MY SUBMISSION FOR : Coastal Defence Proposals for Portrane & Rush
I have outlined in my submission the reasoning and necessity for coastal erosion protection measures to be applied to the real South Beach, Rush which runs from North of the South Beach Car park to Rush Sailing Club covering a distance of approx. 2.2 km. My intention is to disprove the myth that the South Beach is mostly fronted by in the main agricultural valued land. I am questioning the validity of the cost benefit analysis used in deciding and hence not proposing measures and I am arguing the information used was not accurate in both the valuation and general make up of properties fronting onto the beach.
I also call on the cost benefit analysis used for the South Beach Rush to be published prior to any planning application for coastal erosion protection measures and the methodology used for the South Beach, Rush ( the real one ) be compared with other measures promoted elsewhere in the study.
I would ask what studies were carried out and ask that any report be published to outline the potential knock on effects and escalation of coastal erosion will have on residential and other properties on the South Beach area if measures are implemented elsewhere and the South Beach is left unprotected. I refer to the study carried out in 2018 which notes the condition and I outlined below extracts in the FCC sponsored report.
8.3 ENVIRNONMENTAL DESIGNATIONS IN CONTEXT OF CFERM OPTIONS
Hold the Line Option 2 Fish tail groynes & renourishment
Potential for increased erosion beyond the Burrow, i.e. at Rush
Rush Golf Club is one of the finest Links courses in Ireland which is playable all year round due to it’s location and as one of the most cherished amenities in Rush as well as North Dublin it is essential that all measures possible are put in place to protect the amenity.
The South Beach Rush is a Natura 2000 designated site which is the largest coordinated network of protected areas in the world and on that basis alone FCC are morally bound to protect the site from being wash away and implement protection measures as required.
On the NPWS website this area is also specifically contained in the proposed Rogerstown Estuary Natural Heritage Area. This needs to be protected and cannot be allowed to become an ecological and geographical disaster.
I think the non-inclusion of the details of the most recent coastal erosion measurement study i.e the black poles visible today on the South beach is inexcusable and unforgiveable and casts a huge doubt on the entire project in relation to the South Beach Rush and that the information “not being available “ alone necessitates the study in relation to the South beach to be re-evaluated in a major way.
In conclusion the option of doing nothing on the South Beach is both a morally bankrupt and environmentally disastrous course of action to pursue. I sincerely believe if the reasoning outlined and physical layout on the beach is taken into account as well as the vulnerability of both properties and amenities along the South Beach any proper analysis will come to the same conclusion and promote the protection measures as required.
To help identify and outline the various very different geographic areas along the beach I have subdivided the beach into several different areas with the metreage of each area in order to help identify it.
Area 1. is 269 mtrs in length.
Consists mainly of the South Shore public car park along with a public green space area down to the barriered entrance to Rush South Beach. All the area’s surrounding the Car Park have a zoning objective RESIDENTAL. Note, our consultants deemed all such lands as ZONED FOR AGRICULTURE.
There is rock armour here already, installed as a condition of planning permission granted to Irish water for the Rush Sewage Network scheme. [Work will be carried out on it from Monday July 27th. Irish Water, under instruction from Fingal County Council, will begin rehabilitation works on the rock armour installed by them previously. It failed to achieve its purpose in the storms of Jan. this year].
The condition attached to Irish Water’s planning permission i.e. to install the rock armour in this area, is proof positive from Fingal C.C. that it suffers from coastal erosion. From my own observation and local knowledge, plus the fact that the rock armour failed in the January storms, there is further evidence of the severity of the Coastal erosion at the South Beach.
Attached is a copy of an Email from Irish Water, as proof of the condition for Rock Armour and the fact that it failed, due to the severity of the storms earlier this year.
From pictures attached it is clear to see that houses to the rear and along the entrance to it are below the level of the public carpark on Convent Road. As the road rises up the hill, any breach or erosion at the car park would leave these houses extremely vulnerable to coastal erosion. I have spoken to FCC officials who expressed severe concern of the Car Park being able to withstand any further storms, hence exposing all the nearby houses directly to the sea.
It should be borne in mind that all the houses in the area involved are houses that were either granted permission in the recent past or are in a state of long-term existence.
The practice of turning chalet / holiday houses in fulltime residences does not apply here.
