Here is a short version of the objection template.  This is not intended to be a comprehensive objection document, it is simply a way of having your voice heard in the planning process.  Print it, fill in your name and address, sign it.  Bring it to An Bord Pleanala offices on Marlborough Street with your €20 payment. Alternatively, hand it into the offices of McCabe Auctioneers on Vernon Avenue (opposite Beshoffs).  Clontarf Resident’s Association have arranged to collect objections from McCabes for onward delivery to An Bord Pleanala.  All objections must be with An Bord Pleanala before 5.30pm on Monday 5th February.









28th January 2018


Strategic Housing Unit

An Bord Pleanála

64 Marlborough Street

Dublin 1



            Re: Objection to Application Reference Number: ABP-300559-18



A Chara,


I am writing in relation to the planning application submitted by Crekav Trading GP Ltd. for residential development on park lands to the rear of St. Paul’s College, Sybil Hill Road, at St. Anne’s Park, Raheny, Dublin 5. To this end, I enclose the requisite fee of €20.


I object in the strongest possible terms to the proposal to build 536 residential units of up to 8 storeys high on the St Paul’s Playing Fields at St Anne’s, for the following reasons:


This proposal contravenes the Z15 planning regulations. Specifically, it does not secure the retention of the main institutional and community uses on the lands, including space for any necessary expansion of such uses, a requirement of the legislation. It does not secure the retention of existing functional open space e.g. school and community playing fields. In particular, the developer has not made sufficient provision to accommodate the existing and long established prior community use of St. Paul’s playing fields by Clontarf GAA, soccer and rugby clubs. Any argument that the Z15 objectives can be achieved in other parts of the park in concert with the proposed development by way of development levies or ‘community gain’ payments implicitly acknowledges that it cannot be achieved on the St. Paul’s lands as the proposal currently stands.


This land was originally part of the park and when acquired by the Vincentians, its envisaged sole use was as playing fields, not development. Up until 2001 it was considered by the public to be part of the park with no fence and no restrictions on entering. It is surrounded on three sides by parkland and on the fourth side by St. Paul’s School. It is undeniably within the curtilage of St. Anne’s Park which is a designated buffer zone for the Dublin Bay Biosphere. If no longer required by the school the land should revert to a planning designation in common with the rest of St. Anne’s. At a minimum the planning conditions applicable in the park should also apply to the St. Paul’s fields.


The Environmental Impact statements provided by the developer are inaccurate, incomplete, overly partisan and not objective. 

Wintering Bird Implications – Protected species including the Brent Geese will be adversely impacted by this development. Dublin City Council Parks and Landscape division describe the St. Paul’s Playing fields as ‘…..the most important ex-situ feeding site for Brent Geese in Dublin based on highest peak counts of Brent Geese, regularity of use, its geographical location in relation to North Bull Island, its size, and the relative lack of disturbance’. An Bord Pleanála should mandate the completion of a Full Appropriate Assessment using independent objective analysis. In order for this planning application to succeed, the Stage 2 Appropriate Assessment ‘…..must provide a clear conclusion regarding the absence of adverse effects on the integrity of European sites’. The planners cannot rely on subjective and suggestive conclusions offered by the advisors paid by the developer to complete the Natura assessments and should seek further independent analysis. Any doubt about an adverse impact on these protected birds is sufficient to require the planning authorities to deny Planning Permission under the current legislation.


Likewise, there is insufficient analysis presented by the developer to assess the impact on Curlews. They are listed as a species of special conservation interest in the North Bull Island Special Protection Area. St. Anne’s Park and St. Paul’s Playing Fields are by far the largest of the five “Wet Lands” within the Dublin Bay Biosphere Catchment area. The peak observation of Curlews in St. Paul’s playing fields of 86 is statistically significant in an Irish context and to ignore the Curlews in any Natura assessment is wrong.  Equally at best cursory consideration is given to the bats that live on or traverse the lands in this application. No analysis is provided and no research was completed to see if protected bat species (EU Habitats Directive) who live in St Anne’s Park are or will be impacted by this development. Finally, the protection of the protected Holm Oaks and Pines along St. Anne’s Avenue has not been considered sufficiently in the developer’s proposals, in particular in regard to their root protection.


The potential impact to the Dublin Bay Biosphere is significant. The developer is relying on an agreement with Dublin City Council to divert waste water away from its natural path into the Naniken River and beyond that into the UNESCO nominated Dublin Bay Biosphere. This river system is already proven to be considerably polluted and regularly causes flooding and pollution in St. Anne’s and onto the Clontarf Road. To allow this planning to proceed with any potential adverse impact on Dublin Bay Biosphere would be a dereliction of the planners obligations. Explicitly any development should be required to reduce risk to the biosphere not increase it.


The developer has understated the likely landscape and visual impacts of the proposed development on St. Anne’s Park.  The nature and scale of the proposal does not integrate with the surrounding lands and does not properly assess the visual significance and sensitivity of the site. The most sensitive visual receptors, the walking view from the Avenue toward the playing fields and the fields to the north, pitches 1 and 2 (overlooked by 3 blocks of 8 storey apartments) are largely ignored. The photomontages provided by the developer are at best insufficient, more probably misleading. The use of terms such as ‘glimpse views’ are entirely inaccurate. The factual reality is that the existing visual experience from the Avenue will be largely eliminated and that the scale, height and bulk of the proposed development will negatively impact the Avenue and the northern playing fields, will be visually obtrusive and be out of character. This will seriously diminish the historic aesthetic character of the park and will cause loss or damage to its special character. The emotional reality is that a very fine historic avenue and park will be irretrievably damaged if any development is allowed to proceed in these fields.



Yours sincerely,



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