Submission to FCC, Pre- Draft Kilmartin LAP 2012-2018, 2nd Feb 2012A

Submission to
Having Your
Say Strategic
Issues Paper
for
the Kilmartin
Local Area Plan
2012-2018
Pre-Draft Stage
Submission on behalf of
the KF Partnership
February, 2012

Submission to Fingal County Council, Pre-Draft Kilmartin Local Area Plan 2012-2018, 2nd
February 2012
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222
Consultants
Lead Coordinators
Johanna Varghese and Simon Keogh
urban – asylum
planners and architects
________________
35 malone gardens
bath avenue
dublin 4
ireland
T : + 353 1 668 0926
E : johanna@urban-asylum.com
in consultation with
Philip Crowe
MCO Projects Ltd
Specialists in Sustainable Design | Energy Management | Local Area Development
The Warehouse
121/122 Capel Street
Dublin 1
T: +353 1 887 0630
E: pcrowe@mco.ie
W : www.mco.ie
Jay Stuart
DW EcoCo
Integrated Sustainable Design Consultants
Bloomfield House
Bloomfield Avenue
Dublin 8
T : +353 1 411 3058
E : jstuart@dwme.ie

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Introduction
Submission to Fingal County Council, Pre-Draft Kilmartin Local Area Plan 2012-2018
We make this submission in response to ‘Having Your Say’, Strategic Issues Paper Kilmartin, Local
Area Plan 2012-2018 and on behalf of our clients who hold c. 210 acres within the Fingal Development
Boundary and which are within the townslands of Powerstown and Kilmartin, and are partly adjoining
and to the west of the Local Area Plan lands at Kilmartin and Hollywoodrath.
Our clients wish to draw your attention to the fact that that they have previously made the following
submissions to Fingal County Council:
Submission Details Submitted to Fingal County Council
call for submissions under
Colin Buchanan and Partners Planning
Report - March 2008
Moylan Engineers Preliminary Engineering
Report - March 2008
Powerstown, Kilmartin, Tyrrelstown and
Environs Study - February 2008
Colin Buchanan and Partners Planning
Report - March 2008
Moylan Engineers Preliminary Engineering
Report - March 2008
T. A. Mellor Sustainability Report - June
2009
Development Plan 2011-2017
– First Stage (Pre-Draft)
u-a architects Planning Report – June 2010 Development Plan 2011-2017
– Second Stage (Draft)
u-a architects Submission on Material
Amendments – January 2011
Development Plan 2011-2017
– Third Stage (Material Amendments)

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Contents
__________________________________________________________________
Summary
Vision
Aims
Strategies 1-4
Strategy 1. Green Infrastructure Provision - Introduction of a SMART Corridor
Strategy 2. Integrated Water Resources Strategy
Strategy 3. Sustainable Energy Provision
Strategy 4. Food Production
Appendices
Bibliography

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List of Figures
Fig 1. Map showing connectivity incorporating the SMART Corridor as part of the ‘necklace’
effect route; connecting communities and amenity spaces and integrating HSL’s and NDA’s
with the Green Infrastructure.
Fig 2. Map showing the regional Green Infrastructure connecting the proposed SMART Corridor to the
wider context, enhancing the connection of the Tolka Valley Park to the large expanse of Green
Belt north of Tyrrelstown which adjoins the LAP lands.
Fig 3. Sketch Perspective - Indicative view of proposed SMART Corridor.
Fig 4. Map shows the ‘necklace’ effect of the Green Infrastructure integrating the proposed SMART
Corridor and Protected Structures, Recorded Monuments / Places and Historic Graveyards.
Fig 5. Map showing proposed integration of the SMART Corridor including Local Water Resource
Centre, Main Distributor Road alignment and physical linkages with the LAP lands, Tyrrelstown
lands and the Zoned Public Park.
Fig 6. Sketch Perspective – Indicative view of a large ‘clearing’ to the Zoned Public Park between the
LAP lands and existing Tyrrelstown community.
Figs 7-10. Precedent of Living Machine Greenhouse, Harbor Park, Budapest, Hungary serving a
population of 5000, visited September 2006.

