which place limits on the levels of harmful gases in the atmosphere.  In particular, PM10, SO2 and NO2 resulting from traffic and industry, are particularly harmful especially to young children and the elderly.
During construction, great efforts must be made to limit the spread of dust, particularly in area of existing housing.  Regular spraying of construction sites will help limit the rise of dust.  Roads should be kept clean and clear of dirt.  Trucks carrying materials and waste should not be over-loaded and all material should be taped down and/or covered to prevent spillages.  A programme of inspection of construction sites should be drawn up to ensure these safeguards are maintained.
19.  PARKS AND LANDSCAPING
There will be an estimated loss of 93.9 hectares of open spaces in Ballymun.  While the creation of ‘places’ is important, it is important to ensure that all 5 neighbourhoods have access to ‘spaces’.  The 1993 Dublin Development Plan requires 2 hectares of open space per 1,000 of population. The Development Plan thus would require 52 hectares of open space for the population of 26,000 instead of the 26.4 hectares proposed.  
BRL have stated that the average ‘green space’ after regeneration in Ballymun will be 16% and that this is above the average for Dublin which is apparently 10%.  There are serious problems with this assertion.  Firstly, no definition has been given of ‘green space’.  This must be provided for any figure or percentage to have any meaning.  Secondly, the average of 10% for Dublin includes the city which has little green space.  The average of 16% green space for Ballymun is far less than that enjoyed by other suburbs in Dublin.  Are working class communities entitled to less green space than middle class communities?  The argument that existing green spaces are poor in quality is a weak argument for building on them.  Proper maintenance would have ensured that that were adequate for regular use.  
The provision of planned green space and parks, while desirable, must recognise the need for regular access.  While alternative amenities are also planned and are desirable, it should be recognised that a green field is an inexpensive source of entertainment and that not everyone will be able to afford admission charges to certain planned amenities.
It goes without saying that green space will be lost to development.  How much green space, and which green space is a contentious issue.  There can be no alternative to negotiating the use of green spaces in areas immediately adjoining existing houses (e.g. Poppintree/Belclare). A wider distribution of green space and football pitch provision must be examined and implemented.  This is especially the case where the quantity of green space cannot be improved from the original intention in the Masterplan.
Care must be taken to ensure that all newly planned developments, particularly those with maisonette and apartment developments, have access to at least communal green space in the immediate vicinity.
Landscaping will be particularly important in the new Ballymun given the predetermined plan to convert Ballymun to a town from a suburb.  On this issue, it would be hard to over-do landscaping.  Existing ancient trees in Ballymun (e.g. those at Scoil and Tseachtar Laoch) must be preserved at all costs.  In addition one ancient tree in Ballymun is reputed to nest bats.  European Law protects bats and their habitat.  As far as possible, existing mature trees, e.g. along Ballymun Road, should be preserved.  New plantations must be properly fenced to prevent vandalism and should be fast maturing trees.  Conifers must be avoided. Trees are particularly important along route ways.  In addition, tree planting should be considered between the rear gardens of back-to-back houses.  This would help allay the fears of existing residents that their privacy will be compromised and it would help improve the poor drainage in some gardens.
Parks should be landscaped so as to provide habitats for wildlife.  In this context, a small open stream could be considered if it does not compromise safety.  The Business and Technology Park must be heavily landscaped also.
Poppintree Park should not be developed for housing but should remain as it was specifically designed – a public park.
Care must be taken in the expression of certain statements in EIS’s. For example, the Masterplan Environmental Appraisal refers to open space which possess ‘no sense of place’.  It should be noted that the concept of ‘sense of place’ is characterised by the perception of the users of a space and defines an identifiable area.  ‘Sense of place’ is not an objectively quantifiable phenomenon which can be accurately measured by outside observers.  Many of the open spaces in Ballymun are characterised by a ‘sense of place’, hence local colloquialisms for areas such as ‘The Monos’.  Similarly, a statement such as ‘few trees have survived the exposed conditions of present day Ballymun’ is inaccurate and unappreciative of the natural environment.  The correct statement would be that ‘few trees remain either because they were felled (e.g. to make space for the development of Poppintree) or because they were vandalised’.  What may appear a mute point can quickly become a focus of opposition to development due to inaccurate presentation of facts likely to be interpreted as a deliberate attempt to conceal and mislead people.

