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Riversdale House,

Athenry,

County Galway.

Date:  Friday, 14 January, 2022.

Re.  Reference No: 21/2281, Galway County Council PA. Ghost Zapper Ltd.

Abbrevations and TERMS used in this submission:

ABP – An Bord Pleanála.

gfa – gross floor area (M2).     nrfa – net retail floor area(M2).

p3/15 – page 3 of a 15 page document.

PA – (Galway County Council) Planning Authority.

LA – Local Authority (Galway Co Co)      DoTCAGS&M – Dept. of Tourism, Culture, Arts,

GAA – Gaelic Athletic Association.                                   Gaeltacht, Sport and Media.

CEMP report – Construction Environmental Management Plan.

PDF Doc – Documents on the Galway County Council planning website, and relevant to Planning Reference 21/2281, unless otherwise stated. E.G. PDF 5.746Mb  ‘Application Form – Part A’, 13 pages;  20/1384 PDF: 0.176Mb.

A Chara,

I wish to make the following two points by way of introduction to the principal body of my submission to PA 21/2281 – Ghost Zapper Ltd. :

1. Swandive Ltd. has planning permission since October, 2015 (PA 15/356; ABP 07.245198; PA 20/41= retention) for a substantial 1,379 m2(nrfa) single storey discount retail store on the former Arrabawn Co Op site (0.66 hectare) which is currently accessed at Clarke street. A ‘Brownfield’ site, it is zoned ‘C1’ – Town Centre/Commercial.  What is occupying the minds of many within the town and the broader catchment area is: why this Aldi discount store didn’t open its doors four years ago?  Apart from a submission from An Taisce to 15/356, NOBODY from 20/1384 made a submission to 15/356.

2. Similarly, in February 2015, a 1.08 hectare site at Church Street applied for planning permission (PA 15/149; ABP 07.244999) for a single storey discount  foodstore (nrfa: 1.743m2).  The PA granted permission in May 2015 with fifteen conditions attached.  It was subsequently appealed to ABP by RGDATA only and ABP issued a decision to refuse based on two reasons (PA 15/149 – PDF 0.028Mb = 2 pages).  Many townspeople considered this a major setback for the town as it was, generally, well received locally by interest groups and the business community.  Apart from two individuals (one for and one against) NOBODY else from 20/1384 made a submission to 15/149.  There were nine eventual submissions to 15/149 – six in favour and three against.

ATHENRY HOUSE SITE – 21/2281

NOTE: Not a single piece of the subject site of 21/2281 falls within the zoning matrix ‘C1’

as claimed by MKO Consultants in PDF Doc 19.516Mb. See p.6 in this submission.

The current site at Athenry House is a wholly different scenario to either of the aforementioned sites for a number of reasons, namely:

·       It is a substantially bigger site – 3.24 hectares (21/2281 – PDF 5.746Mb, p3/15).

·       It has a significant commercial element with a substantial residential mix.

·       It was the subject of a major excavation in 2007 and, as yet, an  unpublished archaeological report.

·       It is a ‘greenfield’ site.  The frenzied removal of topsoil in May, 2008 to Doughiska, Galway does not render it a ‘brownfield’ site, a term used by Ghost Zapper Ltd repeatedly throughout 21/2281.

·       It contains two extant (one protected) recorded structures namely Athenry House (RSP 131) with its attendant ashlar cut stone outhouse/stables and, a Dovecote.

·       The southern section of the subject site is adjacent to Athenry Town Wall, 81.45m, a National Monument in state care (GA084-001021-).

·       It is within the area designated as a Heritage Town.  It should be noted here that Aldi GmbH – PA: 15/356, are making a massive effort to incorporate their building into the existing medieval fabric of the town.

·       In the context of medieval walled towns, the site at 21/2281 is part of a unique setting which does not appear to be built upon in any significant manner during the post-medieval period.  The excavation report!

·       There is not a single medieval walled town in Ireland, the UK or Europe where such an unique situation occurs.

·       This site is what makes Athenry Town unique among any other medieval walled towns and, of international importance as a ‘Heritage Town’.

Therefore, it is incumbent upon the guardians of this town (those of us with ancestral links and those who have choosen to make Athenry their home) to insist that any development that takes place on this site reflects the status this once great town had in the medieval period.  It was a major ecclesiastical centre of learning with university status . It was an important Anglo-Norman settlement route with, originally wooden and then stone turreted and a moated wall defence and, finally, one of the finest examples in Ireland of a castle (not a fortified tower house) – the ultimate signature of wealth, status and prestige at that time.

