town planning submission - fingal · the data centre campus would represent a technically...

Town Planning Submission

Draft Fingal Development Plan 2017-2023

Formal Submission on behalf of John Smith

Lands at Courtlough, Balbriggan, Co. Dublin

April 2016


Lands at Courtlough, Balbriggan, Co. Dublin. 1

1.0 Introduction Hughes Planning and Development Consultants, The Mash House, Distillery Road, Dublin 3 have been instructed by John Smith, in conjunction with the Macken and O'Hara families, owners of the lands at Courtlough, Balbriggan, Co. Dublin, to make a submission on the Draft Fingal Development Plan 2017-2023, with respect to lands at Courtlough, Balbriggan, Co. Dublin. The purpose of this submission is:

That Fingal County Council rezone c. 28.5 hectares (70.4 acres) from Objective ‘RU’ Rural to Objective 'GE' General Employment, in the Fingal Development Plan 2017-2023; and

That Fingal County Council adopt the following Specific Local Objective for the submission lands:

‘To provide for the development of data centre facilities and associated related industries, with extensive landscaping, a high architectural standard of layout and building design’

With a view to the provision of data centre services from an Irish base, Mitsubishi Corporation, global leaders in the provision of information systems and datacentre equipment and services, have expressed a strong interest in the subject site and have dedicated personnel to work with the Project Advisory Panel to finalise a plan which will enable the site to realise its full potential as a world class data centre node. The zoning of the land, as per the Draft Fingal Development Plan 2017-2023, is shown in Figure 1.0 below while Figure 2.0 shows the zoning as per this submission request. We request that the recommendations of this submission be given full consideration in preparation of the Fingal Development Plan 2017-2023.

Figure 1.0 Zoning Map as per Draft Fingal Development Plan 2017-2023, showing the submission lands (outlined in red) zoned ‘RU’ – Rural

‘HA’

‘HA’

‘HT’

‘GE’

‘RU’

‘RU’



Figure 2.0 Zoning Map as per Draft Fingal Development Plan 2017-2023, showing the Courtlough submission lands (outlined in red), with proposed rezoning from ‘RU’ Rural to ‘GE’ General Employment

It is submitted that a ‘GE’ zoning for the submission land, with the intention to support the development of a data centre campus, comprising data storage halls and supporting industries and facilities, would represent a positive measure in the national and regional context and in particular in the context of Fingal County Council’s own economic land use policy framework. In this regard, we would note that James Boyle of the IDA has advised that they will include this project as part of discussions with Fingal County Council for FDI projects in the Greater Dublin Area, and will work with the Project Advisory Panel in delivery of Courtlough site. It is important for Council to appreciate the type of facility envisaged for the submission lands. The concept is to create a campus, comprising data halls which accommodate advanced storage and communications equipment to the standard required by global corporations, involved in the provision of services related to Cloud hosting and related activities. The data centre campus would represent a technically sophisticated node with advanced power and data backup facilities, supported by companies employing highly trained graduates from local colleges. In this regard, the objective for the submission lands is to deliver high tech employment opportunities alongside conventional data centres.

‘GE’

‘HT’

‘HA’

‘RU’

‘RU’

‘HA’

‘GE’

‘GE’



2.0 Submission Lands The submission lands extend to an area of c. 28.5 hectares (70.4 acres) and are strategically located proximate to Junction 5 on the M1 Motorway and adjacent to the R132 (Old Dublin to Belfast Road) to which the land has c. 700 metres of road frontage. The lands are located approximately 5km southwest of the Large Growth Town of Balbriggan and 10km north of the Metropolitan Growth Town of Swords.

Figure 3.0 Locational context of the submission lands (outlined in red)

