Bartra Property appeal DLR planning refusal

Bartra Property group has appealed the refusal of their planning application by Dun Laoghaire Rathdown County Council planners.

The Irish system is that appeals to planning refusals are made to An Bord Pleanala – and the reference number for the appeal is ABP-301237-18.  The county council will make the content of the Bartra appeal publicly available.

Individuals and organisations who made observations on the planning application earlier this year may make observations on the appeal.  The cost of doing so is an unequivocal €50.  More information re how to “observe” will be published on this website and on our Save Bulloch Harbour Facebook page.

Planning permission refused

The recent planning application by Bartra Property group for the site adjacent to Bulloch Harbour was rejected by Dun Laoghaire Rathdown planners on 22 February 2018.

The decision came a mere two and a half weeks after the closing date for “observations”.  Around 270 observations were submitted by local people, user groups, community organisations, politicians, statutory bodies and interest groups.  Bulloch Harbour Preservation Association, which led the campaign against the planning application, would like to thank the hundreds of supporters who contributed to the right decision being made.  “This is great news.  We are very relieved but acknowledge that this is only the latest skirmish in what may be a long war” said an association spokesman. ”  The developer has four weeks to lodge an appeal with An Bord Pleanala, should they decide to do so.

The council’s reasons for turning down the application were emphatic:

“In relation to the significant imbalance and predominance of residential use in the proposal and having regard to the low percentage of overall floor area being provided for the marine related uses together with the low developable site area being provided to support and service such uses, it is considered that insufficient provision has been made for waterfront, harbour and marine related uses. It is considered that the amount of site area reserved for residential use is excessive and seriously compromises the achievement of a quality mixed use and integrated development with adequate and appropriate provision for waterfront, marine and harbour related activities. It is therefore considered that the development as proposed would seriously compromise the harbour’s ability to attract and maintain good marine related uses and harbour activities, would limit the scale and diversity of such uses, which the harbour could support and would be contrary to the ‘W’ zoning objective for this site which is ‘to provide for waterfront development and harbour related uses’. The Planning Authority therefore considers that the development as proposed would be contrary to the zoning objective for this location of providing for waterfront development and marine related uses and would also be contrary to the requirements of Specific Local Objective 22 as set out in the 2016 – 2022 Dun Laoghaire -Rathdown County Development Plan. The proposed development would therefore be contrary to the proper planning and sustainable development of this area. 2. It is considered that the lack of an integrated design approach and the almost exclusive use of the majority of the site area for residential use would seriously erode and weaken the existing ‘W’ land use zoning objective for the site of providing for waterfront, marine and harbour related uses. This would undermine the existing land use zoning objective for this site and would seriously compromise the harbour’s ability to attract and maintain good marine related uses. It would also limit the scale and diversity of uses, which the harbour could support and would be contrary to the zoning objective for this site which is to provide for waterfront development and harbour related uses. The proposed development would therefore be contrary to the proper planning and sustainable development of this area. 3. Given the prominent harbour and coastal location of the proposed development and taking into account the special character of the immediate harbour area, concerns exist that the proposed quayside elements are visually and physically segregated from the rear of the development site with no meaningful integration, visually or functionally. The proposed development fails therefore to respond appropriately to the unique site context, which requires a high quality, distinctive and integrated mixed use design approach, which considers the site holistically and responds appropriately to the special character of the area and seeks to strengthen and reinforce a positive sense of place at this location. The proposed development would therefore be seriously injurious to the special character and amenities of the harbour area and contrary to the requirements of Specific Local Objective 22 as set out in the 2016 – 2022 Dun Laoghaire -Rathdown County Development Plan. The proposed development would therefore be contrary to the proper planning and sustainable development of this area. NOTE: The applicant is advised that the Council’s Drainage Planning report in respect of this application highlights significant coastal flooding issues at this location. The report recommends a refusal of permission for the two apartments proposed within the quayside block and recommends seeking further information with respect to flood defence measures for the other elements of the development.”


5 February 2018 deadline for Bullock planning objections

“It’s a numbers game” was the political opinion at our public meeting on Tuesday 23 January 2018.  If you find the buildings in this planning application objectionable, then it is important that you lodge an objection with the planning authority.  It is by far the most important act of citizenship open to you in this situation and the only one that the decision makers among Dun Laoghaire Rathdown planners are required to take into account.

We’ve posted how-to guidance on lodging your “observation” here.   You can lodge your observation on line: some words of explanation are here.  Further advice on lodging observations are here.

Thank you for your support. 