20.  LITTER
Litter is problem which will take years to resolve.  Few people litter deliberately.  Few people consider the effect of throwing a piece of paper on the ground so it happens almost as a reaction to having waste paper in hand – get rid of it!  It is sufficient to note that the woeful shortage of litter bins in Dublin is significant in the failure to combat litter.  The new Ballymun must have a large quantity of litter bins not only on the Main Street and at landmark buildings, but also in and around housing. A litter-awareness programme forms part of the CSPE syllabus in schools.  Primary schools should be encouraged to make younger children aware of the damage litter causes to the environment.  Parents taking the housing transition programme should also be encouraged to inculcate in their children the need to avoid littering.  A full time litter warden must also be employed in the new Ballymun.

21.  EDUCATION
The physical and social regeneration of Ballymun cannot be separated from the economic regeneration of Ballymun.  In fact the physical and social regeneration are dependent on the success of the economic regeneration.  While there will be job creation during the construction phase, the most important contribution to economic regeneration will come from the creation of long term employment.  The desire to improve the socio-economic profile of the community partly through the introduction of new residents in private housing will contribute to the economic revitalisation of Ballymun.  However the success of the regeneration depends upon economic regeneration of Ballymun and the economic future of its existing residents.  
To this end, education plays the most important role in regeneration.  While formal education is not, and should not be seen as the ‘be all and end all’ of economic regeneration, it is a matter of fact that those with a good standard of education and saleable qualifications are far more likely to succeed in building a secure economic future for themselves than those without qualifications.  While the National College of Ireland has been lauded, it must be remembered that 50% of Ballymun children do not complete the Leaving Certificate and therefore third level education is not an option for them.  Therefore early and perhaps radical intervention measures must be adopted to promote the value of education and to ensure that children remain on in education.  
It is recognised education is not within the remit of BRL.  Nonetheless BRL can play an important role in lobbying proposals that improve access to education in Ballymun.  This issue more than any other involves the entire community since education and the concomitant improved economic future will determine the success of the regeneration programme.  
The following are outline proposals for education in Ballymun:
1.	A representative of the education sector should be nominated to the Board of BRL.
2.	A campaign in Ballymun to highlight the importance of education to the future of children. A programme should be adopted to encourage local parents to send their children to the schools in Ballymun rather than outside the area.
3.	Implementation of early learning and pre-school education across Ballymun in order to promote in children as early as possible, the importance of education.  This could be done in tandem with the provision of crèche facilities.
4.	Allocate more resources to Primary Schools to reduce Pupil-Teacher ratios and to improve the educational experience of younger children
5.	In 1991, a proposal to amalgamate the Comprehensive Schools was opposed.  It is now supported by all the schools involved. The Senior Comprehensive School Building must be given over to Adult, Continuing and Second Chance education after amalgamation. A programme facilitating these education sectors should be implemented.  Adult, Continuing, and Second Chance educational initiatives must be fully funded to enable people to improve their job prospects
6.	Allocate more teachers to the Comprehensive Schools to reduce the Pupil-Teacher Ratio and improve the school environment for children.  This improvement must go beyond the provisions of the latest plans to reduce the PT ratio nationally
7.	The Amalgamated Comprehensive School must be fully refurbished to the highest standards and must incorporate the latest in Classroom equipment and technology.
8.	All Schools should be fully resourced to provide a greater variety of educational experiences and programmes
9.	A dedicated Information and Communications Technology teacher must be provided for each level of the education system in Ballymun and resourced with the appropriate equipment
10.	The Ballymun Initiative for Third Level Education must receive increased annual funding in order to extend its invaluable work, including mentoring and after-school study, to the greatest number of students possible. 