In view of the points above, the large discount superstore ( gfa: 2.157m2)  is grotesquely inappropriate in the context of this site in terms of its statement of intent, aesthetics and, in particular, the amount of vehicular traffic it will create within the site in general and, more specifically, at the junction with Swangate.  No amount of traffic reports (PDF 4.972Mb; PDF 25.643Mb = 321pages and not a single mention/report on Kenny Park match day traffic) can hide the fact that the Swangate junction can’t handle this volumn of vehicular traffic.  It will become a major bottle neck and a potential hazard to road users and pedestrians alike, particularly during the  construction phase.  It will not work.  It’s a no-brainer.  Surely, there are dozens of alternative near-town sites more appropriate to this type of large discount superstore with potential underground car-parking and the correct amount of surface parking spaces available.  Its ‘statement of intent’, I would suggest, is that during the construction phase it will necessitate another entrance/exit to the site. This planning application 21/2281 is premature pending Ghost Zappers inclusion of its Cross Street plans for vehicular access through an existing car-park to the north of the Athenry House site.  The residents of Clarke Street and Cross Street have a right to know if it will be a permanent fixture and what are the plans for the site formerly known as “Dennison’s scrap-yard”.  Presently, it is a vacant car-park.

PDF: 11.810Mb, p.89/123 – ‘Description of the Proposed Development’ – Site Location .  MKO – Planning and Environmental Consultants.

QUOTE: “The application site can be accessed via Swan Gate to the north-west corner of the       site and Cross Street through an existing carpark to the north. Athenry Town Centre is situated to the north and north west of the subject site”.

PDF: 9.836Mb, p.5/22 – ‘Design Statement’  CCH Architects.

QUOTE: “The site is currently accessed from one location to the west, opposite the Swan Gate car park road.” (My emphasis).

PDF: 20.041 Mb, p.7/51 – ‘SITE AND PROJECT DETAILS’ – Site Location and

Development Description  (The CEMP report) MKO.

QUOTE:  “The proposed development site is located on lands in Athenry, Co. Galway (Grid Ref: M50264 27567), adjacent to the existing town centre. The site is surrounded by the historic Athenry stone walls and contains the ruins of Athenry house (a protected structure) as well as an adjacent unoccupied coachhouse/mews. The Clarin river flows along the eastern development site boundary. The application can be accessed via Swan Gate to the north-west corner of the site and Cross Street through an existing carpark to the north.” (my emphasis). “Athenry town centre is situated to the north and north-west of the proposed site, and Kenny Park GAA pitch is situated to the immediate west of the site.”

PDF: 20.041Mb, p.10/51 – 2.3.3  ‘Site Establishment’

QUOTE: “The site will be accessed from the via(sic) Swan Gate to the north-west corner of the site and Cross Street through an existing carpark to the north”.

The Traffic and Transportation Assessment report:

The ‘Traffic and Transportation Assessment’ report containing 321 pages (25.643Mb) by Tobin Consulting Engineers is an embarrassing attempt to defend this junction at Swangate.  It is clear to all locals that it won’t work. There is not a single report in the assessment referencing the traffic mayhem that will occur during a major gaelic game at Kenny Park.  I doubt there are many GAA grounds in Bexley, Somerset, Cambridgeshire, Durham, Cardiff City, Aberdeen, Perth & Kinross or Sterling that could create the same problem!

Residential and Cafè design

Apart from a reduction in the density of residential properties on site, due in part to restrictions on height and one(?) primary vehicular access, Ghost Zapper has made little effort to incorporate the design element in to the existing fabric of the town.  In fact Ghost Zapper blatantly ignores the advice of the DoTCAGS&M (20/1384 PDF: 0.138Mb; PDF: 0.176Mb) and The Heritage Council ( 20/1384 PDF: 0.068Mb ) in regard to Block 12 where it was made abundantly clear that a three storey building was not acceptable in such close proximity to the National Monument. The road servicing ‘block 12’ comes within c. 20m of the town wall.

Where in the town is there a streetscape that has a two-storey dormer at the beginning and end of each street?  It is ugly and, I believe it is an attempt to have all the houses two storey dormers or three storey dwellings. Also, why are all these houses not fitted with solar panelling? This should not be a condition of planning! It should be part of the current application before the Planning Authority.

