High Court dismisses planning challenge to housing development, allowing stay of derogation licence for further submissions.
Legislator summary
AI generatedThe High Court dismissed the applicants' judicial review challenge regarding the planning decision for a new housing development at Delgany. While the court rejected arguments concerning zoning, material contravention, and statutory invalidity, it acknowledged issues with the bat derogation licence. Consequently, the challenge to the board's decision was dismissed, but the stay of the derogation licence was continued pending further submissions on that specific ground.
Legislator headnote
AI generatedSections 50, 50A and 50B of the Planning and Development Act 2000; Sections 50, 50A and 50B of the Planning and Development (Housing) and Residential Tenancies Act 2016: A planning challenge is dismissed where the plan provides sufficient flexibility for the decision, but a stay of a related environmental derogation licence may be maintained pending further submissions on specific procedural or substantive grounds.
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AI generatedFull text
[2023] IEHC 381
THE HIGH COURT
JUDICIAL REVIEW
[2021 No. 251 JR]
IN THE MATTER OF SECTIONS 50, 50A AND 50B OF THE PLANNING AND DEVELOPMENT
ACT 2000 AND
IN THE MATTER OF THE PLANNING AND DEVELOPMENT (HOUSING) AND RESIDENTIAL
TENANCIES ACT 2016
BETWEEN
ALICE O’DONNELL, COLIN ACTON, SEÁN GOFF, EVELYN CAWLEY, DECLAN MORRIS,
CIARA MAN, GARETH MADDEN, AILEEN LENNON, KEITH SCANLON AND CARINA HARTE-
HOLMES
APPLICANTS
AND
AN BORD PLEANÁLA, MINISTER FOR HOUSING, LOCAL GOVERNMENT AND HERITAGE,
IRELAND AND THE ATTORNEY GENERAL
RESPONDENT
AND
DRUMAKILLA LIMITED
NOTICE PARTY
JUDGMENT of Humphreys J. delivered on the 5th day of July, 2023
1. Like Sherwin v. An Bord Pleanála [2023] IEHC 26, [2023] 1 JIC 2701 (Unreported, High
Court, 27th January, 2023), this case relating to the proposed construction of residential units and
associated works at the former Carmelite monastery at Delgany, County Wicklow is another window
on the rise and fall of the Catholic Church in Ireland.
2. The central section of the monastery, according to the National Inventory of Architectural
Heritage (NIAH), was originally a country house built around 1810. The Carmelites took possession
of the house in 1844. According to other public domain material (wicklowheritage.org), the building
of the monastery church was delayed by the Famine. The foundation stone was laid in 1851 and
the first Mass was celebrated in 1853. The same source describes the church as having been called
“a little gem of gothic architecture”.
3. According to the NIAH, a large two and three-storey wing to the south was built around 1860
and a school was held within the monastery until 1896. Wicklowheritage.org states that:
“In recent times, due to diminishing numbers in the Order, the Carmelite Sisters decided to
sell the monastery and move the small remaining congregation to a Carmelite monastery in
Stillorgan Co. Dublin. The bishop instructed that the church be deconsecrated and religious
artefacts be removed before the property was vacated ... the final Mass in the church was
celebrated in February 2019.”
4. In anticipation of the development consent application, an application for a bat derogation
licence was made to the National Parks and Wildlife Service (NPWS) on 17th January, 2020. The
licence was issued on 4th March, 2020.
5. On 16th July, 2020, a request was made to amend the licence to include the brown long-
eared bat. That was granted and an amended licence issued on 21st July, 2020.
6. Pre-application consultation took place on 23rd July, 2020, which resulted in a board order
identifying issues to be addressed dated 12th August, 2020.
7. The application for planning permission under s. 4 of the Planning and Development
(Housing) and Residential Tenancies Act 2016 was submitted on 21st October, 2020. The revised
derogation licence was appended to the application documentation, so the application date was the
first date on which the applicants could have known about it.
8. The applicants made submissions on the application. The board’s inspector then prepared
a report recommending grant of permission with conditions dated 3rd February, 2021. The board
broadly accepted this recommendation and granted permission on 15th February, 2021.
Procedural history
9. Proceedings challenging the board’s decision and the derogation licence were issued on 25th
March, 2021.
10. On 19th April, 2021, I granted leave to seek judicial review and a stay on the works. I gave
case management directions on 14th May, 2021. An issue then blew up because one of the points
being made by the applicants was covered by the Waltham Abbey v. An Bord Pleanála [2021] IEHC
312, [2021] 5 JIC 1002 (Unreported, High Court, 10th May, 2021) proceedings and the matter was
then delayed pending a resolution of that issue.
11. On 28th March, 2022, the directions were amended and were further amended on 9th
May, 2022 by agreement of the parties. There were then further revised directions by agreement on
20th June, 2022 and further agreed adjournments on 25th July, 2022 and 3rd October, 2022.
Ultimately,
following completion of the exchange of pleadings and affidavits, a date was fixed in the list to fix
dates on 30th January, 2023 and the matter was heard on 9th to 11th May, 2023. On the latter
date, an additional affidavit exhibiting further material that was before the board was admitted
without objection.
12. Following the CJEU judgment in Case 721/21 Eco Advocacy CLG v. An Bord Pleanála (Court
of Justice of the European Union, 15th June, 2023, ECLI:EU:C:2023:477), the matter was listed for
mention on 19th June, 2023 for any further submissions arising from that case. It was then
adjourned on consent to 26th June, 2023, at which point some further argument was offered in
relation to pleadings issues. The applicants wanted to reserve the right to yet a further reply so the
matter was adjourned to 27th June, 2023 for that purpose. At that point some discussion arose as
to whether the court could give a judgment on most of the issues but indicate provisionally any
views or difficulties that arose in respect of aspects of the derogation licence arguments and invite
further submissions on those. That was not particularly objected to and judgment was formally
reserved on the basis that such an option would be available.
Reliefs
13. The reliefs sought by the applicants are as follows:
“1. An order of certiorari quashing the decision of the Respondent granting planning
permission for the construction of 232 residential units and associated works at the site of
the former Carmelite Monastery Lands, Delgany Co. Wicklow on 15th February 2021 (ABP
Ref 308467-20) (the ‘Decision’).
2. An order of certiorari quashing the Derogation Licence (DER/BAT 2020/9) (the ‘Derogation
Licence’) granted by the Second Respondent in respect of bats and issued to the Developer
in respect of the proposed development on 21st July 2020.
3. Such declaration(s) of the legal rights and/or legal position of the applicants and (if and
insofar as legally permissible and appropriate) persons similarly situated and/or of the legal
duties and/or legal position of the respondents as the court considers appropriate.
4. A declaration that (to the extent that they are not capable of bearing a conforming
construction) sections 5, 6, and 7 of the Planning and Development (Housing) and
Residential Tenancies Act, 2016 (‘the 2016 Act[’]) are incompatible with Article 6(4) of
Directive 2011/92/EU and/or the requirements of fair procedures and natural and
constitutional justice.
5. A declaration that (to the extent that it is not capable of bearing a conforming
construction) section 5(6) and 9(6)(c) of the 2016 Act are incompatible with Articles 3 and
4 of the Strategic Environmental Assessment Directive, Directive 2001/42/EC.
6. A stay on works being carried out pursuant to the Decision pending the resolution of these
proceedings.
7. An order that section 50B of the Planning and Development Act, 2000 (the ‘2000 Act’),
and/or sections 3 and 4 of the Environment (Miscellaneous Provisions) Act, 2011, and/or
Article 9 of the Aarhus Convention apply to the present proceedings.
8. Costs."
14. Since core ground 1 was withdrawn, relief 4 falls so the preliminary objections at paras. 6
and 7 in the State’s statement of opposition does not arise.
Core grounds
15. Core ground 1 states as follows:
“The Decision is invalid as the statutory pre-consultation procedures provided in sections 5
and 6 of the Planning and Development (Housing) and Residential Tenancies Act, 2016 (the
‘2016 Act’) are incompatible with Article 6(4) of Directive 2011/92/EU (as amended) (the
‘EIA Directive’) and/or the requirements of fair procedures and natural and constitutional
justice.”
16. As noted above, this ground was not pursued.
17. Core ground 2 states as follows:
“The Decision is invalid because the Board granted planning permission for the proposed
development in contravention of a zoning objective or an objective in relation to the zoning
of land contrary to section 9(6)(b) of the 2016 Act.”
18. This is dealt with below as a domestic law issue.
19. Core ground 3 states as follows:
“The Decision is invalid because the Board failed to identify any basis pursuant to section
37(2)(b) of the 2016 Act as to why it was entitled to grant permission notwithstanding that
the proposed development constitutes an acknowledged material contravention of the
relevant Development Plan and Local Area Plan.”
20. This is also addressed below as a domestic law issue.
21. Core ground 4 states as follows:
“The Decision is invalid as the material contravention procedure provided by the Minister in
section 5(6) and/or 9(6)(c) of the 2016 Act is incompatible with the requirements of Directive
2001/42/EC ([‘]the SEA Directive’) and/or that the Board was required to but failed to ensure
the effectiveness of the law of the European Union.”
22. This is a tortuously and inaccurately phrased point because obviously a provision of primary
statute law is not a “procedure provided by the Minister”. Essentially, this is a complaint about
statutory validity which is best dealt with on a reach-constitutional-issues-last-basis.
23. Core ground 5 states as follows:
“The Decision is invalid because the Developer and the Board failed to comply with Article
299B of the Planning and Development Regulations 2001.”
24. This ground was not pursued.
25. Core ground 6 states as follows:
“The Decision is invalid because the Board erred in failing to have any, or any adequate
regard for the protection of bat fauna for the purposes of Annex IV and Article 12 of the
Habitats Directive and/or section 23 of the Wildlife Act 1976 (as amended).”
26. This is an EU law point which is best postponed until after dealing with domestic law issues.
27. Core ground 7 states as follows:
“The Derogation Licence issued to the Developer by the Second Respondent is invalid
because the decision maker failed to establish that there is no satisfactory alternative and/or
where the rationale for granting it is wrong in law and fact and/or is so unreasonable that
no reasonable decision maker could have arrived at it.”
28. This is the sole core ground relating to the challenge to the derogation licence.
29. Core ground 8 states as follows:
“The Decision is invalid as the Board breached the EIA Directive and/or acted irrationally or
unreasonably and/or breached the Applicants’ rights to fair procedures and reasoned
decision making in its assessment of traffic impacts from the proposed development on the
greater Delgany area.”
30. This is a partly domestic and partly EU law point.
31. Core ground 9 states as follows:
“A stay, if necessary, on works being carried out pursuant to the impugned grant of planning
permission pending the resolution of these proceedings.”
32. That is flawed drafting in that it doesn’t constitute a ground, but rather a claim for relief. As
noted above, that was granted when leave was sought.
Domestic law issues regarding the development consent
33. There are essentially three domestic issues raised going to the validity of the development
consent, which can be summarised as follows:
(i) core ground 8 – reasons regarding traffic;
(ii) core ground 2 – material contravention regarding zoning; and
(iii) core ground 3 – material contravention regarding apartments.
Core ground 8 - reasons regarding traffic
34. As an initial point in favour of the applicants, the notice party complains that this point is
not sufficiently particularised (statement of opposition para. 55), but while the cry of non-
particularisation has a lot more resonance in relation to other parts of the applicants’ case, I think
the point the applicants are trying to make under the traffic reasons heading is acceptably clear.
35. However, insofar as the applicants ambitiously complain that the board fell into “material
errors of fact”, this is a misunderstanding. There is no “error” in the sense of the caselaw. Rather
there is merely difference of methodological and expert opinion.
36. Insofar as a complaint is made about irrationality on the pleadings, this wasn’t the primary
focus of the applicants’ arguments, but it hasn’t been demonstrated that the conclusion was irrational
in the sense of not being open to the board.
37. Insofar as there is a complaint about “fair procedures”, this seems essentially to boil down
to the reasons argument which is the core of the issue under this heading.
38. The inspector sets out a detailed set of reasons in relation to traffic at paras. 10.7.1 to 10.7.9
as follows:
“10.7.1. The development proposes a [sic] three vehicular access points, one from Bellevue
Road and the other two from Convent Road. There will be no cross route through the site
from Bellevue Road to Convent Road by vehicular traffic. The Bellevue Road access road
will service 45 dwelling units, 13 houses along Bellevue Road will avail of direct access and
the two access points along Convent Road will serve the remaining 174 units. The existing
road, footpath and cyclist infrastructure in the vicinity of the site is well below standard and
observers highlight this point.
10.7.2. The applicant has submitted a Traffic and Transport Assessment (TTA), the
methodology of which the planning authority are satisfied with. Local observers comment
on the internal layout of the site and are unhappy that a through road has not been proposed.
All observers that had something to say about traffic and transport were concerned about
additional traffic on the local road network leading to congestion and delays at key junctions.
