HomeMy WebLinkAbout2560481 - Submission - [E] Brendan BuckSubmission Details
Submitter
Name Brendan Buck
Address BPS Planning Consultants LTD, PO Box 13658 Dublin 14
Note
BPS Planning & Development Consultants LTD – a firm of Irish Planning Institute accredited
rural & urban planning consultants - have been retained by the Concerned Residents of
Doohamlet Group , c/o Chairperson, Mr Enda Connolly, Doohamlet, Castleblayney, County
Monaghan, A75 YV56 [hereafter “client”] to object on their behalf to Monaghan County
Council [hereafter “MCC”] planning application, reg. ref. 2560481, which proposes the
following development, at Dernaglug, Doohamlet, Co. Monaghan, described in the statutory
notices as: "Permission for development consisting of the following: • The provision of 29 no.
dwellings comprising: • 1 No. 2 bed detached bungalow dwellings, • 4 no. 2 bed semi-
detached bungalow dwellings, • 6 No. 2 bed semi-detached two-storey dwellings, • 2 No. 3
bed detached two-storey dwellings, • 11 No. 3 bed semi-detached two-storey dwellings, • 5
no. 4 bed semi-detached two-storey dwellings, • Together with boundary treatments, hard &
soft landscaping, public lighting, new estate road, connection to existing mains services
together with all ancillary and associated site works." Please find this objection attached
(cover letter, report, and form). This planning application was submitted on 2/12/2025. The
final date for the submission of objections is 14/1/2026. This objection is lodged on or prior
to this deadline. Best wishes, Brendan Buck MIPI. .
In relation to application
File Number 2560481
Name Co. Ltd Doohamlet Construction
Address Dernaglug Doohamlet Co.Monaghan RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 1
Submitted by way of the Local Government Online Portal
The Secretary,
Planning Department,
County Buildings,
Monaghan County Council,
The Glen, Glen Rd, Tirkeenan,
County Monaghan,
H18 YT50.
18 December 2025
Dear Sir/Madam,
Third Party planning objection vs. Monaghan County Council planning application, reg. ref. 2560481,
which proposes: “Permission for development consisting of the following: • The provision of 29 no.
dwellings comprising: • 1 No. 2 bed detached bungalow dwellings, • 4 no. 2 bed semi-detached
bungalow dwellings, • 6 No. 2 bed semi-detached two-storey dwellings, • 2 No. 3 bed detached two-
storey dwellings, • 11 No. 3 bed semi-detached two-storey dwellings, • 5 no. 4 bed semi-detached two-
storey dwellings, • Together with boundary treatments, hard & soft landscaping, public lighting, new
estate road, connection to existing mains services together with all ancillary and associated site
works” at Dernaglug, Doohamlet, Co. Monaghan.
BPS Planning & Development Consultants LTD – a firm of Irish Planning Institute accredited rural & urban planning
consultants - have been retained by the Concerned Residents of Doohamlet Group1, c/o Chairperson, Mr Enda
Connolly, Doohamlet, Castleblayney, County Monaghan, A75 YV56 [hereafter “client”] to object on their behalf to
Monaghan County Council [hereafter “MCC”] planning application, reg. ref. 2560481, which proposes the following
development, at Dernaglug, Doohamlet, Co. Monaghan, described in the statutory notices as:
Permission for development consisting of the following: • The provision of 29 no. dwellings comprising: • 1 No. 2 bed
detached bungalow dwellings, • 4 no. 2 bed semi-detached bungalow dwellings, • 6 No. 2 bed semi-detached two-
storey dwellings, • 2 No. 3 bed detached two-storey dwellings, • 11 No. 3 bed semi-detached two-storey dwellings,
• 5 no. 4 bed semi-detached two-storey dwellings, • Together with boundary treatments, hard & soft landscaping,
public lighting, new estate road, connection to existing mains services together with all ancillary and associated
site works.
This planning application was submitted on 2/12/2025. The final date for the submission of objections is 14/1/2026.
This objection is lodged on or prior to this deadline.
Our client’s group wishes to confirm that they have not been consulted by the applicant and have not agreed in
advance of the lodgement of this planning application to any part of this development. They are concerned to protect
the amenities of their properties and of this area.
Our client maintains several Grounds for Objection in respect of this planning application. These are set out in turn in
Section 9.0 ‘Grounds for objection’ of the attached Planning Objection Report. However, the entire contents of the
attached report and the attached cover letter should be considered by MCC to comprise our client’s complete
planning objection.
For validation of this objection (here lodged online), please find attached:
1) Grounds for Objection set out in the attached Planning Objection Report; and
2) Payment of €20 attached (paid online) which is the statutory fee payable for a Third Party objection.
1 Full list of member names, addresses and signatures included in Appendix 1 of the attached BPS Report. RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 2
We trust this is all in order. If you have any questions, please contact BPS at the address and phone numbers provided.
Best wishes,
Brendan Buck
Brendan Buck MIPI
Managing Director
BPS Planning & Development Consultants LTD RECEIVED: 18/12/2025
BPS Town Planning & Development Consultants | www.bpsplanning.ie
Third Party Planning Objection Check List
1. Name of the objector: Concerned Residents of Doohamlet Group1, c/o Chairperson Enda
Connolly.
2. Address of the objector: Doohamlet, Castleblayney, County Monaghan, A75 YV56.
3. If an agent is involved, state the name of the agent: Brendan Buck MIPI.
4. Address of the agent: BPS Planning & Development Consultants LTD., PO Box 13658, Dublin 14,
D14 RW01.
5. State the Subject Matter of the objection: Third Party planning objection vs. Monaghan County
Council planning application, reg. ref. 2560481, which proposes: “Permission for development
consisting of the following: • The provision of 29 no. dwellings comprising: • 1 No. 2 bed
detached bungalow dwellings, • 4 no. 2 bed semi-detached bungalow dwellings, • 6 No. 2 bed
semi-detached two-storey dwellings, • 2 No. 3 bed detached two-storey dwellings, • 11 No. 3
bed semi-detached two-storey dwellings, • 5 no. 4 bed semi-detached two-storey dwellings, •
Together with boundary treatments, hard & soft landscaping, public lighting, new estate road,
connection to existing mains services together with all ancillary and associated site works”.
6. Location of development: Dernaglug, Doohamlet, Co. Monaghan.
7. Local authority area: Monaghan County Council.
8. Planning authority register reference number: reg. ref. 2560481.
9. Attach, in full, the grounds for objection and the reasons, considerations and arguments on
which they are based. Please find a Planning Objection Report attached.
10. Enclose/Pay the correct fee for the third party objection: €20 (paid online at the Local
Government Planning Portal).
11. Ensure that the OBJECTION is received by Monaghan County Council in the correct manner
and in time. This planning application was submitted on 2/12/2025. The final date for the
submission of objections is 14/1/2026. This objection is lodged on or prior to this deadline.
1 Full list of member names, addresses, and signatures provided in the attached BPS Report. RECEIVED: 18/12/2025
3rd Party Planning Objection Report
Third Party planning objection vs. Monaghan County Council planning
application, reg. ref. 2560481, which proposes: “Permission for development
consisting of the following: • The provision of 29 no. dwellings comprising: •
1 No. 2 bed detached bungalow dwellings, • 4 no. 2 bed semi-detached
bungalow dwellings, • 6 No. 2 bed semi-detached two-storey dwellings, • 2
No. 3 bed detached two-storey dwellings, • 11 No. 3 bed semi-detached
two-storey dwellings, • 5 no. 4 bed semi-detached two-storey dwellings, •
Together with boundary treatments, hard & soft landscaping, public
lighting, new estate road, connection to existing mains services together
with all ancillary and associated site works” at Dernaglug, Doohamlet, Co.
Monaghan.
This Planning Objection Report has been produced by bps for and on
behalf of the Concerned Residents of Doohamlet Group, c/o Chairperson
Enda Connolly [address].
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 2
Document Control Sheet
Project Third Party planning objection vs. Monaghan County Council planning
application, reg. ref. 2560481.
Project No. 2025– 614
Document title Third party planning objection report.
Contents No. of pages
Cover page 1
Control sheet 1
Table of contents 2
Text 54
Total No. of Pages 73 (including Appendix 1)
Rev. Distribution Author Checked Approved Day Month Year
1 BPS Planning BB FB EB 20 10 2025
2 BPS Planning BB FB EB 28 10 2025
3 Monaghan Co. Co. BB FB EB 10 11 2025
4 Monaghan Co. Co. BB FB EB 11 12 2025
BPS Planning & Development Consultants LTD
PO Box 13658, Dublin 14, D14RW01
Tel: 01 539 4960 / 087-2615871
Email: info@bpsplanning.ie
Web: www.bpsplanning.ie
This document has been prepared for the exclusive use of our Client and unless otherwise agreed in writing with BPS
Planning & Development Consultants LTD, no other party may use, make use of, or rely on the contents of this document.
The document has been compiled using the resources agreed with the Client, and in accordance with the agreed scope
of work. BPS Planning & Development Consultants LTD accepts no responsibility or liability for any use that is made of this
document other than for the purposes for which it was originally commissioned and prepared, including by any third
party, or use by others, of opinions or data contained in this document. BPS Planning & Development Consultants LTD
accepts no liability for any documents or information supplied by others contained or referenced in this document. It is
expressly stated that no independent verification of any documents or information supplied by others for this document
has been made. BPS Planning & Development Consultants LTD has used reasonable skill, care, and diligence in compiling
this document. It should be noted that no changes of whatsoever nature are to be made to any wording, information or
details set out or contained in any BPS document unless the express consent has been obtained in advance, in writing,
from BPS.
18 December 2025
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 3
Contents
1.0 Introduction
1.1 Pre-planning consultation with Monaghan County Council
2.0 Technical issues, planning law matters & missing information
3.0 Rationale for objection & summary
4.0 Location & description of the subject site
4.1 No zoning or other designation (site located outside of the village boundary)
5.0 Existing relationship between client group’s properties & the applicant site
6.0 Planning history of the applicant site
6.1 The downzoning of the site
6.2 Conclusions from the planning history of the site
7.0 The proposed development description
8.0 Proposed relationship between client property & the applicant scheme
9.0 Grounds for objection
9.1 Ground 1: The principle of development is not accepted – the site is unzoned
9.2 Ground 2: Contrary to MCDP 2025-2031 policies & objectives to prevent urban sprawl
9.3 Ground 3: Proposal would leapfrog undeveloped lands within village boundaries
9.3.1 Proposal raises the same concerns as reg. ref. 21/378 / appeal PL18.313034
9.3.2 The Inniskeen site was serviced – the applicant site is an agricultural field
9.3.3 There was pre-planning with MCC Planning and Housing for the Inniskeen site
9.4 Ground 4: Proposal is premature pending the site being re-zoned & a village plan adopted
9.5 Ground 5: Doohamlet is a recent Tier 4 village – the applicant wants all its growth to 2031
9.6 Ground 6: No Social Infrastructure Audit has been submitted to address isolation concerns
9.7 Ground 7: The capacity of the Doohamlet WWTP is not stated & WWT issues unaddressed
9.8 Ground 8: Proposal is contrary to s. 15.8.10 & Objective RDSP 1 of the MCDP 2025-2031
9.9 Ground 9: The density of the proposal is not acceptable outside of any village boundary
9.10 Ground 10: The proposal would cause further piecemeal development in the village
9.11 Ground 11: Contrary to s. 15.8 ‘Multi-Unit Residential Developments’ of the MCDP
9.12 Ground 12: The Part V proposal is not compliant with planning policy
9.12.1 The applicant’s Part V proposal in the Concept Statement require clarification
9.12.2 Doohamlet is isolated and poorly serviced as a site for 29 social houses
9.12.2.1 No age-friendly housing is provided & Doohamlet is unsuitable for this type of housing
9.12.3 No cumulative assessment of over-provision of social housing at this location is provided
9.13 Ground 13: The cut and fill proposed is not advertised and is excessive
9.14 Ground 14: The siting, design, scale, bulk & massing of the proposed development is poor
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
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9.15 Ground 15: Trees & hedgerows have disappeared & Visual Impact Assessment is missing
9.16 Ground 16: Landscape mitigation is poor and likely impossible
9.17 Ground 17: No Site Specific Flood Risk Assessment is provided
9.18 Ground 18: A Construction Environmental Management Plan is required
9.19 Ground 19: An Ecological Impact Assessment is required
9.20 Ground 20: Appropriate Assessment Screening is required
9.21 Ground 21: No Conservation Report is provided re. impact on the protected structure & curtilage
9.22 Ground 22: Concerns over the Archaeological Report
9.23 Ground 23: Historic roads & pedestrian and cycle access concerns are not addressed
9.24 Ground 24: Negative precedent concerns
9.25 Ground 25: Depreciation in the value of property in the vicinity
10.0 Conclusion
11.0 Recommendation
11.1 Recommended reasons for refusal
11.2 Details and drawings needed if MCC requests Further Information
Appendix 1: Signatures of members of the Concerned Residents of Doohamlet Group
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 5
1.0 Introduction
BPS Planning & Development Consultants LTD – a firm of Irish Planning Institute accredited rural & urban planning
consultants - have been retained by the Concerned Residents of Doohamlet Group1, c/o Chairperson, Mr Enda
Connolly, Doohamlet, Castleblayney, County Monaghan, A75 YV56 [hereafter “client”] to object on their behalf to
Monaghan County Council [hereafter “MCC”] planning application, reg. ref. 2560481, which proposes the following
development, at Dernaglug, Doohamlet, Co. Monaghan, described in the statutory notices as:
Permission for development consisting of the following: • The provision of 29 no. dwellings comprising: • 1 No. 2
bed detached bungalow dwellings, • 4 no. 2 bed semi-detached bungalow dwellings, • 6 No. 2 bed semi-
detached two-storey dwellings, • 2 No. 3 bed detached two-storey dwellings, • 11 No. 3 bed semi-detached two-
storey dwellings, • 5 no. 4 bed semi-detached two-storey dwellings, • Together with boundary treatments, hard &
soft landscaping, public lighting, new estate road, connection to existing mains services together with all
ancillary and associated site works.
This planning application was submitted on 2/12/2025. The final date for the submission of objections is
14/1/2026. This objection is lodged on or prior to this deadline.
Our client’s group wishes to confirm that they have not been consulted by the applicant and have not agreed in
advance of the lodgement of this planning application to any part of this development. They are concerned to
protect the amenities of their properties and of this area.
For the convenience of the planning authority, Section 5.0 of this objection report sets out the existing relationship
between the applicant site and our client’s group’s properties; Sections 8.0 and 9.0 set out those areas of the
proposed development that BPS has identified that would impact negatively on our client’s group’s properties and
on the proper planning and sustainable development of the area; and Section 11.0 sets out our client’s
recommendations following the BPS planning assessment.
Our client maintains several Grounds for Objection in respect of this planning application. These are set out in
turn in Section 9.0 ‘Grounds for objection’ of this report. However, the entire contents of this report and the
attached cover letter should be considered by MCC to comprise our client’s complete planning objection.
1.1 Pre-planning consultation with Monaghan County Council
Our client notes how the submitted Planning Application form states that pre-planning consultation has been
undertaken by the applicant with MCC. This proposal, which seeks to site 2741.93sq.m of housing development on
unzoned lands outside of any settlement boundary, was, the form states, the subject of discussions with Lorcán
MacCinna (of the Housing Section) and Brian McGeary on “2025-06-05”. No Section 247 pre-planning meeting
reference is provided and there are no pre-planning notes available on the planning file or searchable by way of
the MCC online planning portal.
It is wholly unclear to BPS how this site and this design could be considered to be acceptable even in principle by
MCC. This Planning Objection Report sets out a range of in principle and in practice concerns.
We are especially concerned that pre-planning discussions took place regarding this site prior to the adoption of
the MCDP 2025-2031. Pre-planning took place while Doohamlet was still a Tier 5 small rural village.
Given the need for this planning application to be fully and carefully assessed, we note that our client’s group
objects to the media coverage that has arisen in respect of this matter.2
BPS notes that any feedback offered to the applicant by way of pre-planning was, as per the Development
Management Guidelines (2007), provided “without prejudice” to the outcome of any submitted planning
application.
Having reviewed the submitted planning application in detail, it is the professional opinion of BPS that this
proposed development should be refused planning permission and for the reasons set out in Section 11.1 of this
report.
2.0 Technical issues, planning law matters & missing information
Our client asks that MCC consider the following technical issues arising from the submitted planning application.
We note how the previous planning application was deemed invalid and we have sought to amend this section
insofar as possible. These points remain important and they have not all been addressed by the applicant:
1 Our client’s group comprises of all the local signatories which have added their name to the list included in Appendix 1. These people
maintain all the concerns set out in Section 9.0 ‘Grounds for Objection’ of this report.
2 https://www.independent.ie/regionals/monaghan/news/multi-million-euro-housing-development-planned-for-
monaghan/a252047614.html RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
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1. The MCC Letter of Consent’s red line boundary has been amended following the invalidation. Concerns arise
that the applicant needed the areas outside of the Letter of Consent to address and maintain sightline issues
and to maintain this area generally (which passes through and over communal open space serving another
scheme. This point has been left in to illustrate the problem. We acknowledge that the technical concern is
addressed.
Fig. 1: The scheme red line boundary far exceeds the areas over which MCC issued consent
2. There are issues with the submitted red and blue line boundaries:
- The applicant’s blue line boundary confirms that they own only lands outside of the designated
development envelope. The red line boundary is then shown to pass around lands to the northwest which
connect the site up to the R183 (at present). The applicant has formally confirmed that they are reliant on
MCC to obtain even access to the development envelope of the village.