Junction 5 M1 Motorway

R132

Swords

Road



Figure 4.0 ‘HT’ and ‘GE’ zoned land at M1 Junction 5 (submission lands outlined in red) 3.0 Current Planning Context 3.1 National Spatial Strategy Section 5.2 of the National Spatial Strategy (NSS) acknowledges the importance of Foreign Direct Investment (FDI) in Ireland and the need to continue to attract such investment. The ICT and software sector is recognised as an innovative and competitive sector which should be supported and expanded within the national economy. The emergence of a sophisticated and internationally competitive IT and internet based sector involving both Irish and foreign owned companies is also noted, as is the importance of continued FDI investment in Ireland. The availability of suitable sites capable of responding to global demand for datacentre facilities is critical to enable Ireland to maintain its competitive position in attracting global players. The subject site brings together all of the technical features required by advanced datacentre operators and has the attributes which should enable the replication of FDI successes achieved in other Fingal areas. 3.2 Regional Planning Guidelines for Greater Dublin Area 2010-2022 Balbriggan is categorised as a Large Growth Town II in the Regional Planning Guidelines. According to the RPGs these towns, with populations of between 15-30,000 persons, are strong active towns, economically vibrant with high quality transport links. The Development Plan states that Balbriggan “has developed as a major residential town in the north of the County with a young and expanding population which has more than doubled over the past 20 years”. Economic growth is identified as a key planning and development issue in the GDA. Section 3.3.2 notes that ICT services is the largest agency supported sector in the GDA comprising of companies such as Microsoft, Google and IBM. This sector has also seen the largest absolute growth in employment in the sector over the period 1998 and 2008, increasing employment by over 10,000 during this period. The growth of the ‘new software economy’ and cloud computing is noted in the Guidelines The Guidelines seek to promote and consolidate these new emerging sectors in developing the economic strategy. The administrative area of North Fingal Council Area is recognised as facilitating new local employment opportunities that will generate a greater balance of employment across the whole of the Greater Dublin Area, and reduce long distance commuter patterns. The Regional Planning Guidelines 2010-2022 recognise the need to facilitate rural development by improving the overall viability of the



rural economy together with the provision of improved Information and Communications Technology (ICT), particularly broadband. Relevant Strategic Policy and Recommendations are as follows: Policy EP2 To seek sustainable economic growth across the GDA, by the promotion of identified

core economic areas across the GDA in both the Dublin and Mid East Regions to facilitate new employment opportunities for existing populations and seek to reduce the volume of unsustainable long distance commuting.

ER18 Encourage and facilitate new employment opportunities within hinterland towns with high

levels of long distance commuting amongst the existing population to a) provide new local employment opportunities and assist in reducing long distance commuting patterns and b) build up the local economy to a more locally sustainable level and generate a better balance of employment opportunities across the GDA region as a whole.

3.3 Fingal Development Plan 2011-2017 Under the Fingal Development Plan 2011-2017, the land is zoned ‘RU’ – the objective of which is to ‘Protect and promote in a balanced way, the development of agriculture and rural-related enterprise, biodiversity, the rural landscape, and the built and cultural heritage.’ The vision for this zone is as follows:

‘Protect and promote the value of the rural area of the County. This rural value is based on:

- Agricultural and rural economic resources; - Visual remoteness from significant and distinctive urban influences; - A high level of natural features

Agriculture and rural related resources will be employed for the benefit of the local and wider population. Building upon the rural value will require a balanced approach involving the protection and promotion of rural biodiversity, promotion of the integrity of the landscape, and enhancement of the built and cultural heritage.’ 3.4 Draft Fingal Development Plan 2017-2023 The Draft Development Plan 2017-2023 envisages no changes to the zoning objectives of the lands from that contained in the Fingal Development Plan 2011-2017. 4.0 Submission Request Our clients request that Council actively pursues a stronger role for Fingal in the data storage and cyber security industry and in doing so acknowledge the suitability of the submission lands for the development of a Data Centre complex. Recent indications from IDA and others involved in identifying sites consistent with the current demands of potential FDI category, datacentre operators, highlight the shortage of sites that have the requisite characteristics involving, rural location close to motorway and aviation links, high speed data links, along with adequate power and on site natural gas access to support backup power systems. The subject lands have the aforementioned attributes, and are positioned to benefit from the forthcoming upgrade of the electricity grid network. In this context, our clients have established an expert project advisory panel, (see Appendix A), who are engaged in active discussions with a number of multinational corporations/ datacentre operators, a number of whom have expressed interest in the site and have the capability to enable the site to become a showcase site for the North County Dublin, M1 corridor. This in turn will create substantial benefits for the area and would encourage the creation of other sites of similar capability. The lands are strategically located in North County Dublin adjacent to the M1 Motorway Junction 5, adjoining the M1 Business Park and has c. 700 metres of frontage to the R132, Old Dublin to Belfast Road, allowing convenient access to the national road network. From an environmental and land use perspective, the lands are not identified in CFRAM mapping to be at risk of flooding, nor are there any



Natura 2000 sites within close proximity and the area is distinctly void of any sensitive land uses. An important element to the rezoning proposal is that the infrastructure necessary to operate a data centre is readily available to the site, comprising frontage to access to the national road network, pressurised gas main, 110kv power distribution line, fibre optic data network, and availability of mains water on site. In this regard, this submission requests the following:

That Fingal County Council rezone the c. 28.5 hectares (70.4 acres) from Objective ‘RU’ Rural to Objective 'GE' General Employment, in the Fingal Development Plan 2017-2023; and

That Fingal County Council adopt the following Specific Local Objective for the submission lands:


