HomeMy WebLinkAbout2560481 - SubmissionOBPS
Planning & Development
Consultants
Submitted by email to: planningaa monaghancoco.ie
The Secretary,
Planning Department,
County Buildings,
Monaghan County Council,
The Glen, Glen Rd, Tirkeenan,
County Monaghan,
H18 YT5o.
7 August 2026
Dear Sir/Madam,
M 087 2615871
T 01539 4960
E info(aibpsplanning.ie PO Box 13658
W vwvw.bpsplanning.ie Dublin 14
MON. CO. CO.
PLANNING SECTION
F 11
Further Third Party planning objection submitted at Significant Further Information stage 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 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 original statutory notices as follows:
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 the subject of a Further Information request issued by MCC on 3 February 2026. Further
Information was submitted on 30 July 2026, and it has been deemed'significant'. New site notices indicate that further
submissions can be made by Third Parties, such as our client who has already made submissions and there is no
further statutory fee.
Our client's group wishes to confirm that they have not been consulted by the applicant about this Further Information
submission, and they have not agreed in advance of its lodgement or 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 g.o 'Grounds for objection' of their original Planning Objection Report. The remainder of this letter sets out our
client's response to the applicant's Further Information submission.
We have reviewed the Significant Further Information (SFI) submitted by the applicant on 30 July 2026, together with
the revised plans, Engineering Services Report, volumetric analysis, and all supporting documentation.
Full list of member names, addresses and signatures included in Appendix 1 of the attached BPS Report.
BPS Planning
Consultants Ltd
Company reg. no. 702762
Corporate Member of the Irish Planning Institute VAT no. IE37g6154CH
Director: Brendan Buck
BA, MRUP, Dip. (UD),
Dip. (EIA/SEA), MIPI, MHSA,
Dip. Planning Law (King's Inns)
FURTHER INFORMATION STAGE THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
Our client maintains their strong objection to the proposed development, The SFI does not resolve the fundamental
planning deficiencies identified in the original objection (lodged December 2025) and, in several respects, confirms
that the proposal remains contrary to the proper planning and sustainable development of the area.
We respond on an item -by -item basis to the eight points raised in the Council's Further Information request of 3 February
2026.
1.0 Assessment of and responses to the Further Information submission
1,1 Assessment of response to Item I - Justification under Section 15.8.10 (Social Housing Need &
Sequential Development)
The applicant's response relies heavily on national housing shortage statistics, Housing for All targets, and a single piece of
correspondence from the Housing Section referring to a need for "31 additional social housing units within the Doohamlet
area."
This response is inadequate for the following reasons:
• Section 15.8.10 of the Monaghan County Development Plan 2025-2031 is an exceptional provision that allows social
housing outside the settlement boundary only where a clear and demonstrable need is proven and the proposal
contributes to sequential development.
• The correspondence cited does not demonstrate that 28/29 units of wholly social housing are required specifically in
Doohamlet at this location, nor does it address the cumulative impact of the second concurrent application (reg. ref.
25/60489 - 44 dwellings) also under assessment within the village.
• Two large residential applications progressing simultaneously in a small Tier 4 village that was only recently upgraded
from Tier 5 represents a disproportionate and unsustainable scale of growth. The combined quantum would significantly
exceed the growth envisaged for Doohamlet under the Core Strategy.
• The site remains largely outside the settlement envelope. The proposal continues to leapfrog undeveloped lands closer
to the village core and does not represent sequential development.
• No Social Infrastructure Audit has been provided to demonstrate that Doohamlet (a relatively isolated rural village) has
the services, amenities, public transport, or community infrastructure to support a 100% social housing scheme of this
scale.
The following points set out detailed concerns regarding the cumulative impact that two large residential
applications/developments could have on such a small village.
Cumulative concerns for Doohamlet - a small Tier 4 village
Doohamlet is a small rural village that was only recently elevated from Tier 5 to Tier 4 in the Monaghan County Development
Plan zo25-2031. It has a limited existing housing stock, modest community facilities and a constrained local road network.