Fig. 2: Red and blue line boundaries do not match
- The applicant’s red line boundary excludes any existing entrance into the site from the R183 or from
anywhere else. It is unclear why the applicant would include a red line boundary which maintains no
existing public road entrance. This would appear to be contrary to the P & D Regulations 2001 (as
amended). RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
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- The applicant proposes a new entrance to serve the site which would pass into an adjoining housing cul-
de-sac and the development would intensity use of the R183 road entrance into this cul-de-sac. Areas that
may need sightline works or maintenance into the future are not included in the red line boundary.
3. It is unclear to our client as to why a previous planning application was invalidated. Reg. ref. 25/60379 was,
MCC states in its invalidation decision, due to a lack of detail on Part V provision. The current planning
application includes the same letter from the MCC Housing Section which is dated 11.9.2025.
4. The applicant’s invalidated planning application and this planning application make misleading and incorrect
statements regarding these agricultural lands which are sited outside of the development boundary of the
village (excepting the area included to gain access to the R183). The applicant states, inter alia:
- “It is considered that this development is sustainable in that it is utilising a zoned infill site …” These
agricultural lands are unzoned.
- “The site is provided on the edge of the proposed development limit”. The developable area of the site is
an agricultural field sited outside of the village boundary and the development limit.
- “… it is utilising a zoned infill site …” These agricultural lands are unzoned.
5. The applicant has not provided an Appropriate Assessment Screening Report.
6. The applicant’s public notices and development description are inadequate because:
- The public notices fail to refer to the proposed development of a new entrance to open into the housing
estate to the north of the site. The notices refer to a “new estate road” but this fails in any way to inform
residents of the 12 house cul-de-sac and other households who live nearby that a new entrance is to be
opened into the cul-de-sac. This is a significant failing.
Fig. 3: The proposed entrance development into the adjoining housing estate cul-de-sac road is not
advertised
- This is a planning application for wholly social houses. The public notices do not state this. Having been
advertised as a wholly private housing estate of 29 no. dwellings, the development is subject to Part V
which requires 20% and not 100% of the scheme to be provided as social housing.
7. The applicant’s previous planning application, reg. ref. 25/60379, was invalidated for failing to provide Part V
compliance. It is unclear how a 100% social housing development submitted by a private developer can have
been provided with a Part V compliance letter or similar (see Section 9.12 of this report).
8. The applicant states incorrectly that the existing agricultural entrance serving the site, accessed via a laneway,
that opens onto the R183, is located in an adjoining housing. It is not. The existing laneway entrance opens
directly onto the R183. The applicant is proposing to reconfigure the laneway and its entrance such that it
opens into the existing housing estate. This would appear to be contrary to the hierarchy of roads given how
the applicant wishes to pass all traffic from this 29 house development into an existing cul-de-sac.
9. The applicant needs to provide an updated Stage 1 Road Safety Audit as regards the entrance proposal into
the adjoining cul-de-sac and then onto the R183. It is not reasonable for the submitted RSA to state: “The Audit
Team is satisfied that the proposed new entrance is designed to an appropriate and safe standard” and then to
note how “The existing junction with the R183, which falls outside of the red line for the subject development, RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
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has a number of legacy shortcomings typical of junctions constructed prior to the introduction of the street
design principles set out in the Design Manual for Urban Roads and Streets (DMURS)”. The applicant proposal is
that the existing cul-de-sac ‘and’ this scheme of 29 new dwellings suffer permanently from shortcomings. This
requires review. If any sightlines improvement works are required, the applicant will need to explain how these
can be achieved within the red line boundary.
10. The applicant’s proposed vehicular entrance into the housing estate cul-de-sac to the north does not appear to
consider the safety of future traffic movements from the adjoining housing estate dwelling. Will these remain
safe? What if a truck is exiting the new entrance?
Fig. 6: The proposed entrance into the adjoining residential cul-de-sac
Fig. 7: Existing view toward the applicant’s proposed vehicle entrance
Fig. 8: Existing view toward the applicant’s proposed vehicle entrance
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
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11. The applicant indicates that lands to the east of the site will be the subject of future development. As the
applicant is legally required to declare all lands in their ownership, can this be clarified?
12. The applicant’s site lands to the south of the proposed entrance rise up in level (see Fig. 8). How will the
applicant address this without significant cut and fill type works (such works have not been advertised)?
Section 9.13 of this report objects to what would be largescale cut and fill as the site contains a small hill (see
Fig. 9). It is unclear how the applicant’s description of topography set out in the Concept Statement matches
Fig. 9. It states: “The site’s highest point is in the north- east corner, where a hill rises to 104m above datum,
gradually falling to its lowest point in the south- west and proposed site entrance. We propose lowering the hill
by approximately 3m creating a gentle slope from east to west to create coherent road and house levels,
compliant footpaths and functional public open space”.
Fig. 9: The topography of the site with a small hill included therein
13. The applicant states as regards ‘Childcare Provision’ – “We have liaised with childcare providers in the area in
relation to the current capacity of their facilities. It is apparent that there is sufficient capacity in the local area
with many providers not currently operating to full capacity and have spare spaces. Therefore, as there is
capacity in the surrounding area in existing childcare providers it is not necessary to provide a new facility on
site”. No evidence is provided that any background research has been conducted. While BPS accepts that
generally a childcare facility is required for every 75 no. units, the applicant proposal is unusually large and
single tenure for a village context. Evidence of the claims made as regards available childcare provision in the
area should be provided.
14. The application relies on screen grabs from the Uisce Eireann website to argue that there is spare capacity in
the Doohamlet WWTP. The applicant is required to provide a Confirmation of Feasibility for a connection letter
from Uisce Eiureann. This is not included in the planning application.
15. The water connection to the mains appears to be outside of the red line boundary.
Fig. 10: Is the mains water connection located outside of the red line boundary?
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16. Has the applicant obtained consent to build the proposed up to 2m tall masonry wall shown on the landscape
plan on the existing boundaries shared with the housing cul-de-sac to the north?
17. Has the applicant sited the proposed 2m wall to the south of the site in a manner whereby it is inside of the
boundary of the site? If so, what happens to the land on the south of it? If the wall is sited on the boundary,
consent is required from the adjoining landowner.
Fig. 11: The siting of a proposed 2m tall wall to the south of the scheme adjoining an existing rural house
18. The proposal adjoins the village’s graveyard and areas of the blue line boundary are shown as to be the subject
of a future planning application. Should this matter not be resolved at this stage? What screening is to be
provided to both sides. Will this proposal be compatible, as designed, with the graveyard?
Fig. 12: The current planning application is Phase 1 of a wider scheme
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
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3.0 Rationale for objection & summary
Our client’s group viewed the public notices, reviewed the drawings and detailed online at MCC, and became
concerned. They have asked BPS to assess this planning application and to set out their concerns.
BPS has reviewed the planning application, including all drawings, viewed the site, had due regard to the
provisions of the National Planning Framework, the Development Management Guidelines (2007), to Natura 2000
sites in the surrounding hinterland, to Section 4.2: ‘Density Standards’ of the Sustainable Residential Development
in Urban Areas (2009), to Chapter 5: ‘Infill Development’ of the Urban Design Manual: A Best Practice Guide (2022),
to Table 2.1: ‘Rural Typologies’ of the Sustainable Urban Housing: Design Guidelines for Apartments & Houses
(2023), to Design Checklist Appendix B of the Quality Housing for Sustainable Communities (2007), to National
Policy Objective 18, NPF 2040 pertaining to Compact Growth, and to Village Design Statements (Model, DECLG
2012) as regards ‘Local Adaptation’, to the Architectural Heritage Protection Guidelines, and to the Monaghan
County Development Plan 2025-2031 and to all matters arising and we consider the following significant planning
concerns to arise:
There are technical issues, planning law matters and missing information concerns which suggest this is not a
valid planning application and/or is an incomplete planning application.
The site – as owned by the applicant – is outside of the designated development envelope of Doohamlet (and
the MCDP 2025-2031 was only adopted in 2025). The principle of development is not accepted – the site is
unzoned.
The proposal is contrary to MCDP 2025-2031 policies and objectives which aim to prevent urban sprawl
The proposal would leapfrog undeveloped lands within the designated development envelope of Doohamlet.
The proposal raises the same concerns as refused planning application reg. ref. 21/378 and appeal
PL18.313034. This was a better site with existing services and there had been considerable pre-planning
discussions with MCC to design the scheme.
The proposal is premature pending the site being re-zoned & a village plan adopted
Doohamlet is a recent Tier 4 village – the applicant wants all its growth to 2031. This is not appropriate or
sustainable. The scheme is over-scaled for what was recently a Tier 5 village.
No adequate infrastructure audits have been submitted including no Social Infrastructure Audit to address
isolation concerns and no audit proving the current capacity of the Doohamlet WWTP.
The proposal is contrary to s. 15.8.10 and Objective RDSP 1 of the MCDP 2025-2031
The density of the proposal is not acceptable outside of any village.
The proposal would cause further piecemeal development in the village.
The proposal is contrary to s. 15.8 ‘Multi-Unit Residential Developments’ of the MCDP.
The Part V proposal is not compliant with planning policy. The Part V proposals are confused and may
represent a material contravention of the MCDP. Looked at as a wholly social housing scheme, this is an
isolated and poorly serviced as a site for 29 social houses
The cut and fill proposed is not advertised and is excessive.
The siting, design, scale, bulk and massing of the proposed development is poor. The proposal could cause
negative and permanent residential and visual impacts including loss of privacy to nearby properties.
No Landscape and Visual Impact Assessment is provided.
Landscape mitigation is poor and likely impossible.
No Site Specific Flood Risk Assessment is provided.
A Construction Environmental Management Plan is required.
An Ecological Impact Assessment is required.
RECEIVED: 18/12/2025
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Appropriate Assessment Screening is required. Insufficient information has been submitted to ensure that the
proposed development would not significantly impact on a downstream Natura 2000 site via a hydrological
connection. The proposals are premature having regard to appropriate assessment screening.
No Conservation Report is provided regarding impact on the protected structure & its curtilage.
There are concerns over the Archaeological Report’s veracity and accuracy.
The proposal raises negative precedent concerns.
The proposal would cause depreciation in the value of property in the vicinity
The proposal would cause significant and cumulative impacts on the rural village amenities, landscape and
environment of this area. The scheme would impact on the amenities of existing residents and is not a suitable
proposal for social housing tenants.
It is the professional opinion of BPS, having regard to Section 9.0, that this planning application should be
refused and for the reasons set out in Section 11.1 of this Planning Objection Report.
4.0 Location & description of the subject site
The subject site is unzoned and located at Dernaglug, Doohamlet, Co. Monaghan. Doohamlet village is located
along the R183 Ballybay to Castleblayney Road. The village is located 6km from Castleblayney.
This is an unzoned site under the Village Map for Doohamlet.
The site is shown by the applicant to be accessed by way of an agricultural laneway off the R183.
The site is an agricultural green field located behind and adjoining existing houses and surrounding open lands.
The site measures approximately 1.64 hectares and features a sloping topography. The site’s highest point is in the
north-east corner, where a hill rises, gradually falling to its lowest point in the south-west.
The applicant site, which comprises of open backlands in agricultural use, adjoins 12 no. residential properties and
would be visible from other residential properties.
Fig. 13: The location of the site within the Monaghan rural area and adjoining Doohamlet/Dernaglug (Source:
Google Earth as annotated by BPS)
Applicant site RECEIVED: 18/12/2025
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Fig. 14: The approx. boundary of the site (Source: Google Earth as annotated by BPS)
Fig. 15: The existing agricultural laneway access to the subject site (Source: Google Earth as annotated by BPS)
Fig. 16: The existing agricultural laneway access to the subject site (Source: Google Earth as annotated by BPS)
Applicant site
Laneway entrance to agricultural
access to the site off the R183
Laneway entrance to agricultural
access to the site off the R183 RECEIVED: 18/12/2025
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4.1 No zoning or other designation (site located outside of the village boundary)
The site of the proposed housing development is unzoned and is located outside of the Doohamlet Village Map’s
boundary. Fig. 17 forms part of the adopted Monaghan County Development Plan 2025-2031).
The only part of the site area included in the village boundary is the existing accessway area which is located
between housing developments to the east and the west.
The applicant’s proposed development is located on rural, agricultural lands, not envisaged by MCC for
development prior to 2031.
The existing MCDP is newly adopted – 2025 – and it was two years in its drafting. These lands were not included
in the development boundary of the village. Had these lands been included in the village boundary during the
drafting of the MCDP our client’s group would have opposed this.
The applicant planning application asks MCC to materially contravene the MCDP.
Fig. 17: The location of the site outside of the Doohamlet Village Map’s boundary (Source: Monaghan County
Development Plan 2025-2031)
5.0 Existing relationship between client group’s properties & the applicant site
Our client’s group comprises of all the local signatories which have added their name to the list included in
Appendix 1. These people maintain all the concerns set out in Section 9.0 ‘Grounds for Objection’ of this report.
It is important to note how, as it stands, the applicant site, currently in agricultural use, does not impact adversely
on any nearby property. Importantly:
The existing housing estate of 12 no. houses to the north of the site is a quiet and safe cul-de-sac. It offers a
high level of existing amenity to the households who live on it.
The applicant’s unzoned site outside of
the Doohamlet Village Map boundary RECEIVED: 18/12/2025
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The 10 no. housing estate houses whose rear windows and gardens face and back onto these lands presently
maintain a high level of privacy and amenity. There are no existing overlooking, overbearing, adverse visual, or
adverse noise impacts arising.
The existing laneway by which it is possible to access the site from the R183 passes alongside an existing
dwelling on its west side and these vehicular movements may be noticeable to the closest estate house to
the east. It is infrequently used by agricultural vehicles, and no adverse impacts arise beyond what one would
expect in a rural area.
There are as number of existing dispersed rural dwellings to the west, east and southeast of the applicant site
whose views and setting is presently primarily of a relatively dispersed and low density rural settlement.
6.0 Planning history of the applicant site
In the run-up to the economic crash. these lands were the subject of a large-scale planning application, reg. ref.
061369, for
A housing development of seventy houses and crèche, consisting of 14 number semi-detached three
bedroom two storey units, 34 number semi-detached four bedroom two storey unit, 36 number detached
garages, 10 number detached five bedroom two storey units with detached garages, 2 number detached
four bedroom two storey units with attached garages, nine number detached four bedroom two storey units
with detached garages and one number detach four bedroom two storey unit, connection to public water
and existing sewer treatment unit. All site services and new combined entrance with existing council houses
This planning application was granted subject to conditions on 19/02/2007.
The planning files are not available online. Only the planning conditions can be accessed.
Planning permission was granted despite a range of shortcomings with the planning application, including:
No written legal consent from Monaghan County Council for the construction of the proposed access road
and footpath link to the application site had been provided.
No written legal consent from third party land owners for the construction of the proposed footpath link to the
north east of the application site had been provided.
No written legal consent from third party land owners for the construction of the proposed sewer/services
pipeline to the north east of the application site had been provided.
No Part V agreement had been reached with MCC.
No adequate tree and hedgerow survey had been carried out. MCC added conditions 3 and 4 stating: “The
existing line of mature trees and hedgerow along the northern, north eastern, eastern, southern and south
western boundaries of the site shall be retained intact and protected from damage at all times, particularly
during building operations” and “The existing line of mature trees and hedgerow running through the centre of
the site shall be retained as indicated on the plans and details submitted to the Planning Authority on 24th
January 2007, and protected from damage at all times, particularly during building operations.”
MCC recognised a deficiency in footpath provision to the west of the R183 entrance. The south side of the
road had no footpath (and still does not). MCC added the following condition: “Prior to the occupation of any
dwelling the developer shall provide a 2m wide pedestrian footpath with associated drainage facilities along
the existing public lighting on the R183 public road in the western direction from the existing entrance that is
proposed to serve the development to Doohamlet National School. This footpath shall be linked to
Doohamlet National School via a controlled pedestrian zebra crossing and shall also be linked to the
proposed footpaths in the development site. Dropped kerbs, associated tactile paving and the controlled
zebra crossing facility for the proposed footpath to be constructed in accordance with the
regulations/specifications detailed in Section E of the Traffic Management Guidelines Publication. All details
and method statement for the construction of the pedestrian footpath, location of any necessary
gullies/drainage facilities along kerbline, appropriate locations for dropped kerbs and the pedestrian crossing
facility shall be agreed with the Planning Authority prior to commencement of construction works.”
The existing and proposed entrance onto the R183 required significant works with WCC conditioning that it be
a shared entrance with the adjoining housing development to the north and east of the site: “The existing
entrance onto the R183 public road that is proposed to serve the development shall be upgraded to form a
bellmouth of 10 metres radius with edge of new boundary.”
There were no adequate sightlines at the R183 entrance and so MCC added the following conditions: “The
Developer shall ensure that minimum clear sight distances of 80 metres in the eastern direction (towards
Castleblayney) and 100m in western direction (towards Ballybay) are to be provided and maintained at all RECEIVED: 18/12/2025
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times from a point in the centre of the existing entrance onto the public road 3 metres from the road edge and
1 metre above ground level. Sight distances to be measured to the nearside road edge in both directions
Where it is necessary to remove hedgerows/trees/side banks/walls/fenclines etc in order to achieve these
sight distances, the new boundary should be located clear of sightlines. Any pole, column, sign or other
obstruction materially affecting visibility must also be removed or relocated behind the required visibility
splays. All site works required to fulfil the minimum sight distance requirements above to be carried out prior
to the commencement of any building works” and “The area within the visibility splays shall be cleared to
provide a level surface no higher than 250 mm above the level of the adjoining carriageway and shall be
retained and kept clear thereafter. No work shall commence on site until the visibility splays have been
provided.”