4.1 Background to Data Centres A Data Centre is a large group of networked computer servers typically used by organisations for the remote storage, processing, or distribution of large amounts of data. They are commonly run by large companies or government agencies. More recently there is increasing use of a cloud solution service by private businesses. They are not renowned for generating significant employment during their operation phase however their presence is representative of Ireland’s role in the international data storage industry, acting as a catalyst for further investment in associated high employment sectors. Reasons why Ireland is so attractive for the development of data centres include: Secure, low-risk & well-provisioned location for data centre hosting Ireland is politically and economically stable and is rated extremely low-risk from the perspective of both natural & man-made disasters. Critically, it has plenty of electrical power and large, expanding data centre space, located outside vulnerable city centre areas. Excellent government support for business Ireland’s Industrial Development Authority (IDA) is a state run organisation that supports companies financially and administratively when setting up operations in Ireland and provides ongoing support for companies based in Ireland. Well educated & talented workforce 40% of Irish people aged between 25 and 34 have completed university education, with a very high number specialised in Information Technology qualifications and accreditations. Ireland is placed joint 1st of 10 European countries in a 2008 IMD ranking of the percentage of the population with a third-level qualification. 4.1.1 Review of Data Centres in Ireland The submission lands are located on the M1 Dublin - Belfast Corridor and on the periphery of Balbriggan, classified in the Regional Planning Guidelines as a Large Growth Town. The nature of data centres is that they are suitable to locations peripheral to urban centres rather than within conventional industrial estates. The following is a review of data centres approved at comparable locations. Facebook Data Centre, Dunboyne / Clonee Corridor, Co. Meath Meath CoCo Reg. Ref. RA150605 An Bord Pleanalá Ref. PL17.245347



On 23/07/2015, Meath County Council granted a 10 year permission for a Facebook Data Centre on a 92 hectare (227 acres) site in Clonee, north of the M3. The proposal comprised the construction of a data centre campus in two phases with a total gross floor area of 76,200 square metres together with ancillary administration buildings, new access road and ancillary works including drainage and landscaping. The application stated that the 3no. data centres will store on-line communications in support of 1.4 billion users worldwide. The site’s location is comparable to that of the submission lands, being peripheral to Blanchardstown, a Metropolitan Consolidation Town, and Dunboyne, a Large Growth Town II, and adjacent to a major junction on a motorway (M3). It is also noted that the Facebook Data Centre site is located directly adjacent to developed HT (High Technology) and GE (General Employment) zoned lands within the administrative boundary of Fingal County Council. This is comparable to the locational context of the submission lands and acknowledges the compatibility of these uses.

Figure 5.0 Location context of approved Facebook Data Centre on lands within the Dunboyne

/Clonee (M3) Corridor, Co. Meath

M3 Motorway



Figure 6.0 Locational context of approved Facebook Data Centre adjacent to ‘GE’ and ‘HT’ zoned

land within Fingal’s administrative area

Figure 7.0 Artist's impression of the approved Facebook Data Centre on a 92ha site in Clonee Apple Distribution international, Palmerstown Toberroe & Derrydonnell, Co. Galway Galway County Council Reg. Ref. 15/488 An Bord Pleanála Ref. PL07. 245518

‘HT’

‘GE’

Approved Data Centre site



On 9th September 2015, Galway County Council granted permission for the construction of a 24,505sqm single storey data centre building, a 5,232sqm single storey Logistics and Administration Building, a 289sqm single storey Maintenance Building, a 16sqm Security Hut and associated barriers, 2 number 48sqm Fibre Huts, 18 external standby generators, all associated external plant and a 20kV Electricity Substation. A third party appeal is awaiting decision with An Bord Pleanála. The site, 197ha (486acres) is located off the Regional Road R348, between M6 Motorway junctions 17 and 19, approximately 5km southwest of Athenry town and some 15km east of Galway City. The application site is located in the rural area of Galway, and we note that Galway County Council’s decision to grant permission was principally based on Galway County Development Plan objective EDT1 (Strategic Economic Corridor) which reads: Objective EDT1 – Strategic Economic Corridor The objectives for the Strategic Economic Corridor include:

- To upgrade, improve and maximise the infrastructural facilities available within the corridor. - To seek to reserve lands to support nationally and regionally significant activities and to attract

specialist enterprise development that is large scale or high value. - To facilitate opportunities for science and technology based employment. - To ensure development is compatible with the enhancement, preservation and protection of

the environment and cultural resources recognised within the corridor. - To identify sites of adequate size and location to accommodate necessary infrastructure or

support activities which would not be appropriate in proximity to centres of population or sensitive environments or environmentally sensitive economic activities.

- To inform and to aid the preparation of Local Area Plans for strategic areas and those surrounding immediate environs within the corridor

Objective EDT1 refer to the M6 corridor, from which the Apple Data Centre site is conveniently accessed. In this regard, the following commentary is noted from the Galway County Council Planner’s Report:

‘The objective supports the proposed development at this location given its position within this strategic corridor’

The locational context of the Apple data centre site is comparable to the submission lands. The submission lands are located on an identified strategic economic corridor, some 5km southwest of Balbriggan Large Growth Town and 10km north of Swords Metropolitan Town Centre.