Against this background, the simultaneous assessment of two substantial residential applications raises serious cumulative
planning concerns.
i. Scale relative to the existing village
The current application (reg. ref. 25/60481) proposes 28-29 dwellings (almost entirely social housing). The concurrent
application (reg. ref. 25/60489) proposes 44 dwellings on a 1.87 ha site at Doohamlet. Combined, the two schemes would
deliver in the order of 72-73 new dwellings in a short period. This quantum is disproportionate to the existing size, character
and service base of Doohamlet and would fundamentally alter the scale and social composition of the village.
2. Leapfrogging and non -sequential development
Both schemes rely on lands that are either outside or only partially within the designated settlement envelope. This
constitutes leapfrogging of undeveloped lands closer to the village core and is contrary to the sequential approach required
by national policy, the Development Plans Guidelines for Planning Authorities (2022) and the Core Strategy of the Monaghan
County Development Plan 2025-2031.
3. Infrastructure and service capacity
A small village such as Doohamlet has limited capacity in terms of:
• Local road network and junctions (particularly the existing residential cul-de-sac proposed as the sole access for the
current scheme);
• Wastewater and water infrastructure;
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FURTHER INFORMATION STAGE THIRD PARTY PLANNING OBJECTION VS, MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
• Community facilities, primary school capacity, public transport and social supports.
No robust Social Infrastructure Audit has been submitted to demonstrate that these services can absorb the cumulative
population increase arising from both applications.
4. Landscape, topography and visual impact
The current application involves approximately 26,000 m3 of net cut. When considered alongside a second large scheme of
44 dwellings, the cumulative alteration of the natural drumlin landscape and the introduction of suburban -style layouts on
the edge of a small rural village would have a transformative and largely negative visual impact,
5. Context of Office of the Planning Regulator (OPR) concerns
The Office of the Planning Regulator has repeatedly raised concerns about over -zoning and the risk of unplanned or
excessive growth in County Monaghan. In its submissions on the Draft Monaghan County Development Plan 2025-2031 and
subsequent material alterations, the OPR:
• Criticised the extent of Strategic Residential Reserve zoning, particularly where it is peripheral and exceeds actual
housing need;
• Emphasised the need for compact growth, sequential development and consistency with the Core Strategy;
• Stressed that growth in lower -tier settlements must be commensurate with their size, function and infrastructure
capacity;
• Sought the removal or significant reduction of zonings that would facilitate sprawl or undermine the settlement hierarchy.
• While the OPR's formal interventions have focused more on the larger towns, the underlying principles — avoiding over-
development relative to the scale of the settlement, preventing leapfrogging, and ensuring infrastructure -led growth —
apply with particular force to a newly elevated Tier 4 village such as Doohamlet,
The cumulative effect of the two concurrent applications (28-29 units under reg. ref. 25/60481 and 44 units under reg. ref.
25/60488) would deliver a level of growth that is out of scale with Doohamlet's existing character, infrastructure and position
in the settlement hierarchy. Approval of either scheme (and especially both) in their current form would set an undesirable
precedent for unplanned expansion of small Monaghan villages and would be inconsistent with the Core Strategy, national
compact -growth objectives, and the concerns previously expressed by the Office of the Planning Regulator regarding over -
zoning and over -development in the county.
The applicant has failed to provide the robust, site -specific justification required by Section 15.8.10. The existence of a second
large application being assessed by MCC in the same village at present further undermines any claim of sequential or
proportionate development. Permission should be refused on this ground alone.
1.2 Assessment of response to Item 2- Public Lighting
The applicant has submitted revised lighting proposals. While technical compliance with lighting standards may be
achievable, this does not overcome the fundamental principle objections (unzoned land, leapfrogging, scale, and sequential
development). Lighting design cannot render an otherwise unacceptable development acceptable.
1.3 Assessment of response to Item 3 - Layout, Design & Residential Amenity
As regards the assessment of the response to Point 3 - Layout, Design & Residential Amenity (Policy MURP1 / Section 15.8),
the revised layout still exhibits:
• A roads -dominated suburban character inappropriate to a rural village edge;
• Poor permeability;
• Awkward relationship of certain units to existing dwellings:
• Visually prominent boundary walls;
• Privacy concerns arising from opposing first -floor windows;
• Questionable usability of certain open -space areas.
The modest redesigns do not address the core criticism that a large, single -tenure estate of suburban character is being
forced onto unzoned agricultural land outside the village envelope.
1.4 Assessment of response to Item 4- Dwelling Plans & Elevations
Revised house -type drawings have been submitted. This is a technical response and does not resolve the in -principle
objections.