The area starts with four houses, accessed from the Bawn Road. All the dwelling’s border on to the coast itself. At the rear of the car park are six large dwellings, where planning permissions were granted as recently as September 2019. Listed below are the references and dates of FCC granted planning permissions for the dwellings at the rear of the car park. It shows these are not historic housing, but recently approved and built houses. Large contributions would have been paid for facilities and works carried out locally. In any reasonably thinking that would include coastal protection, which in this case is Rock Armour.
I would also point out that the car park contains the new Rush Sewage Network pump station. It goes without saying this is a vital piece of infrastructure for the town of Rush and the general Fingal area. Any threat to this facility has the potential to pollute not only the immediate coast-line but the extended coastline and it must be protected at all costs.
The car park also houses the public toilets. This is one of only two public toilets servicing the town of Rush, which has a population of over 10,000 persons. South Beach is extremely popular, visited by residents from nearby towns as well as locals, making the toilets another vital facility for Rush.
In regard to the Irish Water Email attached. I think it bizarre in the extreme that FCC would condition another state organisation to [A] carry out studies and publish coastal erosion measures [B] make the Rock Armour condition part of its planning permission [C] insist it be rehabilitated to a standard needed to meet the harsh coastal erosion conditions involved, whilst at the same time recommending a consults report which declares that Coastal Erosion measures are not required in the immediately adjoining areas.
Dates of the planning permissions granted to the rear of the Car Park all of which are available on FCC Planning portal.
11TH of September, 2019
12th of June, 2018
17th of September. 2013
9th of November, 2004
18th of October, 2004
14th of January, 2004
19th of February, 1998
Email received from Irish Water :
Date: Fri, Jul 24, 2020 at 10:46 AM
Subject: Irish Water
Dear Councillor Dennehy,
Thank you for your recent communications in relation to barriers adjacent to entrance to South Beach, Rush, Co. Dublin.
I have received an update from the relevant department advising that Rock armour that was reinstated as part of the Rush Sewerage Network Scheme failed in January during a storm. Rehabilitation works on the rock armour at South Beach, Rush, are due to commence on Monday 27th July, 2020. A specialist contractor and landscaping contractor will be carrying out the works on the rock armour on behalf of Irish Water. These barriers were installed to protect the affected area and will be removed upon completion of the rehabilitation works.
Please do not hesitate to contact us should you require any further information. Thank you for contacting Irish Water.
Local Representative Support Desk
T:1890 178 178 | Minicom: 1890 378 378
Area 1. Where the area that the current Rock Armour applies is 269 mtrs in length.
To help in identifying the area I have put a running total at the end of each segment. While the measurement of each section as I move on is fairly exact, and includes the built up area alone, I would assume any proper coastal defence mechanism decided upon would run some considerable distance beyond the exact measurement in order to give effective protection to the area.
Area 2. 480 mtrs
There are currently 16 separate premises that front onto the beach in this area along the coastal stretch and a further 16 to the rear of them on the stretch bordered by the South Shore Road which measures 480 mtrs in length.
This Is an area with a large number of existing housing. Many of the planning permissions were granted in the recent past, hence planning was granted in the full knowledge that coastal erosion was an issue in the area, as already proven in the details at area 1. Similarly to area 1, most of the houses in the stretch are large dwellings, which would have commanded large contributions to FCC. It follows that residents involved could expect that works and public facilities carried out in the locality with this funding would include Rock Armour to help protect their homes from this Coastal erosion.
local residents who sought planning permissions to extend or modernize existing dwellings in the area have been told that planning permissions cannot be entertained in the area until the coastal erosion measures in the report are completed. With this consultant’s report no protective measures are being recommended, so where does this leave those people following the publication of the report.
As area 2 is very similar to area 1 as outlined, the same conditions and requirements for coastal erosion measures should apply and I would ask that the cost benefit analysis used in other area’s of the report be used and compared with here.
Listed below are dates of the planning permissions granted in area 2, starting with a permission granted less than nine months ago.
12th December 2019
28th August 2017
28th November 2016
24th July 2014
20th October 2011
17th June 2008
27th September 2005
22nd May 1997
17th August 1994
21st January 1993
The over-all measurement of area 2 is 480 mtrs but here again as in area one I would expect any coastal erosion measures brought forward would extend beyond the 480 mtrs so as to have any realistic effect rather than having measures directly in front of the distance outlined.
The running total measurement including area 1 and 2 at this point brings the Running total to 749 mtrs on the South Beach heading from the Car Park area to the Rogerstown end.