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Summary
Arising from the existing natural assets, social capital and location, this submission offers strategies
for consolidation, building on the strengths of Tyrrelstown and Kilmartin including its potential for
connectivity, renewable energy provision, waste water management and food production that is in
accordance with local, regional and national policies and plans.
To avoid creating a discrete and isolated community in the LAP lands that relies heavily on existing
centralised infrastructure, this submission offers strategies for integration within its environs as well as
encouraging self sustaining and resilient solutions to take the pressure off overloaded centralised
infrastructure.
The ideas put forward in this document cover issues such as Green Infrastructure, Integrated Water
Resources, energy provision and food production and are exploratory and for discussion with Fingal
County Council.
The principle strategies include:
1. Introduction of a SMART1
Corridor
2. Integrated Water Resources Strategy
3. Sustainable energy provision
4. Local food production
As a separate issue, the submission puts forward for consideration that lands to the west of
Tyrrelstown and the Kilmartin LAP lands are not compromised by any policies and plans in the LAP so
that the potential of these lands (Zoned Objective RU - Agricultural) remain open in the new planning
context.
Our clients also request that in the planning of the Kilmartin LAP lands, clear rationale for plans,
proposals and boundary lines are provided.
Vision
1
SMART is an acronym for potential goals of the Corridor namely Specific, Measurable, Agreed upon, Realistic
and Time-based and is in compliance with the National Transport Policy, ‘Smarter Travel - A Sustainable
Transport Future’ , 2009-2020.

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Consolidation of the LAP within its environs through increased connectivity
and integrated sustainable strategies
Aims
The aim of this submission is to set out an integrated land use plan that consolidates the existing
Tyrrelstown lands, the LAP lands and the environs to promote a resilient community in the new
economic and environmental context by:
- Improving connectivity of the Tyrrelstown lands, the LAP lands and the environs through Green
Infrastructure.
- Promoting renewable energy provision, integrated water resource strategy and biological waste
water treatment system.
- Building on local assets through job provision from food and energy production.
- Respecting and nurturing local biodiversity, natural and cultural assets.
- Supporting and building community capital to improve well-being.
Opportunities and Threats
Table A – Opportunities, Strengths, Threats and Weakness
Opportunities and Strengths
 strong existing community in Tyrrelstown.
 landscape of surrounding area/agriculture/rural landscape.
 location of LAP land adjoining Green Infrastructure including Ecological Corridors, Green
Belt, Highly Sensitive Landscapes and Nature Development Areas.
 dynamic young population.
 location near the airport, Blanchardstown Town Centre, Dublin and the M50, N2/M2 and
N3/M3.
 impact of the new Building Regulations, December 2011 and pending increases in 2013 to
shift towards Renewable Energy.

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Threats and Weaknesses
 Tyrrelstown/Kilmartin may continue to develop as a discrete and isolated development.
 weak connectivity within both its immediate neighbourhood context and wider regional
context.
 new development that does not balance Green Infrastructure and Biodiversity issues
 new development that impacts further pressure on the existing overloaded waste water
facilities in Ringsend.
 lack of adequate and varied recreational spaces.
 lack of adequate cycleways and walkways to connect Tyrrelstown/Kilmartin lands to both
the immediate and wider context.
Strategies 1-4
In response to the Strategic Issues Paper for the Kilmartin Local Area Plan (LAP) we put forward the
following strategies for your consideration:
Strategy 1. Green Infrastructure Provision - Introduction of a SMART Corridor
(see Figs 1-4)
Consolidate the existing Green Infrastructure by connecting the LAP lands to its environs through the
introduction of a SMART Corridor which extends from the Ecological Corridor along the Pinkeen River
to the Green Belt.
The SMART Corridor which integrates the LAP lands to the existing Green Infrastructure would create a
public realm that:
 connects the established communities in the area to the LAP lands offering a space for social
affiliations.
 enhances the connection between the Ecological Corridor along the Pinkeen River and the
Green Belt.
 connects the existing amenity spaces of the Hollystown Golf Course, the Zoned Pubic Park, the
Tyrrelstown House Proposed Public Park and the amenities spaces shared between the
Parslickstown and Lady’s Well Communities.

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Fig 1. Map showing connectivity incorporating the SMART Corridor as part of the ‘necklace’ effect route; connecting
communities and amenity spaces and integrating HSL’s and NDA’s with the Green Infrastructure.

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Connectivity (see Fig 1)
The suggested Green Infrastructure SMART Corridor completes the ‘necklace’ effect when combined
with the Ecological Corridor along the Pinkeen River and would be in accordance with Fingal
Development Plan (FDP) 2011-2017 Objectives BD21 – BD29 and Local Objective 426.
To the west of the LAP lands the proposed SMART Corridor directly links to the following:
 the Green Belt and surrounding Hollystown community
 the future Kilmartin community
 the Zoned Public Park
 the existing Tyrrelstown community
 Tyrrelstown House Public Park (FDP 2011-2017 Local Objective 415)
 the Ecological Corridor/Linear Park along the Pinkeen River (FDP 2011-2017 GI Maps #2, BD 21-29 and Local Objective
426)
The Ecological Corridor along the Pinkeen Rover connects into the Highly Sensitive Landscape (HSL) of the
Tolka Valley Park and surrounding Parslickstown, Lady’s Well and Mulhuddart communities and therefore the
SMART Corridor would physically enhance connectivity between Kilmartin and these adjacent communities
and so encourage social affiliations (see Appendix E for a precedent of a SMART Corridor).
A physical connection is proposed between Hollywoodrath lands and the Nature Development Area
(NDA) and the Green Belt to the north east of the LAP lands.
The SMART Corridor could provide Green Infrastructure onto which future peri-urban development
could integrate.
Linkage (see Fig 2)
The proposed SMART Corridor could enhance the connection of the Tolka Valley Park (which runs from
Dublin City through County Fingal and into County Meath) to the large expanse of green belt north of
Tyrrelstown which adjoins the LAP lands.
The strategy would provide opportunities to link the LAP land from Tyrrelstown Local Centre to
Mulhuddart Local Centre and Blanchardstown Town Centre.
The SMART Corridor within the LAP lands could provide for interconnected cycleways, skateways and
walkways. This could make a contribution to changing the habit of car dependency, facilitating an
increase in the modal share of sustainable modes of transport and bringing more attractive multi
modal options to the area. This multi modal travel options could be further enhanced through a
Tyrrelstown/Blanchardstown bike scheme.