MCC was concerned over the gradient from the R183 into the site and added the following condition:
“Gradient in access roadway proposed to serve the development to be not greater than 1:20 (5.0%) for the first
15 metres from the R183 public road edge and thereafter should conform to gradients specified in publication
“Recommendations for Site Development Works for Housing Areas.”
No adequate surface water management scheme was provided and MCC added a condition which states:
“Applicant to ensure that adequate provisions are made within the site for surface water drainage and no
surface water to be allowed flow onto public roadway or into the foul sewer lines.”
MCC was concerned the site could not be safely accessed or drained without significant works and added the
following condition: “All site works required to fulfil the minimum sight distance and drainage requirements
above to be carried out prior to the commencement of any building works. Failure to do so will result in forfeit
of part or all of cash deposit.”
Archaeological concerns were addressed by way of condition: “22 a. The proposed development is in
proximity of a protected structure (Doohamlet Church) and in an area where archaeological remains may exist.
Prior to commencement of development, the developer shall employ a suitably qualified archaeologist,
licensed under the National Monuments Acts 1930-1994, to monitor all topsoil stripping associated with the
development. b. In the event of archaeological material being found during the course of monitoring, the
archaeologist may have work on the site stopped pending a decision as to how best to deal with the
archaeology. The developer shall take and act upon advice from Department of Environment, Heritage, Local
Government with regard to any necessary mitigating action and shall facilitate the archaeologist in recording
any material found. c. The Planning Authority and the Department of Environment, Heritage, Local
Government shall be furnished with a report describing the results of the monitoring. d. The development of
the site shall be carried out in accordance with any recommendations made by the Department of
Environment, Heritage, Local Government in response to the report submitted. e. No sub surface work shall
be undertaken in the absence of the archaeologists without their express consent.
6.1 The downzoning of the site
Many unsuitable developments were permitted in small villages in the years up to the economic crash. Thankfully,
permission reg. ref. 061369 was not commenced and no ghost estate was left to wait for the crash to pass.
Recognising the unsuitability of these lands for development and that this planning permission had been a
mistake, MCC downzoned the lands in circa 2007 or 2008. This was part of a process of de-zoning significant areas
of land in the village of Doohamlet and other areas of County Monaghan when the Minister intervened to stop
over-zoning of lands in unsuitable locations. MCC may remember the following sample articles:
https://www.irishtimes.com/news/monaghan-council-angry-at-gormley-rezoning-refusal-1.951680
https://www.irishtimes.com/news/gormley-directs-council-to-rescind-rezonings-1.950896
https://www.independent.ie/irish-news/gormley-facing-showdown-with-councillors-on-
planning/26539742.html
When viewed in light of this controversy and the fact that MCC deliberately downzoned these lands at that time
and did not re-zone them in 2025 when the new CDP was adopted suggests that the current planning application
is aimed at essentially finding a way around the fact that the site is unzoned and outside of the designated
development envelope of the village.
6.2 Conclusions from the planning history of the site
The following conclusions arise from the planning history of the site:
The lands were the subject of a Celtic Tiger planning permission which was not completed. The lands were
subsequently downzoned and they remain that way. This arises from the statutory decision of MCC to exclude
these lands from the designated development envelope of the village. RECEIVED: 18/12/2025
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Objection concern: The current proposal is at odds with the previous Ministerial intervention made to prevent
over-zoning and over-development of lands within MCC’s rural villages.
The development of these lands would require multiple legal consents.
Objection concern: The applicant has provided consent only from MCC.
The site has previously contained:
The existing line of mature trees and hedgerow along the northern, north eastern, eastern, southern and
south western boundaries of the site shall be retained intact and protected from damage at all times,
particularly during building operations.
The existing line of mature trees and hedgerow running through the centre of the site shall be retained as
indicated on the plans and details submitted to the Planning Authority on 24th January 2007, and protected
from damage at all times, particularly during building operations.
Objection concern: These trees and hedgerow appear to have been removed from the site. No explanation for
this is provide in the current planning application.
MCC has previously required the development of these lands to be accompanied by a new footpath passing
west from the R183 entrance on the south side of the R183 at 2m wide all the way to the Doohamlet Primary
School.
Objection concern: The current planning application offers no such planning gain.
MCC has previously required the development of these lands to be achieved by way of an upgraded entrance
- to form a bellmouth of 10 metres radius - onto the R183 shared with the adjoining housing estate cul-de-sac.
Objection concern: The current proposal would enter and exit the adjoining housing estate cul-de-sac.
MCC recognised significant deficiencies with the existing sightlines at the R183 and required that this be
permanently addressed by way of maintenance.
Objection concern: The current planning application seeks to avoid this concern entirely referring to only to
how these issues are historic rather than potential road traffic hazards.
MCC was worried about the site gradient relative to the R183.
Objection concern: The applicant now proposes unsatisfactory cut and fill works.
MCC was concerned to protect the protected structure (Doohamlet Church) and this area where
archaeological remains may exist.
Objection concern: The current planning application does not assess likely adverse impacts on the protected
structure, and its archaeological report is deficient (including in its errors) given how cut and fill works are
proposed on the site.
These concerns have implications relevant to our client’s Grounds for Objections.
7.0 The proposed development description
The proposed development is advertised on the public notices as:
The provision of 29 no. dwellings comprising:
- 1 No. 2 bed detached bungalow dwellings,
- 4 no. 2 bed semi-detached bungalow dwellings,
- 6 No. 2 bed semi-detached two-storey dwellings,
- 2 No. 3 bed detached two-storey dwellings,
- 11 No. 3 bed semi-detached two-storey dwellings,
- 5 no. 4 bed semi-detached two-storey dwellings.
Together with boundary treatments, hard & soft landscaping, public lighting, new estate road, connection to
existing mains services together with all ancillary and associated site works.
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8.0 Proposed relationship between the area & the applicant scheme
The applicant proposals for this unzoned and undesignated agricultural field site, the only part of which that
connects to the village being owned by MCC, would represent a significant change to the environs of adjoining
and surrounding properties and to the area, including:
Developing lands mostly not envisaged to be developed by the MCDP 2025-2031.
This is a single access, cul-de-sac, development which would focus all vehicle traffic into a small area around
the existing agricultural laneway to the R183 and between the two closest residential properties. This would
cause noise, disturbance, light flicker, etc. 24/7.
The proposal would site a large residential scheme into an unzoned agricultural field behind and close to at
least 13 dwellings. This would adversely alter and impact adversely on the residential and visual amenities of
these properties.
The proposal would generate traffic movements in quiet backland areas which would impact on adjoining and
nearby properties.
The proposal would impact on the existing protected structure and its curtilage (graveyard) to the east).
The proposal would generate significant cut and fill works as the applicant re-grades the level of the site by up
to 3m or more.
Section 9.0 sets out our client’s Grounds for Objection against this scheme.
9.0 Grounds for objection
BPS has been asked by our client to assess the planning application from their perspective and the perspective of
the area into which it is proposed.
BPS has identified the following concerns with the submitted planning application. We note that these points have
been discussed in detail with the group.
9.1 Ground 1: The principle of development is not accepted – the site is unzoned
Section 4.1 of this report confirms that the applicant lands are unzoned and located outside of the village boundary.
Despite this, the applicant states: “In principle there are no objections to the development at this location. The
mixture of dwelling types and tenures are acceptable.” On what basis is this claim made?
The only part of the “site” which is within the village’s development boundary is an area of land through which
these lands can presently be accessed from the R183. This is only located in the village boundary because it falls
between the residential developments sited to the east and west which are sited inside the boundary.
As noted in Section 6.2, these lands were downzoned at the behest of the Minister following the economic crash.
The current planning application seeks to find a loophole to get around this.
This being the case, the applicant proposal is essentially for 29 rural houses all grouped together in an agricultural
field wherein no development has been anticipated by MCC under the MCDP 2025-2031.
The only way for this planning application to be permitted is for MCC to materially contravene the MCDP which has
only just been adopted.
Our client’s group would have opposed any attempt during the drafting of the MCDP to alter the village boundary
to include these backland agricultural lands. The democratic position of MCC as set out in the adopted MCDP is
that this site is not suitably zoned or sited for development at this time. This position should be upheld.
While MCC may consider granting permission and material contravening the MCDP we note how this proposal:
Is not of strategic or national importance being a poorly sited and over-scaled rural housing development.
There are no conflicting objectives in the development plan, and the objectives are clearly stated, insofar as
the proposed development is concerned. This is because the MCDP has only just been adopted.
Permission for the proposed development should not be granted having regard to regional spatial and
economic strategy for the area, guidelines under section 28, policy directives under section 29, the statutory
obligations of any local authority in the area, and any relevant policy of the Government, the Minister or any RECEIVED: 18/12/2025
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Minister of the Government. This is because the MCDP post-dates all relevant planning policies and guidance
documents issued at national and/or regional levels.
Permission for the proposed development should not be granted having regard to the pattern of development,
and permissions granted, in the area since the making of the development plan because to do so would set an
adverse precedent for similar developments to be proposed on sites outside the development boundaries of
villages throughout the MCC area.
We respectfully submit that the proposed development is unacceptable in principle. This being the case, the
planning application should be refused.
9.2 Ground 2: Contrary to MCDP 2025-2031 policies & objectives to prevent urban sprawl
The MCDP contains repeated references to the need to ensure that all development in Tier 4 villages is properly
managed. This aligns with the NPF which requires a major new policy emphasis on renewing and developing
existing built-up areas rather than continual expansion and sprawl into the countryside. Policy Objective 53 which
states requires: “greater efficiency in land management, greater use of renewable resources and by reducing the
rate of land use change from urban sprawl and new development”.
One of the five growth ambitions of the Regional Spatial and Economic Strategy (RSES) for the Northern and
Western Regional Assembly 2020-2032 states: “Compact growth will be pursued to ensure sustainable growth of
more compact urban and rural settlements, supported by jobs, houses, services and amenities, rather than
continued sprawl and unplanned, uneconomic growth”.
The Development Plan includes Objective SSO 12 (see Fig. 18). The purpose of Objective SSO 12 is to prevent
developments being proposed outside of the designated development envelopes (village boundaries) set out in
the Development Plan. Doohamlet has been allocated a designated development envelope – see Fig. 17. The
applicant’s proposed development is – excepting the access road area between the site and the R183 – located
outside this designated development envelope. This being the case, the proposal is not sustainable development;
instead, it is urban sprawl of the type which Objective SSO 12 is designed to prevent.
The applicant proposals would represent a material contravention of Objective SSO 12.
Fig. 18: Objective SSO 12 of the MCDP 2025-2031
Further, the MCDP requires at Section 7.2 ‘Planning for Sustainable Transport in County Monaghan’ and states:
The integration of land use and transportation is a fundamental principle of the National Sustainable Mobility
Policy document. Land use planning which promotes compact building forms and restricts urban sprawl while
making provision for good public transport connections and safe routes for walking and cycling will be
encouraged. The policy recognises the vital importance of continued investment in transport to ensure an
efficient economy and continued social development.
The applicant proposal is a housing only scheme of urban sprawl in a village unsuited to this scale of development
being provided without services. The scheme will be car based with all social housing tenants needing up to 2 cars.
9.3 Ground 3: Proposal would leapfrog undeveloped lands within village boundaries
The proposed development would leapfrog undeveloped lands within village boundaries and, as such, is contrary
to the MCDP requirement to achieve sequential development.
Chapter 2 ‘Core Strategy’ includes Section 2.0 which states:
The core strategy of the County Development Plan recognises the role of settlements in driving the
development of the County but also identifies the scope of development possible for the County, while
remaining consistent with national and regional policy. It also identifies the quantum and location of
development for the plan period, consistent with the population targets and settlement hierarchy that reflects
the availability of existing services, planned investment, sequential development and environmental
requirements [emphasis added].
Section 2.9 ‘Housing Need and Demand’ states: “Given that most land zoned for housing has remained
undeveloped, it is proposed to apply the following approach to promote growth in the designated settlements of RECEIVED: 18/12/2025
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County Monaghan: … Encourage sequential development of lands from the settlement centre outwards …”
[emphasis added].
Section 2.10 states:
The Core Strategy provides for the development of lower density houses within the urban settlements. This will
be permitted through schemes that provide suitable housing to meet the needs of people who might otherwise
seek to build a one-off dwelling in the rural area. Such schemes will only be permitted on suitable lands
located within the designated settlement boundaries where it is demonstrated that there is a demand for
the development within the settlement and where it contributes to the sequential development of land
from the centre of the settlement outwards or represents a consolidation of the settlement footprint
[emphasis added].
Section 3.18 ‘Delivering the Housing Strategy’ includes Housing Strategy Objective HSO 2 which aims
To guide urban residential development in a sequential manner outward from the centre of the settlements
to maximise the use of existing and future infrastructure provision, to promote sustainability, to make more
efficient use of underutilised lands, and to avoid the extension of services and utilities to more remote
areas [emphasis added].
Fig. 17 of this report sets out the Village Map and boundary of Doohamlet. There is considerable land within the
village boundary which could be developed into housing, either single houses or groups of houses.
There is no justification for the applicant to propose a single housing development which would leapfrog these
undeveloped lands within the village’s development boundary.
The applicant is, in short, trying to achieve the re-zoning of these lands and/or their relocation to inside the village
development boundary without having achieved this during the drafting of the MCDP. Our client’s group notes that
these lands being agricultural only would achieve a significant increase in value if they were de facto re-zoned to
facilitate this scheme.
There is also the concern that this scheme could be located on suitably zoned lands within the development
boundary of any of MCC’s villages. Our client’s group has also studied the Village Maps for Annayalla, Ballinode,
Clontibret North, Emyvale, Glaslough, Inniskeen, Newbliss, Oram, Rockcorry, Scotshouse, Scotstown,
Smithborough, and Threemilehouse. Each of these villages maintains lands which could accommodate new
housing development. The applicant proposes to leapfrog all these suitable lands. This is not appropriate.
9.3.1 Proposal raises the same concerns as reg. ref. 21/378 / appeal PL18.313034
As MCC is aware, in 2021, a planning application was lodged for a 23 dwelling housing estate in Inniskeen (a rural
village in south Monaghan). The planning reference is 21/378 and the subsequent appeal reference is An Coimisiún
Pleanála reg. ref. PL18.313034.
This was described as a “23-unit residential estate (mix of 2-3 bed semi-detached, bungalows, and terraced units;
11 private, 12 social/retirement), new access, ESB substation, communal open space, landscaping, drainage, and
site works on 1.07ha brownfield site”.
The site was also partially outside the defined village boundary envelope. The applicant argued that the lands
were close to the village core yet they were partly outside the development boundary of the village. MCC
found site’s periphery location unacceptable as the village retained undeveloped lands closer to village core,
conflicting with sequential development policy (VIL1).
The current application’s strategy of offering all social housing units was used in a similar manner as this refused
proposal which included: “Units 1-11 inclusive as private housing and units 12-23 as a combination of social and
retirement housing”. The portion outside the village boundary envelope included the social housing and
retirement housing. MCC found that the unit mix was not justified with the area of social units not having been
justified or demonstrated to be required.
MCC’s concerns are set out in its very detailed 2 no. reasons for refusal which state:
1. The site of the proposed development partially lies within the settlement envelope of Inniskeen. Policy VIL 1 of
the Monaghan County Development Plan 2019-2025 seeks “to require applications for residential development
within these settlements to demonstrate that the proposal contributes to the sequential development of the
settlement of land from the centre outwards and/or represents an infilling of the existing settlement envelope”.
The site of the proposed development is located on the periphery of the Tier 4 settlement of Inniskeen and the
development of same would result in the retention of a large portion of undeveloped land located within the
ownership of the applicant which is sequentially closer to the village core than the submitted site area.
Consequently, the proposed development, if permitted, would be contrary to the provisions of Policy VIL1 of the RECEIVED: 18/12/2025
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Monaghan County Development Plan 2019-2025, would not represent a co-ordinated and consolidated pattern
of growth and would be contrary to the proper planning and sustainable development of the area.
2. The site of the proposed development partially lies outside the settlement envelop of Inniskeen. Policy VIL 2 of
the Monaghan County Development Plan 2019-2025 states “Notwithstanding the provisions of Policy VIL1 and
Section 15.7 ‘Multi Unit Residential Developments’, and taking into account the objectives of the ‘Rebuilding
Ireland’ Strategy to address the shortage of housing, the planning authority may favourably consider proposals
for social housing developments which are outside the defined settlement limit where a clear demonstrable
need can be proven, and where the lands are contiguous to the settlement limit and can be adequately
serviced”. The proposed development affords for the provision of 12 number dwellings on lands which are
outside of the development limit of Inniskeen. The dwellings will comprise a combination of social and
retirement housing. Notably policy VIL 2 does not afford for the provision of retirement housing on lands outside
defined settlement limits. Additionally, the proposal to provide a mixture of social and retirement housing on
lands outside the settlement limit does not address the demonstrable need for social housing in the village.
Consequently, the proposed development, if permitted, would be contrary to the provisions of Policy VIL2 of the
Monaghan County Development Plan 2019-2025, would not represent a co-ordinated and consolidated pattern
of growth and would be contrary to the proper planning and sustainable development of the area.
Fig. 19: The Site Location Map for refused planning application reg. ref. 21/378`
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Fig. 20: Excerpt of the Site Layout Plan for refused planning application reg. ref. 21/378
Fig. 21: Reason for refusal issued under appeal, reg. ref. PL18.313034
9.3.2 The Inniskeen site was serviced – the applicant site is an agricultural field
The current planning application refers to the subject site as a serviced site. This is not the case – there has been
one previous planning permission granted by MCC on this site which was not commenced. No services have been
delivered to this site based on the site’s planning history. The site is presently an agricultural field accessed from
an agricultural laneway. What the applicant means is that, if planning permission is granted, services can be
delivered to the site. However, this in no way supports the current planning application because there are
undeveloped lands within the designated development envelope of Doohamlet which can just as easily be
serviced. Indeed, why would the capacity of any existing services in the village be directed towards lands primarily
outside of the village?