1,5 Assessment of response to Item 5- Uisce Eireann Pre -Connection Enquiry
The applicant has submitted correspondence from the Doohamlet Group Water Scheme confirming capacity (subject to
connection fees). No formal Confirmation of Feasibility from Uisce Eireann for wastewater appears to have been provided in
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FURTHER INFORMATION STAGE THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
the SFI package reviewed by BPS. Even if capacity exists, the availability of services does not justify development on
unzoned land outside the settlement boundary in contravention of sequential development principles.
1.6 Assessment of response to Item 6- Cut and Fill
The volumetric analysis submitted with the SFI is highly revealing. It quantifies:
• Cut volume: approximately 26,955 m3
• Fill volume: approximately 911 m3
• Net cut: approximately 26,044 m3
This confirms that the development requires very substantial earthworks to lower a significant hill on the site (up to
approximately 5 m in places). These extensive cut -and -fill works were not adequately described or quantified in the original
application and remain poorly justified. The scale of intervention is excessive for a rural edge -of -village location and will
permanently alter the natural topography and landscape character of the area.
This proposal is contrary to:
The Monaghan County Development Plan 2025-2O31
Chapter 15 (Development Management Standards) states: "Sites requiring excessive excavation, filling and/or removal of
natural vegetation should be avoided" (Guidelines for Siting and Designing a Rural House in the Vernacular Style - Site
selection criteria).
Although written primarily for single rural houses, the principle is applied by planning authorities to multi -unit schemes on
the edge of villages, particularly where the land is unzoned or only partially within a settlement envelope. The volumetric
analysis submitted with the Fl shows a net cut of approximately 26,044 m3 (cut = 26,855 m3 / fill = 811 m3). This is clearly
"excessive excavation" by any reasonable measure and directly conflicts with the Plan's stated preference for sites that work
with the natural topography.
Other relevant provisions in the Plan reinforce this:
• The Plan repeatedly emphasises the sensitivity of Monaghan's drumlin landscape and the need to protect its character
(Chapters 6 and 15). Large-scale regrading permanently alters the natural landform that defines the county's landscape
character.
• Policies on visual amenity and landscape protection require that new development should not be unduly prominent and
should respect the traditional pattern of settlement and topography.
• Section 15.32 (Infilling of Lands) and related policies show the Council's caution around significant earthworks, even when
the material is inert.
National Planning Policy Context
While there is no single national SPPR that bans large cut -and -fill, national planning guidance documents support a
restrictive approach:
• The Sustainable Residential Development and Compact Settlements Guidelines (2024) promote efficient use of land and
designs that respond to the existing site context and topography rather than forcing suburban layouts onto unsuitable
ground.
• The Urban Design Manual - A Best Practice Guide and earlier Sustainable Residential Development Guidelines
encourage working with the existing landform and minimising the need for extensive earthworks.
• Architectural Heritage Protection Guidelines - A large-scale alteration of natural topography adjoining a protected
structure / graveyard (All Saints Church) raises additional concerns about impact on setting.
Good planning practice - as reflected in many An Coimisiun Pleanala decisions - treats extensive cut -and -fill as an indicator
that the site is not naturally suited to the proposed density or layout. It often leads to visual scarring, increased construction
impacts, and questions about sustainability. We refer MCC to the following cases.
• PLo6F.249417 (Howth, Fingal) - Refusal reason included: The proposed development requires significant cut/fill works
and reconfiguration of the existing profile and landform contrary to Policy 3.4.1 of the Howth SAAO and Objective NH44
of the Development Plan." The Commission and Inspector treated the extent of cut -and -fill as evidence that the proposal
was insensitive to the existing landform and harmful to visual amenity in a sensitive landscape.
• ABP -319118 (Dunmore East, Waterford) - The refusal reason explicitly referenced: "... the scale, massing, bulk and height
of the proposed development and the level of excavation required ... would seriously detract from the character and
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visual amenities of the area .....The Inspector and Commission considered the extent of groundworks as a material factor
in the visual impact and character assessment.
• ABP -315564-23 (Shankill House (Ferndale Road, RathmichaeL / Shankill, Dublin 18) - The Commission raised concerns
at the quantum of land reshaping to achieve a housing estate on a sloping site.