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Fig 2. Map showing the regional Green Infrastructure connecting the proposed SMART Corridor to the wider
context, enhancing the connection of the Tolka Valley Park to the large expanse of Green Belt north of Tyrrelstown
which adjoins the LAP lands.

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Built Heritage (see Fig 4)
The strategy creates a high quality public realm that enhances the character and identity of
Tyrrelstown/Kilmartin through the linking of Protected Structures, Historic Graveyards and Recorded
Monuments/Places.
Amenities and Facilities (see Fig 4)
This proposed connection would utilise and enhance both the existing and proposed amenity areas and
provide for both passive and active recreation.
The SMART Corridor would further integrate the following facilities either within or directly adjoining it
 existing allotments off Powerstown Road
 attenuation ponds to the west of the Tyrrelstown House Public Park
Attenuation ponds would slow down run-off in storm conditions and allow water to percolate naturally
into the water table. Development in the LAP could employ a SuDS that feeds into an overall surface
water treatment scheme that prevents flooding and is integrated into the Green Infrastructure
The SMART Corridor plugs into the LAP lands, the Zoned Public Park and Tyrrelstown lands. The
SMART Corridor incorporates open space, biodiversity, landscape, water, waste water, heritage,
archaeology, and community and education facilities (see Fig 3).
Fig 3. Sketch Perspective - Indicative view of the proposed SMART Corridor
The future primary school could be integrated into the SMART Corridor adjacent to the LAP lands. The
SMART Corridor would be an appropriate location for other schools and community facilities as school
going children could go to school without interfacing with motorised traffic.

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Fig 4. Map shows the ‘necklace’ effect of the Green Infrastructure integrating the proposed SMART Corridor and Protected
Structures, Recorded Monuments / Places and Historic Graveyards.

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Utilities & Allotments (see Fig 5)
The SMART Corridor within the LAP lands could integrate the proposed Local Water Resource Centre (a
decentralised and comprehensive waste water treatment facility - refer to Strategy 2 and Figs 7 – 10
and Appendix B). This Local Water Resource Centre could act as an educational facility promoting
social interaction for visitors, residents and school children.
The SMART Corridor within the LAP lands and to the north east could accommodate a proportion of
allotments required to service the suggested 1200 dwellings within the Kilmartin lands2
. The
remainder could be serviced via the proposed allotments between the existing ESB transmission lines
which would be in close proximity (200 metres) to the Kilmartin Community and within 50 metres of
the existing Tyrrelstown Community. The latter larger allotments could enhance social affiliations
between the two communities.
Permeability and Access (see Fig 5)
The main distributor road could continue through the western boundary of the LAP lands through the
SMART Corridor to provide a link to lands westwards and to lands to the south which would connect to
the N2- N3 Link Road.
Permeability is proposed both visually and physically with access points from the LAP lands and
Tyrrelstown to the zoned Public Park.
To increase pedestrian permeability, the main distributor road alignment could bisect the Kilmartin
lands allowing spurs and smaller road linkages to occur towards the Public Park thereby increasing
pedestrian permeability.
A large ‘Clearing’ is suggested within the Public Park adjoining the LAP Lands to act as both a nucleus
and focal point for the surrounding residential communities (see Fig 6 overleaf). Providing a large
feature within the Public Park brings a strong identity to the area based on the landscape and provides
an important counterbalance to the Town Centre.
2
The number of these dwellings are calculated on the basis of 80 acres at 15 units per acre (1200 dwellings) on
the portion of Kilmartin lands within the LAP.

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Fig 5. Map showing the Proposed SMART Corridor integrating the Local Water Resource Centre, Built Heritage, Allotments,
Main Distributor Road alignment and physical linkages relating the LAP lands, Tyrrelstown and the Zoned Public Park.

