The letter below is not intended to be a comprehensive response to the planning application. If you have specific issues of concern in relation to this planning application, you should address them yourself separately.


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Insert Date Here

Strategic Housing Division
An Bord Pleanála
64 Marlborough Street
Dublin 1

Re: Objection to Application Reference Number: ABP-305680-19
Construction of 657 Apartments on Lands to the east of St. Paul’s College, Raheny.

A Chara
I am writing in relation to the planning application submitted by Crekav Trading GP Ltd. for residential development on 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 required fee of €20

I object in the strongest possible terms to the proposal to build 657 apartments on the St. Paul’s playing fields at St. Anne’s for the following reasons:

Light Bellied Brent Geese
A previous planning application for this land, (ABP-302225-18), was refused by An Bord Pleanála in 2018. The substantive reason for this decision to refuse permission has not changed.
In the interim, the landowner has ceased to cut the grass on the lands, deterring the protected light bellied Brent geese from their most important ex-situ feeding site. Notably, these birds have been recorded by members of the public, in large numbers, on the one grass pitch retained and maintained by St. Paul’s college for the school’s own use, demonstrating their loyalty to this location, even when they have to contend for limited resources on the site.

Please note that the landowner has failed to establish that light bellied Brent geese will not be impacted in the long term by the loss of this feeding ground. Such statistics would take several years to gather and assess; we have only had one feeding season where the birds were excluded from the lands. Applying the precautionary principle, permission cannot be granted to build on these lands.

Among the many pages produced by the developer as part of this planning proposal, is a reference in the EIAR to a report by Austin Agnew et al; Irish Veterinary Journal, 2016
which suggests goose droppings pose a serious threat to human health. This is a remarkable report to reference at this juncture and very concerning given the lack of context or reference to any contrary opinion. Its inclusion could best be described as disingenuous, and it clearly demonstrates the landowner’s lack of concern for and understanding of the status of these protected birds with whom we share our amenity lands.

Z15 Community Use
In an attempt to extinguish established and legally protected community use on these Z15 lands, several sports clubs were evicted from the St. Paul’s playing fields at the end of 2017 and goal posts were removed. Despite claims by the landowner to the contrary, parents of children who play for these clubs AND the clubs themselves, report ongoing struggles to secure replacement pitches for matches and training. This situation is exacerbated by the cumulative impact of Z15 lands lost to development across the city – which the Board is, no doubt, acutely aware of.

St. Paul’s – a site located within a UNESCO biosphere buffer zone & award winning park
St. Anne’s park forms part of the buffer zone for the protected UNESCO biosphere at Bull Island. Given their location on the main avenue of St. Anne’s, under EU Bird and Habitats directives the St. Paul’s playing fields would reasonably be deemed “projects situated outside SPAs but having significant effect inside them”.
They are not designated as a buffer zone for the Dublin Bay biosphere, but they are undeniably integral to it. This is evidenced by the huge numbers of shore birds, regularly recorded feeding at St. Paul’s.
This ‘bird sanctuary’ was created by the Vincentian Father’s when they erected a fence around the lands in 2001. Taking a ‘birds eye view’, there is nothing to differentiate the privately owned lands at St. Paul’s from the publicly owned lands at St. Anne’s. The birds simply chose the one piece of green in the St. Anne’s demesne that was protected from natural predators in the park by a fence.

St. Anne’s park is a Green Flag award winning park. In September 2019, the public were asked to vote for their favourite Green Flag park in the global Green Flag People’s Choice competition.
Over 45,000 votes were cast from all around the world. The 2019 winners are:
St. Anne’s Park: Dublin City Council Republic of Ireland
Abraham Ledeboerpark: Gemeente Enschede Afdeling Stadsdeelbeeer, The Netherlands
Al Bahya Garden: Abu Dhabi City Municipality, United Arab Emirates
Parque da Cidade: Câmara Municipal do Porto, Portugal
Stadtpark – Botanischer Garten Gütersloh: Fachbereich Grünflächen Stadt Gütersloh Germany

Robert Moss, Republic of Ireland Green Flag Award Manager said: ” Saint Anne’s Park is one of the green space citadels that make North Dublin a special place. Its location within the buffer zone of the Dublin Bay Biosphere makes it an important site for biodiversity, especially as a feeding site for Brent Geese and other shorebirds at high tide.”

Potential Impacts
The playing fields are integral to St. Anne’s itself, surrounded as they are, on three sides by the public park and with no road access save through the St. Paul’s school yard.
St. Paul’s Boys Secondary School
Any building on the St. Paul’s lands will impact the students of St. Paul’s college who will gain the use of a sports hall and 1.25 all-weather pitches at the price of constricting their school forever to its current very limited capacity; losing 5 grass pitches and enduring a building site in their school yard for up to 10 years;
St. Anne’s Flora & Fauna
Any building on St. Paul’s will impact St. Anne’s park and its flora and fauna.
These impacts cannot be anticipated and have not been properly assessed. They will be felt as far away as the park boundary at the James Larkin Road, an area already prone to flooding, where water diverted into the Naniken river from the proposed development will flow into the sea at Bull Island.
Citizens of Dublin
Any building on St. Paul’s will impact the people who use St. Anne’s. These are the people who voted St. Anne’s into the top five people’s parks in the world. They come from all parts of Dublin city. 7,000 of them support the I Love St. Anne’s facebook campaign opposing any building on these lands, 10,000 + signed an opposing petition and contributed to a fund raising campaign to challenge this application. Their voices should be acknowledged.

I appeal to the Board to consider this proposal in the overall context of St. Anne’s park and the wider Dublin Bay biosphere, and refuse it outright.

Mise le meas

(sign here)