Area 3. 120 mtrs.
Area 3 : 120 mtrs.
Occupied by Glass houses, used for the commercial growing of vegetable produce, carrying on a long tradition the town of Rush has with the Horticultural Industry. Two glass houses here are approx. 115 mtrs x 66 mtrs and 40 mtr x 43 mtrs. These are modern and actively worked glass houses, one of which has a coastal frontage of 115mtrs. These glass houses are designed, manufactured and installed as a single unit. Any loss of land where the glass house stand will render the entire unit unworkable. These units are usually not transferable elsewhere. It would be the equivalent of trying to move a building, which would lead to an enormous cost to the local employer and landowner. The landowner in question has been in regular contact with me since this process started and is extremely alarmed at the rate the coastal erosion to the front of his glass houses has escalated. This has become obvious in recent years. Planning permission was received on the site in recent years for a new glass house. [The planning permission granted 1ST February 2016].
I would ask that the cost benefit analysis criteria be explained regarding this situation. Can it be confirmed for me whether it was just a simple usage of agriculture land prices, of approx. 25,000 Euro per acre being applied to costing here. If so it was incorrect as that should not be the criteria used, due to the enormous cost in erecting the glass houses and ancillary items required to work them.
The project of erecting black poles on the beach included this area, so the speed and damage being caused by the erosion is readily available, as the poles are still in position. The pictures attached are showing a shocking deterioration of the dunes, where the Glass Houses outlined are 60mtrs from the water line. For the measurement of area 3 I allowed 120 mtrs. which again is a tight measurement. I would be working on the assumption that any coastal erosion measures would extend beyond that on either side to make it effective. Currently the running total is 869 mtrs
Area 4. 215 mtrs,
The playing area currently used by Rush Golf Club. I measured it at 190 mtrs. beginning at the Glass Houses in area 3. Breaching of the dunes here would be an environmental disaster of proportions not previously seen in North Dublin. Due to the way the land lies here, Rush Golf Course, in one tidal movement, has the potential to become one of the largest lakes in Dublin. It would create serious issues for surrounding premises, including houses and business’s on the Golf Road, as well as houses on the South Shore road, along with an active caravan park bordering onto the Golf Club.
To ignore the necessity to bring coastal erosion measures to this area, be it a basic Rock Armour as installed in Courttown, or more recently by Fingal County Council in Skerries opposite Skerries Rugby Club would be highly irresponsible by the decision makers. Not to include or advise the implementation of any actions in this, or any other report, could lead to one of the most reckless and environmentally disastrous decisions carried out by any local authority. A refusal to bring forward or recommend measures to alleviate ongoing coastal erosion in the area involved would remain as a black mark for ever more on anyone with any part in approving the report as it stands.
By not speaking up or not taking on board, or investigating what I have outlined, this would apply to all involved, be they the Authors, Council Officials, Public Representative or members of the liaison committee.
I have spoken with Engineers working with F. C. C. who are very familiar with this area. They are in total agreement with the sequence of conditions I have just outlined, which will emanate from not bringing forward the required measures. That decision would be followed by an environmental disaster that is guaranteed from the resulting lack of action. I have included pictures of the heavy coastal erosion already happening in area 4, as well as showing the proximity of how golf playing is now happening in relation to the current water line.
Rush Golf Club is one of the best amenities and asset’s available to the town of Rush. It should be protected in its current state. It should not be casually referred to, or even considered as being worth agricultural land prices. It’s worth and value to the town of Rush is multiples of agricultural land. It’s tourism value and amenity to the local area is of massive value to the town of Rush since the formation of the Golf Club in 1943.
The distance in area 4 is 215 mtrs, which brings the running total measurement to 1,084 metres.
Area 5. 80mtrs
The Golf Club Building
I have included the Club House of Rush Golf Club in the area 5. That includes the road area to the front and rear of the building. The building is the home for offices, bar, restaurant, and function room which serves not only the Club members but is also used regularly by the wider general public.
I would ask that a cost benefit analysis of this building, which would be destroyed if there is any breaching of the surrounding dunes, would be brought forward and compared with any other commercial premises held in private ownership, as well as the measures being put in place to protect those premises, versus Rush Golf Club House. If the same criteria was not used in any such cost benefit analysis, I am asking that the reason for not doing so be presented and explained to us.
