Today, Tuesday the 19th November, Finian McGrath TD alongside Cllr Damian O’Farrell have lodged their objection to the planning application in St Anne’s Park to An Bord Pleanála. Locals have been opposing plans to build 657 apartments on the St. Paul’s playing fields at St. Anne’s Park, Raheny, Dublin 5 by the developer Crekav Trading GP Ltd.

The ‘i love St Anne’s’ campaign and the broader community were successful in preventing the last proposed development on this site following a High Court challenge. This then led to An Bord Pleanála reversing their decision to give planning permission on this site. 

McGrath and O’Farrell lodged the following submission

‘We, as elected public representatives for our area are absolutely opposed to the above SHD application for development at this specific location / site and we wish to object in the strongest possible terms.  We are mindful of the chronic housing shortage in our city at present however, we believe that there has never been a more important time for adherence to proper and strategic planning in our city. The planning process allows for observations to be made by residents and public representatives and it is vitally important that planners consider what these people have to say, particularly the local knowledge element they bring to the table.

Inappropriate use of Z15 zoning the development as proposed is entirely inappropriate under Z15 zoning. ‘Residential’ is included as an “Open for Consideration” use under Z15 in order to secure the retention of existing institutional and community uses; a typical example is the use of Z15 for provision of student accommodation for educational institutions. This development by reason of its enormous scale and intensity constitutes a material contravention of the 2016-2022 Development Plan.  

Furthermore, in terms of the SHD application itself we do not agree that this specific application complies with the Strategic Housing Development Regulations 2017 in that a SHD application for 100 units or more can only be made on land zoned for residential use or residential and mixed other use.  The Z15 zoning of this land is we believe outside the scope of the regulations. We request that ABP invalidate the application and that any future applications should be dealt with by DCC in the first instance.   

Loss of existing amenity value to community usersthe lands in question are zoned Z15 and were, until January 2018, accessed by many local sporting organisations. Loss of access to these grasslands will leave hundreds of children, youth and adult teams with no place to play. Dublin City Council’s Development Plan 2016-2022 states that the objective of Z15 zoned land is to protect and provide for institutional and community use. The plan goes on to state that any residential development open to consideration on Z15 land must demonstrate…

 how it secures the retention of the main institutional and community uses on the lands, including space for any necessary expansion of such uses;


…how the proposal…assists in securing the aims of the [Z15] zoning objective;

As outlined above this proposal results in a serious loss of community use and is therefore incompatible with the very definition of the Z15 objectives.  We have been dealing with clubs that have had to vacate this land and I can assure you that there is no existing capacity in the rest of St Anne’s Park to facilitate their youth members and we know of a least one club who has had to downsize / refuse membership already.  We are aware that all the local sporting organisations are opposed to this development and believe that ABP need to take this fact into consideration.   

Damage to Brent Geese foraging grasslands, Curlew feeding areas and the Biospherea 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.   It is not possible nor permissible for a land-owner to extinguish a ‘feeding site’ and any such attempt to ‘get rid of’ or ‘extinguish’ such a site is completely contradictory to the EU Habitat Directive and in fact contradictory to ABP’s own decision to refuse (ABP -302225-18).  Furthermore, 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 must 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. We contend that the applicants Natura Impact Statement which in fact acknowledges the loss of the ex-situ habitat is totally self-serving and have requested that Dublin City Council challenge its bona-fides robustly in their own CEO’s report to ABP.   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 land.

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