Bulloch Dev v3 red


 SUBMISSION DEADLINE: Monday 5th February – 16.00hrs

The only way to influence the Planners’ decision is by personally submitting your own ‘Observation’ or objection.  Our Councillors do not have any direct function in this process.  Last year the large number of Observations lodged made a significant impact, and we ask you to act again now.  When making your observation to the Planning Department –

  • Quote Ref: D17A/1135 –Former Western Marine Site, Bullock Harbour.
  • Include your Name and Address
  • Include the fee of €20 – cheques payable to DLRCC / or Credit Card
  • Add your observation details

Observations may be posted or delivered to the Planning Department, Dun Laoghaire-Rathdown County Council, County Hall, Marine Rd, Dun Laoghaire.  Planning Office public hours: 10.00 – 16.00 weekdays (open through lunchtime).  This may also be done online.  Click on “Search for a planning application” on their website and follow the links.  You will first be asked to Register on their website.


Please frame these points in your own words in your observation:

  • Bulloch Harbour is an area of huge significance, historically and culturally, and is an important part of the heritage of Dalkey.
  • The site is prone to the hazards of wave over-topping i.e. inundation by huge waves and waterborne debris in north-easterly storms, and flooding caused by drainage problems particularly at high spring tides. It is therefore totally unsuitable for residential development.
  • The scale and mass of the proposal for 3 large detached houses and 2 large apartments in addition to the essential marine units is excessive on the site.
  • The height of the three-storey quayside apartments is excessive compared to the adjacent streetscape of single storey cottages and houses. They are closer to the quayside than the previous plan, dominating the view of the bay looking along the quay from the slipway.
  • The three detached houses are excessive in area, height and massing and are not in harmony with the surrounding architecture and coastal landscape and seascape.
  • The proposed high-end residential development will be in conflict with the marine activity of a working harbour and public access to the coastal rocks beyond.
  • There are further concerns regarding parking, access, traffic, drainage, etc.
  • Please include any other points of your own.

Please note that there is no separate application only for demolition and clearance of the site on this occasion.


How to make an effective objection to a planning application (1)

This Irish Times article from 2006 on how to make an effective objection to a planning application is still good advice.  Note the importance of making your observation before the deadline.  Also note that when making an observation on the current (January 2018) planning application for Bulloch Harbour:

  • Include the county council’s reference number D17A/1135.
  • Be specific in stating the applicant (Bartra Property (Dublin) Ltd) and the site name (Former Western Marine Building, Bullock Harbour, Dalkey).  Outline of the planning application is here
  • You must include your name and address in your observation.
  • Even if you provide a handwritten letter, this will be scanned in and posted to the DLR planning website, i.e. it is a publicly available document.
  • The deadline for making observations on the latest planning application for the Western Marine site is 4pm on Monday 5th February 2018.  You can submit on line, by post or in person at the public planning counter in the Dun Laoghaire Rathdown Town Hall on Marine Road in Dun Laoghaire which is open 10 am to 4 pm Mondays to Fridays.
  • You will have to pay €20 to make an observation.  This is a standard charge.  If you decide to club together with friends or neighbours and submit a joint observation, this will be treated as a single submission.

Information on what constitute valid planning objections – and therefore what you could include in your observation – will feature in our next post.

How to make “an observation” on a planning application online

The closing date is Monday 5th February 2018 at 4 pm for “observations” (be they positive, negative or otherwise) to Dun Laoghaire Rathdown County Council on the Bartra Property planning application for the West Marine site, adjacent to Bullock Harbour.  It is possible to lodge an observation online.  To avail of the online system you have to register.  There is a fee payable of €20 whether your observation is made online or at the planning counter.  The Planning Reference Number is D17A/1135.  Remember that your observation is publicly lodged and available for the public to read.

If you are uncertain re how to phrase or what to include in your observation that is valid in planning terms, then come along to our public meeting on Tuesday 23 January 2018 at 7.30 pm at the Royal Marine Hotel, Dun Laoghaire.  And/or keep watching this site and our Facebook group Save Bulloch Harbour for advice.

If intending to make an observation on line, our advice is not to leave it right until the last minute.  At the time of the first Bartra Planning application in 2017, the DLR systems seized up on the last day with the volume of traffic.  They did extend the deadline (I think) but better to allow a day or two as a safety margin.

To see the detail of the planning application online: Go to the DLRCC website (link above) and under Planning Application Online Search, click for Search for a Planning Application and enter the reference number.  So far this is straightforward.  The next steps are less obvious:  At the bottom of the page click Search.  On the next screen click the Reference number in red type.  At the bottom of the Application Details, click the tab marked Documents [0] and then click View Documents in red font. The application, with drawings, and the “pre-planning” discussion details are then available to open as well as any observations already submitted.

Seeing red…

Bartra Property’s proposals for the Bullock Harbour site are now taller and more intrusive even than before. We have inked in their misleadingly bland drawings (you know, the ones where the buildings at the back merge with the fluffy white clouds so you can’t really see them) to show the scale and height of the proposed apartments and houses. And we have supplied a current photo of Western Marine for comparison.

Overtopping – the big wave problem

Overtopping.  This is surely the biggest problem facing any development at Bulloch.  The point about this rather muddy photo is that it represents bad weather at Bulloch but by no means the worst weather. 