Figure 8.0 Locational context of Apple Data Centre site (outlined in red) relative to the M6 and

Athenry Grange Castle Business Park, Nangor Road, Clondalkin, Dublin 22 South Dublin County Council Reg. Ref. SD07A/0632 On 26

th October 2007, South Dublin County Council granted a 10 year permission for a Microsoft

Data Centre on lands in Grange Castle Business Park, Clondalkin, south-west Dublin. The proposal comprised the two phased construction of a two storey data centre with plant at roof level, with a gross floor area 51,155sqm together with computer and associated support and workshop areas and a 110kv electrical compound. The site is located in the Grange Castle Business Park comprising an area of 7.64 hectares (18.9 acres). We note that South Dublin County Council’s decision to grant permission was principally based on compliance with the Grange Castle Business Park Masterplan 2005, with the Planner’s Report providing the following commentary:

‘…The Masterplan for Grange Castle Business Park states that the principle development opportunity for Grange Castle is to attract and establish large scale facilities on the site and thereby generate employment and benefit South Dublin County in overall economic growth. Grange Castle caters for high tech and bioscience companies locating in Ireland and also serves the expanding needs of existing high-tech companies. The proposed development is considered to be in compliance with the provisions of the Masterplan for Grange Castle Business Park.’

M6 Motorway

Athenry



Figure 9.0 Locational context of the Grange Castle Data Centre site Data Centre, Straffordstown, Turvey, Swords, Co. Dublin Fingal CoCo Reg. Ref. F15A/0266 On 19th October 2015, Fingal County Council granted permission for 5no. data halls on lands on the west side of the R132 Old Dublin to Belfast Road, some 2km north of M1 Junction 4. The land is already zoned ‘GE’ General Employment and similar to the submission land is located adjacent to a cluster of employment zoned lands on the M1 Dublin to Belfast Economic Corridor, peripheral to an urban settlement. On recommending approval, the planning officer provided the following commentary:

‘It is considered that of all the zoning categories, the GE is probably the most suitable for a development such as this. The manufacturing of a product does not take place and employment levels are low, however, the development does not prevent the development of adjoining lands for other ‘GE’ uses that are in accordance with the uses listed in the Permitted in Principle category. The development is therefore appropriate on these GE zoned lands.

It is noted that the application site at Straffordstown is 3.2 hectares compared to the 28.5 hectares of lands subject of this development plan submission. It is important for the Planning Authority to appreciate the type of facility envisaged for the submission lands. The concept is to create a campus, comprising data centres and also associated industries and facilities such as research and development facilities. The campus would represent a data centre node backed up by technical and development support. In this regard, the objective for the submission lands is to deliver technology based employment generating uses alongside conventional data centres.



Figure 10.0 Locational context of approved Data Centre at Straffordstown Zoned Lands, Ashbourne, Co. Meath In addition to the above planning permissions, we also consider it relevant to make reference to Meath County Council’s approach to encouraging and attracting data centres to their area. Ashbourne Local Area Plan 2009-2015 In this regard, we note that the Ashbourne LAP 2009-2015 assigned a specific objective to attract a data centre to a 35 hectare ‘E2’ (Employment) zoned parcel of land on the north side of the town. Framework Plan Objective 3 (FP Obj. 3) reads as follows:

‘To provide for the development of Data Centres in the general vicinity of the Rath Roundabout. This shall seek to provide for data centre facilities and associated related industries set in open parkland with extensive landscaping and a high architectural standard of layout and building design. Employment types other than those related to data storage shall show a clear process related requirement to locate in proximity to a data centre’.

In recognition of this local policy objective in the Ashbourne LAP, the Meath County Development Plan 2013-2019 places Ashbourne in the category of a Secondary Economic Growth Town, with targeted sectors being High value added manufacturing, Logistics, Distribution & Supply Chain Management, Data Centres and Retail (convenience, comparison and limited warehousing).



To further this economic framework, the Meath County Development Plan states that consideration will be given to including the following particular local zoning objective in the review of the Ashbourne Local Area Plan 2009-2015:

Data Centre in the vicinity of Rath Roundabout, Ashbourne. To provide for the development of Data Centres in the general vicinity of the Rath Roundabout. This shall seek to provide for data centre facilities and associated related industries set in open parkland with extensive landscaping, a high architectural standard of layout and building design. Employment types other than those strictly related to data storage shall show a clear process related requirement to locate in proximity to a data centre. A data centre is a facility used to house computer systems and associated components, such as telecommunications and storage systems. It generally includes redundant or backup power supplies, redundant data communications connections, environmental controls (e.g. air conditioning, fire suppression) and security devices.