MCC may wish to refer to the Inniskeen site’s planning application (see Section 9.3 of this report). That site was
refused notwithstanding that by virtue of previous site works carried out in accordance with previous permission
04/ 1438, the site was a brownfield parcel of land with hardcore, foul and storm infrastructure already in place.
Reg. ref. 04/ 1438 referred to: “5 No. four bed two storey detached dwellings, 18 No. three bed two storey semi-
detached dwellings, 8 No. four bed two storey semi- detached dwellings, 4 No. three bed single storey detached
dwellings (35 houses in total). The planning application will include connection to the existing public sewer and
discharge of storm water to the Fane River and incorporate a new site boundary and entrance onto public road (LP
04622) and all ancillary and associated site works”. This was granted.
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The current planning application site has not been the subject of any previous planning applications and is
unserviced. In any case, Section 2.6.4 ‘Tier 4 – Villages’ of the MCDP sets out that each village within the
designated village networks has the necessary infrastructural capacity available to ensure they can continue
their function as local growth settlements and serve the needs of their hinterlands.
9.3.3 There was pre-planning with MCC Planning and Housing for the Inniskeen site
Our client’s group is concerned that the fact that pre-planning meetings have taken place with MCC Planning and
Housing Sections this means there is a pre-agreement in place with the applicant.
BPS has explained to our client that such discussions are held ‘without prejudice’ and pointed to how in the
Inniskeen case such pre-planning meetings also took place.
9.4 Ground 4: Proposal is premature pending the site being re-zoned & a village plan adopted
As noted in Section 9.2 of this report, the applicant’s residential development could be sited on lands located in the
development boundary of any one of MCC’s villages (or located on zoned lands in any town). Instead, the applicant
has proposed that it be located in unzoned lands outside of the development boundary of Doohamlet Village.
It is however the professional opinion of BPS that this proposal is premature pending the site being re-zoned, these
lands being included in the village’s development boundary, and a village plan being prepared for Doohamlet
Village (which sets out anticipated population growth, housing growth numbers, etc.).
Had these lands been re-zoned into the designated development envelope of Doohamlet during the drafting of
the CDP, the Office of the Planning Regulator may have intervened (as the Minister did previously).
The applicant has not offered any masterplan for the village into which this proposal would fit.
Non-compliance with Section 2.6.4 ‘Tier 4 – Villages’ of the MCDP
In trying to make a case in favour of MCC overlooking the unplanned status and rural/agricultural nature of the
site, the applicant argues in their ‘Concept Statement’ that because Doohamlet is a Tier 4 – Village, the matter can
be deemed addressed. This is not the case. Section 2.6.4 ‘Tier 4 – Villages’ of the MCDP notes how:
Including the village network as part of the Settlement Hierarchy is an acknowledgement of their importance to
the rural areas of County Monaghan in sustaining the vitality of rural communities. Each village has the
necessary infrastructural capacity available to ensure they can continue their function as local growth
settlements and serve the needs of their hinterlands. These villages provide services to rural communities,
including housing, neighbourhood level retail and social facilities which are critical to the on-going viability of
these rural communities.
Section 2.6.4 notes how the villages are a network, and they act together. Lands placed within the development
boundaries of any one of the villages adds to the total available. These are the appropriate lands which the villages
most need developed.
Section 2.6.4 refers to “local growth” as regards “housing”. With all due respect, the scale of this proposal at 29
houses on a 1.64 hectares is commensurate with urban scale development ongoing in the county’s towns. This is
not a development aimed at supporting local growth in an existing rural community. The proposal is out of scale
with what would be an appropriate infill development within the village boundary.
Section 2.6.4 is also clear that development should be for rural communities, local growth, etc. That is, any
development should be critical to the ongoing viability of the village. Our client’s group ask MC to explain how a
proposal of 29 social housing unit, as indicated on the Planning Application Form, would bear any relationship to
meeting local needs. While there may be demand for 29 social housing units within the county, with respect, there
is not demand for 29 social housing units in this village. The proposal is not for local growth; instead, it is to create a
single tenure housing enclave at a wholly unsuitable rural village location where the development approach is
meant to be incremental. That a supporting letter has been provided to the applicant from the MCC Housing
Section is irrelevant to the assessment of whether this proposal aligns or not with the proper planning and
sustainable development of the area and complies with the MCDP 2025-2031.
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Fig. 22: Excerpt from the Planning Application Form
Non-compliance with Section 2.6.4 – Objectives SHO 4 and SHO 5 of the MCDP
The applicant also attempts to rely on Section 2.6.4 and Objectives SHO 4 and SHO 5 of the MCDP. The following
problems arise with these arguments:
As regards Objective SHO 4, the proposal does not constitute development that is commensurate with the
nature and extent of the existing village. This is a 29 unit social housing only scheme, which, as noted above,
could not reasonably be considered to represent incremental residential growth in the village to meet local
needs. While the village may be a location for some housing growth, this must be within the development
boundary of the village (or any MCC village). Being a social housing development, not one of the proposed
units would be available for purchase by local people. This being the case, the proposal would not address
local housing need and may, in fact, drive demand for further rural housing development in the countryside
which is contrary to national, regional and local planning policies.
As regards Objective SHO 5, this proposal is, as stated above, wholly premature. MCC states its intention: “To
prepare Tier 4 village plans during the lifetime of this plan, with a focus on housing, amenity, infrastructure,
transport and the sustainable reuse and regeneration of existing derelict, vacant, or underutilised sites”. The
applicant could make their case for the re-zoning of these lands and/or their relocation into the village
boundary once MCC has opened consultation on a draft village plan. Further, the objective does not state that
MCC will look to include large agricultural fields as the focus for new village development in the future; instead,
it refers to “existing derelict, vacant, or underutilised sites”. The applicant has not provided a breakdown of the
available volume of zoned residential lands and/or lands suitable for residential development within the village
boundaries of all MCC’s villages. Our client submits that these lands are more than sufficient to accommodate
local demand for new housing in each village. If this was not the case, MCC would have increased the quantum
of lands available for development in the villages prior to adopting the MCDP.
Fig. 23: Section 2.6.4 – Objectives SHO 4 and SHO 5 of the MCDP
9.5 Ground 5: Doohamlet is a recent Tier 4 village – the applicant wants all its growth to 2031
The MCDP 2025-2031 confirms that Doohamlet was until the MCDP 2025-2031 was adopted, a Tier 5 - Rural
Community Settlement which are described as: “Small villages and dispersed rural communities providing daily
convenience goods and possibly a pub and/or community centre”.
It appears wholly unsatisfactory to our client that a small village barely designated a Tier 4 village more than a few
short months should find itself now the subject of this substantial planning application on lands primarily outside of
the designated development envelope. The MCDP 2025-2031 was only adopted on 7th July 2025 and was the
subject of a Draft Ministerial Direction.
It appears remarkable to our client’s group that the applicant was able to locate the subject site, obtain
ownership/control over it, appoint a project team, undertaken pre-planning meetings with MCC Planning and
Housing sections, prepare the current planning application, lodge the planning application, be invalidated, re-
lodge the planning application, and it is still only October 2025.
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Clearly, the applicant was planning this proposal before Doohamlet was re-designated a Tier 4 settlement. Indeed,
the pre-planning meeting/consultation with MCC referred to in the Planning Application Form took place while
Doohamlet was still a Tier 5 small rural village.
BPS acknowledges how National Policy Objective 3a within the NPF aims to “Deliver at least 40% of all new homes
nationally within the built-up footprints existing settlements” and how the MCDP states that “these villages have
projected population growth of 6.8% over the plan period”. This is less than the 7.5% growth targeted for all Tier 4
villages. Given the recent re-designation of Doohamlet, clearly anything under 6.8% would be appropriate. This is in
line with Table 2.2 of the MCDP.
The current proposal would obviously take up a large proportion of the total proposed population growth for the
entire village for the next 6 years – growth which the MCDP anticipated (and based its figures) on taking place in
the designated development envelope.
However, it is only when one reviews Table 2.4 ‘County Monaghan Population Projections 2022 to 2031’ that the
applicant’s proposal ceases to represent any credible case. The village’s current population is only 287. The
predicted and planned population increase up to 2031 is 30 persons (to 317). For the applicant proposal to align
with the Table 2.4, only 1.03 persons could live in each house.
MCC is asked to refuse planning permission on the basis that the applicant wishes to take up all the planned
population growth for the village, leaving none for any other residential development up to 2031. And, they
wish to site 27 of the 29 proposed dwellings outside of the designated development envelope of the village. In
short, this one field would replace all other lands designated for development in the village up to 2031. The
proposal is wholly out of proportion with the growth targets for the village and would detract from the proper
planning of lands within the village.
We note also that Table 2.5 Core Strategy Table of the MCDP indicates how there will only be 205 new houses
in all the Tier 4 villages over the next 6 years. The applicant proposal would consume 14.1% of this and do so
on lands mostly outside of the designated development envelope of any of the Tier 4 villages.
Fig. 24: Doohamlet – a Tier 5 Small Rural Village under the MCDP 2019-2025
Fig. 25: Excerpt from Section 2.4 ‘Projected Population Growth –2025-2031’ of the MCDP
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Fig. 26: Table 2.2 Population Targets 2031
Fig. 27: Table 2.4 County Monaghan Population Projections 2022-2031
Fig. 28: Table 2.5 Core Strategy Table
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9.6 Ground 6: No Social Infrastructure Audit has been submitted to address isolation concerns
Doohamlet is a small rural village and townland in north-central County Monaghan, Ireland, located on the R183
road between Castleblayney and Ballybay, approximately 3 miles from the N2 Dublin-Derry route. With a
population of around 1,000 across its district (including ~325 households), it forms part of the Clontibret parish and
is classified as a Rural Node or small village under Monaghan County Council's planning hierarchy. This
designation supports limited, sustainable infill development to address local needs and combat rural
depopulation, but it requires rigorous assessments for larger schemes like a 29-unit social housing development.
A Community and Social Infrastructure Capacity Audit is needed to address concerns that the applicant is seeking
to locate a large-scale social housing scheme in an isolated village which has insufficient services to support it
without residents making constant car journeys and the scheme offers no new services.
The applicant has not provided an evidence-based Community and Social Infrastructure Capacity Audit
Ireland's planning system, under the Planning and Development Act 2000 (as amended), mandates sustainable
development via Project Ireland 2040 (National Planning Framework [NPF] and National Development Plan [NDP]).
The NPF emphasises:
Compact growth in settlements (NPF Objective 3), with 50% of new housing in cities like Dublin and the rest in
regional towns, villages, and rural areas.
Rural regeneration (NPF Objective 5), but only where infrastructure supports it, to prevent "one-off" sprawl or
service strain.
In Monaghan, the Monaghan County Development Plan 2025-2031 integrates this. Chapter 4 (Sustainable
Communities) and Chapter 8 (Rural Development) require rural village housing to:
Demonstrate compatibility with the area's scale, character, and amenities.
Prove no adverse impacts on water, wastewater, education, health, transport, and community facilities.
Social housing (e.g., under Housing for All 2021-2030, targeting 9,000+ units annually) is prioritized but
scrutinized in rural nodes like Doohamlet to ensure viability. A 29-unit scheme could add 70-100 residents
(assuming family occupancy), significant for a village of this size, so an audit verifies sustainability.
What is a Social Infrastructure Audit?
The audit assesses:
Current capacity: Schools, creches, GPs, community centres, shops, public transport, and recreation (using
Central Statistics Office [CSO] data and local surveys).
Future demand: Projected impacts from new residents, focusing on vulnerable groups in social housing (e.g.,
families needing education/childcare).
Gaps and mitigations: Recommendations for upgrades (e.g., bus route extensions or school expansions) if
needed.
Outcome: A "no additional infrastructure required" finding allows permission; otherwise, refusal or conditions
apply.
This is standard for "multi-unit housing estates in smaller settlements" per Monaghan's plan (e.g., similar to Policy
SC-P8 in the 2019-2025 plan), requiring capacity audits for developments over 5-10 units). It's also tied to Section
28 Ministerial Guidelines, making it binding on the council.
Why is it Needed Specifically for This Scheme in Doohamlet?
Doohamlet's rural setting—remote from Monaghan town (~20km) and with limited services—highlights fragility in
infrastructure. Without the audit, permission risks non-compliance and appeals to An Coimisíun Pleanála. Key
reasons include:
Protecting Limited Rural Services from Overburden: Doohamlet has basic amenities (e.g., All Saints RC Church,
O'Neill's GAA club, local businesses like Doohamlet Motors), but one primary school and intermittent transport to
Castleblayney/Ballybay. A 29-unit influx could exceed:
Education/Childcare: School enrollment limits; audit checks CSO-projected pupil increases.
Healthcare: Sparse GP access; verifies clinic capacity via HSE consultations.
Transport/Access: Reliance on R183; ensures pedestrian links and no traffic strain.
Ensuring Viable Social Housing Delivery:
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Housing for All promotes rural social units for depopulation, but requires "social mix" and integration (NPF
Objective 13). The audit confirms the scheme won't create isolated low-income pockets, reducing vacancy risks (a
post-2008 issue in Monaghan).
In small villages, concentrated housing must prove community benefits; Doohamlet's estates (e.g., Cois Cill from
the 2000s) set a precedent for scaled assessments.
Recommendation to MCC
We recommend that MCC request an audit.
MCC should consult stakeholders (e.g., Department of Education, HSE, etc.) to confirm if the applicant’s case is
credible.
We note that the MCDP 2025-2031 strengthens rural audits amid Housing for All targets.
In essence, the audit seeks to ensure that Doohamlet's 29 social units would foster sustainable growth without
straining Monaghan's rural fabric, reflecting evidence-led policies.
Our client does not consider the applicant scheme to be sustainable at this location, at the scale proposed, and
given the shortage of services in the village.
9.7 Ground 7: The capacity of the Doohamlet WWTP is not stated & WWT issues unaddressed
The application relies on screen grabs from the Uisce Eireann website to argue that there is spare capacity in the
Doohamlet WWTP. The applicant is required to provide a Confirmation of Feasibility for a connection letter from
Uisce Eireann. This is not included in the planning application.
Based on the latest available information as of October 20, 2025, there is no publicly available data confirming the
exact current capacity or available headroom (unused treatment capacity) at the Doohamlet wastewater treatment
plant. Doohamlet. It has a modest municipal wastewater treatment system managed by Uisce Éireann, but it is not
featured in recent upgrades, national capacity registers, or EPA discharge reports for Monaghan. This lack of
specific mention suggests it is a smaller facility without recent public assessments, which is common for plants
serving populations under 500–1,000 people.
Key Findings from Available Sources:
No Specific Capacity Data: Searches across Uisce Éireann's Wastewater Treatment Capacity Register (updated for
2023 loads with 2025 projections), EPA wastewater discharge licenses, and Monaghan County Council reports yield
no details on Doohamlet. Larger Monaghan plants (e.g., Carrickmacross, Clones, Ballybay) are highlighted for
upgrades, but Doohamlet is absent.
General Monaghan Context: Uisce Éireann is investing €1.1 million in upgrades across Monaghan towns/villages as
of September 2024, focusing on Clones, Ballybay, and Smithborough to improve water quality and support
housing/business growth. Nationwide, over 60% of raw sewage discharges have been eliminated since 2015,
adding capacity for ~120,000 people, with most remaining removals targeted by end-2025. However, rural plants
like Doohamlet's may not have been prioritized.
EPA Oversight: All Monaghan wastewater plants (including smaller ones) are regulated by the EPA for discharges.
Uisce Éireann handles operations, but no 2025 license or capacity report mentions Doohamlet specifically. If
overloaded, it could appear on the EPA's Priority Action List (now down to 97 plants nationally from 148 in 2017),
but it's not listed.
Recommendations for Confirmation:
The applicant should contact Uisce Eireann for precise, up-to-date capacity (e.g., population equivalent or PE
headroom), email developerservices@water.ie or call their Connections & Developer Services team at 1800 278
278. They provide site-specific advice for developments and can confirm if upgrades are planned.
Monaghan County Council’s Water Services team should require the applicant to confirm feasibility pf connection.
MCC should search the EPA's wastewater discharge register at epa.ie for "Doohamlet" to view any license
conditions or compliance reports.
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9.7 Ground 7: Proposal is contrary to s. 15.8.10 & Objective RDSP 1 of the MCDP 2025-2031
The applicant’s planning application must comply with Section 15.8.10 ‘Residential Development in Tier 4
Settlements’ and Objective RDSP 1 of the MCDP 2025-2031. Objective RDSP 1 (see Fig. 29) states: “Proposals for
residential developments within Tier 4 settlements shall comply with Section 15.8.10 of the Monaghan County
Development Plan 2025-2031”.
Section 15.8.10 states:
Residential development and serviced sites on suitable lands located within any of the defined Tier 4
settlements which have capacity within existing public foul drainage and public/group water systems, will be
considered subject to compliance with the following:
a) The submission of evidence to the satisfaction of the Planning Authority that there is demand for the
proposed residential development taking account of the extent, nature and status of 306 extant permissions for
residential development, and vacant residential properties in the settlement.
b) The proposal contributes to the sequential development of land from the centre of the settlement outwards
and/or represents an infilling of the existing settlement envelope.
c) The scale and density of the development accords with the character of the village.
Several areas of non-compliance arise:
The applicant has not demonstrated that there is demand for the proposed development of 29 social
houses within the rural village of Doohamlet. The applicant has not set out details of:
1) Any extant planning permissions in Doohamlet.