The building with blue tarpaulin that you see to the left of the photo is the back roof of Western Marine – just the place where three massive, tall houses are proposed to be built.  The rocks are part of the agglomeration of the Bulloch rocks.  What happens with overtopping is that the submerged rock formations at this point of Dublin bay, a north east wind and a high tide combine to create huge waves that crash over the Bulloch rocks.  The effect has been to deluge the land behind the rocks (gardens, backyards, Western marine) with huge quantities of water and projectiles.  In less bad weather, as per the image above, the “spray” has been intense with significant volumes of water.   Our video shows one moderately bad incident in 2017.  The Western Marine structure is fairly bunker-like: would you build a much taller, heavily glazed house here?  What damage will happen to these structures and especially to the roof gardens and lift housings?

On our stretch of coast overtopping happens only at Bulloch.  Despite being an internationally recognised coastal phenomenon, it does not appear to have attracted attention here, probably because it is a very local and unpredictable phenomenon.  Certainly, it appears to have escaped the notice of the public bodies (e.g. OPW, DLR county council) who need to know and understand its impact.

Bartra’s planning application – the ever present element that’s too big and too intrusive

One element of Bartra’s development proposals never changes.  Whether they are presenting interim proposals, or having pre-planning meetings with county council planners, or submitting planning applications, they always include three huge houses to the rear of the Western Marine site. Sometimes these houses have been circular but more usually – and in both planning applications –  they are cuboid blocks.

We have included below our mock up from the first planning application as it is the only illustration that we have seen that accurately represents the impact of these houses.  The developer’s own visuals in the first application pretty well ignored them entirely.  In the current application, they are shown hazily in white, merging with fluffy clouds, so that their impact is dampened down.  The three cube shaped houses are crowded together to the rear of the site each comprising 412 sq m (4465 sq ft) of floor space over three storeys plus structures above each house for lift and stairs access to the roof terrace.  These houses appear to be now a metre higher than the previous proposal, that is taller than the adjacent county council pumping station, with a further 1.6 m (5.25 ft) access structure projecting above.

We believe that the proposed  buildings are too large and too intrusive for this sensitive location.  As we pointed out in our “observation” to the first planning application these will present as a single block and will obliterate the view to the Bulloch rocks and dominate the site.

bulloch blocks 3 copy

Initial examination of planning application

Bulloch Harbour Preservation Association:  statement on the Bartra Property Group’s Planning Application for former Western Marine site.

On Friday 22 December 2017 Bartra Property Group lodged a planning application, their second, for the former Western Marine site at Bullock Harbour.   The planning committee of Bulloch Harbour Preservation Association has made an initial examination of this application and have reached the following preliminary conclusions:

We were mindful of the first application last year and the Planner’s Report on the Refusal in February 2017, and find that many worrying features are still present – some almost unchanged –  in this new proposal for the site.

  1. The proposal plans still include buildings that we believe to be too large and too intrusive for this sensitive location. It includes (again) the cube shaped houses crowded together to the rear of the site, each comprising 412 sq m (4465 sq ft) of floor space, of three storeys plus structures above each house for lift and stairs access to the roof terrace.  These houses appear to be now a metre higher than the previous proposal, that is taller than the adjacent county council pumping station, with a further 1.6 m (5.25 ft) access structure projecting above.   The proposed quayside development will comprise a three storey building at the end of the quay with pitched roofs, to house a café and retail unit on the ground floor and two apartments each of 160 sq m (1722 sq ft) on the first and second floors, plus a craft boat workshop of 416 sq m (4478 sq ft) and a small single storey structure for community use,.   The three storey building would be two metres taller than the previous proposal and twice as high as the existing Western Marine grey and white quayside wall.  This building also extends 3.7 m (12 ft) closer to the edge of the quay than existing structures.
  2. The question of flooding and risks of over-topping are still not adequately addressed.
  3. Much is made in the developer’s proposal and attendant publicity about the handing over of the rock area to the north and east of the site to the County Council for public use. In living memory this area has been open to public access and suggesting otherwise is certainly disingenuous and offers no additional public benefit.
  4. The new proposal still does not address multiple concerns re access, traffic and parking.
  5. We wish that we could be more positive about the proposed provision of some public space and a craft boat-building workshop but have concerns re apparent contradictions within the proposal re commercial viability and in the absence of a detailed proposal for the use of both the public space and the commercial units.
  6. Little consideration is given in the proposal to the history and heritage of Bullock and the character of the area.
  7. We continue to be concerned that the proposal will cause problems to the existing harbour businesses, users, visitors and residents.

We are continuing to examine the planning application in order to fully understand its extent.  We plan to organise a public meeting on 23 January 2018.  The closing date for “observations” to the planning department of Dun Laoghaire Rathdown County Council is 4 pm on Monday 5 February 2018.