Delete the paragraph on page 34 and 35 regarding a reduction of car parking standards, starting with "The car parking standards set out in Table 16.1 of the development plan shall…" and ending with "… Will consider the relaxation of car parking standards when assessing the type and nature of the development proposed."

Reason: There should not be any relaxation of car parking standards for Ballymun, otherwise we will be wasting valuable land for surface car parking and we won't be able to provide quality environment for walking and cycling.

The LAP states that there is more active travel in the Ballymun areas than other areas of Dublin, and so there is less need for extra car parking.

The LAP is also on the proposed Metro North route, another reason for reducing and not increasing car park provision. Nearby developments in Fingal such as the Gullivar's retail park have very large car parks that are empty and a waste of space.

Section 5.4.6 of the Draft LAP references the car parking standards and policies as set out in the Dublin City Development Plan 2016-2022.

The LAP references in particular, Section 16.38 of the Development Plan which permits the provision of car parking in excess of the maximum car parking standards. The Development Plan states this is allowable in exceptional circumstances, for example in areas adjoining different local authorities or to facilitate the sustainable development of a regeneration area.

The LAP is noting that Ballymun adheres to the ‘exceptional circumstances’ for this policy relaxation. Such relaxations should apply until such time as a similar accessibility based parking policy and parking standards as applicable to the City Council area are adopted by the adjoining planning authorities in the Dublin metropolitan area.

This is of particular importance for the LAP area as it borders Fingal County Council to the north, and there are significant variances between the car parking requirements of the two authorities, with Fingal’s car parking standards in excess of the City’s. In this regard, given the regeneration policies contained within the Development Plan, the importance of building
on the existing investment in the area, making it easier to do business and attracting new investment into the area, the Draft LAP notes that the City Council, may consider the relaxation of car parking standards for Ballymun when assessing the type and nature of the development proposed. Such relaxations are not considered to be permanent measures, but are considered important tools in attracting business and commercial activity into the Ballymun area,
which is needed to stem the retail seepage and spend out of the area.

The top three locations for convenience retail spend are identified in the ‘Retail Study for Ballymun’ as (i) Aldi, Santry Avenue, (ii) Dunnes, Charlestown Shopping Centre and (iii) Tesco, Omni Shopping Centre; with all three of these centres having significant levels of free parking to
attract consumers. Ballymun needs to compete with these centres in attracting
convenience retail providers.

Until such a time as the optimised Metro North is approved and on site, omitting this text and this provision would put Ballymun at a distinct commercial disadvantage.

The text regarding the relaxation of car parking standards is per the Dublin City Development Plan (Chapter 16, Section 16.38) ensuring compliance with the planning hierarchy and national legislation.

Further to the above, it is noted that submissions were received by Lidl and B4B supporting the general provision of car parking in the area for visitors and customers.