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Fig 6. Sketch Perspective – Indicative view of a large ‘clearing’ to the Zoned Public Park between the LAP lands
and existing Tyrrelstown community.
Strategy 2. Integrated Water Resources Strategy
‘Water is a finite resource that is under increasing demand, capacity of catchment areas and
soils from natural or anthropogenic causes, leading to more demand for irrigation, increased
demand for intensive livestock husbandry, extraction of groundwater at a faster rate than it
can recharge, and a decline in water quality from processing and salination’.
Fingal County Council Water Services Assessment of Needs, 2005 – 2013.
Waste water management is an issue where the Kilmartin LAP lands can demonstrate sustainable and
cost effective strategies which promote a ‘self sustaining’ community.
An Integrated Water Resources Strategy could be a sustainable solution to the challenges above. The
strategy would address all the issues of surface water, rainwater harvesting and storage, waste water
treatment and storage of cleaned water for reuse and recycling.
This comprehensive approach to the water resources of the site will significantly reduce the costs of
water services in the area and provide employment, recreational amenities and educational
opportunities. The sustainable systems used are robust and have a low environmental impact. It
would improve the environment by enhancing the biodiversity, landscaping and aesthetics of the site.

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The strategy would include SuDS3
and a Local Water Resource Centre incorporating a Living Machine4
(see Box overleaf) and both could be located on the SMART Corridor. (see Fig 5)
The implementation of the strategy would:
 Ensure that, within the LAP, growth is commensurate to waste water capacity and can meet growth
estimates for the future.
 Establish long term effectiveness in the context of a changing environment the provision for waste water
to be recycled and reused in a sustainable manner.
 Reduce demand on water supply to protect long term future water sources in the Dublin Region as stated
in the RPGGDA 2010-2022 and the FDP 2011-2017.
Local Water Resource Centre
The Local Water Resource Centre could be located within the proposed SMART Corridor and within the
western portion of the LAP lands.
The Local Water Resource Centre and its greenhouse plants will also act as an education facility as a
landmark exemplar of sustainable technology delivering sustainable and cost effective solutions to the
communities it serves. It is also near the agricultural lands, fields and public park so that the
landscaping can be irrigated by the recycled water and water features supplied with water without
using mains drinking water wastefully.
The Centre would address the LAP issue of specifying a programme for the phasing of construction of
residential and commercial development in tandem with the delivery of appropriate augmentation of a
public drainage and water supply infrastructure plan, as well as provision of recreational community
and educational infrastructure.
3
SuDS (Sustainable Urban Drainage System) would feed into an overall surface water treatment scheme with
attenuation ponds that prevent flooding and are integrated into the Green Infrastructure. A precedent is found in
the village of Cloughjordan, where a Sustainable urban Drainage System has been installed as part of the village
infrastructure, slowing run-off in storm conditions and allowing water to attenuate naturally into the water table.
Green roofs combined with localised rain butts to dwellings would mitigate surface water runoff and be in
compliance with a SuDs strategy (see Appendix C for precedent in County Cork, Ireland).
4
The Living Machine system is a decentralised and comprehensive ecological wastewater treatment facility which
treats waste water of all types to any required high standard. The proposed system will accept wastewater from
the existing sewer system and treat it to meet current rigorous water reuse standards. The on-site Living Machine
system can be designed to treat and recycle any amount of surface water and wastewater per day.

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The Living Machine (see Figs 7-10 overleaf and Appendix B for a precedent in Europe)
A Living Machine is a waste water treatment system that looks like a botanical garden in a greenhouse. It uses
specially selected plants, most of them aquatic plants growing in a series of tanks, to treat the waste water to
the same standards as conventional municipal waste water treatment plants but without the use of chemicals
and using less energy and land area. The system has been built in many countries over the last 35 years to
serve a variety of sites and waste flows.
The Living Machine can be designed to function, and resemble, a “river” through the creation of eddies,
countercurrents, and contact zones in which a diversity of life will arise. The Living Machine is a water garden
that can be designed to provide advanced treatment in a sustainable system which then becomes an
educational resource and a local amenity. They cost less to build and operate than a conventional waste water
treatment system and they can be designed to occupy less land area. Some of them are designed as
educational facilities and attract schoolchildren, graduate students developing their theses, engineers interested
in the system and the general public. Some are so popular they charge entrance fees and give guided tours.
A robust ecosystem is created in the Living Machine between the plants, microbial species and the distinct
treatment zones. Within the Living Machine, all the major groups of life are represented, including microscopic
algae, fungi, bacteria, protozoa, and zooplankton, on upward to snails, clams, and fishes. Higher plants,
including shrubs and trees, are grown on adjustable industrial racks suspended within the system. The result is
an efficient and refined wastewater treatment system that is capable of achieving high quality water without the
need for hazardous chemicals.
The system often includes an anaerobic pre-treatment component, flow equalization and aerobic tanks as the
primary treatment followed by a final polishing step, either utilizing ecological bioreactors or a small constructed
wetland. The size requirements are entirely dependent on the waste flow and are determined during the
engineering design of the project.
There is a growing awareness in Ireland of the benefits of this sustainable and cost effective system. In Ireland,
water engineers in two local authorities agreed to accept and incorporate the Living Machine system in to the
waste water infrastructure and planning process. Due to the recession both schemes remain on hold.
For the LAP land, the Local Water Resource Centre (incorporating the Living Machine) could be wholly located in
a 30m x 40m greenhouse engineered system treating waste water from population of 10,000 people (PE
equivalent load). Wastewater is treated in a series of bio-reactor tanks. The treated water may then be stored
in ponds and recycled for non-potable purposes such as landscape irrigation, toilet flushing, industrial processes,
washing, maintenance, for animal uses, landscape water features (For example fish ponds and waterfalls) and a
wide variety of other uses.