2) The achievable number of houses which could be built on undeveloped lands within the designated
development envelope of Doohamlet.
3) The number of vacant properties in the village.
As Section 9.3 of this report confirms, the proposal is contrary to the proper sequential development of land
from the centre of the settlement outwards. The proposal does not represent an infilling of the existing
settlement envelope.
The scale and density of the development is excessive for such a small rural village. The proposal does not
accord with the character of the village’s established character and pattern of development. The applicant
has not set out any adequate planning and sustainably development based justification for why an entire
social housing estate of 29 units should be located in an isolated rural village at Doohamlet when this both
represents a disproportionately large number of social housing units to be included in one privately
proposed housing development and it would be a very large residential area within the village to be
occupied only by social tenants. Even the MCC Housing Section’s letter notes how there is a need for private
housing in this area.
It is in fact the case that the only reason why the applicant is making this proposal is to try to take advantage of a
loophole in the zoning and designated development envelope requirements which apply to proposed
developments in rural villages. This loophole reads:
Notwithstanding the requirements of criteria a-c above for Tier 4 settlements and Section 15.8 ‘Multi Unit
Residential Developments’ of the Monaghan County Development Plan 2025-2031, and taking into account the
objectives of the ‘Housing for All – A New Housing Plan for Ireland’ to address the shortage of housing, the
Planning Authority may favourably consider proposals for social housing developments which are outside the
defined Tier 4 settlement limit where a clear demonstrable need is proven to the satisfaction of the Planning
Authority, and where the lands are contiguous to the settlement limit and can be adequately serviced.
With respect, our client’s group submits that this loophole is designed to benefit social housing developments
proposed by the Housing Section of MCC or an Approved Housing Body essentially working on behalf of MCC
and/or the government. What the applicant is presenting to MCC is a case for primarily unzoned lands outside the
Doohamlet designated development envelope to be essentially rezoned to facilitate housing development and is
using a poorly sited and considered proposal for 29 social houses (and no private houses at all) to justify this claim
under the loophole. Only 2 no. of the proposed dwellings are located on lands within the designated development
envelope: 27 are located outside it.
BPS refers above to planning application reg. ref. 21/378 / appeal PL18.313034. This case was refused, though the
applicant sought to make use of this same loophole (included in the previous MCDP). It was refused because:
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The proposed development affords for the provision of 12 number dwellings on lands which are outside of the
development limit of Inniskeen. The dwellings will comprise a combination of social and retirement housing.
Notably policy VIL 2 does not afford for the provision of retirement housing on lands outside defined settlement
limits. Additionally, the proposal to provide a mixture of social and retirement housing on lands outside the
settlement limit does not address the demonstrable need for social housing in the village. Consequently, the
proposed development, if permitted, would be contrary to the provisions of Policy VIL2 of the Monaghan County
Development Plan 2019-2025, would not represent a co-ordinated and consolidated pattern of growth and
would be contrary to the proper planning and sustainable development of the area.
The current planning application proposes no less than 27 houses outside of the designated development
envelope of Doohamlet. Only social housing is proposed. The proposal is excessively over-scaled as regards any
need to address social housing demand in the village (this would be a significant social housing development in a
large town). The applicant has not demonstrated a social housing need of this scale in the village. MCC’s own
Housing Section notes how the proposal would likely supply every name ever placed on the housing register by
any person from this area despite how many would have no interest in living in an isolated village at Doohamlet.
The MCC Housing Section points to a need for private housing in the area.
It is simply the case that Doohamlet needs some housing development proportionate to the size of the village and
to its housing demand – private and social. This can be achieved by a development within the Doohamlet
designated development envelope. This proposal cannot be justified under this loophole policy and would set a
poor precedent for overscaled, single tenure housing estates to be proposed in villages across MCC area merely
as this allows agricultural lands to be converted into residential lands (albeit for social housing).
Fig. 29: Objective RDSP 1 of the MCDP 2025-2031
9.9 Ground 9: The density of the proposal is not acceptable outside of any village boundary
The applicant proposes development on a site with a total area of 1.64ha. Most of the site outside of the designated
development envelope of the village is agricultural land with a small part of the site within the envelope
comprising 2 no. dwellings and the entrance and access area.
Section 3.14 ‘Residential Density’ refers to 20 units per hectare (gross) in the smaller settlements (Rural town and
Villages). The applicant site is mostly outside of Doohamlet’s designated development envelope and, as such, the
maximum density is that which would apply in the rural area under Section 3.15 ‘Rural Housing’. In this regard, the
proposal is at odds with rural housing policy which does not support large clusters of houses.
The rest of the site contains 2 no. dwellings which could be deemed infill dwellings if proposed in a new planning
application.
9.10 Ground 10: The proposal would cause further piecemeal development in the village
Our client’s group is concerned that this proposal would exacerbate the existing piecemeal nature of the village
which comprises of traditional rural type houses, small sized multi-house schemes, and one large multi-house
scheme. The cul-de-sac housing estate to the north of the village appears over-scaled relative to Doohamlet and
to lack any proper connections into and with the village. There appears to be no rhyme or reason to the existing
development pattern in the village. The centre of the village north of the R183 needs to be consolidated with
structures addressing the road. The sports grounds to the east of the village are isolated and need to be better
connected into the development envelope of the village.
As the focus of the village is the R183, there is a need to avoid developments such as that proposed, and to look to
drawings more development(s) to the north and east of the R183 together to create a coherent village. There is
considerable land within the village boundary which needs to be infilled.
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Fig. 30: Existing piecemeal multi-house developments at Doohamlet
Fig. 31: Lands within the designated development envelope of Doohamlet requiring infill housing development
9.11 Ground 11: Contrary to s. 15.8 ‘Multi-Unit Residential Developments’ of the MCDP
Section 15.8 of the Monaghan County Development Plan 2025-2031 sets out planning policy requirements for
‘Multi-Unit Residential Developments’, which reflect the following planning guidance documents:
Sustainable Residential Development and Compact Settlements - Guidelines for Planning Authorities (2024) •
Sustainable Urban Design Guidelines – Standards for New Apartments (DHLGH, 2025).
Quality Housing for Sustainable Communities- Best Practice Guidelines for Delivering Homes and Sustaining
Communities, (2015).
Design Manual for Urban Roads and Streets (2022).
Urban Design Manual- A Best Practice Guide (2009).
Quality Housing for Sustainable Communities (DEHLG, 2007).
Delivering Homes Sustaining Communities, Statement on Housing Policy (DEHLG, 2007). RECEIVED: 18/12/2025
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BPS Planning & Development Consultants | www.bpsplanning.ie 32
Our client’s group submits that the applicant proposals contravene these policies. Their concerns are:
Adverse impacts on the established community: Our client’s group which represents all the residential property
owners surrounding the proposed development consider that it will impact adversely on their properties and
on the community and for the reasons set out in Section 9.14 of this report.
Not acceptable in principle: Section 15.8 states: “Multi-unit residential developments will not normally be
permitted outside of the designated settlements of County Monaghan”. The proposal is sited mostly outside of
the designated development envelope of Doohamlet; therefore, it is not acceptable in principle.
Misleading context description: With respect to context, the applicant has indicated that the site comprises 1.64
hectares located within the village. This statement is incorrect as the site is only very partially located within the
development limit of Doohamlet. The village is classed as a Tier 4 village, but it is a small village and is typically
very low density in terms of residential use. The site is accessed at present from the R183 though this entrance
is not included in the red line boundary. To avoid opening onto a regional road, the applicant shows all of the
scheme’s traffic being forced into and out of an existing 12 dwelling cul-de-sac.
Existing services: There are no existing services within the subject site and there are no planning permissions to
permit same therein. The site’s existing R183 entrance, accessed via a long agricultural laneway, is not included
in the red line boundary. The proposal would connect into the limited footpath network of Doohamlet at one
point only – the adjoining housing estate cul-de-sac to the north.
Layout and connectivity concerns:
- The proposed development is sited in an agricultural field which is sited behind an existing housing
development which addresses the main street of Doohamlet. The proposal bears no relationship to the
existing character, street pattern, streetscape and building lines of the area. The proposal’s siting is at odds
with and would adversely impact on adjoining properties - a layout where roads do not dominate the
proposed development.
- The proposal has one entrance in and out for pedestrians and motorists and is a car-based development
with no adequate pedestrian permeability or mixture of linkages into the existing village. Forcing all traffic
into and out of a 12 dwelling cul-de-sac to avoid proposing the scheme’s main entrance onto the R183 is of
concern. The scheme would not support walking, cycling, or convenient access to public transport. The
layout is not well connected and integrated with the surrounding urban area. It is a large, road dominated,
cul-de-sac scheme which would feed into an existing cul-de-sac of only 12 houses.
- The proposal does not provide or provide adequate buffers alongside existing and proposed roads to
protect the residential amenity of the dwellings, and to protect the visual amenity of the setting of the
settlement.
- The scheme offers no active frontage to Doohamlet. It leapfrogs undeveloped lands within the designated
development envelope which would contribute to the infilling and streetscape development of the village
as it grows incrementally into a larger settlement.
- Section 15.8 seeks: “The creation of different urban forms to provide a more varied building line to reduce
appearance of suburban layouts”. The proposed housing estate could not maintain a more suburban design
appearance than that included by the applicant. The entire estate is an impermeable cul-de-sac with no
connections to adjoining lands or the road to the southeast corner of the site. The internal layout is of
suburban housing estate houses each addressing cul-de-sacs with turning heads required in multiple
locations. This is 1970s housing estate design of a type which is contrary to national, regional, and local
planning and transport planning policies.
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 33
Fig. 32: The impermeable, single access, cul-de-sac design, also with internal cul-de-sac
- The scheme offers a poor vista from surrounding properties, lands, and roads to the east, west and south,
comprising a de facto suburban estate whose design bears no relationship to a rural village (recently a Tier
5 village). In these views, Doohamlet would be converted to having the appearance of the outer suburbs of
more urban and larger settlements such as Castleblayney.
- The proposal, being a suburban housing estate sited in an agricultural field behind this rural village’s main
street building line (the R183) fails to benefit from any existing passive surveillance. The individual houses in
this housing estate would not overlook the main entrance area to the scheme. The entrance into/front the
existing housing estate cul-de-sac would be a blind spot.
Tenure mix concerns: Section 15.8.4 ‘Dwelling Mix’ states: “For a residential development to be considered
inclusive, it should make provision for housing of different types, sizes and tenures” [emphasis added]. This
provides choice and helps to create a balanced, sustainable community”. The applicant proposal is single
tenure which will not provide for housing choice and help to create a balanced, sustainable community.
Inclusivity concerns: The proposal cannot be attractive to “a range of people and household types” as it is
proposed to be a social housing scheme only. MCC’s Housing Section note how there is demand for private
housing in Doohamlet yet the scheme offers no private housing.
Open space design concerns: The proposed development does not position open space at its centre. The
scheme sites all the proposed housing in the centre of the site and then sites the majority of the open space
along the west side of the site where it adjoins scrubland. The scheme does not respond well to the
topography of the site.
Distinctiveness concerns: As the site is an agricultural field in the backlands edge of the village, it currently
does little by means of creating a sense of place or adding to the settlement' s character. Other lands sited
within the designated development envelope of the village could be better developed, including addressing
the R183 to add entrances to the village and a more defined streetscape. The applicant proposal would add
nothing to the village’s sense of place. The proposed design and layout is homogenous in its suburban type
and would be better suited to the suburb of a town.
Layout: For the most part, these lands do not form part of the designated development envelope of the village.
They comprise a backland field. The village needs developments which contribute to its emerging urban
structure. It does not need another ad hoc and piecemeal single use residential scheme. The applicant’s
arguments in favour of this proposal comprise those which could be applied to any new housing estate in the
county, The problem in this case is that Doohamlet badly needs infill development to help to make the
settlement appear less a random assortment of dispersed developments one associates with a small rural
village. The reason MCC has re-designated the village a Tier 4 village is to encourage this; it is not to encourage
over-scaled suburban schemes to be attached to the backlands of the designated development envelope. This
scheme would do nothing to enhance the perception of a proper village as one drives along the R183. RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 34
The applicant refers to maximising the development potential of the site when this site is mostly an unzoned
field. The proposal bears no relationship to the individual characteristics of the surrounding area. The
applicant’s field does have varying topography and is an attractive area of land; however, it is unsuitable for the
proposed development. It has one entrance in and out – if one can call it that – and is a cul-de-sac scheme
with no adequate pedestrian or cyclist permeability to the village. It is a 1980s style housing estate which fails
address the planning policies which subsequently emerged in the 1990s and 2000s as regards achieving
appropriate development in Irish villages.
BPS considers this proposal to be out of time and at odds with each of the planning policy and urban design
guides provided in Table 1. This proposal is not in the best interests of this emerging small village. MCC has not
issued a detailed Village Design Statement for Doohamlet, but it has made clear which areas of the village are
to be developed. The applicant wants to impact the future of the village with an unanticipated scheme that will
further cause a donut effect, with the centre adjoining the R183 quite lightly developed/underdeveloped, with
its outer areas, such as the applicant’s site, being intensively developed. This is the cart pulling the horse. It is
not compact growth, it is not proper infill development, it is contrary to developing in line with the existing rural
village development typology, it is not a development customised to the village, and it fails to protect the rural
village landscape.
Guide/Document Key Reference Application to Village Infill
Sustainable Residential Development in
Urban Areas (2009)
Section 4.2: Density
Standards
Requires a "sense of place" be developed
within zones and designated lands when
they are developed.
Urban Design Manual: A Best Practice
Guide (2022)
Chapter 5: Infill
Development 10 principles.
Sustainable Urban Housing: Design
Guidelines for Apartments & Houses
(2023)
Table 2.1: Rural
Typologies
The guidelines set out how new
development should contribute positively
to an emerging settlement’s structure
from the centre outward.
Quality Housing for Sustainable
Communities (2007)
Design Checklist
Appendix B
24 criteria—e.g., natural surveillance,
biodiversity.
National Policy Objective 18, NPF 2040 Compact Growth Mandates infill to protect rural
landscapes.
Village Design Statements (Model, DECLG
2012) Local Adaptation Customize for village (e.g., no pastiche
suburban housing estate designs).
Fig. 33: National planning policy documents relevant to the assessment of the current planning application
National Policy Objective 18 (NPO 18) of the National Planning Framework (NPF) 2040 aims to “Ensure that any
new housing in the open countryside, including one-off housing, is located in suitable locations and is
integrated with the rural landscape, and that it contributes to vibrant and viable rural communities” [emphasis
added]. The NPF notes how this objective supports the NPF's National Strategic Outcome (NSO) of
"Strengthened Rural Economies and Communities." It promotes rural housing, including in villages, that avoids
sprawl, respects environmental sensitivities, and aligns with local needs, while addressing depopulation in rural
areas. This proposal fails to respond to NPO 18b which aims to: “Develop programs for serviced sites in small
towns and villages to encourage self-build housing and attract residents, in partnership with local authorities,
Irish Water, and communities”.
This small village in rural Ireland could best benefit from infill residential development - building within existing
village boundaries on underused sites like derelict buildings, vacant lots, empty lands within the designated
development envelope by prioritizing compact, high-quality housing in small developments that enhances
community vitality, sustains local services, and preserves rural character. This approach counters rural
depopulation (e.g., 10% village decline since 2011 Census), supports NPF 2040 goals for 30% of new housing in
existing settlements, and complies with Village Design Statements under the Sustainable Residential
Development in Urban Areas Guidelines (2009).
The applicant’s entire approach is to maximise the development potential of the “site” and not to maximise
benefits to the village. The proposal is not a natural extension of the village. It is sprawl.
The proposal would fail to address what should be the key benefits of infill development in this rural village:
Consolidate the town centre: The proposal is not emphasized sensitive infill—small-scale, context-sensitive
builds on underused urban land—to consolidate the town centre and avoid sprawl. It is a develop-led and
unplanned addition to a small village which needs to consolidate its centre around the R183 and entrances
into the village.
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 35
Public realm gains: The proposal is sited mostly in a backland field and will not contribute to the public
realm. No existing person living in the village would enter this scheme through its one entrance to access
its open spaces, etc. It would identify as a defensive design which discourages interaction with the village
while contributing nothing to its public realm.
Contribution to emerging services: The proposal is single use – residential – and fails to provide any
supporting services to the village. It includes no shop, no creche, no office space, etc. What will residents
do for work, for childcare, for access to retail services? There are two creches in the area – do they have
spare capacity?
Social Cohesion: The above guidelines and planning policy documents (see Fig. 33) require mixed tenure
(80% market/20% affordable/social) to attract families/elderly. This ensures social housing households are
not isolated away from all necessary services and sources of employment or identifiable as social housing
tenants.
Environmental Gain: The proposal is car-based and would fail to lower car dependency. While private
development in villages can argue that they are an alternative to propel building rural one-off houses; this
issue does not arise in the case of a social housing estate. The applicant has failed to provide a social
infrastructure assessment report which set out how all of the future households of this isolated social
housing proposal would access employment, services, etc.
Heritage Protection: This is a greenfield development proposal on lands which are outside of the
designated development envelope. The applicant should be reusing brownfield sites, using infill sites,
contributing to development within the village envelope. This proposal constitutes sprawl into farmland
which is not compatible with an emerging Tier 4 rural village.
Rural vernacular design: There is no part of the applicant scheme which one could describe as emerging
from any existing Irish or Monaghan-based rural vernacular architectural style. This is a homogenous
suburban housing estate based on a cul-de-sac layout. The applicant has failed to set out any examples of
precedent rural village designs on which this proposal is based. The rural vernacular style would require, for
example, the applicant to use local stone/render, pitched roofs (25-35°), etc. to match the Building for a
Sustainable Future (2008) rural typology.