There are concerns too about the provision of housing directly fronting onto Bellevue Road
and that there may be conflicts between vehicles and people exiting their homes. The lack
of existing pedestrian facilities in the area are also heavily criticised, and local observers
worry about the safety of pedestrians and cyclists. In addition, observers comment that
given the lack of basic pedestrian/cyclist facilities in the area, the expectation that future
occupants will leave the car at home and travel by more sustainable methods is not realistic.
There are also some technical criticisms levelled at the modelling techniques used and overall
methodology expressed in the TTA. However, the planning authority have no similar
concerns expressly detailed in the Chief Executives Report.
10.7.3. The applicant’s TTA addresses existing traffic behaviour, new proposed access
arrangements, trip generation associated with the proposed residential development, traffic
impact of the proposal and the proposed car and bicycle parking arrangements and assess
five junctions in the vicinity of the development site, as follows:
• Junction 1- Bellevue Hill / Glen Road / Church Road
• Junction 2- Convent Road / Church Road
• Junction 3- Church Road / Delgany Wood Avenue
• Junction 4- Convent Road / Chapel Road / Delgany Wood Avenue roundabout
• Junction 5- Bellevue Hill / Ballydonagh Road / Lower Windgates
10.7.4. The TTA states that expected trip generation for the proposed residential
development, community centre and crèche was estimated utilising the TRICS database and
was revealed to be in total 35 trips inbound and 78 trips outbound in the morning peak hour
and 69 trips inbound and 43 trips outbound in the evening peak hour. In addition, the
adjacent permitted Richview development (WCC Ref. 15/1307, ABP Ref. PL 27.248401) trip
generation figures were added in with development scenarios. The analysis and operational
assessment of the proposed residential development at the five junctions revealed that at
present the junctions operate below the normal design threshold during the morning and
evening peak hours. The Church Road arm on Junction 1- Bellevue Hill / Glen Road / Church
Road during the morning peak hour will approach the design threshold with minor queues
and delays for motorists beginning to occur. Likewise, the Convent Road arm on Junction
2- Convent Road / Church Road, will approach the design threshold. The report goes to
state that into the future all five junctions will continue to operate below the normal design
threshold during the evening peak hour and that overall, the development will have a
minimal impact on the junctions. Observers strongly disagree with this analysis, criticising
the TTA at a technical level and from an anecdotal perspective with descriptions and
photographs of traffic problems. The planning authority do not challenge the findings of the
TTA, but do have a number of technical requirements regarding site specific issues that can
be addressed by condition.
10.7.5. I note the findings of the TTA but I must highlight issues that lie beyond the site,
roads are narrow, junctions are angled, footpaths lack width or are non-existent and cyclist
facilities are token at best. Delgany Village, its centre and environs has been allowed to
grow without the required and needed advances in road/footpath/cyclist facilities. I
observed challenges relating to current car parking practices – whereby cars park on the
footpaths within the village and obstruct safe and pleasant pedestrian passage. I note that
a large volume of observations have underlined the issue of traffic congestion as one of the
major concerns for the area. I do not doubt that most if not all local roads are extremely
congested at peak times, the accounts and photographs submitted by observers adequately
illustrate the existing problems for car users and pedestrians/cyclists alike. The dates of my
recent site visits are not representative of likely traffic, but I did observe a large volume of
cars parked across footpaths and along streets. In my view, the overall transport character
of the area is defined by private car use and this is exemplified by the profusion of cars
parked on footpaths in the village centre. The planning authority are also concerned about
the phasing of the development and particularly the delivery of footpaths along Bellevue
Road. I agree that footpath facilities should be delivered within the first phase of the
development, especially along Bellevue Road, where there currently are none.
10.7.6. To address issues that might arise in terms of increased traffic volumes, the applicant
proposes to open up the site to pedestrian and cyclist permeability and this is to be
welcomed. Specifically, I note that connections to the development site to the north area
proposed and should be supported. In this context, it would be desirable that such
connections are actually implemented. I am satisfied that this can be achieved as Gorteen
Way Ltd, the owner of the adjacent site, has given consent for this current application to be
made, so logically conditions could be attached to ensure pedestrian/cyclist connections are
implemented from the outset. In addition, the planning authority note that universal access,
in terms of a ramp, should be designed to allow permeability for all users, specifically at
units 74-75, I agree.
10.7.7. The proposed development will add significant public realm improvements along
Bellevue Road and Convent Road. I note that residents along Bellevue Road are concerned
that a profusion of new entrances along Bellevue Road will constitute a traffic hazard. The
planning authority have not raised any particular concern other than compliance with DMURS
and welcome the new frontage and pedestrian facilities along Bellevue Road. At present the
road in the vicinity of the site, is narrow and there are no footpaths with housing on just one
side, traffic is inclined to move swiftly along this route. With the arrival of individual houses
facing onto and accessing Bellevue Road at multiple locations, together with a dedicated
footpath, the resultant behaviour and speed of passing traffic change. The provision of
multiple entrances along Bellevue Road will moderate driver behaviour resulting in slowing
traffic and making the pedestrian environment safer and more pleasant than it is now.
Aesthetically, this location is part of Delgany and the urban expansion of the town is
encouraged through the objectives of the LAP. The roll out of pedestrian facilities such as
footpaths and street lighting is welcomed and in my opinion a beneficial addition to the
overall amenity of the area.
10.7.8. The applicant has not prepared a specific Mobility Management Plan as part of their
Traffic and Transport Assessment. It is clear that current commuting habits based on the
private motor car are unsustainable and even a low density residential development would
not improve matters and in fact damage the economic viability of public transport plans in
the area or make more sustainable modes unattractive. Therefore, the production of a
Mobility Management Plan that combines some measures to manage and control car parking
should take place before development commences and I am satisfied that this can be dealt
with by condition.
10.7.9. On balance, the proposed development is located at a well-served suburban location
close to a variety of amenities and facilities. Current public transport options are limited to
moderate frequency bus services without defined bus corridors and feeder routes to the
DART station at Greystones are noted. The cycle and pedestrian facilities in the area are
poor and significant improvements in the wider area are needed. However, I note that the
proposed development will add significant improvements to the public realm in the
immediate vicinity and this is to be encouraged. It is inevitable that traffic in all forms will
increase as more housing comes on stream. However, I am satisfied that most of the
ingredients are in place to encourage existing and future residents to increase modal shift
away from car use to more sustainable modes of transport and this can be achieved by the
implementation of a mobility management plan and a car parking strategy to be submitted
prior to the commencement of development.”
39. As the board states in written submissions “[t]he obligation is to provide the main reasons
on the main issues (see e.g. Balscadden [Road SAA Residents Association Ltd v. An Bord Pleanála,
[2020] IEHC 586, [2020] 11 JIC 2501 (Unreported, High Court, 25th November, 2020)] § 39 and at
least ten High Court judgments since).”
40. Balscadden noted that the main guidance on reasons was Connolly v. An Bord Pleanála
[2018] IESC 31, [2021] 2 I.R. 752, [2018] 2 I.L.R.M. 453, [2018] 7 JIC 1701 and that Balz v. An
Bord Pleanála [2019] IESC 90, [2020] 1 I.L.R.M. 367, [2019] 12 JIC 1202 did not create an additional
layer of obligation as to reasons but rather was about dismissal of a point in limine. As the board
points out in the present case, Balz could not have been intended to be a radical new departure in
relation to the law of reasons. If the Supreme Court were going to do that, they would do it expressly
and would outline the departure from the authorities on reasons, as well as considering the practical
implications involved.
41. In Sliabh Luachra against Ballydesmond Wind Farm Committee v. An Bord Pleanála [2019]
IEHC 888, [2019] 12 JIC 2017 (Unreported, High Court, 20th December, 2019), McDonald J. said at
para. 38 that requirement for reasons does not require a submission-by-submission analysis, at
least not in every case.
42. In Friends of the Irish Environment CLG v. Government of Ireland [2020] IEHC 225, [2020]
4 JIC 2405 (Unreported, High Court, 24th April, 2020) (currently under appeal but not on this point),
Barr J. at para. 122 noted that reasons can be provided on an issue-by-issue basis.
43. In Balscadden, I attempted to summarise the practical effect of Connolly, in essence as
requiring the main reasons on the main issues. This standard has been applied in numerous cases
since then:
(i) Atlantic Diamond Ltd v. An Bord Pleanála [2021] IEHC 322, [2021] 5 JIC 1403
(Unreported, High Court, 14th May, 2021) §§8, 14, 18.
(ii) Clifford and Sweetman v. An Bord Pleanála [2021] IEHC 459, [2021] 10 JIC 1501
(Unreported, High Court, 15th October, 2021) §63.
(iii) Flannery, Nolan and Kearns v. An Bord Pleanála [2022] IEHC 83, [2022] 2 JIC 2504
(Unreported, High Court, 25th February, 2022) §§135, 147, 157, 158.
(iv) Stanley v. An Bord Pleanála [2022] IEHC 177, [2022] 3 JIC 2805 (Unreported, High
Court, 28th March, 2022) (Phelan J.) §67.
(v) Cork County Council v. Minister for Housing, Local Government and Heritage [2022]
IEHC 281, [2022] 5 JIC 2701 (Unreported, High Court, 27th May, 2022) §81.
(vi) Monkstown Road Residents’ Association v. An Bord Pleanála [2022] IEHC 318, [2022] 5
JIC 3106 (Unreported, 31st May, 2022) (Holland J.) §64 (leave to appeal was sought
regarding the application of that standard in Monkstown Road Residents’ Association v.
An Bord Pleanála [2023] IEHC 9, [2023] 1 JIC 1907 (Unreported, High Court, 19th
January, 2023)).
(vii) Killegland Estates Ltd v. Meath County Council [2022] IEHC 393, [2022] 7 JIC 0106
(Unreported, High Court, 1st July, 2022) §75, 78, 79, 99, 114, 190.
(viii) Protect East Meath Ltd v. Meath County Council [2022] IEHC 395, [2022] 7 JIC 0108
(Unreported, High Court, 1st July, 2022) §57.
(ix) McGarrell Reilly Homes Ltd v. Meath County Council [2022] IEHC 394, [2022] 7 JIC 0107
(Unreported, High Court, 1st July, 2022) §§38, 42.
(x) Hickwell Ltd and Hickcastle Ltd v. Meath County Council [2022] IEHC 418, [2022] 7 JIC
1206 (Unreported, High Court, 12th July, 2022) §47.
(xi) Foley v. Environmental Protection Agency [2022] IEHC 470 (Unreported, High Court,
26th July, 2022) (Twomey J.) §227.
(xii) Sherwin v. An Bord Pleanála [2023] IEHC 26, [2023] 1 JIC 2701 (Unreported, High
Court, 27th January, 2023) §§227, 237.
(xiii) Glassco Recycling Ltd. v. An Bord Pleanála [2023] IEHC 293 (Ferriter J.), §67.
44. While it is probably too much to expect that all cases will word the same point identically, it
is clear that there is a centre of gravity in the jurisprudence which I think could reasonably be
described as converging around the concept of the obligation being to provide the main reasons on
the main issues. Virtually all authorities are consistent with Balscadden insofar as it adopts that
interpretation of Connolly.
45. As regards the question of whether the inspector here gave the main reasons on the main
issues insofar as concerns traffic, certainly the report does not address the full detail of the
applicants’ submission. But it provides a broad reason as to why that was not accepted. The board
did agree that there would be an increase in traffic, but referred to a number of features that may
mitigate this to an extent that the board considered acceptable. The lack of objection by the local
authority is also considered in a context where this is not an appeal decision.
46. Also notable is the fact that the board introduced condition number 11 which required that
the internal road network be compliant with the Design Manual for Urban Roads and Streets (DMURS)
standard. In addition, the board added condition number 14 which requires the submission and
agreement of a mobility management plan.
47. The applicant is obviously dissatisfied with this reasoning; but on the law as it stands at the
moment, the decision passes the minimum standards. To require anything more would be to get
into an area of a requirement to give micro-specific reasons for sub-issues. There isn’t such a
requirement.
48. The applicants submit that “it is hard for these losers to accept the position” without being
given further reasons, but that is not the test. A decision-maker cannot be required to give a level
of reasons that would satisfy the losing party – that would be a fool’s errand anyway. What the
decision-maker has to do is give the main reasons on the main issues, and the board has done that
here.
49. The applicants claim that their submission was “simply overlooked”, but there is no basis for
that. It is clearly signalled by the inspector that technical objections were raised.
50. Insofar as outsize reliance is attempted to be placed on certain comments of Holland J. in
Ballyboden Tidy Towns Group v. An Bord Pleanála [2022] IEHC 7, [2022] 1 JIC 1001 (Unreported,
High Court, 10th January, 2022), it is clear from paras. 278 to 280 that there is consensus on the
legal principle that the requirement is to give the main reasons on the main issues. The court in
that case stated that such main reasons were required, identified one of the main issues and
concluded having examined such reasons that were given on that issue that they didn’t constitute
“main reasons”.