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The advantages of the Local Water Resource Centre are:
1. Eases the pressure of the already overloaded central system in Ringsend. The Centre offers a
sustainable solution to the problem of transporting treated water to the LAP area only to send
wastewater a long distance to a centralised sewage treatment plant.
2. The SuDS urban drainage system for surface water can be enhanced by the Living Machine and
other aspects of the Water Resources Strategy.
3. Site specific solution allows for onsite water recycling, producing clean water for irrigation,
toilet flushing, industrial processes, washing equipment or animal areas.
4. The treatment system offers environmental and economic advantages over conventional
electricity intensive plant in terms of lower operating costs: about two thirds the cost of a
conventional municipal waste water treatment system. Capital costs are also lower: about two
thirds the cost of conventional municipal waste water treatment system. It requires lower
energy consumption and produces lower Green House Gas (GHG) emissions.
5. Storing surface water, rainwater and treated water in a series of ponds and productive
wetlands which can then be a landscape and recreational amenity which might include fishing
ponds. This would improve the biodiversity of the area.
6. Small building footprint and scalable for any volume.
7. Associated opportunities include the possibility of supplying fish ponds and other aquaculture
and biotechnology based food and plant businesses.
8. Ecological treatment uses biological processes instead of chemicals and thus has a lower
environmental impact.
9. Doubles as an Education centre showcasing the workings of a local recycling facility using plant
based green technology.
10.Brings identity to the area as a green technology hub which could attract associated green
businesses and generate local employment opportunities.

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Figs 7-10. Precedent of Living Machine Greenhouse, Harbor Park, Budapest, Hungary serving a population
of 5000, visited September 2006. (Source DW EcoCo)

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Strategy 3. Sustainable Energy Provision
‘Climate change, energy security and competitiveness are inter-related challenges that will be
addressed through the transforming of Ireland’s economy from one based on fossil fuel
dependence to a low carbon economy based around energy efficiency, renewable energy and
smart networks.’
The National Renewable Energy Action Plan (NREAP), 2009.
Sustainable energy provision is an issue where the Kilmartin LAP lands can demonstrate strategies
which promote energy efficiency and energy conservation.
In this section, strategies are put forward for the following purposes:
 to encourage energy conservation and energy efficiency and the development of alternative
sources of renewable energy within the LAP and environs.
 to contribute to minimising effects and impacts of climate change within the LAP and environs.
We suggest that the following provisions are considered in the LAP:
 Ensure that site layout optimises passive and active solar design potential. A sufficient proportion of roofs
on residential units to face south to maximise the efficiency of the solar collectors to comply with current
Building Regulations (December 2011). Part of the Urban Design Section could include the orientation of
buildings to be in accordance with energy conservation and efficiency.
 Support the retrofitting of existing housing and buildings in the environs, in particular existing dwellings in
Tyrrelstown with a retrofit awareness programme which encourages people to make use of the Better
Energy Homes Grant scheme operated by SEAI.
 Investigate the use of commercial scale wind energy to service the LAP and its environs.
 Provide a Local Renewable Energy Centre (LREC) using biomass to service the LAP and its environs.
These steps would encourage energy conservation and efficiency and enable the decentralisation of
energy provision. Improving the energy performance of buildings and providing energy using local
wind generators and biomass obtained locally are cost-effective ways of reducing green house gas
emissions in an attempt to minimize the negative impacts of climate change. These initiatives will also
reduce reliance on imported fossil fuels and so improve energy security, while also creating local
sustainable job opportunities, particularly in the building sector.