22.  HOUSING POLICY
One of the core problems experienced by Ballymun results from the statutory obligations of Dublin Corporation, namely, the requirement to provide low cost rented accommodation to those in need of such accommodation.  As a result, Ballymun acquired a concentration of lower socio-economic group residents, in particular those who were unemployed or single parents.  It must be acknowledged that some of these people remained on in the community even when they could have left and worked for the betterment of the community.  More often than not, such residents decided to move on to other locations as soon as the possibility arose.  This led to the high turnover in population, making Ballymun something of a ‘transit point’.  In addition, the concentration of lower socio-economic group people resulted in a local economy which stagnated at a low level.
It is clear that the Corporation policy of concentrating people in a lower socio-economic group in Ballymun has failed the area.  This policy must change.  While encouraging non-tenanted type residence is a good policy, the option for this type of accommodation is restricted by market factors.  High interest rates can penalise house purchasers and while this remains a prospect, together with the uncertain factor of future demand for privately owned homes in Ballmun, it is uncertain whether or not home-ownership will be come a reality for people in Ballymun.  This is particularly the case of single parents whose income may not stretch to cover a mortgage, even under the shared ownership scheme. It must be noted however that for a small number of people, housing cooperatives can in some way alleviate this problem, however cooperatives are still at the mercy of interest rate rises with only the prospect of cheap land sites to miligate the high cost of self-constructed homes in the current market.  
In this environment, and considering 32% of people said they would leave Ballymun regardless of the regeneration, the Corporations policy is thrown into stark relief.  It is in the interests of regeneration that Ballymun no longer houses a concentration of lower socio-economic group residents.  No new tenants should be housed within the estate from now on.  Effectively, this places a cap on the accommodation to be provided by the regeneration. Neither should this be used to allow for increased private housing.  The figure of 1200 private units to be provided is roughly 40% of the existing total.  After regeneration, and assuming no new residents are housed from now on, this percentage would be higher.  It also means however that fewer Local Authority homes need to be built.  Land and capital would be saved which could be used to better effect, for example, in the provision of a more balanced distribution of green space, improved housing densities and/or the provision of amenities. 
A clearer and stiffer policy on anti-social behaviour, particular of those involved in the drugs market, must be adopted and the means sought to implement it.  In some cases, tenants have been evicted only to return some months later and re-engage in anti-social behaviour.  These tenants must not be allowed to return to the estate.  While this may seem harsh, when it comes to the issue of the welfare of Ballymun, it works.

23.  NEIGHBOURHOOD CENTRES AND COMMUNITY GROUP FACILITES
Care must be taken in deciding the location of neighbourhood centres to ensure that no residents are disadvantaged by the location of the centre.  They should be located equidistant between the parts of the areas they serve. However account must be taken of the residential areas in which it is intended to construct them so as to avoid undue disturbance to residents living close by (e.g. senior citizens).

A thorough survey should be carried out to establish the threshold and range of the centres and so help identify the businesses which would survive in the centres.  Clearly there will be a need for a convenience store in the neighbourhood centres.  A pub may not survive in a neighbourhood centre but in any case is likely to cause disruption to local residents and should not be considered.  The concept and size and location of these centres may have to be reviewed.

One option for the neighbourhood centres is as a focus point for community activity within a particular forum area.  It is an established fact of life in Ballymun that children/youths from one part of the estate will not cross over to another to avail of community clubs and services there.  This problem could be solved by the provision of community group facilities in each of the neighbourhood centres.

24.  TIMBER CLAD HOUSING

Up to this point in the regeneration, issues such as re-housing flat dwellers, providing playgrounds and other developments have been planned.  However with the exception of notice that tax incentives are available to private residents in the timber clad housing for the repair of their houses, and notice that funds are available to replace some of the underground services, the timber clad estates appear not to have been addressed by the regeneration.

While BRL is to be congratulated on achieving tax incentives for the timber clad estates, there are many private residents who are also retired and therefore cannot avail of the tax incentives to renovate their homes.