51. Ballyboden is certainly not authority for the proposition that all a participant in a process
has to do is to produce an expert report in order to force the decision-maker to produce a more
detailed decision than might otherwise be the case, or that a mere clash of experts is enough to
warrant some form of more detailed reasons. A decision-maker can prefer one expert to another as
long as she gives the main reasons on the main issues. If it is broadly clear why one expert is
preferred, then the requirement is satisfied. Here, the board basically accepted that there would be
additional traffic but that there would be elements in place to mitigate that. Reasonable people can
and no doubt will disagree about that, but the basic broad logic of the decision-maker is acceptably
clear.
52. The applicants predictably and indignantly deny that they want a detailed response. They
try to argue that all they want is to know as between their expert and the developer’s experts why
the board prefers the developer’s experts. But in practice that comes down to something fairly close
to a detailed refutation. The applicants over-interpret the concept that the points made in
submissions should be addressed. As a bald proposition, that is not the law.
53. Not all points need to be addressed, only the main issues; and even they don’t need to be
“addressed” in a narrative type of treatment or even in a totally complete manner – only the main
reasons need to be given.
54. More fundamentally, it is not up to an applicant to dictate the form of the decision. For
example, while loud complaint is made about issues of methodology and construction traffic not
having been addressed, one has to read the decision not solely from an applicant’s point of view (an
impossible standard), but from the starting point of it being valid rather than invalid where possible.
One has to stand back and ask what the decision is fundamentally saying. The obvious interpretation
here is that even if the development creates an increase in traffic and, therefore impliedly, even if
there is some merit in the criticisms being made, nonetheless the effects can be mitigated to an
acceptable extent. For good measure, the inspector notes that lower density accommodation will
undermine the long-term viability of public transport. Construction effects are by their nature
generally ephemeral in the long run and often won’t constitute main issues, and no failure to give
the main reasons on the main issues has been demonstrated here.
55. Analogous principles apply in other areas of the law. For example, an applicant for asylum
does not win their claim just because they come forward with a medical report. Such a report does
not have to be knocked back on a point-by-point basis. It is open to the tribunal to say that, without
quibbling with the expert report, it doesn’t determine the issue, because an applicant’s injuries, real
as they may be, didn’t necessarily happen in the way the applicant says they happened. By analogy
here, it is accepted that there will be traffic impacts, but even assuming that the applicants are right
about that, that doesn’t mean that the application should be refused.
56. I have helpfully been provided with the inspector’s report in Ballyboden. While this is by no
means a completely unreasoned document, the ultimate conclusion and, to some extent, the analysis
is somewhat on the stark side and the board in submissions here didn’t strongly disagree with that.
Viewing the wording there, it is understandable how Holland J. might have been uncomfortable with
the level of reasons provided. That aspect must be regarded as fact-specific. However, reasons are
clearly provided in the present case.
57. If the court were to interpret the law as providing anything beyond broad reasons and
moving towards a detailed refutation of experts or others, it would impose a burden that could
rarely or never be met in practice. There can be hundreds of submissions on any given planning
application. In the present case, there were 167 observer submissions with four prescribed bodies
also getting involved. It would be unworkable to go further than requiring the broad reasons on the
broad issues.
58. Furthermore, judges don’t do more than that and it would be hypocritical to impose an
obligation on administrative bodies that I wouldn’t be prepared to take on for myself. Such a more
stringent obligation would also have a series of unintended consequences. It would significantly
delay decision-making because each point would have to be examined in detail for the purposes of
preparing responses. It would also create a perverse incentive whereby participants in a process
could flood the decision-maker with a huge volume of points, safe in the knowledge that if one were
accidentally omitted from the reasons, then the whole decision could collapse. That would raise an
untenable burden on the decision-maker because there is no limit to the detail and volume of the
points that could be made generally or that could be included in an expert’s report in particular.
59. There is also the real danger of creating a completely ad hoc piece of doctrine, especially if
such an obligation were confined to the board specifically or even to answering expert reports more
widely. There are so many potential administrative and judicial decision-makers and so many
contexts where general reasons have been held to be acceptable that one would fundamentally
unsettle the law in this area to require the reasons obligation to be intensified. Such problems don’t
go away merely by attempting to create a special category on an essentially lawless ad hoc basis
for expert reports.
60. Finally, it would be anomalous if the high standard of reasons that the applicants incorrectly
seek to extract from Irish administrative law were to be significantly higher than the standard of
reasons required by EU law for the special context of impact on European sites: “... where a
competent authority decides to authorise a plan or project likely to have a significant effect on a site
protected under that directive without requiring an appropriate assessment within the meaning of
that provision, that authority is not required to respond, in the statement of reasons for its decision,
to all the points of law and of fact raised during the administrative procedure”, although “it must
nevertheless state to the requisite standard the reasons why it was able, prior to the granting of
such authorisation, to achieve certainty, notwithstanding any opinions to the contrary and any
reasonable doubts expressed therein, that there was no reasonable scientific doubt as to the
possibility that that project would significantly affect that site” (Case C-721/21 Eco Advocacy v. An
Bord Pleanála, emphasis added).
Core ground 2 - material contravention regarding zoning
61. Under s. 9(6)(b) of the 2016 Act, the board can materially contravene the development plan
but not “in relation to the zoning of the land”. The issue then is – what is “zoning”?
62. That is a deceptively simple question to which one might have thought one had the answer
prior to contact with the present case. But the question has brought out a range of ambiguities that
now require to be resolved. To get a proper handle on that question one has to look at the overall
situation.
63. The starting point, as always, is the statute; and s. 10(2)(a) of the Planning and
Development Act 2000 states that the development plan shall include objectives for “the zoning of
land for the use solely or primarily of particular areas for particular purposes (whether residential,
commercial, industrial, agricultural, recreational, as open space or otherwise, or a mixture of those
uses), where and to such extent as the proper planning and sustainable development of the area,
in the opinion of the planning authority, requires the uses to be indicated”.
64. That involves not the concept of “use” simpliciter (as in the general sense of the 2000 Act
which distinguishes between “use” and “works”) but a use for a particular purpose. The purpose for
which particular land is to be used is intimately and inextricably connected to, and for most purposes
functionally indistinguishable from, the type of works or uses that will be permitted on the particular
land to which the zoning relates. Yes, perhaps a council could designate lands for a purpose in
purely abstract terms, say as a “village centre”, without specifying what sort of developments that
would involve. But any attempt to implement such a vague zoning would immediately throw up a
need to answer the question of what type of developments were compatible with such a zoning. So
whether a council addresses the issue directly or indirectly, the use of lands for particular purposes
comes down to some concept of the type of thing that is to happen on the lands, whether that is
works or “uses” in the narrower sense.
65. Such an interpretation is backed up by the ministerial guidelines on development plans
which, while of course not law and while of course are not something that in themselves change the
interpretation of the Act, are nonetheless informative. The fact that they were adopted after the
decision here (on 1st July, 2022) is irrelevant because I am consulting them only to illustrate and
illuminate the ways in which the concept of zoning has been applied and understood. That doesn’t
change the meaning of the legislation but it helps orient one’s thinking about it. Paragraph 6.2 of
the guidelines says:
“Land-use zoning is therefore about identifying land needed for particular use types, the
best locations for such land-uses and the acceptability or otherwise of the various classes of
land-use within any particular zoning. It also allows for the identification of areas suited to
a combination of uses, which is particularly important to facilitate flexibility and mixed-use
development to support compact growth and generate activity within urban centres, in line
with Town Centre First policy. The provision of land-use zoning within the development plan
is intended to provide a degree of certainty and clarity to the community, landowners,
developers and investors regarding future development.”
66. Paragraph 6.2.2 in particular headed “Consistency in Zoning Objectives” says:
“In order for development plans to have coherence across administrative boundaries, a
greater degree of consistency is required in the zoning objectives utilised by planning
authorities. While there are a relatively small number of core zoning objectives focused on
principal land use and development types, such as residential, employment, town centre,
agriculture or amenities, these can vary greatly in their wording and remit, especially
between different local authority development plans. When such objectives are compared
across planning authority boundaries, this can result in a degree of ambiguity and confusion
in the development priorities for a zoning type, especially when examined on a regional or
national basis. This wide variation in zoning objectives also militates against the monitoring
of development trends, both regionally and nationally. Certain zoning objectives can also
be overly specific or narrowly devised, which is not appropriate to the general purpose of
land-use zoning. From the perspective of an applicant for planning permission, this can give
rise to unnecessary variation in the purpose for which certain lands or locations may be
zoned, when considering different locations for development and investment. Accordingly,
there is a need for greater standardisation in zoning objectives in order to enhance
consistency, both within local authority areas and across the Country. Appendix B to these
Guidelines provides a list of zoning objectives that planning authorities may incorporate into
development plans which allow for a degree of local variation where necessary, but achieves
the required standardisation on a national basis.”
67. Appendix B to the guidelines referred to indicates illustratively a number of possible sub-
categories of zoning and acknowledges that in making zoning decisions a council is not limited to,
for example, a simple category of “residential”. The ministerial guidelines give, as an example, a
proposed zoning “RS residential” or, alternatively, “R1 new residential” and provide for a series of
other possible zonings that could include a residential element such as “UC urban core” or “DC
district centre”. Similarly, commercial purposes are sub-divided into a number of options, as are
community-type purposes. There is no suggestion that councils should be prohibited from being
more specific than say a mere “commercial” label, or should be unable to link particular types of say
commercial use to particular sites.
68. McDonald J. in Highlands Residents Association v. An Bord Pleanála [2020] IEHC 622, [2020]
12 JIC 0201 (Unreported, High Court, 2nd December, 2020) reflected this approach at para. 37:
“In my view, counsel for the Board was correct in his submission that zoning relates to the
use for which lands are designated. This seems to me to follow from the terms of s. 10 (2)
(a) of the 2000 Act which expressly refers to the zoning of land ‘for the use solely or primarily
of particular areas for particular purposes…’ That language is also reflected in para. 20
of the Fourth Schedule to the 2000 Act. It seems to me that the language of s. 10 (2) very
clearly establishes that zoning of land means the designation of that land for a particular
use. It is therefore necessary to consider whether, under the terms of the County
Development Plan (as varied by Variation No. 2) the subject lands are zoned for residential
use. Having regard to the decision of Simons J. in Redmond [v. An Bord Pleanála [2020]
IEHC 151, [2020] 3 JIC 1003 (Unreported, High Court, 10th March, 2020)], the labels used
by the planning authority are not conclusive in this context. I must therefore consider the
substance of the relevant objectives of the County Development Plan (as varied) in order to
determine its true nature. Furthermore, having regard to the case law cited in para. 25
above, I must also consider the terms of the County Development Plan (as varied)
objectively and construe them by reference to the way in which they would be understood
by ordinary reasonably informed members of the public without legal training as well as by
developers and their agents.”
69. As in effect reflected in the ministerial guidelines, the words “to such extent” in s. 10(2)(a)
of the 2000 Act have the natural meaning that the council concerned can cut down the broad
categories of zoning such as “residential” with a view to identifying particular types of residential
purposes (or other purposes) in particular zoned lands. There is no necessity or logic to reading the
statute in an extremely inflexible manner that would put councils in handcuffs, as being limited to
the broad headings of recreational, commercial, industrial, agricultural and so on alone, without any
ability to make any more specific decision as to the types of residential, commercial or other
purposes that are appropriate for a particular piece of land. That would be a massive intrusion on
the autonomy and freedom of the statutory decision-maker which would be unjustified by any clear
basis in the text. It would also be highly illogical in planning terms. Such an unwarranted
interpretation would conflict with the express statutory requirement of proper planning and
sustainable development, which imply that a decision-maker must have sufficient flexibility to
achieve those ends. We are not just playing with words here – this is about whether councils are to
be hamstrung in their assigned statutory mission to promote good planning.
70. The board made the submission that because “density” is referred to in the first schedule to
the 2000 Act (part II, para. 1) among the matters which may, rather than must be included in a
development plan, then it must be “different from, and … not included within, zoning objectives”.
However, that is absolutely not what the first schedule says. It has the effect that stand-alone
objectives regarding density and a whole series of other matters may be included in the development
plan. That much is fairly obvious. But that does not mean that objectives or provisions relating to
zoning cease to be such objectives or provisions merely because they include requirements relating
to such matters. There is no rigid distinction in the first schedule as to what can be a zoning objective
and what cannot be. A council is not excluded from including elements of parts I or II, for example,
when making zoning decisions. Objectives in part III relating to identification of community facilities
could give rise to a zoning objective, as could environmental protection in part IV or reserving land
for infrastructure in part V. Needless to say, those objectives could be met otherwise than by way
of zoning, but that does not preclude their inclusion in zoning objectives.