The lands identified for the development of a data centre in the Ashbourne LAP 2009-2015 are shown in Figure 11.0 below. This policy approach by Meath County Council is similar to the Facebook site in Clonee. We would encourage Fingal County Council to take a similar proactive approach to encouraging technology based campuses at suitable locations.

Figure 11.0 Locational context of the FP Obj 3 lands in Ashbourne, identified for the development of

a Data Centre 4.2 Proposed Zoning Objective The submission requests that Council consider the merits of rezoning the lands from ‘RU’ (Rural) to ‘GE’ (General Employment). The objective of the ‘GE’ zoning is to ‘Provide opportunities for general enterprise and employment’, with the vision being as follows:



Facilitate opportunities for compatible industry and general employment uses, logistics and warehousing activity in a good quality physical environment. General Employment areas should be highly accessible, well designed, permeable and legible.’

It is considered that the ‘GE’ zoning objective is the most suitable for this site. An array of draft development plan policy objectives seek to support Fingal’s role in driving new and innovative enterprise and industry in the region, with those of particular note being as follows: Objective ED01 Ensure that there is a sufficient quantum of zoned lands to facilitate a range of

enterprise development and a mix of employment creation across all business and industry sectors within Fingal.

Objective ED02 Ensure that economic development zonings are logically and coherently located

to maximise upon infrastructural provision, particularly in relation to locating high-employee generating enterprise and industry proximate to high capacity public transport networks and links thereby reducing reliance on private car transport.

Objective ED03 Prioritise locating quality employment and residential developments in proximity

to each other in order to reduce the need to travel, and ensure that suitable local accommodation is available to meet the needs of workers in the County.

Objective ED04 Support existing successful clusters in Fingal, such as those in the ICT,

pharmaceutical, aviation and agri-food sectors, and promote new and emerging clustering opportunities across all economic sectors within the County.

Objective ED05 Promote the regeneration of obsolete and/ or underutilised buildings and lands

that could yield economic benefits, with appropriate uses and subject to the proper planning and development of the area.

Objective ED09 Maximise the sustainable economic potential of Fingal through sustainable

means, being part of the Dublin City Region, the County’s unique strengths and its advantageous position within the East and Midlands Regional Assembly.

Objective ED10 Maximise sustainable economic opportunities associated with the presence of

key infrastructural assets within the County including Dublin Airport, the national motorway network, railway services, and the close proximity to Dublin City and Dublin Port via the Port Tunnel.

Objective ED11 Ensure that Fingal plays a pivotal role in the promotion of Dublin as the primary

Gateway in the Eastern and Midlands Region through engaging and collaborating with the other Dublin local authorities and the East and Midlands Regional Assembly.

Objective ED12 Realise the benefits associated with the Dublin-Belfast Economic Corridor

through supporting appropriate forms of development at key locations in accordance with the Fingal Settlement Strategy.

Objective ED13 Engage and collaborate with adjoining local authorities and regional assemblies,

as appropriate, to promote the continued economic development of the Dublin–Belfast Economic Corridor.

Objective ED26 Promote the continued growth of the ICT sector in Fingal by creating high quality

built environments offering a range of building sizes, types and formats, supported by the targeted provision of necessary infrastructure.

Objective ED27 Engage and collaborate with key stakeholders, relevant agencies, and sectoral

representatives to develop the ICT sector in Fingal and to ensure that the economic potential of the sector is secured for the benefit of the local economy, and national economy.



The draft development plan recognises that Fingal, as a key authority within the EMRA, is well placed to implement national policy through appropriate local strategies. The plan plays a pivotal role in achieving targets set at national level, particularly in relation to employment creation, stimulating the domestic economy and building world class clusters within the technology sector. Critically we submit that the relevant products, services and facilities involved in these clusters must be in line with sectoral, locational and site requirements. 4.3 Locational Context As outlined at the beginning of this section, the submission lands are strategically located on the M1 Dublin to Belfast Economic Corridor and immediately adjacent to a clustering of ‘GE’ (General Employment) and ‘HT’ (High Technology) zoned land around M1 Motorway Junction 5. In addition to the benefits associated with clustering of employment uses and convenient access to the national motorway network, there are other considerations which make the submission lands extremely conducive for the development of a data centre campus. These considerations can be fully outlined as follows:

- Adjacent to Junction 5 on the M1 motorway; - 700 metres frontage to R132 Old Dublin to Belfast Road; - Adjoins cluster of ‘GE’ and ‘HT’ zoned land; - No identified flood risk; - High Pressure gas main traverses the submission lands; - 110kv electricity line traverses the site; - Site can benefit from unique capability of Stephenstown substation and planned upgrades - Multiple Fibre Optic Data networks available; and - Availability of mains water on site.