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Energy Requirements for Dwellings in the LAP
Fingal County Council is renowned for its progressive policies with regard to the above documents
from 2005 but the Building Regulations and the Plan for Government are now sufficiently progressive
and advanced that in 2013 the last revision to Part L for energy use will be implemented. This will
require ‘nearly net zero energy use’ and there will be little need for any further increases in these
requirements. Since 2008 Part L has required that dwellings generate an amount of renewable energy
and together with increasing requirements for energy efficiency, Ireland currently has one of the most
ambitious and progressive regulations for energy use in dwellings.
Building Regulations Part L 2011 require that each dwelling generates 10KW/h of renewable heat
energy or 4 kWh/sqm/yr of renewable electricity. The most cost effective manner in which this is
achieved is through the use of 4 sqm of solar panels. Therefore the LAP must state that site layout
permits a sufficient part of roofs on residential units to face south to optimise the efficiency of the
solar collectors to comply with this Regulation.
To enhance requirements on energy conservation and efficiency each dwelling could contain the
following additional specifications:
 optimal south facing windows for passive solar gain
 high standards of insulation
 a high degree of air tightness
 a designed energy efficient ventilation system
 high performance triple glazing
 optimal south facing roof for solar collectors
 winter gardens to use passive solar heat
The above provisions encourage passive solar design, energy conservation, energy efficiency and use
of renewable energy technology. (see Appendix C for an example of a dwelling cross section
integrating high standards of energy efficiency and conservation and for a precedent in County Cork)
We suggest that there are opportunities to ensure compliance with the current Building Regulations
such as an inclusion in the LAP requiring that, together with the Commencement Notice, the
developer/owner of a new dwelling shall submit a digital copy of drawings, details, reports and
calculations of the proposed dwelling to the LAP to demonstrate compliance with current Building
Regulations.

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The Building Regulations Part L 2013 and plan for Government will require a minimum standard of
‘nearly net zero’ energy use so conventional heating systems may not be required and only a small
amount of heating energy will be demanded. (see Appendix A – Table A for a schedule for residential
energy reduction, 2005-2013)
Development Management Sustainability Matrix
For the proper and sustainable development and planning of the LAP land, we put forward that a Development
Management Sustainability Matrix5
is adopted. The Development Management Sustainability Matrix is a checklist
of different criteria involving areas such as transport, community, resource efficiency, water, waste, energy, etc.
and has been used by the Carlow-Kilkenny Energy Agency and Limerick County Council.
Within the Development Management Sustainability Matrix, energy saving from compliance with Part L
should be balanced with supporting facilities including public transport provision and the SMART
Corridor. A Sustainable Transportation Strategy could include:
 incentive based multi modal alternative travel options. For example car clubs and bike
scheme.
 public transportation run on bio-gas from a Local Renewable Energy Centre. (see overleaf)
Wind Energy
There could be possibilities for the LAP to integrate the development of an area in its environs for wind
generators. Presently the lands in the LAP environs are Acceptable in Principle for wind turbines with a
wind speed at 7.5 m/s. An anemometer, which measures wind speed and pressure, would need to be
in place for two years to verify the suitability of specific lands for wind generators. They would need to
be positioned so they are not too close to existing housing and catch the most favourable prevailing
local winds.
5
The energy saving in Part L has to be balanced with supporting facilities like good public transport provision and
the SMART Corridor. The benefits of well insulated homes can be ‘completely wiped out by car travel of more than
10km a day simply because the travel will account for a far greater proportion of carbon than that used by even a
badly insulated house.’ Refer An Taisce submission for Draft RPGGDA 2010-2022. Refer also Chapter 13 The
Sustainability Toolkit, Clonburris SDZ Planning Documents, South Dublin County Council. Refer
http://www.clonburris.ie.

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District Heating System
In response to the suggestion of the provision of a District Heating System we would question
the viability of a district heating system as the Building Regulations Part L have been revised in
2011 and will be further revised in 2013 in line with the National Plan for Government. The high
standards of energy efficiency and renewable energy for all new dwellings means the heating
demand is very low. District heating pipework is costly and in this situation the amount of heat
sold would not justify the high infrastructure costs of a district heating system.
Renewable Energy Provision for the LAP and Environs
To consolidate the Tyrrelstown/Kilmartin lands and increase connectivity within its immediate context
of Blanchardstown North, the LAP needs to address how the area weaves together issues of energy
demand, energy production and the utilitisation of energy feedback loops.
The medium term strategy for energy provision within the LAP lands and the surrounding environs
would be a proposal for a Local Renewable Energy Centre (LREC) and network. The LREC could be
developed in phases to match development.
In Blanchardstown North, there is a large area of lands surrounding the LAP which are already zoned
for enterprise, employment, office, research, high technology, and hi-tech manufacturing. The
proposed LREC could act as a catalyst to attract existing and new industries interested in operating
their businesses on renewable energy which is produced locally.
Precedent – Gussing, Austria
One example we refer to which has achieved just this is the LREC in Gussing in eastern Austria which uses
waste biomass from the surrounding forests to produce biogas, heat and power (electricity). The renewable
biogas is piped to nearby dwellings for use in boilers as this is more cost effective than district heating
pipework. The heat can be used in local greenhouses for food production and the power is sold to the grid
and used locally. By-products such as biochar are fed back into the land to enhance fertility, plant growth,
biomass production and carbon sequestration. The local renewable energy network in Gussing has acted as a
catalyst and has attracted industries interested in renewable energy and controlled energy costs. Refer
http://www.mirai-energy.info/wp-content/uploads/03-Press-Information-EEE_English.pdf