71. Going down the road of an extremely narrow definition of zoning objectives, as at times
seemingly argued for by the board here, would in effect exclude almost anything referred to in the
first schedule. That would emasculate the flexibility and jurisdiction of local government to specify
zoning in the exercise of its statutory powers (as underpinned of course by Article 28A of the
Constitution). If there was ambiguity, which there isn’t, there must be some presumption of local
autonomy in the preparation of the plan and more specifically in the framing of zoning objectives
(see the emphasis on protecting the role of local authorities in R. v. Secretary of State for the
Environment ex parte Norwich City Council [1982] QB 808, [1982] 1 All E.R. 737, [1982] 2 W.L.R.
580, 80 LGR 498, 126 Sol Jo 119 per Lord Denning MR at p. 824, Cork County Council v. Minister
for Housing, Local Government and Heritage [2022] IEHC 281, [2022] 5 JIC 2701 (Unreported, High
Court, 27th May, 2022)).
72. The compensation provisions of the fourth schedule of the 2000 Act are not hugely
determinative, not least because they are worded in a different manner. Paragraph 20 of the fourth
schedule reads as follows: “[t]he development would contravene materially a development objective
indicated in the development plan for the zoning of land for the use solely or primarily of particular
areas for particular purposes (whether residential, commercial, industrial, agricultural, recreational,
as open space or otherwise or a mixture of such uses)”. This was discussed in Abbeydrive
Developments Ltd v. Kildare County Council [2005] IEHC 209, [2009] 3 I.R. 58, [2005] 6 JIC 1707
where Macken J. took a relatively limited view of the words “or otherwise” (at p. 73). However, it
is important not to over-interpret this. It would be restrictive and indeed destructive of proper
planning and sustainable development if a planning authority was for example confined to the word
“residential” simply because that is used in a general way within a general provision of the 2000 Act.
The overriding importance of proper planning and sustainable development, which is the cornerstone
of the 2000 Act, strongly militates against an interpretation which would mean that the local
authority when framing zonings was limited to headings like “residential” alone, and unable to
distinguish within that in any way between, for example, campsites, caravan parks, detached
houses, apartment blocks, aparthotels, or housing estates.
73. On the other side of the coin however, merely because something is described as a zoning
objective by a particular council in a particular development plan does not make it a zoning objective
as a matter of interpretation of the 2000 Act: Redmond v. An Bord Pleanála [2020] IEHC 151, [2020]
3 JIC 1003 (Unreported, High Court, 10th March, 2020). We must note one point of nomenclature.
In that case, Simons J. treated matters related to zoning as being equivalent to a zoning objective
and there is much discussion of what is such an objective; but the wording of the statute does not
refer to contravening an “objective”. Section 9 of the 2016 Act is clear that the issue is whether the
contravention of a plan is “in relation to the zoning of the lands”, which McDonald J. held at para.
44 of Highlands Residents Association was a wide phrase. It is not clear to me that anything major
turns on this in the present case, however. To repeat however, a council’s view of what is a zoning
objective is not a determinative one and the same logic applies to the board. Just because it decides
that something is not a provision of the plan in relation to the zoning does not make the board right
or even presumptively right, because it is a matter of interpretation.
74. Ultimately, the purpose of zoning provisions generally, and zoning objectives in particular,
is to specify the purposes for which the lands may be used, which in turn means the particular type
or category of works and uses which may be carried out on such lands. The concept of the type of
development is really critical to determining what is a zoning objective and what is not. If the
objective limits the type of development in some way that is clearly distinguishable from a different
type of development, then it can be said to be a zoning objective. If, on the other hand, it merely
regulates the detail of the types of permitted developments involved, for example by reference to
scale, design, density or similar factors, where such factors are not ones that change a development
from being of one type to being of another distinct and distinguishable type, then the provision is
not a zoning objective.
75. Thus, a development plan can legitimately distinguish between land zoned for different types
of housing. Thus it can distinguish between say, land suitable for a campsite, sheltered
accommodation or an aparthotel. Those specifications would be zoning objectives. Whereas if a
council went further and included provisions in relation to density of such housing, that does not
relate to a distinction between different types of development, and so is not a zoning objective. This
can be something of a fact-specific exercise. For example, in relation to floor space, a large house
and a small house are still houses. But in many situations, as a particular development gets bigger
or smaller, it turns into a different type of development. Thus, a zoning objective could legitimately
distinguish areas suitable for local shops as opposed to convenience stores, for supermarkets as
opposed to superstores, for hypermarkets as opposed to retail outlets. Such a distinction could
legitimately be based on, for example, floor space. Such size or floor space criteria legitimately
mark a divide between distinct types of development and thus distinct uses, and consequently
constitute zoning objectives, as opposed to mere detail, design or regulation within a single purpose
or a type of development.
76. Applying all of this to the present case, there is no doubt that the way in which the council
have framed the Greystones, Delgany and Kilcoole Local Area Plan 2013-2019 here means that the
R22 residential zoning is expressly linked to a maximum density of 22 units per hectare. But a
density provision like this does not distinguish between particular types of development permitted
and thus does not relate to the purposes for which the land can be used in the sense of the 2000
Act. It is not a zoning provision.
77. The council could, for example, have distinguished between land suitable for houses as
opposed to land suitable for apartments (and indeed they did do that to some extent as we will see
from the next heading, although not in a purported zoning objective), or identify land suitable for
both. That would have been a zoning objective because it relates to the type of developments
permitted. Of course, they are all residential, but a council is entitled to be more specific than such
a bald heading, for the reasons outlined.
78. It is therefore open to a planning authority to identify the purpose to which land can be put
by means of a zoning provision by reference to either:
(i) the specific type of developments permitted, thus for example under the commercial
heading distinguishing land suitable for a logistics warehouse from an individual
commercial warehouse or an abattoir from an incinerator, or under the community
heading to distinguish a place of worship from a hospital; or
(ii) secondary characteristics provided that such characteristics go to the type of
developments permitted, thus distinguishing the local shops from hypermarkets by
reference to floor space or otherwise.
79. But by contrast, if the terms of the plan relate to details, design, orientation, density, scale
or some other feature applicable within a particular type of use, then that is not a zoning provision.
80. The applicants submit that “the planning authority has itself linked density to zoning” which
is absolutely correct. The problem however is that “zoning” has an autonomous meaning in the
2000 Act, does not necessarily mean whatever the particular council decides to include under the
heading of zoning, and certainly doesn’t mean that here. A provision of a plan regarding density is
not a provision regarding zoning, even if it is included within the literal terms of a zoning objective
in a particular plan.
81. This ground therefore fails.
Core ground 3 - material contravention related to apartments
82. Policy RES5 of the Local Area Plan states as follows:
“RES5: On undeveloped residentially zoned land, it is an objective of the Council to provide
for the development of sustainable residential communities up to a maximum density, as
prescribed by the land use zoning objectives indicated on Map A and described in ‘Table
11.1: Zoning Matrix’. In existing residential areas, infill development shall generally be at a
density that respects the established character of the area in which it is located, subject to
the protection of the residential amenity of adjoining properties. However, where previously
unsewered, low density housing areas become served by mains sewers, consideration will
be given to densities above the prevailing density, (up to 10 / ha, depending on local
circumstances), subject to adherence to normal siting and design criteria. Apartments
generally will only be permitted within Greystones Town Centre, Kilcoole Town Centre,
Delgany Village Centre, Neighbourhood Centres, Small Local Centres, Greystones Harbour
and North Beach Action Plan, South Beach Action Plan and within 10 minutes walking
distance of Greystones train station. Within existing residential areas, regard shall be paid
at all times to the overriding objective of the Council to protect the residential amenity of
these areas and to only allow infill residential development where this reflects the character
of the existing residential area. Apartments will not normally be permitted on sites
surrounded by predominantly single family occupied housing estate developments.”
83. This reflects objective HD13 of the County Development Plan:
“HD13 Apartments generally will only be permitted within the designated centres in
settlements (i.e. designated town, village or neighborhood [sic] centres), on mixed use
designated lands (that are suitable for residential uses as part of the mix component) or
within 10 minutes walking distance of a train or light rail station.”
84. The development at issue in the present case is not in the “village centre”, and indeed on
that basis the developer identified the inclusion of apartments in the scheme as a potential material
contravention. However, the board appears not to have agreed with this and treated the issue as if
there was no material contravention. Obviously, the plan does confer some planning judgement on
the board by reference to the provision that apartments “generally” will only be permitted in the
village centre. But how much planning judgement?
85. A qualifier like “generally” does not confer open-ended flexibility or planning judgement.
Any departures from that must themselves be limited in nature and peculiar to their own facts, and
not such as can be generalised in a way that would undermine or rewrite the plan. If the basis for
an exception was one that could itself be applied generally, then the plan would indeed be materially
contravened. To put it another way, the word “generally” does create flexibility, but only in ball-
park terms, as in Jennings v. An Bord Pleanála [2023] IEHC 14, [2023] 2 JIC 1711 (Unreported,
Holland J., 17th February, 2023). For example, an apartment complex on a suitable site across the
road from, but just outside, a village centre might come within the ball-park, but an apartment
development which is well outside the area and that is favoured on a logic that could apply to a wide
number of apartment developments would be outside the ball-park.
86. Notable here is the link with the heritage of the village, connecting it with the church and
Carmelite monastery. This is emphasised in para. 2.1.1 of the developer’s response document which
states:
“It is considered that appropriate links applies to visual, physical and social links to the
village core. The urban fabric includes the physical environment including form, scale,
density and connections and extends to socio-cultural, ecological and economic structures.
The core of Delgany is not defined but may be assumed to be focused on Church Road and
in particular the section between Bellevue Hill, Delgany Wood and Convent Road with
emphasis on the area from Convent Court, opposite the application site towards the south.
The core of Delgany may be considered to include as a focal point, Christ Church on Church
Road, which was completed in 1789 and is a notable gothic building with a graveyard to the
west and the north side of the church. To the west of Christ Church fronting Church Road
is Delgany national school. The small irregular section of Church Road between the junction
of Convent Road and Bellevue Hill connects five roads and contains many of the buildings
associated with Delgany including the Wicklow Arms (1856) and the Delgany Inn (mid-19th
century). The section of Convent Road between the application site and Church Road consist
of a number of commercial businesses including food shops, cafes and the [Horse] and
Hound (1790). The existing site is oriented towards Convent Road and the core of Delgany.
The existing Convent property is set back from the road with a solid boundary topped with
high railings with a variety of solid planting behind. This was raised at the tri-partite
meeting. In relation to a visual link to the core of Delgany, the existing long boundary wall
and railing which is not considered of conservation value (see conservation report which
reports it is a modern addition) will be removed. A new boundary will be lower with a lighter
railing so that the entire development is visually more connected to the core, making the
scheme an integral part of Delgany and removing the ‘gated’ situation that currently applies.
The steel gate and solid piers will be removed and a modern entrance designed as in [sic]
invitation into the scheme and particularly to the protected structure. The wall will be set
back to the north of the existing main entrance. The high scrub that has grown behind the
railing will be removed and new low, softer[,] more open planting retaining some trees will
allow views into and out of the scheme while providing biodiversity and accessibility. Three
main connections are located on Convent Road which provide the main direct links and
connection to the core and one main access to Bellevue Hill. Five internal secondary
connections are proposed as well as secondary access to Bellevue Hill.”
87. The report continues at para. 2.1.2 to state:
“Access No. 1 Convent Road - access beside Gatehouse
The closest connection to the core is the existing access beside the gate lodge. The location
of this access to the site is at the south east boundary and consists of two piers and a high
metal gate. The Planning Authority to improve the footpath connection at this point. All of
the render, including the moulded caps to the piers, consists of hard sand and cement,
dating from the middle years of the 20th century. The permanently closed steel gates close
the Convent grounds visually and physically from the core of Delgany and this is reinforced
by the dense planting adjacent.”
88. It goes on to say:
“This access provides a key pedestrian and cycle connection into the Convent grounds c.130
m from the junction of Convent Road and Church Road, the core of Delgany. This connection
will bring pedestrians from the core of Delgany into a new public open space to the front of
the Protected Structure (a new creche and community/cultural space, residential homes and
open space to the north west that connects to the permitted development at Richview[)].This
connection represents the anticipated desire line into the scheme and will provide an
accessible access to the creche and new community facility.”
89. At para. 2.1.4 it states:
“Delgany is part of a heritage trail which indicates parking, walking trails and points of
interest. The proposed development is wholly consistent with the Heritage trail and will
provide new linkages between Bellevue Hill and Convent Road and onto Church Road and
Priory Road. In addition, it will allow the Protected structure be viewed from a public open
space and the removal of the modern extension will restore the protected structure to the
original layout. The large modern structure to the side of the Church dominates the building
and by removing it, will allow the protected structure to be restored visually to how it was
designed. The Protected Structure which is unoccupied since the departure of the Carmelite
order from Delgany will be reused and available as a community and cultural facility and will
enhance the heritage trail.”