Some of us with long memories of the planning history of this site will recall an  attempt by a previous developer to alter significantly (PA 07/3703; ABP PL 07.227445) the agreed plans of an earlier An Bord Pleanàla decision (PL 07.214418).  A much admired and unbroken linear landscape feature running from the proposed Athenry House Hotel to the eastern mural tower on the town wall was obstructed to facilitate the inclusion of a larger supermarket.

No effort was made to create a café that would make a big architectural design statement out of the ordinary and mundane. Instead, pluck it out of a design book from Brooklyn, Picadily or Southend and stick it in there. It’ll be alright!

A BRIEF ZONING OVERVIEW OF THE SUBJECT SITE:

Back in the early 1990s when the subject site and adjoining lands were zoned from  Agriculture/Amenity,Open Space to residential/Commercial and, presently(Athenry Local Area Plan {LAP} – 2012-2022) to Residential (phase 1 & 2) = Riversdale House and Commercial/Mixed Use (C2)= Athenry House, quite  a number of people, including myself, were disappointed that these lands were not kept as amenity, open space/agriculture and, sometime in the future, if the opportunity presents itself, as a park for residents and visitors to enjoy.  Sadly, this pipe-dream appears to have passed and these lands are determined by some to be developed in time.

However, an opportunity will arise in 2022 when the citizens of this town will be given an opportunity to decide the zoning destiny of these lands once again, rather than ‘gift’ them to persons who may be domiciled outside this country for whatever reasons?

NOTE:  MKO Planning and Environmental Consultants (PDF 19.516Mb, p.16/51) state that “a

small part of the westernmost edge of the site falls within ‘C1 Town Centre/Commercial’

zoning”. This is incorrect. The 42m2 wedge of land in question belongs to

LA 17/05 – the Local Authority carpark at Swangate.  MKO further states that ” ‘Also

a small part of the south-eastern corner falls within ‘OS Open Spaces/Recreation

& Amenity’.” Again, not true. This is the 30m ‘no’ development ‘buffer zone’ in place

to protect the national monument which, incidentally, Ghost Zapper Ltd have choosen

to ignore close to the ‘site of’ the Spittal Gate. The buffer zone is independent of the

zoning matrix. It’s a ‘no’ development area specific to one feature ONLY – to protect

the  town wall – a National Monument, both inside and out.  The present owner

of Riversdale House has respected this through the years (since 1951) and has asked

repeatedly the DoEHLG (now DoTCAGS&M) and Galway County Council to remove

the ugly concrete insertion created by a previous owner of Riversdale House in the

late 1940’s. The original stones are still there, neatly and carefully stacked.

The Adjacent Coach House to Athenry House

While the ‘Archaeological Impact Assessment’ (PDF:6.458Mb – ‘Archaeology Report’) and the ‘Architectural Heritage Impact Assessment’ (PDF: 5.783Mb – ‘Conservation Report’) both refer to part of this building being removed in the past, it still retains a close relationship to Athenry House and, most definitely does not merit demolition. It appears to be a very late questionable planning decision by Ghost Zapper as the coach house is included in the following:

PDF: 15.694Mb, p.62/162 – ‘Ecological Impact Assessment’  MKO Consultants.

QUOTE: “Stable Building : The stable building is proposed to be retained.”

PDF: 9.836Mb, p.16/22 – ‘Design Statement’  CCH Architects.

4.6.5 Athenry House

QUOTE: “Athenry House and its adjacent stable building remain the only aspect of the

proposed development, principally late 18th century, with variations dating from

the 19th century. The proposal, developed in close consultation with John Cronin &

Associates Heritage Consultants, aims to convert the house to community use. The

proposals will seek to retain the essential historic character and features of the

existing buildings”.

Worryingly however, in the important CEMP report, it would appear that Athenry House is not all that ‘stable’ and may also make contact with the wrecking ball:

PDF: 20.041Mb, – ‘Construction Environmental Management Plan’   MKO.

2.3.5 Demolition Activities

QUOTE: “The existing site contains the ruins of Athenry house. The demolition phase of the

proposed development will involve the removal of this structure within the site. The

sequencing of the demolition works will be decided by the main contractor following

detailed site survey of the buildings and surrounding area. Such a survey will provide

detail on the :

·       The condition of the building and demolition methods recommended.”