Ideal rural village housing development layouts: The applicant should be trying to achieve a scheme which
contributes to the emerging structure of the village, which has a car-free core, and shared surfaces (see
Urban Design Manual (2022), Chapter 4 for 10-min walkability). A new development of this size for
Doohamlet has the potential to address MCDP objectives but this needs co-design with the MCC Planning
and Architecture Departments. Instead, the applicant wishes to essentially attach 29 dwellings to a small
rural village by way of one entrance. The applicant should be required to set out a framework plan for the
village and to demonstrate how this proposal would contribute to any of its objectives – excepting
increasing numbers of social houses.
Community-led or Approved Housing Body-led: Increasingly, rural village developments are achieved by
way of a community-led or Approved Housing Body-led design approach. This allows Placemaking Ireland
metrics to be considered at an early stage. These have not been considered here. The applicant scheme is
a private development of 100% social housing with almost no consideration of how best such a large
number of new houses could be sited in the village. The proposal mostly ignores the designated
development envelope.
Public realm: As noted above, the applicant’s entire approach is to maximise the development potential of the
“site” and not to maximise benefits to the village. The proposal is not a natural extension of the village. It is
sprawl. It is a defensive cul-de-sac design approach which would contribute nothing to the existing village’s
public realm. Indeed, the applicant entrance is even into an existing housing estate and stops short of even
addressing the R183. The internal open spaces are scheme open spaces and not village open spaces. The
applicant refers to passive surveillance. This scheme design is excessively inward focused and offers nothing
to the public area of the village.
Adaptability: The applicant proposes a wholly social housing scheme with some mix of suburban type housing
designs which cause the scheme to appear as a very standard housing estate design. The scheme is not
adaptable in the sense that it is isolated within County Monaghan and offers no private housing in an area
which needs it. This is not a scheme which will reduce one-off housing proposals in this area.
Privacy/ Amenity: The proposal being in the backlands of the village in a field wherein no development is
anticipated by the MCDP, it is reasonable that residents of the housing development to the north and other
houses surrounding the site consider it will detract from their privacy and established residential and visual
amenities. It is not difficult to design a suburban style housing estate with standard houses. The question arising
is whether this is achieved with any relevance to Doohamlet.
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 36
Parking: The applicant refers to 2 no. parking spaces per social house as “A restriction on car parking provision”.
In fact, it is this provision is indicative of how the scheme is isolated and social housing tenants will need to
travel by car to reach most services, sources of employment, etc. The applicant offers no bike parking with
MCC told that bikes would be housed in back gardens (as per 1970s and 1980s housing schemes). has been set
at 2 spaces per dwelling. Bicycle storage can also be provided within the curtilage of each dwelling to
encourage sustainable modes of travel for local trips.
Detailed Design: For the reasons given above, the applicant site is not appropriately located for this
development. The proposals fail to address the site context and relevant policies and objectives set out in the
development plan and relevant guidelines. Our client objects to the development at this location. The mixture
of dwelling types and tenures are acceptable.
The applicant proposal is contrary to the MCDP 2025-2031, to Section 4.2: ‘Density Standards’ of the Sustainable
Residential Development in Urban Areas (2009), to Chapter 5: ‘Infill Development’ of the Urban Design Manual: A
Best Practice Guide (2022), to Table 2.1: ‘Rural Typologies’ of the Sustainable Urban Housing: Design Guidelines for
Apartments & Houses (2023), to Design Checklist Appendix B of the Quality Housing for Sustainable Communities
(2007), to National Policy Objective 18, NPF 2040 pertaining to Compact Growth, and to Village Design Statements
(Model, DECLG 2012) as regards ‘Local Adaptation’.
9.12 Ground 12: The Part V proposal is not compliant with planning policy
The applicant, a private developer, is proposing a single tenure housing development on unzoned lands wherein
29 units would all be social housing. The Concept Statement states: “Part V Requirement & Housing demand. All
proposed houses are intended to be provided as social housing …”.
While the applicant has set out a case in favour of this, it is in fact a material contravention of Section 15.8.6 ‘Part V’
of the MCDP 2025-2031 and it is contrary to the Planning and Development Act 2000 (as amended) which require
that: “Under the provisions of Part V of the Act 20% of all private residential developments on land zoned for
residential or mixed uses (where residential development is included) shall be provided for social housing (or as
otherwise amended by legislation)”. The figure is not 100%.
As one cannot provide a 100% private housing development without 20% social housing, one cannot reasonably
propose 100% social housing with no private housing.
Section 3.12.1 of the MCDP indicates that it remains local planning policy to retain “the 20% reservation for social
housing”: there is no reference to requiring 100%.
A letter from the Housing Section of MCC is included with this planning application which sets out the total number
of applicants for social housing in the total area covered by Doohamlet. The applicant relies on this to argue that a
fully social housing development is required. However, this position is not supported, in fact, by the letter itself
which indicates that it is unlikely that the 31 names currently on the list would take up all the 29 houses in this
proposed development. There are those who wish to live in social houses in other locations. MCC’s letter also
notes that there is “an unmet need for private housing in this area”. Why then are 29 social houses proposed?
This planning application essentially declares that it is exempt from providing private housing yet no exemption
certificate in this regard is produced.
9.12.1 The applicant’s Part V proposal in the Concept Statement require clarification
Irrespective of Section 9.4, the applicant’s Part V proposal in the Concept Statement require clarification. It states:
Part V Requirement & Housing demand. All proposed houses are intended to be provided as social housing,
with demand confirmed in a supporting letter from Monaghan CC Housing Section included in this submission.
Under current Part V legislation, local authorities are entitled to acquire up to 20% of this land at Existing Use
Value ( EUV), which can then be used to deliver homes for households eligible for social and affordable housing
support. Accordingly, we propose that a 6 will be sold to the local authority, 24.6% of the total plots, for use as
social housing at an estimated Net Monetary Value (NMV) of €1,640,000. For the location, area and cost
calculations breakdown, please see the submitted letter relating to Part V.
Can MCC please explain what is proposed? The houses do not all appear, based on this statement to be social
housing, only 6 will be sold to the local authority. What then for the rest of the dwellings?
9.12.2 Doohamlet is isolated and poorly serviced as a site for 29 social houses
Doohamlet was a Tier 5 rural village up to July 2025. It is now Tier 4 where villages are described as, “consisting of
a post office, one or two pubs and limited comparison retailing”.
This being a very small rural village with limited services, it is unclear how 29 social housing households will
address their retail, community services, educational and other needs at this location. RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
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MCC is reminded that other than an Isuzu garage and some random businesses that do not serve the daily needs
of households, Doohamlet is essentially a grouping of houses.
Households in this scheme would need to rely on Castleblayney for many of its services.
Those without a car can pay – for every trip - to take the TFI Local Link Cavan-Monaghan bus on route MN2, which
connects Doohamlet to Monaghan Town via Ballybay and to Castleblayney. This route operates on weekdays with
limited daily trips or Bus Éireann route 162 provided school-day service to Doohamlet linking it to nearby towns like
Castleblayney, Ballybay, Newbliss, Clones, and Monaghan (though current timetables emphasize the TFI Local
Link as the primary option).
Those not wanting to pay bus fares would face a 1 hour 24 minute walk.
Alternatively, social housing tenants would have to be able to afford cars in order to properly access services on a
convenient and regular basis, i.e. taking the bus is not pleasant with bags of groceries.
Given that Castleblayney is in fact only 6.2km away, it would be more appropriate for this social housing scheme to
be located on zoned lands in that town where it can access all necessary services.
Fig. 34A: Walk time to Castleblayney from Doohamlet
9.12.2.1 No age-friendly housing is provided & Doohamlet is unsuitable for this type of housing
No age friendly housing is provided nor is Doohamlet suitable for this type of housing. This is a time when
Monaghan has an increasingly older demographic. The applicant presents this social housing scheme as being
suitable for any future social housing tenant. It is unclear how this is the case.
Age-friendly housing requires a specific design approach at locations where al necessary services are easily
accessible. Neither is the case in this instance. The houses are all standard suburban designs. The estate itself is
isolated within Monaghan, and the bungalows are isolated within the site.
Has the applicant considered how older people would obtain access to all necessary services such as community
services, retail, medical, etc.
Doohamlet is a small rural village located about 10km from Castleblayney and 20km from Monaghan town. Its
remote location means many specialized services are centralized in larger towns. This leads to accessibility
barriers like limited public transport, long travel distances, and fewer on-site options, rather than complete
unavailability. Below, we outline key services that may be limited or effectively unavailable locally, based on rural
challenges in Monaghan (e.g., transport and information gaps as major hurdles for older adults). General
entitlements like the State Pension (Non-Contributory) and Free Travel Scheme apply nationwide, but practical
access varies.
Rural Monaghan’s services are delivered from hubs like Castleblayney or Monaghan town. Common issues include:
Transport Dependency: Sparse bus services (e.g., Bus Éireann route 162 only on schooldays to
Castleblayney/Monaghan). New routes like TFI Local Link's Kells-Cootehill (2025) don't directly serve
Doohamlet.
Service Centralization: HSE and community supports prioritize urban/rural hubs, leaving small villages
underserved.
Awareness Gaps: Older people may miss out due to limited digital access or outreach.
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 38
The applicant has not set out a list of services that may be limited/unavailable locally. Fig. x offers a breakdown of
common services for those +65, highlighting what's available county-wide vs. gaps in Doohamlet.
Service
Category County-Wide Availability (Monaghan) Limitations in Doohamlet/Rural Areas
Healthcare (e.g.,
GP Out-of-
Hours,
Specialists)
HSE Public Health Nursing,
chiropody/podiatry, day hospitals (e.g., in
Cavan General).
No local GP clinic or out-of-hours service; nearest in
Castleblayney (10km). Rural delays in emergencies
or specialist referrals (e.g., "just lie there and die"
barrier for urgent care). Dementia support via
helpline/advisers, but no local centre.
Day Care &
Social Activities
16 HSE-supported day care centres
county-wide; community centres for
events; befriending via MID's "Good
Morning Monaghan". Mens Sheds scattered
across Monaghan.
No dedicated day care in Doohamlet; nearest in
Clones (20km) or Carrickmacross. Limited local
events at Doohamlet Community Centre (general
use, not senior-specific).
Home Support
& Meals
Meals on Wheels (south Monaghan, e.g.,
Carrickmacross); homecare via Irish
Homecare or Comfort Keepers. Housing
adaptation grants.
Delivery may be inconsistent in remote spots like
Doohamlet; no on-site meal prep hubs.
Residential &
Long-Term
Care
Nursing homes and short-stay units (e.g.,
via HSE "Service Without Walls").
No local facilities; all in towns like Castleblayney or
Monaghan (15-20km away). Boarding-out schemes
rare in rural HSE areas.
Transport &
Mobility
Free Travel Scheme; community text alerts
for safety. Multi-stakeholder transport
group active.
Infrequent buses; no dedicated senior shuttles to
hubs. Rural isolation common.
Other (e.g.,
Advocacy, DIY
Repairs)
Age Action's Care and Repair (free small
jobs); SVP emotional/practical support;
suicide prevention outreach.
Limited local advocacy; repairs may require travel
for assessment.
Fig. 34B: Assessment of the design arising from considering age-friendly siting & design criteria
In short, the design of the development is inadequate under key elements of acceptable age friendly housing:
Connection to local services is a key element of age friendly housing and Doohamlet is severely lacking in any
of the required services used by aging social tenants (GP, Post Office, Local Shop, Pharmacy, Limited public
transport etc.). The provision of these local services should be considered first within the environs of the village
centre before any suitable age friendly housing is proposed. The complete lack of these services shows the
developer has put no thought or consideration into the proposal of age friendly housing as part of the
development as providing age friendly housing without these services is both unprofessional and inconsiderate
of their proposed occupiers.
Suitable age friendly housing should be easy to approach and traversing hilly topography should be avoided.
The hilly topography of the proposed site is not suitable for elderly social tenants in accessing the village
centre/public transport services and again highlights the lack of thought or consideration in proposing this type
of housing within Doohamlet in this location.
No input from the Monaghan County Council Age Friendly Dept to support the application highlights a lack of
consultation and that the applicant is using age friendly housing as a deflection/cover for overdeveloping of
unsuitable lands.
MCC is asked to view https://agefriendlyireland.ie/age-friendly-resources/ with the Ten Universal Design
Features a key document in the overarching design of suitable age friendly housing.
9.12.3 No cumulative assessment of over-provision of social housing at this location is provided
The applicant states that this scheme adjoins and would use an existing social housing development for pedestrian
and vehicular access
No cumulative assessment of possible over-provision of social housing at this location is provided. There needs to
a mix of private and social housing in order to create a balanced community. This balance is already lacking at this
location.
9.13 Ground 13: The cut and fill proposed is not advertised and is excessive
The applicant site is not flat. This is clear from views toward the site from the R183 and from surrounding
properties. Achieving this proposed development will require considerable cut and fill. This work has not been
advertised, is not fully outlined in the submitted drawings and details, and is not appropriate. RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
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The applicant’s Concept Statement states: “The site’s highest point is in the north- east corner, where a hill rises to
104m above datum, gradually falling to its lowest point in the south- west and proposed site entrance. We propose
lowering the hill by approximately 3m creating a gentle slope from east to west to create coherent road and
house levels, compliant footpaths and functional public open space” [emphasis added].
Requiring such cut and fill work suggests the site is not appropriate for this development. Such land shaping works
should only arise when there are no other developable lands in the village. There are however considerable other
lands and those are located in the designated development envelope of Doohamlet.
Cut and fill work is noisy, dusty, and often requires many HGV trips into and out of the site, the village, and the
wider area. These construction stage impacts cannot reasonably be justified.
We consider that the applicant needs to provide more cross sections and plans which show the full extent of cut
and fill which is proposed. It is likely that a construction phase waste management plan is required which sets out
where any soil subsoil not re-used on the site would be taken.
Fig. 35: Cut and fill required to develop the entrance, access road, and Dwellings 1 and 2
Fig. 36: Proposed cut and fill as set out in the submitted cross sections
9.14 Ground 14: The siting, design, scale, bulk & massing of the proposed development is poor
The proposed development fails to comply with the requirements of the MCDP 2025-2031 as regards siting and
design. The design has been prepared by – according to the submitted planning application details – a firm of
chartered building surveyors, engineers, and designers.
We note the following concerns with the scheme. We divide these between those in the designated development
envelope of the village and those which are not.
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 40
1. Objections to the proposed development sited inside the designated development envelope of the village
Objections to the proposed development’s entrance area on existing public open space
The applicant wishes to carry out cut and fill works, to install an attenuation system, to build the scheme’s
vehicular entrance and footpath, etc. all within an area of public open space which presently serves the housing
cul-de-sac to the north.
This open space is landscaped, grassed, maintained, and has defined boundaries. The existing applicant laneway
serving their field is located to the west of this public open space and there is a boundary treatment.
As this public open space forms part of the original required open space for that scheme, the applicant proposals
would adversely impact this area, detract from the existing scheme, and reduce amenities for the existing
residents. The proposal is unreasonable.
Fig. 37: The applicant proposals require the loss of public open space to the adjoining housing scheme
Fig. 38: The applicant proposals require the loss of public open space to the adjoining housing scheme – this open
space is landscaped, grassed, maintained, and has defined boundaries
Objections to the proposed dwellings sited inside the designated development envelope of the village
2 no. dwellings appear to have been squeezed into the entrance area into and out of the scheme such that the
applicant can argue some of the proposed dwellings are sited in the designated development envelope of the
village. These 2 no. dwellings, which can only be achieved by way of cut and fill works as this area is heavily
sloping, are sited very close and extremely close to the existing adjoining dwelling and rear garden to the east.
Dwelling 1 is setback as little as <5.68m, while the applicant chooses not to provide the setbacks to Dwelling 2 as
these are, it appears, as low as 4m. These two dwellings are 9.065m tall with elongated pitched roofs (possibly to
allow future attic conversions). This is very tall for this location and Dwellings 1 and 2 are orientated east-west while
the dwellings to the east are orientated north-south.
Dwellings 1 and 2 would adversely impact on the established residential and visual amenities of the dwellings sited
to the east and their rear gardens. Adverse overbearing, overshadowing, and overlooking concerns arise.
As regards overbearing, the applicant could have proposed single storey dwellings but has instead set out the
maximum sized dwellings which could be sited at this location. The scale of the rear elevations and their height
are excessive as they would adjoin the dwelling and rear garden to the east.
As regards overshadowing, the proposed dwellings would cause a material loss of daylight and sunlight in the
late afternoons and evenings when the sun is passing to the west. This adverse impact is unnecessary and
arises from the siting of the dwellings.
As regards overlooking: The dwellings each maintain first floors with 2 no. overlooking hall and top of stair
windows. While these windows could be obscured, they would always give the perception of overlooking to
the dwellings and rear gardens to the east.
We submit that Dwellings 1 and 2 should be removed from the scheme.
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 41
Fig. 39: The siting of 2 no. proposed dwellings within the designated development of the village within metres of the
rear garden of an existing village dwelling
Fig. 40: The siting of 2 no. proposed dwellings within the designated development of the village within metres of the
rear garden of an existing village dwelling
Fig. 41: The siting of 2 no. proposed dwellings within the designated development of the village within metres of the
rear garden of an existing village dwelling RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 42
Fig. 42: The siting of 2 no. proposed dwellings within the designated development of the village within metres of the
rear garden of an existing village dwelling
2. Objections to the proposed dwellings sited outside the designated development envelope of the village
Dwellings sited to the south and southwest of the existing housing cul-de-sac to the north
The dwellings sited to the south and southeast of the existing housing estate to the north are sited in a suburban
manner and this must raise concerns as to whether this proposal is appropriate at Doohamlet.