90. It continues:
“The proposed development contributes to the objectives outlined above and in particular
provides a rejuvenation of the village, be [sic] creating a new centre for the community while
also creating a more attractive place to live and work. The reuse of the protected structure
as a community facility and for cultural uses will enhance cultural awareness and community
identity. This will also reinforce the heritage identity of the area. The foot connections
through the village will be expanded by linking Bellevue Hill to Convent Road through the
site and onto Church Road and Delgany Wood. Overall, the accessible shared green space
for recreation, linking the permitted open space at Richview towards the south west will
enhance the heritage trail and improve the potential of tourism in the area.”
91. Also relevant is para. 8.2 of the inspector’s report which records the council’s view that:
“[t]he extension outwards from Delgany town centre is considered logical and acceptable
from a phasing perspective”.
92. At para. 10.2.6 the inspector stated:
“The site is located at the edge of Delgany Village centre, a location that provides a variety
of local retail, restaurant/café and other services including a primary school and a church
within easy walking distance. Further afield, to the east are the commercial and leisure
facilities associated with south Greystones.”
93. At para. 10.4.2 the inspector states:
“Open spaces are provided throughout the scheme, with a large area combined with a new
civic plaza at Convent Road to the front of the Chapel, numerous pocket parks and the linear
green spine that runs through the entire scheme. Other public open spaces are found at the
margins and are more of a visual amenity together with buffer space for tree retention and
are to some degree also usable spaces.”
94. At para. 10.6.3 the inspector said:
“In fact, the opening up of the forecourt area and the provision of a new public plaza will
enhance and set off the centre piece role that the church will now take. In my view the
three storey over basement apartment block to the rear of the church and villa house will
act as a backdrop and focus one’s eye towards the steeply angled gable of the church itself.
I am satisfied that the urbanisation of the former convent grounds has been designed
sensitively and that the public realm gain from Convent Road will significantly enhance the
character of the area and expand the public domain of Delgany Village in a positive way.”
95. While it may be something of a line call, a number of site-specific factors are particularly
important in regarding the flexibility as sufficient here: proximity to the village centre, additional
public realm provision in the form of the new plaza, a new crèche and community/cultural space,
open space provision including pocket parks and the linear green spine, the rejuvenation of the link
between the village and its historical heritage in the form of the church and monastery, the re-
opening of access to these structures, and the related issue of permeability particularly in the context
of established heritage trails. This is certainly not an example of merely building out into rural areas
in a way that could be replicated at any edge of centre site. Having regard to all of the foregoing,
including the very considerable public realm provision and indirect enhancement of the village centre
and linkages to its history and heritage, the zone of planning judgement conferred by the word
“generally” has not been exceeded here, because such substantial and site-specific features of this
particular development mean that no comfort is thereby provided for other potential developments
in a way that would undermine the requirement that matters are to be “generally” as defined by the
plan.
96. As the domestic law issues fail, I now turn to the EU law issues.
EU law issues in relation to development consent
97. There were two primary issues:
(i) EIA-related reasons in relation to traffic; and
(ii) strict protection of bats.
Core ground 8 – EIA reasons in relation to traffic
98. Core ground 8 has been dealt with above as a domestic law point. The applicants provided
no convincing EU law-related authority or material either in this jurisdiction or any of the 27 other
current or former member states, or at a European level, or otherwise, which would require a
different conclusion when considering the matter from the standpoint of the EIA directive (see Toole
v. Minister for Housing (No. 3) [2023] IEHC 378 para. 86). This point has not been made out.
Core ground 6 - strict protection in relation to bats
99. The basic problem for the applicants is that, as the board points out in its submissions (para.
51):
“The arguments made by the Applicants in their submissions (§§52-66) are quite different
to those made in the Statement of Grounds [note refers to pleadings, pp. 8 (core ground 6),
15-19]. There is no sign in the submissions of any of the six legal errors pleaded by the
Applicants under this core ground in the Statement of Grounds.”
100. Insofar as the applicants have now made new arguments based on the EIA directive, and in
particular arts. 4 and 11 and para. 3(b) of Annex IIA, none of these arguments are pleaded. As the
board notes at para. 55 of its submissions:
“As is apparent, there is no reference in the core ground to any alleged breach of the EIA
Directive. The Board objects to any interpretation of detailed grounds 31-46 that goes
beyond this core ground.”
101. Insofar as the sub-grounds are concerned, there are only two references to the EIA directive.
The first is sub-ground 39, which is obviously merely contextual, and the final phrase comes in at
para. 41 where the sub-ground states “[i]t also undermines the conclusion on EIA screening”.
102. That’s it – that barely-there, blink-and-you’ll-miss-it comment is the totality of the pleading
on which the applicants now seek to hang an elaborately confected case under this heading.
103. Beyond this isolated throwaway comment in the pleadings, the lone and level sands of the
6,912-word statement of grounds stretch far away. There is not even a single piece of supporting
legal tumbleweed on the horizon.
104. It strains credulity to breaking point to believe that when they filed the statement of grounds,
the applicants had any definite intention to make a case that the board’s treatment of strict
protection of bats was contrary to arts. 4 and 11 of, and para. 3(b) of Annex IIA to, the EIA directive.
To believe that you would have to believe:
(i) that when the applicants made an express reference to EIA in core ground 8 as
regards traffic, they were also planning to challenge the decision on EIA grounds on
other issues not mentioned in the core grounds;
(ii) that the applicants thought it was appropriate to have a whole section of the sub-
grounds devoted to EIA screening but also thought that it was not necessary or
appropriate to signal in a similarly clear manner that the EIA screening was being
fundamentally attacked on bat-related grounds;
(iii) that the applicants thought it was appropriate in drafting terms to advance an EIA
case under core ground 6 without mentioning the EIA directive in that core ground
(which refers only to the habitats directive and the Wildlife Act 1976);
(iv) that the applicants contemplated that the decision regarding bats was invalid by
reference to arts. 4 and 11 of, and para. 3(b) of Annex IIA to, the EIA directive, but
their view of drafting was such that they considered it unnecessary or inappropriate
to refer to any those provisions;
(v) that the applicants’ view of drafting was such that it was considered unnecessary or
inappropriate to refer to the EIA directive at all under that heading (instead referring
only to the “conclusion on EIA screening”);
(vi) that the applicants’ view of drafting was such that it was considered unnecessary or
inappropriate to refer to the decision as being “invalid” (or cognate terms) by
reference to the EIA directive as applied to assessment of bats, and that it was
sufficient to merely comment in passing that the treatment of bats “undermined”
the screening decision (whatever that means);
(vii) that the applicants’ view of drafting was such that it was considered unnecessary or
inappropriate to explain in the pleadings how or why the treatment of bats led to
the decision being invalid by reference to the EIA directive, or to provide any route-
map whatsoever from the reference to undermining that would lead to certiorari;
(viii) that the applicants’ view of drafting was such that it was considered unnecessary or
inappropriate to refer to the specific provisions of the transposing legislation by
reference to which any validity issue would initially have to be considered; and
(ix) that it is purely coincidental that after the statement of grounds was filed on 25th
March, 2021, arts. 4 and 11 of, and para. 3(b) of Annex IIA to, the EIA directive
came into focus by virtue of the Waltham Abbey Residents Association v. An Bord
Pleanála (No. 1) [2021] IEHC 312, [2021] 5 JIC 1002 (Unreported, High Court, 10th
May, 2021) and (No. 3) [2023] IEHC 146, [2023] 3 JIC 2403 (Unreported, High
Court, 24th March, 2023) decisions.
105. I appreciate that not everyone is blessed with an intuitive understanding of the principles of
drafting. But nobody could be that unfortunate.
106. Looking at the circumstances overall, it is obvious that there never was any definite and
precise intention to challenge the validity of the planning permission by reference to its treatment
of bats having regard to arts. 4 and 11 of, and para. 3(b) of Annex IIA to, the EIA directive. The
available and most plausible inference is that even assuming in their favour, for the sake of
argument, that the applicants had some glimmer of concern in relation to this originally, the actual
legal point only crystallised for them as the Waltham Abbey proceedings unfolded subsequently.
Such things happen; but to make a point that occurs to one after the event one has to seek to
amend one’s pleadings, not seize on a fortuitous stray reference within the pleadings to try to re-
programme the whole case under this heading. The abandonment of the specific sub-grounds as
pleaded within this core ground only reinforces the sense of complete and impermissible re-
configuration of the case.
107. Even if I am wrong on all of the foregoing, O. 84, r. 20(3) RSC requires this point to be
dismissed because it is wholly unparticularised, as correctly pleaded by the notice party at para. 41
of its statement of opposition. This is a passing comment as opposed to “any kind of proper ground
invoking a legal basis for quashing a decision”, as the board submitted. It would be unfair to the
opposing parties to allow the applicant to build a tottering edifice reaching to certiorari on such an
ephemeral foundation.
108. The CJEU has recently confirmed that the pleading requirements reflected in rules of court
are perfectly consistent with EU law. In Case C-721/21 Eco Advocacy v. An Bord Pleanála, the court
said:
“23 Moreover, the Court has held that national procedural rules according to which the
subject matter of the dispute is determined by the pleas in law put forward at the point in
time at which the action was brought are consistent with the principle of effectiveness in so
far as they ensure proper conduct of proceedings by, in particular, protecting them from the
delays inherent in examination of new pleas (judgment of 6 October 2021, Consorzio Italian
Management and Catania Multiservizi, C‑561/19, EU:C:2021:799, paragraph 64 and the
case-law cited).
24 In the present case, the procedural rules at issue, as described in paragraph 17 above,
do not appear to be such as to make it impossible or excessively difficult in practice to
exercise the rights conferred by Directives 2011/92 and 92/43, at issue in the main
proceedings, but, on the contrary, are such as to facilitate the proper conduct of proceedings
by requiring that the pleas relied on in the action be raised with a sufficient degree of
precision.”
109. The applicants rely in particular on the judgment of the Court of Appeal, upholding Simons
J. in this respect, in Friends of the Irish Environment v. Government of Ireland, Minister of Housing,
Planning and Local Government, Ireland and The Attorney General [2021] IECA 317, [2021] 11 JIC
2603 (Unreported, Court of Appeal, 26th November, 2021). But that was a very different case, and
obviously dates from the pre-Eco Advocacy era. For starters, the pleading there was a lot clearer
and more detailed. Paragraph 24 of the judgment sets out paras. 9-12 of the statement of grounds
as follows:
“9. The Environmental Report goes on to consider alternatives and the assessment of the
preferred scenario. The various alternatives are identified at Chapter 7 of the Environmental
Report in which five alternatives are identified. These are each briefly described, and a
tabular format appended where, for each environmental issue, each alternative is given
either a 0/–/+ or in many cases a combination of these. These are intended to indicate
potential neutral, negative and positive effects of the alternatives. There is no explanation
of how these assessments were made or how or for what reason these values were assigned
or the qualitative or quantitative basis for their inclusion. There is no indication as to whether
or not, or to what degree, the targets (identified in Chapter 6 for each environmental issue)
are expected to be achieved by each alternative under consideration (singly ... or in
combination). These targets are not referred to in the alternatives or assessment sections
and only reappear when monitoring is being discussed. In those circumstances there is no
adequate description or evaluation of the likely significant environmental effects of each of
the alternatives identified in the Environmental Report.
10. It is the applicant’s case that the respondents failed to consider, adequately or at all,
the reasonable alternatives to the option selected, failed to identify, describe or evaluate
adequately or at all the likely significant environmental effects of the alternatives and failed
to specify any or any adequate reasons for its preferred option over options 1, 3, 4 and 5.
11. In paragraph 7.3 the respondents simply state a preference for ‘Option 2 – Regional
Effectiveness & Settlement Diversity’ on the basis that it is the alternative allegedly most
likely to achieve these strategic environmental objectives in relation to public transport,
higher densities in city areas and focusing managed growth in supported settlements.
However, no objective qualitative or quantitative basis is provided for this selection and it is
simply baldly stated without further explanation.
12. Subsequently in Chapter 8 of the Environmental Report there is what is described as an
assessment of the preferred scenario i.e. the proposed approach actually adopted in the
[NPF]. As with the consideration of alternatives, there is no reference to the targets specified
in Chapter 3 and no assessment of the degree to which the preferred scenario will or will not
lead to the targets being meet [sic]. The assessment of the preferred scenario appears to
be limited to short discursive sections.”
110. The context therefore is that there is quite a bit of detail in the pleading albeit that there
might have been more detail. The present matter couldn’t be more different.
111. All of this was addressed by Costello J. as follows:
“136. In reply to this point, the applicant referred to Halpin v. An Bord Pleanála [2019] IEHC
352. In that case, objection was taken to arguments being advanced by the applicant which
went beyond the claim as actually pleaded in the statement of grounds. Simons J. accepted
that the applicant was not entitled to rely on general pleas to advance a specific and detailed
complaint which had not been pleaded contrary to O. 84, r. 20(3). He accepted the
unreported decision of the High Court in McEntee v. An Bord Pleanála (Moriarty J., High
Court, 10 July 2015). Simons J. summarised the observations of Moriarty J. in para. 62:-
‘… The judge went on to say that – in determining whether an argument had been
properly pleaded – the court should adopt a ‘fair and reasonable’ reading of, and
conduct a thorough and objective examination of, the statement of grounds.’