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This LREC could be operated on the basis of distributed generation, i.e. the plant would work in
tandem with the national grids of electricity and gas. Based on this principle of distributed generation,
individual solar panels to each dwelling could form part of this network providing renewable energy
back to the grid.
In the context of Blanchardstown North and the LAP, the LREC would work on the basis of energy
derived from biomass waste using a pyrolysis conversion system. The process would produce
electricity (power), heat, bio-gas and bio-oil. (see Appendix A –Table B for a summary of outputs from
a pyrolysis system)
Heat from the process could be used locally, for example in greenhouses for food production, and
power can be sold to the grid and/or used locally. The bio-gas can be piped locally for use in dwellings
(as in Gussing, Austria) and/or used for transportation. By-products from pyrolysis such as biochar
can be returned to the soil to increase soil fertility and carbon sequestration.
Local precedent - Keelings Farm, Fingal County
A local precedent is Keelings to the north of the Airport within 5 kms of LAP lands which has green houses for
food production utilizing renewable energy (see Fig 2 for location). Keelings operate a summertime market stall
near the Airport Road and has attracted related businesses. The operation of Keelings reinforces and supports the
tradition of food production in Fingal which is unique to this area.
Local biomass sources can be supplemented with wood chips from the biomass waste of forestry
management if the forest is within a reasonable distance. The LREC would require biomass storage
facilities and suitable vehicle delivery facilities which would be incorporated into the lands west of the
Tyrrelstown/Kilmartin area. The existing and planned road infrastructure would facilitate the
transportation of the biomass wood chips.
The advantages of a LREC using biomass for renewable energy over provision of energy from a distant
fossil fuel power station are listed below:
1. fosters economic competitiveness by providing locally produced renewable energy.
2. strengthens the concept of the area as a ‘green hub’.
3. provides a localised supply that connects to the national grid. Supports the national plans for
a SMART grid with distributed generation.
4. reduces transmission losses and therefore reduces production of greenhouse gases.
5. creates system linkages between residential and non residential uses.

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6. connects renewable energy production with agriculture and food production as it can use
waste biomass from agriculture and urban areas. This encourages green enterprises which
aligns with other local enterprises, so supporting Fingal’s long history of food production.
7. enables the provision of greenhouses to support more local food production, create new jobs
and markets, enhance food security and supply to the area, thereby reducing the
environmental footprint of food consumption locally.
8. contributes to compliance with the Landfill Directive which requires significant reductions in
the rate of bio-degradable waste going to landfill. The target for 2013 is 50% of the quantity
generated in 1995 (644,956 tonnes).
Precedents
For examples of local energy networks using renewable energy refer to:
 Woking Borough Council, UK: serving a population of 87,000 and providing renewable energy
with solar photovoltaic systems, CHP and fuel cell trigeneration and district heating. The
Council also has a retrofit programme for housing and won the Queen’s Award for Enterprise
2001. (refer Case Study on Woking Borough Council – Renewable Energy Network
http://www.carbon-innovation.com/discussion/viewtopic.php?t=532)
 Dundalk 2020, Ireland - sustainable energy zone (SEZ), targets to achieve 20% renewable
heat, 20% renewable electricity and 40% energy efficiency in selected buildings. (refer
http://www.seai.ie/SEC/The-Communities/Dundalk_2020/)
 Dynamotive Ltd, Ontario, Canada: a pyrolysis plant providing heat, power, bio-oil and biochar
to local businesses which has realised a payback of under 2 years on the initial capital
investment. (refer http://www.dynamotive.com/about/)