Following on from my previous comments regarding the area becoming a lake if the dunes are breached, I would foresee that the Club House, due to its’s low lying location with regard to the sea, will sit bang smack in the middle of any ensuing lake. Currently the Club House building and surrounding car park are only 65 Metres from the water line. This measurement is not reflective of the potential danger, as the area on the other side of the dunes has a sharp decent. Breaching of the dunes in from of the area outlined will not only be catastrophic to that area, as the breach will create not only the demise of the Club House, but also the catastrophic disasters outline in area 4
The Club house will be a considerable cost in Euro’s to recreate. I have enclosed the planning permission to give an indication of the vast size of the building. It would be insulting in the extreme if it has been at any stage referred to as agricultural land. The building is a modern architecturally designed two story building measuring 25 mtrs x 35 mtrs with an additional building of 9 mtrs x 13mtrs along-side.
As with area, 4 I discussed this with local FCC engineers who are familiar with the area and they are in agreement with the ensuing ecological and environmental disaster that will happen if the dunes are breached which is guaranteed if no action occurs in the near future.
The Fingal C.C. planning ref. for the site, which is dated 12 September 2001
The coastal area in front of the Golf Club House and car park measures approx. 80mtrs which brings the running total of the South Beach from the Car Park to the Rogerstown end is 1,164 Meters.
Area 6. : 625 mtrs
This is where the Golf Course meets the bend at the mouth of the Rogerstown Estuary. It is an area used for golfing. All the reasoning outlined in area 4 also applies to this section of the South Beach. Unfortunately in this case, due to the low lying level of the course and the strong danger of the course becoming a lake in one tidal movement once the dunes have been breached, the housing in the areas of Link side and the Crescent road, bordering the Golf club, will have a major threat from Coastal flooding. That treat would be easily preventable and avoidable if corrective action is taken at this time. I have also discussed this scenario with FCC engineers familiar with the area and they are in total agreement with me that, like areas 4 & 5, due to the golf clubs low lying layout a massive lake will be created once the dunes are breached and most likely in one tidal movement. With the houses on the Linkside already exposed to coastal erosion at the rear of their properties they will be exposed to water to the front of their properties if area 6 is breached.
Area 6 is approx. 625 mtrs long which brings a running total of 1,789 meters in total from the car park area of the South Beach to the Rogerstown end of the beach.
Area 7. 415 mtrs
One of the worst effected area’s in regard to coastal erosion along the entire Fingal coast, The area is totally residential, from the sailing club to the Golf Club. When I enquired about this area previously, I was informed verbally, at a full Coastal Liaison meeting, that it was included in the area which was to have the coastal wall to be built on. I see that the map of the area does not include it. I would like it confirmed if the area is included, or not. The pictures of area speak for themselves and show the obvious very severe erosion that is happening at the mouth of the Estuary.
As the stretch is totally residential, with the house developments beside each other, it is hard to imagine that there would not be a major cost benefit to be gained from protecting the housing by implementing proper coastal erosion measures now, before it becomes too late.
All the issues pertaining to area 1 and 2 also apply to this very vulnerable area of our beach and it needs to be outlined very clearly as to why this area should be excluded and how what in my opinion is an irrational conclusion of “No Action “ arrived at by publication of information used and facts used pertaining to this specific area.
Planning permission’s dates approved in this area include :
13th February 2019
3rd August 2016
13th July 2006
8th March 2005
18th April 2002
12th June 2001
10th August 2000
14th March 2000
25th May 1999
11th June 1997
11th September 1996
The area is 415 mtrs in length, from the edge of the Sailing Club to the start of the Golf Club. It contains 14 dwellings. This gives an over-all total of 2,204 Metres,from the South Beach Car park to the Rush Sailing Club.
Please find enclosed my submission regarding the Coastal Defence measures proposed for the Rogerstown end of Rush.
At face value the proposed flood protection
measures for the Rogerstown inner estuary look
positive but the contribution of residents of Rush
would be invaluable in this regard. Unfortunately, the
consultants name the area as the South Beach which
is rather confusing as residents of Rush as well as
FCC refer to the area North of the sailing club as the
South Beach Rush. I have pointed out to the
consultants that there is also required along with the
current measures proposed in the flood defence wall
that rock armour is required to be placed at the
estuary side of the Rush Sailing Club boat yard to
stop the erosion that is currently occurring.