137. Simons J. applied the fair and reasonable test to the Statement of Grounds in the case
before him and concluded that the case as pleaded was broad enough to encompass the
argument advanced at the hearing. At para. 66 he held:-
‘In interpreting the Statement of Grounds, some regard must be had to the fact that
the argument advanced by the applicant would – if well founded – result in a finding
that An Bord Pleanála had not properly complied with an important piece of European
environmental legislation, namely the Seveso III Directive. The applicant should not
be shut out from even making this argument by an overly strict reading of the
Statement of Grounds.’
138. In this case, the applicant raises an important argument in relation to the application
of the SEA Directive and the issue whether it has been properly complied with in the adoption
of the NPF, which sits at the apex of all plans for development within the state and which is
to govern development decisions throughout the state for the next 20 years. While I accept
that the issue whether the reasonable alternatives were assessed to a comparable extent as
the preferred option was not expressly pleaded in the statement of grounds – and therefore
not the subject of an order for leave to seek judicial review – a related argument – namely
the adequacy of the assessment of the reasonable alternatives – was clearly part of the case
from the beginning, and the ground to which objection is now taken was clearly raised in
written submission a month before the case came to trial. The respondents had the
opportunity to respond in their written submissions of 6 March 2020, in oral submissions
and in their supplemental written submissions. On balance, I am satisfied that the impugned
pleading is not of the generic nature which was criticised in the authorities relied upon by
the respondents and, while it undoubtedly would have been preferable if an application for
leave to amend the statement of grounds had been brought, I agree with the observations
of Simons J. in Halpin; it would not be appropriate, on a pleading point, to prevent the
applicant from advancing an argument in relation to the application of a significant EU
environmental provision where the respondents have pointed to no prejudice in meeting the
point in question. In this regard, I note that there was no application to file a supplemental
affidavit by the respondents upon receipt of the written submissions on 10 February 2020,
nor was there any suggestion that there was any relevant evidence which they could have
adduced had the point been expressly pleaded in the statement of grounds, nor was it
suggested that it was a ground upon which the applicant would not have been granted leave
to seek judicial review had it been raised when leave was initially sought.”
112. Apart from the radically different context of there being a much more detailed statement of
grounds to work off, the pleading in Friends of the Irish Environment was addressed by Simons J.
on the basis that it was somewhat relevant that the plea related to an EU law point. This was
accepted by Costello J. But very respectfully, that was all before Eco Advocacy. Logically, that can’t
be the position now. If European law doesn’t create any extra latitude for pleading of EU law points,
then it can’t make any difference that an applicant stretches a forlorn arm above the surface to wave
a blue flag as she disappears wordlessly into the quicksand of defective pleadings.
113. In any event, the reading of the applicants’ pleadings here isn’t “overly strict” – it isn’t within
a country mile of being overly strict. The relatively permissive question which is being asked is
whether the point is acceptably clear. That answers itself – No. A lack of prejudice to the opposing
parties could be a useful factor to confirm a line call, as in Friends of the Irish Environment, but is
irrelevant if the point is dead on arrival.
114. Hence it follows that the applicants’ point, if you want to call it that, regarding the EIA
screening being “undermined”, isn’t a properly formulated complaint, is not properly pleaded, does
not comply with rules of court, and is not saved by any EU law requirement. The message of Eco
Advocacy is that there is no European cavalry ready to ride to the rescue of inadequately-pleaded
applications. That bad news will hit some applicants more heavily than others.
115. As those matters dispose of the administrative and EU law challenge to the consent, we can
turn to the issues of statutory validity and then to the derogation licence.
Core ground 4 – statutory validity
116. The applicants’ complaint regarding the validity of ss. 5(6) and 9(6)(c) of the 2016 Act is
totally misconceived. The argument is as put at sub-ground 22 that “section 5(6) and/or 9(6)(c) of
the 2016 Act (which makes no provision for new or updated environmental assessments, for possible
modifications to, or grants of permission in material contravention of the CDP) is inconsistent and
incompatible with the requirements of the SEA Directive by allowing for the granting of permission
in contravention of the CDP and Masterplan and therefore constitute a derogation from those plans.
This is impermissible as a matter of EU law which requires any such derogation to be within the
scope of Article 2(a) and Article 3(2)(a) of the SEA Directive.”
117. This implies either that:
(i) the legislative framework for an SEA-assessed plan can’t itself provide for
derogations (possibly unless there is a re-assessment of the plan including the
derogation from it); or
(ii) an individual consent should be assessed as if it was a plan merely because it
deviates from a plan.
118. No EU-related authority from any jurisdiction has been brought forward to support the first
proposition. Anyway, it is pointless if the derogating project is itself assessed. The second option
is obviously incorrect.
119. The submissions add a further, unpleaded twist at para. 84: “the grant of permission, without
any modification of the LAP or CDP, authorises development of a sort that—by definition—cannot
have been contemplated in the environmental assessment that preceded the adoption of the relevant
plan.” This implies that for a derogation to be effective, the plan itself has to be modified. Apart
from the pointlessness of such a procedure, there is again no authority produced to make it plausible.
120. The applicants rely by analogy on two cases, Case C-411/17 Inter-Environnement Wallonnie
ASBL, Bond Beter Leefmilieu Vlaanderan ASBL v. Council of Ministers (Court of Justice of the
European Union, 29th July, 2019, ECLI:EU:C:2019:622) and Case C-160/17 Thybaut, De Coster,
Romain v. Région wallonne (Court of Justice of the European Union, 7th June, 2018,
ECLI:EU:C:2018:401).
121. There is no analogy here. Thybaut holds that the adoption of a plan that allows derogation
from a previous plan which had been subjected to SEA is itself required to be subjected to SEA. That
does not have the effect that, where a plan subjected to SEA allows individual decisions to derogate
from it, those decisions have to be treated as plans for the purposes of the SEA directive. They
don’t. Thybaut is basically destructive of the applicants’ whole argument because it acknowledges
that a plan subject to SEA can itself provide for derogations.
122. The EIA directive applies to “projects”: art. 4. The SEA directive applies to “plans and
programmes”: art. 2(a). The habitats directive applies to both a “plan or project”: art. 6(3). This
is a project, not a plan, so SEA does not apply, even if the project is a derogation from a plan which
had previously been subjected to SEA. The distinction between a plan and a project is clear: Case
C-43/10 Nomarchiaki Aftodioikisi Aitoloakarnanias v. Ipourgos Perivallontos (Court of Justice of the
European Union, 11th September, 2012, ECLI:EU:C:2012:560). The issue here is acte clair, or acte
éclairé, no doubt arises and thus there is no question of a reference. The one thing the applicants
have got right is to point out that “[t]he correct application of Community law may be so obvious as
to leave no scope for any reasonable doubt as to the manner in which the question raised is to be
resolved” if “the matter is equally obvious to the courts of the other Member States and to the Court
of Justice” (Case C-283/81 Srl CILFIT and Lanificio di Gavardo SpA v. Ministry of Health (Court of
Justice of the European Union, 6th October, 1982, ECLI:EU:C:1982:335, para. 16)). But they
haven’t gone on to ask the obvious question – is there anything in the caselaw of any other current
or former member state, or of the European courts, that illustrates any such doubt? If there is, they
haven’t produced it in this case.
123. Unfortunately for the applicants, there are only a finite number of possibilities:
(i) EU law does not allow SEA-assessed plans to provide for derogations at all. There
is no authority for that, and such a view is inconsistent with Thybaut.
(ii) EU law does not allow SEA-assessed plans to provide for derogations without re-
assessment. There is no authority for that, and it would be pointless because the
derogation is subject to potential assessment, at least under EIA/AA.
(iii) EU law does not allow SEA-assessed plans to provide for derogations without the
plan being amended. There is no authority for that, and it would also be pointless.
(iv) EU law allows SEA-assessed plans to provide for derogations, which are themselves
to be assessed as plans. That is totally misconceived as explained above.
(v) EU law allows SEA-assessed plans to provide for derogations, which are themselves
to be assessed as projects. That is the position but it doesn’t help the applicants
because this was assessed, or at least screened, as a project.
124. Determined to be helpful, the applicants’ sub-grounds on this point conclude by saying (at
para. 23):
“It is not for the Applicants or indeed to Board to say what a compliant procedure should
be.”
125. This perhaps illustrates the wider jurisprudential point that it generally assists your case to
show how the system makes sense overall. By contrast, an it-all-depends approach, or even worse,
a position that making the law workable is someone else’s problem, is not always the most strategic.
126. The State objected to the unparticularised nature of the claim under this heading (see their
statement of opposition, para. 8), but as the point fails on the merits I don’t need to deal with that
objection.
Core ground 7 – issues regarding derogation licence
127. At the outset regarding the derogation licence, it is important to note that this point is
pleaded independently from the validity of the development concerned. The applicants did not
contend on the pleadings that the permission was invalid because the derogation licence was invalid.
128. Nor did they initially argue that they had ever so contended. The board and notice party
were legitimately emphatic that such case was never made until adverted to in submissions in the
closing minutes of the hearing. Indeed, the applicants were forced to concede that “we’ve claimed
relief not connected with any particular ground”. That of course is a complete non-starter in drafting
terms. Yes, a court can grant unpleaded relief for reasons explained elsewhere (notably by virtue
of O. 84 r. 19), but only within the pleaded grounds. The court can’t expand the case to cover new
grounds not actually pleaded. And there is simply no such ground here. That isn’t something that
can be rectified by creative interpretation of the pleadings, for the same reasons as already
addressed in relation to the flawed pleading regarding “undermining” the EIA screening above: see
Case C-721/21 Eco Advocacy v. An Bord Pleanála.
129. Independently of that, the argument, even if pleaded, would be defeated by logic. There is
no requirement in Irish law to obtain a derogation licence at any particular stage of the process. It
can be applied for before, during or after the planning permission. Even if the permission is
functionally dependent on there being a derogation licence, the fact that a developer has failed to
obtain such a licence in advance (or has obtained an invalid licence) can’t under those circumstances
make the permission invalid (unless perhaps the board relied in some determinative way on the
specific conditions of the licence actually granted, but that hasn’t been demonstrated here).
130. I make this point because we have already seen in Hellfire Massy Residents Association v.
An Bord Pleanála [2022] IESC 38, [2022] 10 JIC 2402 (Unreported, Supreme Court, 24th October,
2022) that applicants can make illogical claims that all parts of their case are mutually
interdependent. That is not always so. Either law or logic, or sometimes (as here) both, can have
the effect that the absence of an entitlement to one relief is not compensated for by any claim to
another relief. In this case, the alleged dependence of the validity of the permission on the validity
of the derogation licence wasn’t pleaded, and makes no sense anyway (save in circumstances that
don’t apply here).
131. With that important point addressed, we can now turn to the question of the challenge to
the derogation licence as an issue in itself.
132. That needs to be contextualised. The applicants here have not challenged the validity of the
European Communities (Birds and Natural Habitats) Regulations 2011 (S.I. No. 477 of 2011) by
reference to the procedure for granting derogation licences. They haven’t made a point that any
possibility of excluding public participation for derogation licences granted before, during or after a
developing consent is impermissible, and they haven’t made any plea regarding a lack of a joined-
up system or about the lack of publication of derogation licences. Nor have they made a point about
a lack of provision to revoke a derogation licence, although in fairness it would seem that the general
power to revoke under s. 22(3) of the Interpretation Act 2005 would cover the situation (because
the definition of “statutory instrument” includes a “licence”), so potentially one could see an
argument that an aggrieved person could apply to the Minister to do so. Whether that is going to
be an effective procedure or not can be left to a case where it properly arises.
133. The derogation licence is a legally separate decision under a legally separate code made by
a legally separate decision-maker. It is not a preliminary decision with any unitary process leading
to a development consent, for the purposes of Irish law. It is of course functionally related to the
development consent in that consent cannot be lawfully operated without a derogation. There are
many similar relationships in law, for example where more than one licence is required. A common
example is where a developer needs both a planning permission and a licence from the EPA.
Reinforcing that is the separate procedural system for the two decisions, particularly the fact that
leave to appeal is not required for a challenge to the derogation licence. Presumably the applicants’
claim that the licence is part and parcel of the permission only applies to legal contexts where that
works in their favour, and will be scornfully rejected in any other context, such as if the opposing
parties were to point out that their argument has the logical consequence that the applicants
shouldn’t be entitled to appeal the rejection of a challenge to a derogation licence without leave to
do so.
134. An important point is that it is obvious as a matter of domestic law (leaving aside how one
is to apply a conforming interpretation) that an extension is required to challenge a derogation
licence if the challenge is brought more than three months after the date of the licence.