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Strategy 4. Food Production
Addressing the environmental impacts of the globalised food system is key. Much can be learnt from
recent history. For example the vegetable needs of Paris and London at the beginning of the 20th
century were met in peripheral lands, and Dublin has had a similar relationship with North County
Dublin.
The current situation of the food industry
The food industry is under increasing pressure from energy costs and climate change, for
example in terms of:
- extreme weather events and patterns
- demand for biofuel crops diverting land use away from food production
- the price of fertilizers and pesticides manufactured from petroleum products
- increasing demand for red meat and cotton due to rising affluence
- ineffectiveness of land reform acts in many countries
- low profit margins making farming unviable
- running up against renewable resource limits
- water scarcity (Holmgren, 2009)
Providing land for urban agriculture is increasingly recognised as an important planning policy option.
We suggest that the LAP is not seen as a discrete isolated community relying completely on food
provision from external fossil fuel dependant sources but as an integrated community which supports
local supply. We include the following objectives:
 Identify land in urban/suburban areas suitable for the development of allotments, Community
Supported Agriculture (CSA) and to promote the production of local food.
 Develop and promote, in conjunction with the VEC and other bodies, training courses in the
start up, use and management of allotments, urban gardens and communal spaces for food,
fruit and vegetable production.
 Initiate, in conjunction with An Taisce and other interested organizations, a schools fruit and
vegetable awareness programme with funding, training and support structure provided for
schools to develop food growing, allotments, raised beds and forest gardens within school
grounds or on adjacent land.

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The success of such guidelines would be measured against set targets for food production and the
carbon footprint of food uses within the region, as well as measuring the elimination from the waste
stream of all biomass waste as required under EU Directives on diversion of organic waste from landfill
and the re-use of this waste for locally distributed compost.
These objectives could be met in the following ways:
 Allotments located along the SMART Corridor.
 Investigation of viability for development within the LAP and environs of Community Supported
Agriculture (CSA) scheme that draws on lessons learnt from the Cloughjordan CSA in County Tipperary.
 Integration of permaculture principles of designing for sustainability, for example through urban
agriculture, into the planning of development within the LAP. (see Appendix D for a precedent in the UK)
 Winter gardens in dwellings. (see Appendix C for a precedent in County Cork)
Precedent in Ireland – Cloughjordan
The Cloughjordan Community farm in County Tipperary uses the CSA technique, where farm members (local
residents) commit to pay a weekly amount to a farmer, who is guaranteed a wage. The members then receive a
supply of produce in return. Growers and consumers support one another, sharing risks and benefits of food
production, and creating local employment and food security. Cloughjordan also has allotments leading to the
creation of an overall productive landscape. (refer www.thevillage.ie)
The strategies set out in this submission show compliance with the following documents:
1. EU Directive 2004/18/EC on Green Public Procurement, March 2004
2. EU Landfill Directive 1999/31/EC, April 1999
3. EU Directive 2010/31/EU on Energy Performance of Buildings, May 2010
4. The National Renewable Energy Action Plan (NREAP), 2009
5. Delivering a sustainable energy future for Ireland – The Energy Policy Framework, 2007-2020
6. National Climate Change Strategy, 2007
7. Sustainable Development Strategy, 2006
8. Regional Planning Guidelines for the Greater Dublin Area (RPGGDA), 2010-2022
9. Greater Dublin Strategic Drainage Study (GDSDS) Final Strategy Report , April 2005
10. Fingal Development Plan (FDP), 2011-2017
11. Building Regulations for New Dwellings Part L, December 2011

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Appendices
Appendix A –Tables A and B
Table A - Schedule for Residential Energy Reduction via Part L
of the Building Regulations
Year Reduction from benchmark
2005 Benchmark for energy use standards in Part L
2008 40% less energy than a house built in 2005
plus either 10 kWh/m2/yr of renewable heat energy
or 4 kWh/m2/yr of renewable electricity
(implemented December 2011)
plus the renewable energy requirement as 2008
With the renewable energy requirement this is the
‘Nearly Net Zero Energy’ target
Table B – Summary of outputs of a Pyrolysis System for Biomass
Renewable Energy
 produces bio-gas for a CHP system which generates green
electricity and heat
 produces bio-oil which is a transportable form of energy
 produces heat to be used for commercial activities including
heat for year round greenhouse food production
 creates biochar for use as a soil conditioner and substitute
for synthetic fertilisers
 produces carbon footprint credits

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Appendix B - Precedent for the Living Machine, Harbor Park, Budapest, Hungary (refer http://www.o-sw.com/wp-
content/uploads/2011/11/organica-casestudy-harborpark-lores_OSW.pdf)

Appendix C – Example of a dwelling cross section integrating high standards of energy efficiency and
conservation (Source: MCO Projects)

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Photographs showing sun spaces which can be used as winter gardens, Baile Glas Housing, County Cork (Source MCO
Projects)

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Appendix D – Precedent of Urban Agriculture in Brixton , London, UK (refer http://www.rudi.net/node/20705)

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Appendix E – Photograph of an example of a SMART Corridor in Alameda,
Bogota, Columbia – part of 11 mile green network including pedestrian and cycleways
linking adjacent communities and successfully encouraging social affiliations.

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Appendix F - Location Map showing proximity to other complementary regional settlements
and proximity to transport infrastructure including N2/N3 link, Dublin-Sligo Railway Line, Dublin
Airport, Dublin City and Dublin Port

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