Plans to renovate the environment of the timber-clad estate should be drawn up as soon as possible.  The issues of when the underground services will be replaced should be included.  The improvement of footpaths is important.  Many of the footpaths have slumped and/or the pavement flags are cracked.  Local green ‘squares’ are subject to soil creep which has led to some footpaths becoming obscured and has contributed to flooding.  Some roads have slumped and flooding is a regular occurrence on them.  As the planned developments surrounding the timber clad estates come on stream, the issue of threats to privacy will become more important.  One resident suggested to me the idea of ‘ring fencing’ the timber clad estates.  Whether there is merit in this idea is something which requires analysis and consultation.  While private residents are not the main priority in the regeneration, they nonetheless have valid concerns regarding the impact of regeneration and will be no less affected by it.

25.  BUSINESS AND TECHNOLOGY PARK

Separate consultation on this feature is required immediately to avoid, at least, the prospect of disruption during construction from those objecting to the loss of land there.  It is clear that the provision of land 5km removed from Ballymun is not going to replace the existing fields – 5km is too far away.  The key point about the fields is that it costs nothing to use them.  This makes them attractive for those who cannot afford leisure centres on a regular basis.  It should be noted that sport, either organised or disorganised, provides the best and most effective safeguard for children against the drugs trap.

26.  OTHER ISSUES

Each of the issues presented below also require consultation as part of any presentation of the new built environment.  Not all of these issues, or those above, will apply to the immediate vicinity of a particular new development.  Which issues do apply need to be analysed for each development.  Nonetheless, a holistic presentation at final design meetings, open to all concerned, should be carried out.

‘All concerned’ is defined as:
•	End-users
•	Immediate residents adjoining the development
•	Existing residents likely to be affected by construction
•	Interested community groups etc.

At final design meetings, all voices should be heard, including those which do not agree with the proposed development.  Ignoring or treating opponents off-the-cuff only strengthens opposition to plans.  Irrespective of this, opponents’ views may actually assist in developing a better plan.  At the least, listening to opponents demonstrates a willingness to remain open to their views rather than to treat them as objectors whose views are worthless by virtue of the fact they are objecting.  A full and complete agreement can never be reached once someone has decided they are against a particular development.  Identifying those who ar epotentially adversely affected by plans and discussing plans with them before the design stage is a useful approach to developing plans/criteria for development.

Issues
•	Employment 
1.	Education and Training
2.	Opportunities
3.	Local enterprise development
•	Social, Community and Local Authority Services
1.	ERHB Offices
2.	Motor Tax Office
1.	There are currently two in Dublin – Chancery Place and Rathfarnham.  An Office in Ballymun could serve north Dublin.
3.	Re-location of Ballymun Library
•	Ballymun Community Law Centre
1.	Legal advice
2.	Community information
3.	Community Counselling Service
•	Leisure Sport and Recreation 
1.	Some facilities could also serve as Neighbourhood Centres, health centres etc.
2.	Low cost facilities
3.	Local trained Leisure leaders
•	Senior Citizens facilities
1.	Senior citizens community building
2.	Access/Mobility to/in housing
•	Main Street commercial area 
1.	Landmark buildings (size/appearance/use)
2.	Local enterprise
3.	Variety of tenants (need for prioritising??)
4.	Access/Parking/Landscaping
5.	Population structure post-regeneration
6.	Student residences and supervision
•	Crèches and Child Care
1.	Need for a comprehensive child-care programme which would facilitate return-to-work mothers
It is clear that there will be a certain degree of repetition at final design meetings, however this will assist in keeping attention focused on the holistic nature of the development and will help contribute towards holistic planning (or some perception thereof).  Not every issue here would need to be presented at final design meetings but could form part of a programme of public meetings.  Final design meetings could focus on issues immediately surrounding housing developments.
Finally, no attempt has been made here to address EVERY issue.  The aim is to draw attention to some of the issues that should be addressed at public meetings to at least allay the fears of existing residents that they are not being taken for granted in the regeneration. As stated previously, these comments are not a scientific analysis and should be interpreted in the context of the Three Phase Model of Consultation (attached).