135. For good or ill, Irish law works on the premise that the time period runs from the date of the
decision (reflected e.g. in O. 84 r. 21(2) RSC), and that if one only finds out about it later one can
seek an extension of time. That is at least a workable rule even if it sounds harsher than it is at first
sight. Where EU law is in issue, conforming interpretation means that one has the full time period
from the date one actually, or should have, found out about the decision (see Case C-456/08
European Commission v. Ireland (Court of Justice of the European Union, 28th January, 2010,
ECLI:EU:C:2010:46), Case C-406/08 Uniplex (UK) Ltd v. NHS Business Services Authority (Court of
Justice of the European Union, 28th January, 2010, ECLI:EU:C:2010:45), per Murray J. in
Arthropharm (Europe) Ltd v. The Health Products Regulatory Authority [2022] IECA 109, [2022] 5
JIC 1003 (Unreported, Court of Appeal, 10th May, 2022) and caselaw discussed in Marshall v. Kildare
County Council [2023] IEHC 73, [2023] 2 JIC 1705 (Unreported, High Court, 17th February, 2023)
(under appeal by the applicants, but this was a point decided in favour of the applicants in that
case)). The courts have yet to declare such an entitlement if the challenge is purely domestic, so
applicants need to move rapidly if they don’t find out about a decision until some time after it is
made.
136. Also one needs to acknowledge that three months from the date they found out about it
wouldn’t be enough for these applicants because they didn’t do anything to challenge the licence
when they found out about it as part of the application documents for the permission. With an
apparent belief in living dangerously, the applicants waited until eight weeks after the date of the
grant of permission to bring the challenge. That obviously complicates the legal situation for them.
So we need to analyse their submission as to why they say they were entitled to disregard the need
for extension of time, and be clear on what they have to establish in order to impugn the derogation
licence, or in other words what is the applicants’ route map to success, if any, under this heading?
137. In considering the applicants’ submissions in that regard, one thing emerges clearly, which
is that the applicants have, I’m afraid, fundamentally misunderstood the relationship between EU
and domestic law. Much of their submissions on the time issue are unfortunately a confused jumble
of decontextualised snippets of EU law which don’t amount to what the applicants think they amount
to.
138. Ground zero for the applicants’ mischaracterisation of European law seems to come in the
following two sentences in their written legal submissions:
“The Applicants also rely on the principle that national procedural rules cannot be relied upon
to frustrate the effectiveness of European law. The judgment in Workplace Relations
Commission provides important clarification in relation to the principle of effectiveness: i.e.
national courts are also required to provide an effective remedy when they identify a breach
of EU law [n82 refers here to Case C-752/18 Deutsche Umwelthilfe eV v. Freistaat Bayern,
(Court of Justice of the European Union, 19th December, 2019, ECLI:EU:C:2019:1114,
§§39-40), Case C-470/16 North East Pylon Pressure Campaign Ltd v. An Bord Pleanála
(Court of Justice of the European Union, 15th March, 2018, ECLI:EU:C:2018:185, §§56-
57)].”
139. The applicants’ reliance on Case C-378/17, Minister for Justice and Equality v. Workplace
Relations Commission (Court of Justice of the European Union, 4th December, 2018,
ECLI:EU:C:2018:979) is as misplaced as it is predictable.
140. We need to remind ourselves what this case actually decided. The court said at para. 31
that:
“EU law, in particular the principle of primacy of EU law, must be interpreted as precluding
national legislation, such as that at issue in the main proceedings, under which a national
body established by law in order to ensure enforcement of EU law in a particular area lacks
jurisdiction to decide to disapply a rule of national law that is contrary to EU law.”
141. That applies to a situation where domestic law is in conflict with EU law – in such a case the
domestic law has to be disapplied even if that means exceeding the domestically-conferred
jurisdiction of the national body. That has, I’m afraid, nothing to do with a situation where the
domestic rule (such as an extension of time) is capable of being applied in a conforming manner. In
such a case, the general rule is that one has to submit to the domestic procedure and argue for a
conforming interpretation. It is not the case that one can simply proceed as if the domestic law
does not exist.
142. The applicants seem to believe that all they have to do is to step on to the pitch wearing a
blue jersey and the game is over. That is not so – they still need to score goals by the local rules,
but such rules cannot make goal-scoring impossible or excessively difficult. The local rule book is
not rendered irrelevant and inapplicable merely by virtue of the fact that the blue team would have
to engage with it.
143. The applicants’ self-penned and wildly inaccurate formula is that “national courts are also
required to provide an effective remedy when they identify a breach of EU law”. That suggests a
free-floating duty on the national court to “identify” a breach of EU law, presumably independently
of the parties’ efforts or their compliance with domestic law, and then an equally free-floating
“require[ment]” to “provide” an effective remedy – on a plate obviously, with all the trimmings, and
no effort required by the supine litigant concerned. Workplace Relations Commission doesn’t decide
anything of the sort, and nor is there any such obligation on any other basis.
144. In Case C-752/18 Deutsche Umwelthilfe eV v Freistaat Bayern, the Grand Chamber held at
paras. 39 and 40:
“39 In addition, in order to ensure effective judicial protection in the fields covered by EU
environmental law, it is for the national court to interpret its national law in a way which, to
the fullest extent possible, is consistent both with the objectives laid down in Article 9(3)
and (4) of the Aarhus Convention and with the objective of effective judicial protection of
the rights conferred by EU law (see, to that effect, judgment of 8 March
2011, Lesoochranárske zoskupenie, C-240/09, EU:C:2011:125, paragraphs 50 and 51).
40 To that end, it is incumbent upon the national court to ascertain, taking the whole body
of domestic law into consideration and applying the interpretative methods recognised by
that law, whether it can arrive at an interpretation of domestic law that would enable it to
apply effective coercive measures in order to ensure that the public authorities comply with
a judgment that has become final, such as, in particular, high financial penalties that are
repeated after a short time and the payment of which does not ultimately benefit the budget
from which they are funded.”
145. Those statements are about the interpretation of domestic law, not giving applicants a free
pass to ignore domestic law (as the applicants have done here by failing to even seek an extension
of time).
146. At para. 42 the Grand Chamber went on:
“In that regard, it should be recalled that, where it is unable to interpret national law in
compliance with the requirements of EU law, the national court, hearing a case within its
jurisdiction, has, as an organ of a Member State, the obligation to disapply any provision of
national law which is contrary to a provision of EU law with direct effect in the case pending
before it (judgments of 9 March 1978, Simmenthal, 106/77, EU:C:1978:49, paragraph 21,
and of 24 June 2019, Popławski, C-573/17, EU:C:2019:530, paragraphs 58 and 61).”
147. So the domestic court should first “interpret national law in compliance with the
requirements of EU law”. Only if that is not possible do we move on to disapplying national law, and
only in cases where the EU law concerned has direct effect due to being clear, precise and
unconditional. Even then, such an EU law provision doesn’t automatically have priority if there is a
conflicting fundamental right recognised in European law as stated at para. 56:
“EU law, in particular the first paragraph of Article 47 of the Charter of Fundamental Rights
of the European Union, must be interpreted as meaning that, in circumstances in which a
national authority persistently refuses to comply with a judicial decision enjoining it to
perform a clear, precise and unconditional obligation flowing from EU law, in particular from
Directive 2008/50/EC of the European Parliament and of the Council of 21 May 2008 on
ambient air quality and cleaner air for Europe, it is incumbent upon the national court having
jurisdiction to order the coercive detention of office holders involved in the exercise of official
authority where provisions of domestic law contain a legal basis for ordering such detention
which is sufficiently accessible, precise and foreseeable in its application and provided that
the limitation on the right to liberty, guaranteed by Article 6 of the Charter of Fundamental
Rights, that would result from so ordering complies with the other conditions laid down in
that regard in Article 52(1) of the Charter. On the other hand, if there is no such legal basis
in domestic law, EU law does not empower that court to have recourse to such a measure.”
148. In North East Pylon Pressure Campaign Ltd, the court said at paras. 56 and 57:
“56 Therefore, if the effective protection of EU environmental law, in this case Directive
2011/92 and Regulation No 347/2013, is not to be undermined, it is inconceivable that
Article 9(3) and (4) of the Aarhus Convention be interpreted in such a way as to make it in
practice impossible or excessively difficult to exercise rights conferred by EU law (see, by
analogy, judgment of 8 March 2011, Lesoochranárske zoskupenie, C-240/09,
EU:C:2011:125, paragraph 49).
57 Consequently, where the application of national environmental law – particularly in the
implementation of a project of common interest, within the meaning of Regulation
No 347/2013 – is at issue, it is for the national court to give an interpretation of national
procedural law which, to the fullest extent possible, is consistent with the objectives laid
down in Article 9(3) and (4) of the Aarhus Convention, so that judicial procedures are not
prohibitively expensive.”
149. Again that is about interpreting domestic law, not ignoring it. One can note in passing that
the court did not consider art. 9(3) and (4) of the Aarhus Convention to have direct effect, but
nonetheless the principle of conforming interpretation applies.
150. The fundamental problem for the applicants is that they think that either they, or the court,
or both, can just ignore O. 84 r. 21 RSC (the three-month rule and provision for extension of time).
But that rule confers some flexibility and is capable of being operated in a manner that complies
with EU law, or to put it another way, nobody has shown that a conforming interpretation is
impossible. If, for example, the rule were to prohibit extensions of time in circumstances where
access to the court was required by EU law, and so where there was a direct conflict with applicable
EU law and a conforming interpretation was not available, then one would be into Workplace
Relations Commission-disapplying-national-law territory. But we haven’t got to that point here.
151. The fundamental point is that there isn’t anything inherently unlawful about national law
providing rules about things like time limits as an aspect of the principle of national procedural
autonomy: see Krikke v. Barranafaddock Sustainability Electricity Limited [2022] IESC 41, [2023] 1
I.L.R.M. 81, [2022] 11 JIC 0303. The CJEU held in Case C-348/15 Stadt Wiener Neustadt v.
Niederösterreichische Landesregierung (Court of Justice of the European Union, 17th November,
2016, ECLI:C:2016:882) at paras. 40 and 41:
“40 ... It is indeed settled case-law of the Court that, in the absence of EU rules in the field,
it is for the national legal system of each Member State to designate the courts and tribunals
having jurisdiction and to lay down the detailed procedural rules governing actions for
safeguarding rights which individuals derive from EU law, provided that such rules are not
less favourable than those governing similar national actions (principle of equivalence) and
that they do not render practically impossible or excessively difficult the exercise of rights
conferred by EU law (principle of effectiveness).
41 The Court also considers that it is compatible with EU law to lay down reasonable time
limits for bringing proceedings in the interests of legal certainty, which protects both the
individual and the administrative authority concerned. In particular, it finds that such time
limits are not liable to make it in practice impossible or excessively difficult to exercise the
rights conferred by EU law (see, to that effect, judgments of 15 April 2010, Barth, C-542/08,
EU:C:2010:193, paragraph 28, and of 16 January 2014, Pohl, C-429/12, EU:C:2014:12,
paragraph 29).”
152. The applicants’ next complaint is:
“It is the Applicant’s case that these domestic rules and procedure cannot be relied upon to
frustrate the objectives of the Directive–in this case the strict protection of bat fauna whose
roosts may be lost to the proposed development.”
153. The loose wording of the submission gives it away – the principle of EU law is that the
domestic procedural rule must not make it in practice impossible or excessively difficulty to exercise
EU law rights. It is not a principle that any and every applicant must be allowed to win their case,
or that nobody can be held to fall foul of a procedural rule because that would “frustrate” the
objectives of a directive.
154. Next, the applicants’ endeavours to find supportive fragments of authority are turned up a
notch:
“As identified by the Court of Justice in Case C-166/97, Commission v. France (§13):
‘According to the settled case-law of the Court, a Member State may not plead provisions,
practices or circumstances existing in its internal legal system in order to justify a failure to
comply with the obligations and time-limits laid down in a directive…’”
155. As is perhaps obvious, that was an enforcement action by the Commission in relation to
failure to fulfil obligations conferred by a directive (art. 4 of the birds directive (Council Directive
79/409). The settled caselaw referred to in the partial quotation also involves enforcement actions.
The language of the CJEU regarding the context of enforcement action is just not transferrable holus-
bolus to the conforming interpretation context, as the applicants seem to imply.
156. The quote continues:
“(see, inter alia, Case C-259/94 Commission v Greece [1995] ECR I-1947, at paragraph 5
and Case C-214/96 Commission v Spain [1998] ECR I-7661, at paragraph 18).”
157. None of this has anything to do with what amounts to an alleged entitlement of the applicants
to exempt themselves from domestic law requirements - in this instance the need to apply for an
extension of time to challenge a derogation licence.
158. The applicants’ submission then reaches its peroration:
“In Case C-415/21 [sic], Commission v. Belgium, the Court of Justice stated (§21):
‘The provisions of Directives must be implemented with unquestionable binding force, and
the specificity, precision and clarity necessary to satisfy the requirements of legal certainty.