The question for MCC is whether it wants this type of development – which relies on the Sustainable Residential
Development and Compact Settlements: Guidelines for Planning Authorities (2024) – to offer the same depths of
rear gardens, etc. as one would find in any new housing estate in any Irish town or city, or whether an appropriate
vernacular rural scaled village scheme sited within the designated development envelope of the village would be
more appropriate.
Fig. 43A: Standard suburban housing estate design and layout of dwellings
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 43
Fig. 43B: Standard suburban housing estate design and layout of dwellings
Dwellings sited to the north of the existing dwelling sited to the south
The dwellings sited to the north of the existing dwelling sited to the south are sited in a suburban manner and this
must again raise concerns as to whether this proposal is appropriate at Doohamlet.
The question for MCC is whether it wants this type of development – which relies on the Sustainable Residential
Development and Compact Settlements: Guidelines for Planning Authorities (2024) – to offer the same depths of
rear gardens, etc. as one would find in any new housing estate in any Irish town or city, or whether an appropriate
vernacular rural scaled village scheme within the designated development envelope of the village would be more
appropriate.
Fig. 44: Context for the south/southeast end of the scheme adjoining a rural dwelling
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 44
Fig. 45: Standard suburban housing estate design and layout of dwellings
Fig. 46: Standard suburban housing estate design and layout of dwellings adjoining the rural dwelling
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 45
Fig. 47: Standard suburban housing estate design and layout of dwellings adjoining the rural dwelling
9.15 Ground 15: Trees & hedgerows have disappeared & Visual Impact Assessment is missing
The site has previously contained trees and hedgerows. MCC’s previous assessment of a 2006 planning
application stated:
The existing line of mature trees and hedgerow along the northern, north eastern, eastern, southern and south
western boundaries of the site shall be retained intact and protected from damage at all times, particularly
during building operations.
The existing line of mature trees and hedgerow running through the centre of the site shall be retained as
indicated on the plans and details submitted to the Planning Authority on 24th January 2007, and protected
from damage at all times, particularly during building operations.
These trees and hedgerow appear to have been removed from the site. No explanation for this is provide in the
current planning application. This matter needs to be addressed. The removal of hedgerows and trees is contrary
to many policies and objectives of the MCDP 2025-2031.
The applicant cannot use existing planting to offer any screening or visual mitigation.
The applicant has not provided any Landscape and Visual Impact Assessment (LVIA)or photomontages which
show the existing appearance of the site relative to the proposed development.
It is not possible to assess the existing topography of the site and its suitability for development without
trespassing, so an LVIA is required.
Photomontages should show the scale and heights of the scheme’s proposed dwellings in the landscape at this
location relative to adjoining development and existing and proposed ground levels.
Only scaled photomontage can properly model the likely relationship of this scheme to the area, to the village, and
to adjoining properties.
Based on the details provided, cross sections, etc. we submit that the 29 dwelling proposal is out of scale with the
village and would cause adverse impacts on both the rural and the village landscape and on surrounding
properties, including by way of visual incongruity, obtrusion, and intrusion.
9.16 Ground 16: Landscape mitigation is poor and likely impossible
The applicant fails to explain where the trees and hedgerows located on this site under the previous planning
application have disappeared to. The MCC Planner’s Report for reg. ref. 061369 stated in respect of the site:
The existing line of mature trees and hedgerow along the northern, north eastern, eastern, southern and south
western boundaries of the site shall be retained intact and protected from damage at all times, particularly
during building operations.
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 46
The existing line of mature trees and hedgerow running through the centre of the site shall be retained as
indicated on the plans and details submitted to the Planning Authority on 24th January 2007, and protected
from damage at all times, particularly during building operations.
Objection concern: These trees and hedgerow appear to have been removed from the site. No explanation for
this is provide in the current planning application.
The applicant proposals cannot realistically be visually mitigated in the landscape including by landscaping.
Avoidance of this development should be applied as the primary mitigation approach.
The applicant’s landscape plan does not show the proposed cut and fill (scorched earth approach).
The submitted planting and fencing proposals are not a tree survey or a “landscape plan” The applicant has not set
out the quantum of vegetation and/or existing trees, if any, which will need to be removed to facilitate this
proposal. This is contrary to Section 15.19 ‘Landscaping (Urban & Rural)’ of the MCDP which states:
Where sites contain mature trees and/or substantial hedgerow(s) a detailed tree and hedgerow survey
should be submitted clearly outlining the extent of what will be retained and replaced. Any existing mature
trees must be protected during site development works and incorporated into the scheme design. The removal
of hedgerows to facilitate development must be clearly identified on the application drawings and a detailed
replanting proposal shall be submitted. This should at a minimum provide for the replacement of an equal
amount of similar hedgerows including three trees for every tree felled. The replacement of hedgerows shall
have due regard to the ecological function of hedgerows as a wildlife corridor and a part of the green
infrastructure network [emphasis added].
The applicant’s Site Layout Plan’ includes some planting, fencing, and other landscaping proposals. These do not
set out a specific number of trees to be planted, etc. They do not add up to a landscape plan which can be
conditioned. This is contrary to Section 15.19 ‘Landscaping (Urban & Rural)’ of the MCDP which states:
New planting schemes should consist of local native plant types that are indigenous to the area and can be
incorporated into sites to enhance the visual amenity and the biodiversity of the area. Landscaping plans
should be submitted with all planning applications and the inclusion of semi-mature trees in larger
development schemes will be required [emphasis added].
As submitted this planning application is deficient and incomplete having regard to policies HCLSO1,
HCL06/7/8/9, HCLP2, and HCLP 3 of the MCDP 2019-2025. Further information is required and amendments to
the proposals will be needed to address that information.
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 47
Fig. 48: MCDP 2025-2031 ‘Landscaping Policies’ (source: MCDP 2025-2031)
9.17 Ground 17: No Site Specific Flood Risk Assessment is provided
The applicant has not supplied any Site Specific Flood Risk Assessment as regards pluvial flooding.
The applicant has set out surface and storm water proposals. However, these are not placed in the context of the
flooding status of the site.
Periods of high rainfall could cause the submitted construction phase and operational phase contaminated and
wastewater proposals to be null and void.
9.18 Ground 18: A Construction Environmental Management Plan is required
Our client opposes this proposal in principle and will not engage here with any purported construction phase
proposals that claim to mitigate the likely impacts of this proposal. The applicant proposes to carry out significant
development including cut and fill works, infrastructure works, house construction works, etc. All of this would
need to be carefully managed to avoid adverse impacts on the area, in local properties and on the environment.
A Construction Environmental Management Plan is required.
9.19 Ground 19: An Ecological Impact Assessment is required
The applicant has not provided an Ecological Impact Assessment. However, the site is to be almost wholly
impacted by cut and fill and the scheme’s development works. This is a site close to a protected structure and its
graveyard, a site where birds and bats have been seen by our client’s group, and where surveys of wildlife need to
be undertaken before any permission could be granted.
Doohamlet is sited near Lough Egish and the Finn River catchment) is in an area with several protected species,
particularly bats, birds, otters, and badgers. These are protected under Irish law (Wildlife Acts 1976–2021 and the
European Communities (Birds and Natural Habitats) Regulations 2011) and EU directives (Birds Directive
2009/147/EC and Habitats Directive 92/43/EEC). The region supports wetland, farmland, and woodland habitats
conducive to these species.
Proximity to Lough Egish (a proposed Natural Heritage Area with wetland habitats) and the broader Monaghan
uplands enhances biodiversity.
Key Protected Species Likely Present:
Based on national biodiversity records (from the National Biodiversity Data Centre and NPWS data), regional
surveys, and habitat suitability:
Species/Group Protection Status Presence/Evidence Near Doohamlet Habitat/Notes
Bats (e.g., Common
Pipistrelle Pipistrellus
pipistrellus, Soprano
Pipistrelle P.
pygmaeus, Leisler's
Bat Nyctalus leisleri)
All 10 Irish bat species
are strictly protected as
European Protected
Species (EPS). Roosts,
hibernation sites, and
foraging areas cannot be
disturbed without a
license.
Common in Monaghan; records within
5–10 km (e.g., near Carrickmacross and
Lough Egish). Suitable habitats include
hedgerows, farm buildings, and
deciduous woodland around
Doohamlet. Surveys in North
Monaghan (2020–2024) confirm activity
in rural villages like Doohamlet.
Forage on insects over
watercourses (e.g., Finn
River tributaries) and
roost in attics/trees.
Development requires
bat surveys (e.g.,
dusk/dawn transects).
Birds (e.g., Barn Owl
Tyto alba, Hen Harrier
Circus cyaneus,
Whooper Swan
Cygnus cygnus,
Corncrake Crex crex)
All wild birds protected
under the Wildlife Acts;
Schedule 1 species (e.g.,
Barn Owl, Hen Harrier)
have extra safeguards
against disturbance.
SPA-designated birds
(e.g., Whooper Swan)
require Appropriate
Assessment.
High diversity: Monaghan has ~200
breeding bird species. Records near
Doohamlet include wintering Whooper
Swans on Lough Egish (~3 km away)
and breeding farmland birds (e.g.,
Yellowhammer, Tree Sparrow). Hen
Harrier breeding sites in nearby
uplands (within 10–15 km). Barn Owls
reported in rural farmsteads.
Wetlands (Lough
Egish), farmland, and
conifer plantations
support these. Breeding
seasons (March–
August) restrict works
near nests. RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 48
Species/Group Protection Status Presence/Evidence Near Doohamlet Habitat/Notes
Otters (Lutra lutra)
EPS; strictly protected,
including holts and
resting sites.
Widespread in Monaghan rivers;
records along Finn River and tributaries
near Doohamlet (within 2–5 km). NPWS
surveys (2019–2023) confirm presence
in 80% of Irish watercourses, including
North Monaghan streams.
Riverine habitats; holts
in bankside vegetation.
Development near
water requires otter
surveys and buffers
(e.g., 30m exclusion
zones).
Badgers (Meles
meles)
Protected under the
Wildlife Acts and
Badgers and Wildlife
Protection Acts; setts
cannot be disturbed.
Common across Monaghan; active
setts recorded in farmland around
Doohamlet (within 1–3 km via
Biodiversity Ireland maps). Rural
density ~1 sett/2 km².
Wooded field edges
and setts in banks;
nocturnal. Surveys
needed for ground
disturbance.
Other Notable (e.g.,
Freshwater Pearl
Mussel Margaritifera
margaritifera, Irish
Hare Lepus timidus
hibernicus)
Pearl Mussel: Critically
Endangered (Red List);
EPS. Hare: Vulnerable.
Pearl Mussel: Potential in Finn River
catchment (records ~10 km upstream).
Irish Hare: Farmed uplands near
Doohamlet support populations.
Clean rivers for
mussels; open
grasslands for hares.
Rare but protected if
present.
Fig. 49: Likely species to be within the site or to use the site in an ex-situ manner
Context and Sources:
National Biodiversity Data Centre (NBDC): Ireland's central repository shows records for bats (e.g., 50+ sightings in
Monaghan 2015–2024), birds (e.g., 1,000+ wintering waterfowl records near Lough Egish), otters (river surveys), and
badgers (setts mapped in rural townlands). Doohamlet grid (H7520) has nearby hotspots.
NPWS (National Parks & Wildlife Service): Monaghan's rural areas are part of the "Northern Ireland Uplands"
biodiversity zone, with protected species surveys emphasizing bats and otters due to habitat fragmentation. No
site-specific Doohamlet report, but regional Red Lists confirm vulnerability (e.g., bats: Near Threatened; otters:
Least Concern but locally sensitive).
Doohamlet's farmland, hedgerows, and proximity to Lough Egish (wetland supporting migratory birds) make it
suitable. Hydrological links to River Finn SAC (~15 km away) should trigger assessments for developments.
Implications:
This development requires protected species surveys via licensed ecologists. Licenses from NPWS are needed for
disturbance. Monaghan County Council mandates this under the County Development Plan 2025–2031.
The applicant should be required to contact NPWS Northern Division (npws@housing.gov.ie) or the Monaghan
Biodiversity Officer.
Note: Data is from NPWS Red Lists (2019–2023) and NBDC records (up to 2024).
9.20 Ground 20: Appropriate Assessment Screening is required
The applicant has not provided an Appropriate Assessment Screening Report so as to allow MCC to determine if
any possible significant impacts on any Natura 2000 site may arise. Being outside of the designated development
envelope of Doohamlet means that much of this site has not been subjected to the MCDP’s Strategic
Environmental Assessment.
It is not the role of Third Parties to provide such reports. Our client reserves the right to raise concerns in this
respect later in the process.
Doohamlet is a small village in north County Monaghan, Ireland (approximate coordinates: 54.25°N, 7.05°W), located
in a rural, drumlin-dominated landscape with scattered lakes and bogs. Natura 2000 sites are protected areas
under the EU Birds and Habitats Directives, consisting of Special Areas of Conservation (SACs) for habitats/species
and Special Protection Areas (SPAs) for birds. County Monaghan has limited such sites compared to western
counties, with only one designated SAC and one SPA. Based on official NPWS data and geographic analysis, the
closest are within the county, with others in adjacent Cavan to the southwest
The following lists the top 5 closest Natura 2000 sites, prioritized by straight-line distance (approximate, derived
from site centroids and Doohamlet center). Distances are estimates using standard mapping tools; actual access
may vary due to terrain.
Cross checking flood risks or biodiversity near Toome Bog is required. RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 49
Failure to require it could lead to judicial review, as seen in recent Monaghan appeals.
Site Name Code Type Approximate
Distance Description
Kilroosky Lough
Cluster IE0001786 SAC 18 km
(southeast)
A cluster of oligotrophic lakes (e.g., Kilroosky Lough near
Clones) supporting Annex I habitats like hard oligo-
mesotrophic waters with benthic vegetation (e.g., Chara
spp.) and the freshwater pearl mussel (Margaritifera
margaritifera). Key for rare aquatic species; located in the
Blackwater River catchment.
Bragan
Mountain
IE004117
(Slieve
Beagh SPA)
SPA 20 km (south)
Upland blanket bog and heathland on Slieve Beagh/Bragan
Mountains, straddling Monaghan-Fermanagh border.
Protects breeding hen harrier (Circus cyaneus), merlin (Falco
columbarius), and golden plover (Pluvialis apricaria). Covers
~2,800 ha of peatland, important for moorland birds.
Lough Oughter
and Associated
Loughs
IE000007 SAC 25 km
(southwest)
Complex of inter-drumlin lakes and rivers in central Cavan,
including Lough Oughter. Designated for alluvial rivers with
Salix alba galleries, oligo-mesotrophic lakes, and species
like otter (Lutra lutra) and salmon (Salmo salar). Area: ~4,756
ha; a Ramsar wetland site.
Cuilcagh -
Benaughlin
Mountain
IE000584 SAC 30 km (west)
Karst upland massif on Cavan-Fermanagh-Leitrim border,
featuring calcareous grasslands, blanket bogs, and
turloughs. Supports alpine lady's-tresses orchid (Spiranthes
aestivalis) and bats; area: ~11,383 ha (expanded from
original).
Killyconny Bog
(Cloghbally) IE000006 SAC 32 km
(southwest)
Raised bog complex near Virginia, Cavan, with active bog
habitats and degraded areas for restoration. Protects Annex
I raised bog types; area: 185 ha.
Fig. 50: The closest Natura 2000 sites to Doohamlet
9.21 Ground 21: No Conservation Report re. impact on the protected structure & curtilage
The applicant has not provided a Conservation Report despite proposing to develop unzoned and undesignated
lands adjoining a protected structure and its curtilage. Under the previous planning application’s assessment, MCC
was worried about the site gradient relative to the R183. The applicant now proposes unsatisfactory cut and fill
works. MCC was concerned to protect the protected structure (Doohamlet Church) and this area where
archaeological remains may exist. The current planning application does not assess likely adverse impacts on the
protected structure, and its archaeological report is deficient (including in its errors) given how cut and fill works
are proposed on the site.
All Saints Church and Graveyard in Doohamlet, County Monaghan is a protected structure under Monaghan
County Council's Record of Protected Structures (RPS) Number: 41401920 (from the Monaghan County
Development Plan 2025–2031). The site is not a full National Monument but aligns with broader heritage policies in
the Monaghan County Development Plan.
The graveyard (churchyard) is integral to the church's curtilage and protected as part of the overall site due to its
historical and architectural significance. Under Ireland's Planning and Development Act 2000 (as amended), works
affecting protected structures or their settings (including graveyards) require planning permission and
conservation input to preserve their character.
Built in phases—opened May 1861, completed 1882. It's a detached T-plan gable-fronted church with a polygonal
apse, gabled entrance porches, and a square-plan bellcote. Features include stained-glass windows (e.g., tripartite
Crucifixion scene), exposed roof trusses, and marbled surrounds. The site includes boundary walls and decorative
cast-iron gates.
It is rated of regional architectural and technical interest by the National Inventory of Architectural Heritage (NIAH
Survey ID: 41401907). Its design reflects 19th-century ecclesiastical architecture, with decorative elements like
battened doors and a graveyard that enhances the setting.
Graveyard Specifics:
Opened in 1921 (land purchased from the Keenan family at Dernaglug). Prior burials were at nearby sites like
Annyalla or Clontibret. As the church's immediate environs, it's protected from demolition, alteration, or
development that could harm the structure's integrity. No standalone RPS entry for graveyards here, but they often
qualify under Section 57 declarations for works. RECEIVED: 18/12/2025
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BPS Planning & Development Consultants | www.bpsplanning.ie 50
Implications for the current planning application
Any adjoining developments such as that now proposed need Monaghan County Council approval and should
involve a conservation architect.