These considerations are further discussed below. We would also ask Council to refer to the enclosed technical note on Roads and Traffic, prepared by Traffic Wise, contained in Appendix B of this submission. 4.3.1 Roads and Traffic The submission lands comprise an area of 28.5ha (70.4 acres) with frontage of 700m to the R132 Old Dublin to Belfast Road, and close proximity to Junction 5 on the M1. This affords the lands the benefit of convenient access to the national motorway network without disruption to sensitive land uses. Referring to the Technical Note prepared by TrafficWise (Appendix B), the following is noted:

Traffic generation to data centre development is typically modest. It is expect that there will be in the region of 80-100 persons employed at the site in a 24hr shift work schedule. It would be reasonable to expect that no more than 60-80 persons will be on site at any one time.

Albeit that some administration staff may be required to operate within traditional business hours, the operators of the data centre will be able to schedule shift start and finish times so as not to coincide with observed network peak times thereby making optimum use of existing infrastructure. Traffic Impact arising from the proposed land use is likely to be modest in the context of the R132 and certainly in the context of the capacity of the wider strategic roads infrastructure serving the site. The forecast traffic impact arising directly from say 50 arrivals and 50 departures during a principal shift changeover cannot reasonably be considered significant in the context of the capacity and operation of the M1 Junction 5 interchange and associated roundabout to the east.

The technical note concludes that the impact of traffic on the surrounding road network arising from the operation of the data centre is not likely to be significant. Therefore we submit that traffic considerations are not an impediment to the establishment of a data centre node at this location.



4.3.2 Location of Submission Lands adjacent to ‘GE’ and ‘HT’ zoned land As outlined above, the submission lands are strategically located adjacent to a precinct of employment zoned land clustered around Junction 5 on the M1 motorway. There are mutual benefits from clustering of similar type industries, recognised in the following draft development plan policy:

Encourage the creation of clusters within sectors thereby maximising on associated economies of scale;

Achieving sustainable economic development, ensuring appropriate forms of employment are located proximate to residential developments, promoting economic clusters and regenerating obsolete or inefficient economic lands;

Objective ED04 Support existing successful clusters in Fingal, such as those in the ICT,

pharmaceutical, aviation and agri-food sectors, and promote new and emerging clustering opportunities across all economic sectors within the County.

Further commentary on ‘clustering’ is provided under Section 6.2 of the development plan, as follows:

Sustainable economic development also can be achieved through clustering. A key economic policy concept, whereby enterprises and industries that have common features cluster together in locations in order to achieve economies of scale and derive the benefits associated from networking opportunities, innovation, synergies, sharing a skilled workforce, and the use of developed infrastructure.’

‘The role of clustering is a central pillar of national enterprise policy. In support of the aim of building resilience and achieving a step-change in enterprise performance, the Government’s recent medium-term policy statement Enterprise 2025 commits to a number of steps with regard to cluster promotion.’

In this regard, we again cite Meath County Development Plan policy framework for seeking to attract a data centre campus and related industries on employment zoned lands on the north side of Ashbourne. Ashbourne LAP Framework Plan Objective 3 (FP Obj 3) reads as follows:

‘To provide for the development of Data Centres in the general vicinity of the Rath Roundabout. This shall seek to provide for data centre facilities and associated related industries set in open parkland with extensive landscaping and a high architectural standard of layout and building design. Employment types other than those related to data storage shall show a clear process related requirement to locate in proximity to a data centre’.

The rezoning of the submission lands will complement the delivery of a clustering of high tech industry within a cluster of suitably zoned land at a strategic location on the M1 Dublin to Belfast Economic Corridor. As previously outlined in section 3.2 above, contained within the Regional Planning Guidelines 2010-2022 there is a need to create more balanced employment within the Greater Dublin Area, with a particular emphasis on job creation in growth centres on the periphery of Dublin, whilst retaining their complementary role of the Dublin Gateway. Strategically the submission lands are well located to facilitate employment that will complement the viability of the rural economy, whilst at the same time providing employment opportunities to existing population, facilitating a reduction in the reliance of unsustainable long distance commuting.

We would again highlight the relevance of draft development plan objective ER18, which seeks balanced employment across the region and recognise the need to facilitate rural development by improving the overall viability of the rural economy together with the provision of improved Information and Communications Technology (ICT). Relevant Strategic Policy and Recommendations are as follows:



Obj. ER18 Encourage and facilitate new employment opportunities within hinterland towns with high levels of long distance commuting amongst the existing population to a) provide new local employment opportunities and assist in reducing long distance commuting patterns and b) build up the local economy to a more locally sustainable level and generate a better balance of employment opportunities across the GDA region as a whole.

