Submission John Callaghan

Submission of John Callaghan on the

Consultation: 

Material Amendments to Draft Mayo County Development Plan 2021-2027

Address: John Callaghan, (REDACTED PERSONAL INFORMATION)

Note. None of this submission should be interpreted as personal data

Introduction:

The 2021-2027 Development Plan is being made through an extraordinary time when the normal interaction of people has been suspended. Opportunities for people to meet their Councillors and members of their community have been curtailed a most extraordinary way. Normal participation in the Development Plan process has not been possible due to COVID

1.0 The problem caused by a view of the sea.

Sea views are wonderful, but they put housing out of reach of too many people who were raised in the locality. Compact development policies have their merit but if the zoned land only includes land with premium sea views the housing will not be affordable to a disproportionate number of local people, particularly if levies envisaged by the Vacant Sites Act are not applied.

Building along the N59 is not an option for many families due it being a National Route.

Hence many people with local roots are squeezed in terms of a housing solution. These are factor in the migration of local people from the area.

Additional land that does not have a sea view should be included in the zoned area so that housing might be more affordable to local people

Consultations are not meaningful unless they can influence the outcome.

2.0 There is a concern that identification of core area will impose a policy related to concentric growth.

3.0 Disproportionately less land being zoned in Mulranny than in Lower Achill. It is notable that no scales were attached to Tier iV Zoning Maps when they went for public consultation. There is a vast difference in the area zoned in Lower Achill and Mulranny with approximately 210 hectares being zoned in Keel West, Slievemore, and Keel East with a population of circa 638

Number of persons enumerated in KEEL WEST in 2016: 92

Number of persons enumerated in SLIEVEMORE in 2016:
284 

Number of persons enumerated in KEEL EAST in 2016:
262
per CSO data https://cso.maps.arcgis.com/apps/webappviewer/index.html?id=4d19cf7b1251408c99ccde18859ff739

In contrast the population of the proposed zoned Mulranny area which includes Murrevaugh is 388 which has a mere 30 hectares proposed for zoning

Number of persons enumerated in MALLARANNY in 2016:
246 

Number of persons enumerated in MURREVAGH in 2016:
142 

Substantially more land is serviced than is being included in the development plan area much of which does not have sea views and hence might allow locals to compete for housing in the area, if some of it were to be included in the Development Plan Area.

The Dooah- Keel area of zoning stretches for almost 4.5km without a core area being identified.

2.0 Mulranny Village Constraints. Mulranny is characterised by very steep gradients with much land having gradients in excess of 1/10. Steep gradients do not lend themselves to access roads running at right angles to the elevation contours of the landscape. Property owners who have a sea view on elevated ground are not interested in selling land for development that will obscure their view of the sea

2.1 Having read the Office of the Planning Regulator’s Comments in relation to Development Constraints OPR Recommendation 5: Development Approach to Settlements 5d.

 I submit that the steep gradient in Mulranny Village should be considered as a constraint. The Mulranny Development Plan 1988-1993 identified a large area with gradient constraints: Available at https://www.mayo.ie/getmedia/0b25be31-36fd-4d12-8095-a074944f4b53/Mulranny.pdf

2.2 The proposed core area lies within an area of steep gradient, that has particular geotechnical challenges for foundations, slope stability, and for the universal access of people, particularly the partially ambulant.

2.3 The area identified in the 1988 Mulranny Development Plan with steep gradient runs from line of easting ITM 482,700 to 483600 and there is little potential for in depth development without additional east west roads through the village. There is extensive rock which adds to construction cost and environmental impact.

3.0 Previous Serviced Land Extension  

3.1 The Serviced Land Initiative extended foul sewer services to significant areas of land to the east of the Mullranny Village, in the townland of Murrevaugh, much of which has low gradients and which is screened from the views from the coastline. Infact the Local Authority acquired land in Murrevaugh Townland for their own 16 house development which had significant emphasis on universal access in its site layout.

3.1 The County Development Plan Maps were published for Tier IV without scales or any indication of Gradient.  

3.2 It would be wasteful to develop Serviced Land at very low density. Serviced land without sea views has the potential to satisfy owner occupier housing needs. Excluding sewer serviced land from the development plan area will tend to have that land developed at low density and probably by use for more second homes.

3.3 Zoning more serviced land which without sea views is the best hope for many local people to meet their housing need.

4.0 Permit taller buildings in areas with sea views

4.1 Mulranny has a large tall building for more than 100 years. I suggest and urge that tall buildings be promoted in the core area of Mulranny, per section 3.6 of the Residential Building and Height Guidelines:

“Development should include an effective mix of 2, 3 and 4-storey development which integrates well into existing and historical neighbourhoods and 4 storeys or more can be accommodated alongside existing larger buildings, trees and parkland, river/sea frontage or along wider streets. Mulranny has an abundance of open spaces which provide public access.”

4.2 It is unlikely that property in good condition will be redeveloped unless   significantly increased density is permitted. The proposed core area of Mulranny could only be redeveloped at substantial density or not at all.

4.3 Carparking: Mulranny needs substantial provision of car parking, and it needs to be in proximity to the commercial centre.

5.0 Amended Development Plan Period. The initial Development Plan Consultation envisaged a plan period of 2021-2027. Development Plans have limited lives in order to allow new plans to be framed that take account of changed circumstances. The World has experienced extraordinary change since the Proposed Development Plan Initial consultation opened. The Mayo County Development Plan Period is being changed without allowing a full Public Consultation contrary to the Aarhus Convention. CONVENTION ON ACCESS TO INFORMATION, PUBLIC PARTICIPATION IN DECISION-MAKING AND ACCESS TO JUSTICE IN ENVIRONMENTAL MATTERS done at Aarhus, Denmark, on 25 June 1998  https://unece.org/fileadmin/DAM/env/pp/documents/cep43e.pdf

It now appears that the Plan will have a life till June -July 2028

Examples of the relevant change is the failure of the Vacant Sites Levy to operate as envisaged Per Allan J. Navratil v An Bord Pleanala and Cork County Council [2020] IEHC 292

Compact Growth Policies were introduced in the context of an envisaged Vacant Sites Levy operating effectively to act as a lever to bring property to the market for development.

The failure of the Vacant Sites Levy to bite is a major factor in the current housing crisis.

Other notable changes include improvements in internet services, more home working, higher energy prices. More people can work remotely since the Covid Wave.

6.0 Core Area.

It is submitted that the core area should be located much farer to the east and that all land within the 60KMPH zone should fall within the Development Zone as it would increase the area of land with low gradients for development. It is not possible to have a consultation unless all matters are open to review