An Architectural Conservation Impact Assessment is required. Third Parties need to be able to review this.
Fig. 51: The approx. outline of the protected structure and its curtilage
9.22 Ground 22: Concerns over the Archaeological Report
The submitted Archaeological testing Report appears to be referring to a different scheme. It refers incorrectly to a
site of 5 hectares and to 50 detached and semi-detached dwellings. The context description is wrong. Please
review Fig. 52.
BPS is afraid that this report requires to be fully re-written. The assessor should provide proof of having undertaken
the claimed testing.
This part of Monaghan has a high archaeological potential.
Claims that the site has no archaeology needs to be backed by irrefutable proof. While the report contains
photographs, we ask that MCC visit the site to determine if the claimed investigations have taken place.
We note finally that while the applicant may have undertaken some trenching, the proposed cut and fill works
would go deeper than this.
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 51
Fig. 52: The Archaeological Report refers to a different site and development
9.23 Ground 23: Historic roads & pedestrian and cycle access concerns are not addressed
The planning assessment for the previous permission on this site (see Section 6.0), reg. ref. 061369 (for seventy
houses and crèche), the MCC Roads Department raised multiple issues which are not addressed by the current
planning application, including:
The current entrance proposal does not align with what MCC Roads considered acceptable previously, i.e. an
R183 entrance which serves the current scheme ‘and’ the adjoining cul-de-sac of social houses. The applicant
seeks to avoid the issue by directing all the scheme’s traffic into the adjoining cul-de-sac. This is contrary to
the hierarchy of roads and fails to offer appropriate and manageable (into the future) sightlines. The
development of these lands should be achieved by way of an upgraded entrance - to form a bellmouth of 10
metres radius - onto the R183 shared with the adjoining housing estate cul-de-sac.
The R183 entrance to the previously permitted scheme was to be amended in various ways in order to
address sightline and traffic hazard concerns. The current scheme seeks to side step these issues by relying
on the cul-de-sac’s existing entrance while arguing, including in the Roas Safety Audit, that the sightline
issues are historic. In fact, the applicant seeks to intensity traffic movements at this location and into and out of
an existing deficient entrance while failing to address, in any way, these deficiencies. No legal consents are
provided to allow the applicant to improve the sightings to the R183 entrance (also located outside the red
line boundary).
MCC has previously required the development of these lands to be accompanied by a new footpath passing
west from the R183 entrance on the south side of the R183 at 2m wide all the way to the Doohamlet Primary
School. The current planning application offers no such planning gain while seeking to develop the same
lands in a single entrance, impermeable, manner.
These concerns need to be addressed to ensure a safe vehicular and pedestrian environment at construction
and operational phases.
9.24 Ground 24: Negative precedent concerns
BPS submits that the proposed development, if granted, would set an undesirable precedent for similar
inappropriate rural developments for non-compliant applicants and in poorly chosen sites on lands primarily
outside of the designated development envelopes of Tier 4 rural villages such as Doohamlet.
This proposal if granted would also set a precedent for further development of backland fields to the south and
north of the village. This could result in a significant areas of housing outside of the designated development
envelope of Doohamlet. The applicant already envisages the scheme connecting to the lands sited to the west.
RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 52
Fig. 53: The applicant’s future intentions for the lands to the west
Fig. 54: Open lands adjoining or in the vicinity of the applicant site
Fig. 55: Open lands to the north of the village
9.25 Ground 25: Depreciation in the value of property in the vicinity
Our client is concerned that the proposed development would adversely impact on the area (as set out above) and
seriously injure the amenities and depreciate the value of adjoining and nearby properties. The potential impact
that a proposed development can have is recognised by the Planning Acts which include a reason for refusal RECEIVED: 18/12/2025
THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
BPS Planning & Development Consultants | www.bpsplanning.ie 53
reason 10. (c) of the Fourth Schedule ‘Reasons for the Refusal of Permission which Exclude Compensation’ of the
Planning Acts 2000-2015:
10. In the case of development including any structure or any addition to or extension of a structure, the
structure, addition or extension would— (c) seriously injure the amenities, or depreciate the value, of property
in the vicinity.
The only basis for this proposal to proceed is that the interests of the applicant are placed above those of the area
and of the established residential and visual amenities of our client’s property.
BPS wishes to advise MCC of how ACP has carried out assessments of Strategic Housing Developments and Large
Scale Residential Developments on which we have worked for communities and stated that we failed to provide
evidence of depreciation of property values.
The High Court in Gleann Fia v An Bord Pleanàla [2019] IEHC 618 has held that it is not necessary to put very
detailed information before the Board that the development as granted would reduce the value of land
significantly or adversely affect the enjoyment of land:
106. Although no valuation evidence was presented to back up the contention that this “would ... reduce
significantly its value”, there is nothing in s.37(6)(d)(ii) that mandates the submission of valuation evidence.
While the court should not speculate as to the Board’s thinking or reasoning, it would not be irrational or
unreasonable for it to have treated the views expressed by RPS in this passage as plausible and common
sense if it also accepted that the greater detail provided in the further information, and the review/approval of
the Traffic and Transportation Section of the Council on 24th October, 2018 rendered the development of the
pedestrian bridge and walkways more imminent, and more likely that it would be carried out by the Council.
107. Accordingly, I am of the view that there was some evidence before the Board from which it could
objectively have come to the view that Condition 1, including the plans and particulars lodged with the further
information, and/or Condition 35 could of themselves have led to a reduction in value of the Notice Parties’
lands. The weight to be attached to this evidence was entirely a matter for the Board. For this reason, if this
were the only criterion in respect of which the applicants made complaint, and was the only ground for
seeking judicial review, I would not grant certiorari.”
It is the professional opinion of BPS that this scheme, as submitted to MCC, would cause the adverse impacts set
out in this report.
10.0 Conclusion
BPS has reviewed the planning application, including all drawings, viewed the site, had due regard to the
provisions of the National Planning Framework, the Development Management Guidelines (2007), to Natura 2000
sites in the surrounding hinterland, to Section 4.2: ‘Density Standards’ of the Sustainable Residential Development
in Urban Areas (2009), to Chapter 5: ‘Infill Development’ of the Urban Design Manual: A Best Practice Guide (2022),
to Table 2.1: ‘Rural Typologies’ of the Sustainable Urban Housing: Design Guidelines for Apartments & Houses
(2023), to Design Checklist Appendix B of the Quality Housing for Sustainable Communities (2007), to National
Policy Objective 18, NPF 2040 pertaining to Compact Growth, and to Village Design Statements (Model, DECLG
2012) as regards ‘Local Adaptation’, to the Architectural Heritage Protection Guidelines, and to the Monaghan
County Development Plan 2025-2031 and to all matters arising and we consider the following significant planning
concerns to arise:
There are technical issues, planning law matters and missing information concerns which suggest this is not a
valid planning application and/or is an incomplete planning application.
The site – as owned by the applicant – is outside of the designated development envelope of Doohamlet (and
the MCDP 2025-2031 was only adopted in 2025). The principle of development is not accepted – the site is
unzoned.
The proposal is contrary to MCDP 2025-2031 policies and objectives which aim to prevent urban sprawl
The proposal would leapfrog undeveloped lands within the designated development envelope of Doohamlet.
The proposal raises the same concerns as refused planning application reg. ref. 21/378 and appeal
PL18.313034. This was a better site with existing services and there had been considerable pre-planning
discussions with MCC to design the scheme.
The proposal is premature pending the site being re-zoned & a village plan adopted
Doohamlet is a recent Tier 4 village – the applicant wants all its growth to 2031. This is not appropriate or
sustainable. The scheme is over-scaled for what was recently a Tier 5 village. RECEIVED: 18/12/2025
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No adequate infrastructure audits have been submitted including no Social Infrastructure Audit to address
isolation concerns and no audit proving the current capacity of the Doohamlet WWTP.
The proposal is contrary to s. 15.8.10 and Objective RDSP 1 of the MCDP 2025-2031.
The density of the proposal is not acceptable outside of any village boundary.
The proposal would cause further piecemeal development in the village.
The proposal is contrary to s. 15.8 ‘Multi-Unit Residential Developments’ of the MCDP.
The Part V proposal is not compliant with planning policy. The Part V proposals are confused and may
represent a material contravention of the MCDP. Looked at as a wholly social housing scheme, this is an
isolated and poorly serviced as a site for 29 social houses
The cut and fill proposed is not advertised and is excessive.
The siting, design, scale, bulk and massing of the proposed development is poor. The proposal could cause
negative and permanent residential and visual impacts including loss of privacy to nearby properties.
No Landscape and Visual Impact Assessment is provided.
Landscape mitigation is poor and likely impossible.
No Site Specific Flood Risk Assessment is provided.
A Construction Environmental Management Plan is required.
An Ecological Impact Assessment is required.
Appropriate Assessment Screening is required. Insufficient information has been submitted to ensure that the
proposed development would not significantly impact on a downstream Natura 2000 site via a hydrological
connection. The proposals are premature having regard to appropriate assessment screening.
No Conservation Report is provided regarding impact on the protected structure & its curtilage.
There are concerns over the Archaeological Report’s veracity and accuracy.
The proposal raises negative precedent concerns.
The proposal would cause depreciation in the value of property in the vicinity
The proposal would cause significant and cumulative impacts on the rural village amenities, landscape and
environment of this area. The scheme would impact on the amenities of existing residents and is not a suitable
proposal for social housing tenants.
11.0 Recommendation
It is recommended that, for the reasons set out above that the proposed development should be refused planning
permission for the reasons set out in Section 11.1 of this Planning Objection Report.
BPS does not consider that a request for Further Information can address the planning concerns arising as these
include ‘in principle’ concerns in this un-zoned and undesignated site. In the event that MCC considers Further
Information should be requested, we advise asking for the details set out in Section 11.2.
11.1 Recommended reasons for refusal
The proposed development should be refused for the following reasons:
1. The site of the proposed development partially lies within the settlement envelope of Doohamlet. Sections 2.0,
2.9, 2.10, 3.18 and Housing Strategy Objective HSO 2 of the Monaghan County Development Plan 2025-2031
which aim, inter alia, to guide urban residential development in a sequential manner outward from the centre of
the settlements to maximise the use of existing and future infrastructure provision, to promote sustainability, to
make more efficient use of underutilised lands, and to avoid the extension of services and utilities to more
remote areas. The site of the proposed development is located on the periphery and outside the development
boundary of the Tier 4 settlement of Doohamlet. These are unzoned and peripheral lands. The development of
same would result in the retention of a large portion of undeveloped land located sequentially closer to the RECEIVED: 18/12/2025
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village core than the submitted site area. Consequently, the proposed development, if permitted, would be
contrary to the provisions of the Monaghan County Development Plan 2025-2031, would not represent a co-
ordinated and consolidated pattern of growth and would be contrary to the proper planning and sustainable
development of the area.
2. The site of the proposed development partially lies outside the settlement envelope of Doohamlet. Section 4.8
‘Agriculture and Forestry’ of the Monaghan County Development Plan 2025-2031 states: “Where an area of land
is outside a settlement envelope and is not otherwise zoned as part of this Plan, the use of such land shall be
deemed to be primarily agricultural”. The proposed development is primarily sited on agricultural lands outside
of the designated development envelope of Doohamlet and, accordingly, is contrary to Objective SSO 12 of the
Monaghan County Development Plan 2025-2031, which aims “To appropriately designate development
envelopes around the towns and Tier 4 villages in order to manage development in a sustainable manner and
restrict urban sprawl and the merging of distinctive areas”. This being the case, the proposal is not sustainable
development; instead, it is urban sprawl of the type which Objective SSO 12 is designed to prevent. The
applicant proposals would represent a material contravention of Objective SSO 12 and would be contrary to the
proper planning and sustainable development of the area.
3. The proposed development is generally contrary to Section 15.8.10 of the Monaghan County Development Plan
2025-2031 as regards residential development and serviced sites on suitable lands located within any of the
defined Tier 4 settlement. The policy however states: “Notwithstanding the requirements of criteria a-c above
for Tier 4 settlements and Section 15.8 ‘Multi Unit Residential Developments’ of the Monaghan County
Development Plan 2025-2031, and taking into account the objectives of the ‘Housing for All – A New Housing
Plan for Ireland’ to address the shortage of housing, the Planning Authority may favourably consider proposals
for social housing developments which are outside the defined Tier 4 settlement limit where a clear
demonstrable need is proven to the satisfaction of the Planning Authority, and where the lands are contiguous
to the settlement limit and can be adequately serviced”. Having regard to Monaghan County Council and An
Coimisiún Pleanála’s planning decisions made under reg. ref. 21/378 / appeal PL18.313034, the proposal would
set a poor precedent as it proposes 27 houses outside of the designated development envelope of Doohamlet.
Only social housing is proposed. The proposal is excessively over-scaled as regards any need to address social
housing demand in the village. The applicant has not demonstrated a social housing need of this scale in the
village nor justified why private housing is not provided alongside the social housing other than to benefit from
this policy. Doohamlet needs some housing development proportionate to the size of the village and to its
housing demand – private and social. This can be achieved by a development within the Doohamlet
designated development envelope. Consequently, the proposed development, if permitted, would be contrary
to the provisions of Policy 15.8.10 of the Monaghan County Development Plan 2025-2031, would not represent a
co-ordinated and consolidated pattern of growth and would be contrary to the proper planning and
sustainable development of the area.
4. Having regard to the location of the site within an area outside of the designated development envelope of
Doohamlet Village, excepting lands owned by Monaghan County Council outside of the blue line ownership
boundary and to National Policy Objective 19 of the National Planning Framework and the Sustainable Rural
Housing Guidelines for Planning Authorities issued by the Department of the Environment, Heritage and Local
Government in April, 2005, it is considered that the applicant does not come within the scope of the housing
need criteria as set out in the Guidelines or the Development Plan for a house at this location. The proposed
development, in the absence of any identified locally based genuine need for 29 social houses, would
contravene local and national housing policy and objectives, would contribute to the encroachment of random
rural development in the area and would militate against the preservation of the rural environment and the
efficient provision of public services and infrastructure. The proposed development would, therefore, be
contrary to the proper planning and sustainable development of the area.
5. The subject site is mostly in an unzoned area previously the subject of a Ministerial Direction as to its
downzoning. It is considered that the proposed development sited on lands which have been cleared of
hedgerows, trees, and vegetation and which are to be the subject of cut and fill works would adversely affect
the character of the area and would adversely affect views along the R183. The proposed development would
therefore seriously injure the visual amenities of the area and be contrary to the proper planning and
sustainable development of the area.
6. Insufficient information has been submitted to the satisfaction of Monaghan County Council to ensure that the
proposed development would not significantly impact on a downstream Natura 2000 site via a hydrological
connection. The proposals are premature having regard to appropriate assessment screening. Accordingly, if
permitted as proposed, the development would be contrary to the proper planning and sustainable
development of the area.
7. A Road Safety Audit has been submitted in accordance with the Monaghan County Development Plan
2025-2031. Concerns identified at the proposed site entrance have not been satisfactorily addressed,
particularly as regards the Stage 1/2 Road Safety Audit. The proposal is therefore deemed to be
unacceptable as it would (i) endanger public safety by reason of traffic hazard, (ii) be contrary to the Monaghan
County Development Plan 2025-2031, and (iii) be contrary to the proper planning and sustainable development
of the area. RECEIVED: 18/12/2025
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8. The Monaghan County Development Plan 2025-2031 outlines the safety and convenience requirements for
accesses onto public roads. As per Section 15.23 ‘Road Access Standards’ and Section 15.12.1 (h) which requires
“Adequate site access and visibility splays, on-site parking, turning areas, and servicing arrangements are
provided for all types of vehicles associated with the site”. The applicant has failed to clearly demonstrate that
the minimum visibility requirements can be achieved at the development entrance. The proposal is therefore
deemed to be unacceptable as it would (i) endanger public safety by reason of traffic hazard, (ii) be contrary to
the Monaghan County Development Plan 2025-2031, and (iii) be contrary to the proper planning and
sustainable development of the area.
9. Cut and fill works are proposed to facilitate the significant site works/excavation. Detailed designs including a
geotechnical report have not been submitted. Accordingly, the satisfactory/appropriate nature of the design
standard is unconfirmed and to permit the development as proposed would be contrary to the proper planning
and sustainable development of the area.
10. The proposed development to be retained would endanger public safety by reason of traffic hazard arising
from additional traffic the development would generate on a substandard road at a point where sightlines to
the R183 are restricted in both the easterly and the westerly directions.
11.2 Details and drawings needed if MCC requests Further Information
If MCC requests Further Information, the following details and drawings are needed:
A revised consent letter from MCC as regards the red line boundary (requiring re-advertising).
A revised entrance proposal which addresses historic and existing sightlines issues.
A proposal to add a footpath to the west of the R183 entrance on its south side passing to the primary school.
Details and drawings showing the extent of cut and fill proposed.
A Social Infrastructure Audit including for older people.
An Architectural Heritage Impact Assessment Report as regards likely impacts on the adjoining protected
structure.
An updated Road Safety Audit regarding the entrance area to the scheme and onto the R183 (which is non-
compliant with DMURS).
A Landscape and Visual Impact Assessment and photomontages.
An Appropriate Assessment Screening Report.
An Ecological Impact Assessment.
A Site Specific Flood Risk Assessment.
A Construction Environmental Management Plan.
A Conservation Report.
An updated Archaeological Report.
Signed:
Brendan Buck
BPS Planning Consultants LTD
Members of the Irish Planning Institute
18 December 2025
RECEIVED: 18/12/2025
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Appendix 1: Signatures of members of the Concerned Residents of Doohamlet Group
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