4.3.3 Flood Risk Assessment In accordance with the Planning System and Flood Risk Assessment Guidelines for Planning Authorities (2009) and Circular PL02/2014 (August 2014), a Strategic Flood Risk Assessment (SFRA), was carried out as part of the Strategic Environmental Assessment under the draft development plan. The SFRA summarises the outputs for different flood risk studies which cover the county including the ongoing Eastern Catchment Flood Risk Assessment and Management Study (ECFRAM), Fingal East Meath Catchment Flood Risk Assessment and Management Study (FEMFRAM) (2011) and the Tolka Flooding Study (2004). The SFRA contains fluvial flood zone mapping for each settlement, including Courtlough (refer to map in Figure 12.0 below).

Figure 12.0 Extract from Fluvial Flood Zone Mapping, Map No. 6 in the Fingal Development Plan 2011-2017, showing the submission lands outlined in red, and also identifying existing ‘GE’ and ‘HT’ zoned lands

Referring to the map in Figure 12.0 above, the SFRA identifies lands affected by Flood Zone A and B and in acknowledging the ‘GE’ (General Employment) zoning, notes that this zoning allows for less vulnerable development but that any future planning applications will require a detailed site specific flood risk assessment. The SFRA states that Site Specific FRA should address the following:

- Apply sequential approach should be applied through site planning and should avoid encroachment onto, or loss of, the flood plain.

‘GE’

‘GE’

‘GE’

‘HT’



- Highly Vulnerable Development shall not be permitted in Flood Zone A or B. - Development in Flood Zone A should be either open space or water compatible. - FRA should address residual risk of culvert blockage (where applicable), increased flood extents

under climate change scenarios and pluvial risk which should be aimed at setting finished floor levels.

- Compensatory storage for development that results in a loss of floodplain within Flood Zone A must be provided on a level for level basis.

As shown on the map in Figure 12.0 above, the submission lands are not located within either Flood Zone A or B, a characteristic which is of great benefit to its potential development. With no flood risk, a development proposal would not cause a loss of floodplain and as such would not require a compensatory flood storage strategy. This is in contrast to ‘GE’ zoned lands to the north, which are substantially contained within Flood Zone A. While employment uses and associated development are of low sensitivity, the potential for flooding poses a risk to the operational capacity of the land in addition to the loss of developable land required to off-set the loss of floodplain. 4.3.4 Gas Supply As shown on the map in Figure 13.0 below, a 70 bar gas supply main, with an associated wayleave in favour of An Bord Gais, traverses the site. Referring to the Technical Note prepared by Clifton Scannell Emerson Associates Consulting Engineers, we can advise that the supply line is the north south high pressurise gas main with the full potential to provide combined heat and power through a Pressure Reduction Station. The benefit of having this gas main readily available is that it provides a significant degree of flexibility in terms of how power and air conditioning are delivered across the site. Further to this, Peter Fagan of Clifton Scannell Emerson Associates, Consulting Engineers has advised that the existing as main, which traverses the site, has the capacity to support the power generation and backup requirements associated with significant dataprocessing capability on the site. This will incorporate the construction of a new AGI and GIS substation. It is proposed to employ a state of the art Mitsubishi Gas Turbine or alternatively a cluster of Mitsubishi reciprocating gas engines for the power generation application. Data centres are high energy users, consuming significant amounts of electricity for their operations and in parallel require cooling of the data storage equipment for optimal performance. The high energy usage means that minimizing the carbon footprint of the site is critical while optimizing the efficiency of the relevant equipment. These factors make data centres an interesting new application for combined heat and power technology or combined cooling and power (CCP) using absorption chillers to convert surplus heat to provide the cooling function required by the on site facilities and equipment.

Figure 13.0 Location of the submission lands (outlined in red) in the context of natural gas

transmission network

https://www.clarke-energy.com/gas-engines/trigeneration/



4.3.5 Electricity Supply As shown on the map in Figure 14.0 below, an ESB 110kv electricity transmission line, with an associated wayleave in favour of ESB, traverses the submission lands. We can advise that while the ESB has plans in place to upgrade the Stephenstown Substation, located some 4km to the north east, by 2019, the substation does have the limited interim capacity to support an initial datacentre operation in the near term. Based on the substantial ESB grid reinforcement plan discussed with Mr David Byrnes of ESB Networks, it is envisaged that the Substation will be in a position to provide the required power supply for the full rollout of the entire data centre campus from 2019 onwards. Further to this, Peter Fagan of Clifton Scannell Emerson Associates Consulting Engineers has further advised that the additional power will be available following the completion of the deep reinforcement to the grid involving the construction of the new 220kV substation at Belcamp in 2018 and the upgrading of the 110kV Substation at Stephenstown by 2019. This will enable the construction of a new GIS substation on the proposed lands, serviced from drop down pylons off the existing 110kV overhead line traversing the site.