The principle of legal certainty requires appropriate publicity for the national measures
adopted pursuant to Community rules in such a way as to enable the persons concerned by
such measures to ascertain the scope of their rights and obligations in the particular area
governed by Community law.’”
159. This case is mis-cited – its correct case number is Case C-415/01. There is no emphasis in
the original, but the submissions do not mention that emphasis has been added. Also, the quotation,
strangely, is incomplete although there are no ellipses noted in the quotation in the submissions.
The full quotation from Case C-415/01 Commission v. Belgium 2003 ECR I-02081
(ECLI:EU:C:2003:118), para. 21, is:
“In that regard, it is important to recall that, according to consistent case-law, the provisions
of directives must be implemented with unquestionable binding force, and the specificity,
precision and clarity necessary to satisfy the requirements of legal certainty (see, in
particular, Case C-159/99 Commission v Italy [2001] ECR I-4007, paragraph 32). The
principle of legal certainty requires appropriate publicity for the national measures adopted
pursuant to Community rules in such a way as to enable the persons concerned by such
measures to ascertain the scope of their rights and obligations in the particular area
governed by Community law (see Case C-313/99 Mulligan and Others [2002] ECR I-5719,
paragraphs 51 and 52).”
160. Case C-415/01 Commission v. Belgium, and Case C-159/99 Commission of the European
Communities v. Italian Republic (Court of Justice of the European Union, 17th May, 2001,
ECLI:EU:C:2001:278), were enforcement actions about the birds directive. Case C-313/99 Mulligan
v. Minister for Agriculture and Food (Court of Justice of the European Union, 20th June, 2002,
ECLI:EU:C:2002:386) was a reference by the High Court here on the interpretation of Council
Regulation (EEC) No 3950/92 of 28th December, 1992 establishing an additional levy in the milk
and milk products sector. Unfortunately for the applicants, paras. 49 to 54 of Mulligan do not support
the EU-law-straitjacket argument underpinning the applicants’ case. Rather they impliedly
acknowledge the scope of national procedural autonomy:
“49 In the present case, the questions referred by the national court, as reformulated in
paragraph 38 of this judgment, concern two specific aspects of the legislative procedure
followed for the adoption of the clawback measure at issue in the main proceedings, namely
the fact that the 1995 Regulations, first, gave the Minister a discretion to adopt decisions
for that purpose and, second, permitted the adoption of those measures by means of a
notice published in the national press.
50 With regard to the first aspect of that procedure, the mere fact that a national legislative
instrument has delegated to an authority of a Member State, such as a minister, authority
to adopt measures pursuant to Article 7(1) of Regulation No 3950/92 is not in itself of such
a nature as to infringe the principle of legal certainty, since the adoption of a measure
following such a procedure does not necessarily mean that that measure is not binding or
does not satisfy the requirement of that principle that it be specific, precise and clear.
51 With regard to the second aspect of that procedure, it suffices to observe that, although
the principle of legal certainty requires appropriate publicity of the national measures
adopted pursuant to a Community regulation, it is nevertheless the case that the principle
does not prescribe any specific form of publicity, such as publication of the measures in the
Official Journal of the Member State concerned.
52 As is clear from the case-law cited in paragraph 47 above, the reason why the principle
of legal certainty, as a general principle of Community law, requires appropriate publicity of
measures adopted by the Member States in implementation of an obligation under
Community law is the obvious need to ensure that persons concerned by such measures are
able to ascertain the scope of their rights and obligations in the particular area governed by
Community law.
53 It follows that to be appropriate publicity must be of such a nature as to inform the
natural or legal persons concerned by the measure of their rights and obligations under it.
It is not therefore ruled out that publication of that measure in the national press may satisfy
that condition. However, it is for the national court to determine, on the basis of the facts
before it, whether that is the case in the main proceedings.
54 Consequently, the answer to the second and third questions must be that the principle
of legal certainty does not preclude, as a general principle of Community law, a Member
State from choosing, for the purpose of adopting national measures pursuant to Article 7(1)
of Regulation No 3950/92, a procedure whereby a legislative instrument authorises the
competent authority, such as a minister, to adopt those measures by means of a decision.
That principle requires that the publicity for such measures be of such a nature as to inform
the natural or legal persons concerned by the measures of their rights and obligations under
them. It is for the national court to determine, on the basis of the facts before it, whether
that is the case in the main proceedings.”
161. Bearing all that in mind, the question is whether there is any remaining path, however
narrow, to enable the applicants to progress their objection to the derogation licence.
What is the applicants’ route-map, if any, to impugning the derogation licence?
162. In order to succeed, the applicants would need to establish the following arguments (phrased
as propositions but I am not to be taken as accepting these for present purposes):
(i) The grant of a derogation licence should be held to be “part of the
development consent procedure” to use the language of the CJEU in Case C-
463/20 Namur-Est Environnement ASBL v. Région wallonne (Court of Justice of the
European Union, 24th February, 2022, ECLI:EU:C:2022:121).
(ii) Therefore the derogation licence should be capable of being challenged as
if made on the date of the development consent. As put in legal submissions,
“[i]nsofar as any time objection may be made in relation to this point, the Derogation
Licence only crystallised and was only published once planning permission for the
proposed development was granted and the Bat Report was published”. The concept
of “crystallisation” is to some extent a conceit of the applicants’ own confection,
although on the other hand one cannot totally rule out such an argument as flowing
from the proposition that the licence should be treated as part of the development
consent for EU law purposes. Hence the applicants submit: “[i]t is the Applicants’
case that the only appropriate time to challenge the Derogation Licence was after
planning permission was granted.”
(iii) This should apply even where national law allows the derogation licence to
be applied before, during or after the development consent, if the detriment
created by a licence in practice requires the approval of the project. In such
circumstances, where the licence is obtained before the development consent, then
the licence should be treated as part of the consent so that it can be challenged as
of the date of the consent, notwithstanding the principle of national procedural
autonomy reflected for example in art. 11(2) of the EIA Directive 2011/92 which
provides that: “[m]ember States shall determine at what stage the decisions, acts
or omissions may be challenged”. Thus any given applicant can simultaneously
challenge an associated derogation licence on the basis that it is a part of the
development consent, even in a member state like Ireland where the law is
unspecific as to whether one can seek any necessary development consents before,
during or after the procedure: see the slightly different fact situation of Namur-Est
Environnement ASBL and in particular the opinion of Advocate General Kokott
delivered in that case (Court of Justice of the European Union, 21st October, 2021,
ECLI:EU:C:2021:868). At para. 37 of her opinion, Advocate General Kokott stated:
“Moreover, the Kingdom of Belgium’s submission is also not convincing in terms of
content, since the permit under species protection law was expressly applied for in
relation to the implementation of the quarry project. According to the observations
submitted in the hearing, detriment caused to protected species is accordingly
permissible only within the framework of the project, and therefore requires, at least
in practice, the approval of the project as a whole. A further reason why such a link
with the project appears to be necessary under EU law is that only the objectives of
the measure concerned, in this case the project, can justify a derogation from the
obligations of species protection in accordance with Article 16 of the Habitats
Directive and Article 9 of the Birds Directive.”
(iv) The applicants were entitled to an extension of time to cover the period up
to when they knew about the derogation licence. The written submission goes
on: “[w]hile the Minister does take a time point against the Applicants (§§29-30 of
the SOO), he does not explain how the Applicants were supposed to challenge a
decision with which they had no involvement, where there was no public
participation, and which was only published in the context of materials being placed
by the Developer on its website for the purpose of applying for planning permission.”
If the complaint is that the applicants couldn’t have challenged the licence before
the application documents were placed on the website, that is a fair point, but it is
not in dispute. Had the applicants moved within three months from that date and
sought an extension of time for the purpose, we would not be having this discussion.
But they didn’t do that either.
(v) The applicants were entitled to a further extension of time to cover the
period from when they knew about the derogation licence up to the date of
the permission. The argument is that this follows from the above points.
(vi) Where an applicant is to be allowed an extension of time by virtue of EU
law, domestic procedures should not preclude a claim merely because an
applicant does not apply for an extension of time to which she would be
thus entitled. Here the applicants are really pushing the boat out, because they
didn’t even invoke the formality of seeking an extension of time in the statement of
grounds, or when applying for leave (even on a conditional basis if and insofar as
such an extension was required), which was the legally ideal time to alert the court
to the problem, or by way of a motion seeking extension of time thereafter. Their
main line of defence seemed to be that they didn’t need to apply for an extension of
time. That is incorrect – obviously so – as a matter of domestic law. There isn’t
anything about the relationship between EU and domestic law that would preclude
that conclusion. But is this only the omission of a formality? It has to be pointed
out that this is a totally self-inflicted addition to the list of issues because it would
have been painless for the applicants to have asked for the extension on the grounds
that they claim to be entitled to it as of right, thereby providing formal compliance
with domestic law rules. On the other hand, if the applicants can ignore domestic
law as to time because it is a formality, then what else can they ignore? Can they
wander into court without pleadings or affidavits, without seeking leave, without
paying stamp duty, without complying with rules of court or practice directions? The
whole doctrine cooked up by the applicants appears on the face of things to be a
recipe for procedural chaos. Perhaps there is some other answer to this that I am
missing and that meets the minimum threshold of plausible doubt warranting
consideration of the Luxembourg route, so I will give the opportunity to clarify that
as stated below.
(vii) A derogation licence cannot conclude that there were no alternatives unless
it actually considers alternatives. Assuming that the applicants get over the
time problem, their next point is that the licence was invalid because it didn’t study
any alternatives, so it could not conclude that there were no alternatives.
(viii) A derogation licence can only be granted for the purpose of protecting wild
fauna and conserving natural habitats if some identified level of protection
is created by the licence rather than by mitigation measures associated with
the detriment created by the licence. The applicants essentially complain that
the licence itself doesn’t provide protection for fauna and habitats so should not have
been issued on the basis that it did.
Conclusion on this issue for present purposes
163. Having identified the foregoing points, I have some concerns that the EU argument on the
time issue crystallised very late in the hearing and that the parties may not have had the fullest
opportunity to address these questions. I am therefore going to give the parties a final opportunity
to make written legal submissions on these points and in particular on whether I should decide these
myself or whether any doubt arises as to these such as would warrant consideration of the
Luxembourg route. By all appearances at the present moment, and totally subject to contrary
argument, the weakest link is point (vi), so the parties will have to focus on whether or not there is
anything to create doubt about the answer to that in particular, while also having the opportunity to
consider the other issues.
164. Subject to any alternative position that may emerge following further submissions, the take-
home point in the meantime is that as a matter of domestic law, a derogation licence should be
challenged when any given challenger finds out about it or at the latest within three months from
the earliest date on which she should have known about it. Where the challenge comes more than
three months after the date of the licence, an extension of time is required as a matter of Irish law.
Any EU law argument can normally only be made once there is compliance with the domestic law
requirement to seek such an extension, which on the face of things is consistent with both
equivalence and effectiveness. If an applicant challenges a licence within three months of the date
she could reasonably have known of it, then an extension based on EU law is there for the asking.
One might have thought that the safer course is to comply with that rather than to add further EU
law dominoes to an already crowded list of things that have to fall one’s way, because to wait for
the final permission means having to face a whole other set of tripwires. But even if an applicant
incautiously waits until then, the prudent and indeed completely obvious course is to formally apply
for the extension of time when seeking leave. These applicants didn’t do that, for reasons best
known to themselves.
Summary
165. Without taking from the more express and operative terms of the judgment, a rough
summary of the outcome is as follows:
(i) Core ground 1 – this was not pursued;
(ii) Core ground 2 – zoning – this misunderstands the concept of a zoning provision;
(iii) Core ground 3 – material contravention – the plan provided sufficient flexibility for
the decision on the specific facts here;
(iv) Core ground 4 – statutory invalidity – this exaggerates the effect of the SEA directive
beyond anything in national or European caselaw;
(v) Core ground 5 – this was not pursued;
(vi) Core ground 6 – insofar as the pleaded case was concerned, this was not pursued,
and insofar as an attempt was made to construct a new case out of a passing
reference to the EIA screening, the argument is not adequately pleaded;
(vii) Core ground 7 – derogation licence – there will be a further opportunity to make
submissions on the remaining net issues here;
(viii) Core ground 8 – traffic – this exaggerates the entitlement to reasons, which were
sufficient in context; and
(ix) Core ground 9 – stay – this can continue for the time being subject to any
application.
Order
166. For the foregoing reasons, it will be ordered that:
(i) the challenge to the decision of the board be dismissed;
(ii) submissions be invited in the terms stated in the judgment on the challenge to the
derogation licence;
(iii) the matter be listed for mention on a date to be notified;
(iv) the stay be continued for the time being until further order with liberty to apply; and
(v) the foregoing order be perfected with no order as to the costs of the challenge to
the decision of the board, and with costs of the challenge to the derogation licence
reserved, unless submissions to the contrary are lodged with the court within 7 days
of the date of this judgment.