A SHORT NOTE ON THE CEMP REPORT

The ‘CEMP’ report is the go-to-document FOR ALL DEVELOPMENT PRINCIPLES relating to this specific site during the pre-commencement, construction (two phases), completion, deliverance and informing the post-deliverance mitigating issues into the future. In this planning application it is a 51 page internet PDF document, identified as follows:

PDF:  20.041Mb,  ‘Construction Environmental Management Plan’.   The CEMP report for Ghost Zapper Ltd by MKO Consultants

p5/51 – QUOTE: “The CEMP provides the environmental management framework to

be adhered to during the precommencement and construction

phases of the development and it incorporates the mitigating

principles to ensure that the work is carried out in a way that

minimises the potential for any environmental impacts to occur.

This CEMP identifies the key planning and environmental

consideration that must be adhered to and delivered during site

construction”.

p6/51 – QUOTE:  “The report is presented as a guidance document for the management

of construction activities and waste materials generated during the

works and following completion”.

There are a number of other issues with this planning application that concern me greatly and should not be treated as ‘conditions of planning’:

·       No reference to an independent qualified and licenced Archaeologist  on site, OR two, to supervise the ground works!

·       No detail of the pedestrian walkway along the Clarin river bank!

·       No intrusive development should take place inside the 30m buffer zone by the developer. This is breached in the south. As a precedent this cannot be allowed to happen.

·       A ‘site compound’ is alluded to but apart from being 50m from the river bank there is no other detail of its location. Its precise location and activities need to be established.

The inspector who ultimately has to adjudicate upon this planning application and decide on the built aspect of this development has the onerous task of satisfying the following:

1.    Is the residential/commercial design element of this planning application a complementary 21st Century expression of the existing built element within the town and how do these buildings reflect the anthropogenic-induced climatic warming that is presently upon us: a truly 21st century phenomenon vis-a-vis solar panels, EV points and bicycle stands?

2.    Could this development be presented to an architectural symposium as an example of the best possible methods in modern 21st century urban design?

3.    People visiting the town especially to view the exciting new development that has won numerous design awards!  This is what we should strive for.

4.    Will this development contribute significantly to the already local flooding problem experienced within the town and surrounding   hinterland over the past twenty-five years and, rainfall models are predicting an increase in extreme rainfall events and shorter return periods? (‘Ireland’s Climate: the road ahead’ – Summary, p.8 ; Ch. 5 ‘Climate change: impacts on Irish temperatures’, p.33 ; Ch.9 ‘Impacts of climate change on Irish precipitation’ p.57 ; Ch. 10, ‘Climate change and catchment hydrology’, p.63. Met Éireann, Dublin 2013).

5.    What constitutes the architectural character of Athenry House as a protected structure?

Finally, I had great difficulty accessing this large and important planning application online. It was received by the Planning Office on or before 2nd December.  It was not available to view online until 17th December. It was not possible to view the hard copy at the planning office despite numerous visits in person. It gave just over two weeks effectively to digest c. 1,100 pages.

I conclude my submission with the following ‘Concluding Statement’ from the 123 page ‘Natura Impact Statement’ (NIS) submitted by MKO Consultants:

PDF: 11.810Mb, p.116/123:  in relation to the ‘Clarinbridge River’, classed in  this Natura report as “an eroding upland river”.

QUOTE:

“It cannot be excluded beyond reasonable scientific doubt, in view of best scientific know-

ledge, on the basis of objective information and in light of the conservation objectives of

the relevant European sites, that the proposed development individually or in combination

with other plans and projects, would be likely to have a significant effect on Galway Bay

complex SAC (000268) and Inner Galway Bay SPA (004031). As a result an Appropriate

Assessment is required, and a Natura Impact Statement shall be prepared in respect of

the proposed development.”   (My emphasis).

Site Notice – 30/11/2021 :  “A Natura Impact Statement (NIS) has been prepared and will be submitted to the Planning Authority with the application.”  (My emphasis).

It would appear from the above that the Natura Impact Statement (NIS) has not yet been received by the Planning Authority and, when it is, it will be written by Sir Humphrey from the BBC2 television comedy ‘Yes Minister’.

Yours sincerely,

_____________________.

Dominic Monaghan.

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Written by Dominic Monaghan

Published here 13 Jul 2023 and originally published 14.01.2022

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