Figure 14.0 Location of the submission lands (outlined in red) in the context of the 110kv

transmission line 4.3.6 Fibre Optic Data Connections Referring to the map in Figure 15.0 below, it is noted that the submission lands are served by four network lines (Eircom network, ESB fibre network, Aurora network and Hibernia), with all four running directly through or adjacent to the submission lands.



Figure 15.0 Location of the submission lands (outlined in red) in the context of fibre optic network 4.3.7 Water Supply The duplication of mains has been completed to Jordanstown. Presently Irish Water are at detailed design stage for the duplication of the mains from Jordanstown to Kilsock (Balbriggan South). The route of the duplication of the proposed main should be in reasonable proximity to the Courtlough Lands to supply water to the proposed development. 4.3.8 Waste Water Existing industry in the proximity of junction 5 is serviced by onsite treatment. It is proposed that a foul sewer rising main be constructed to Balbriggan South to discharge into the existing foul sewerage drainage network. This network requires upgrading to improve its existing capacity. 5.0 Proposed Data Centre Campus Layout With the emergence and success of the IT industry in Ireland, there has been significant interest in the submission lands for the development of a data centre campus. We would also highlight that there is significant support for the rezoning proposal from the IDA, a statutory agency that would provide a partnership and support structure for the development to be delivered. Considering the above assessment, an indicative concept site layout has been prepared by Clifton Scannell Emerson, Consulting Engineers, which as shown in Figure 16.0 below, comprises 5no. data centre buildings and associated facilities including a technical support facility. The indicative layout, as contained in Appendix C of this submission, has been informed through consultation with the intended end users. The site layout has been informed by a number of additional factors. Road frontage of 700 metres offers an excellent interface with the R132 Old Dublin to Belfast Road. Safe and convenient access can be provided along this road in addition to a high quality landscaping programme. The alignment of ESB and An Bord Gais wayleaves have been taken into consideration. A client brief has been to retain the wayleaves in their current form, therefore the layout of the site, including the footprint of the data centre and other buildings, have been designed in this regard.



The location of the data centre and other buildings, together with access roads and car parking, have been informed by the desire to achieve the proposed local objective in terms of making provision for extensive landscaping, a high architectural standard of layout and building design. Subject to this rezoning proposal being supported, a formal planning application would follow in due course, with a full complement of supporting documents.

Figure 16.0 Indicative site layout for Data Centre Campus on the submission lands



6.0 Conclusion The draft county development plan seeks to facilitate a range of enterprise development and a mix of employment creation across all business and industry sectors within Fingal. The draft plan also seeks to maximise sustainable economic opportunities associated with the presence of key infrastructural assets within the County including Dublin Airport, the national motorway network, railway services, and the close proximity to Dublin City and Dublin Port via the Port Tunnel. The submission lands are strategically located adjacent to Junction 5 on the M1, an emerging base for high tech industry on the Dublin to Belfast Economic Corridor. The submission lands are uniquely equipped in terms of the ready availability of key infrastructure and present an opportunity to secure a high tech data centre campus within the northern section of the County. In this regard, the objective for the submission lands is to deliver high tech employment associated with the efficient operation and technical support of world class data centres, which are a critical component of the current and emerging business environment. The submission requests the following:

- That Fingal County Council rezone c. 28.5 hectares (70.4 acres) from Objective ‘RU’ Rural to Objective 'GE' General Employment, in the Fingal Development Plan 2017-2023; and

- That Fingal County Council adopt the following Specific Local Objective for the submission lands:


We trust that the Planning Authority will have regard to and adopt the contents of this submission in the adoption of the Fingal County Development Plan 2017-2023. _____________ Kevin Hughes MIPI MRTPI

Director



Appendix A Project Advisory Panel

- Sean Hayes, WhiteRock Project Advisors Ltd., Former Vice President with Citibank IFSC

- Hugh Loughlin, Advisor to Mitsubishi Corporation, Japan

- Thomas Cooke, Director, Certification Europe and Advisor to Digital Realty, Rackspace, Global Reach, BT and Vodaphone;

- Peter Fagan, Director, Clifton Scannell Emerson Associates, Blackrock, Consulting Engineers to a number of recently established datacentre operators in Dublin along with large scale industrial business park developments in Ireland

- Julian Keenan, TrafficWise Ltd.

- Hughes Planning and Development Consultants



Appendix B Technical Note on Roads and Traffic, prepared by Traffic Wise



Appendix C Indicative Site Layout prepared by Clifton Scannell Emerson, Consulting Engineers

town planning submission - fingal · the data centre campus would represent a technically...

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