There are multiple single house and small -scheme refusals (e.g. Cork, Wicklow, and Dublin cases) where Inspectors
regularly refuse or criticise proposals where:
• Significant cut -and -fill is required to create a level platform;
• The works would permanently alter natural topography:
• Retaining walls become visually dominant: or
• The scale of earthworks indicates the site is not naturally suited to the proposed density/layout.
Please see, for example,
• An CoimisiOn Pleanala - Case reference: PL04.321822. This Cork (rural) single rural house was refused based on
topography, elevated siting and failure to integrate with the landscape (Inspector and Commission emphasised
designing with the landform),
• An Coimisiun Pleanala - Case Reference ABP -319752-24. In this Putland Road, Bray case, the Inspector discussed
changes in ground level and the degree of excavation required for retaining works.
Common language used includes "excessive excavation", "significant cut and fill", "reconfiguration of the existing landform", and
"sites requiring excessive excavation should be avoided".
It is our professional opinion that:
• The scale of cut -and -fill demonstrated in the Fl volumetric analysis (net cut of -26,000 m3) constitutes "excessive
excavation" and is contrary to the explicit guidance in the Monaghan County Development Plan 2025-2031 that such sites
should be avoided.
• The works would permanently alter the natural drumlin topography that forms part of the landscape character of the
area.
• This further demonstrates that the site is not suitable for a development of this scale and density outside the core
settlement envelope.
• Combined with the unzoned status of the majority of the land, the leapfrogging of sequential sites, and the cumulative
impact with the second application in the village, the extensive earthworks reinforce the case for refusal.
1.7 Assessment of response to Item 7- Environmental Information (CEMP, Surface Water, etc.)
A Construction Environmental Management Plan and revised drainage proposals have been submitted. While these address
some technical requirements, they do not overcome our client's fundamental planning objections relating to location,
zoning, sequential development, scale, and cumulative impact with the second application in the village.
There are, for example, significant concerns over:
1. Concerns over the CEMP - Review of the McCloy Consulting CEMP (Mo2283-ol, July 2026)
The document has several weaknesses that are particularly relevant to this small village site and the scale of the proposed
earthworks. Main issues identified:
• Underestimation of the bulk earthworks phase - The CEMP correctly records the cut volume: 26,955 m3 cut, of which only
gin m3 will be re -used on site (Section 5.3). However, the Indicative Programme (Table 4-1) allocates only 1 month to
"Bulk earthworks and infrastructure installation". Moving and disposing of approximately 26,000 m3 of material in one
month is highly ambitious and, in practice, is likely to generate intensive truck movements, prolonged noise/dust, and
significant disruption. The programme does not appear realistic for a constrained village -edge site.
• Access / haul route description is inaccurate or incomplete - Section 5.2 states that construction materials will be delivered
"using the existing access road off the R183" and that "No temporary access points are required." In reality, the proposed
development routes all traffic (including heavy construction vehicles) through the existing residential cul-de-sac to the
north before reaching the R183. The CEMP does not adequately address the impacts of this arrangement on existing
residents (noise, dust, safety, mud on the road, restricted access for residents, etc.). This is a significant omission given
the constrained nature of the access.
• Traffic management section is generic - Section g (Traffic Management) is referenced but the measures described remain
high-level. There is limited site -specific detail on:
- Limits on vehicle size or numbers using the cul-de-sac,
- Timing restrictions to avoid peak residential times,
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FURTHER INFORMATION STAGE THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
- Wheel -washing / road -cleaning protocols tailored to the narrow access,
- How resident access will be maintained during intensive earthworks periods.
• Noise and dust controls are standard /generic - The measures in Section 7 are typical best -practice statements (modern
plant, damping, sheeting, etc.). Given the proximity of existing houses and the large volume of material movement, more
robust, quantified or receptor -specific controls (e.g. real-time monitoring triggers, specific screening locations, tighter
working -hour restrictions during earthworks) would be expected for a small village setting.
• Surface water monitoring - Daily visual checks and weekly monitoring are proposed (as required by the Fl request) and
referred to Appendix C. The text is light on how the large cut operations will be controlled to prevent silt -laden runoff
reaching the Rossollus watercourse.
The document reads as a competent but relatively generic CEMP. It does not fully grapple with the combination of:
• Very large net cut volume,
• Constrained access through an existing residential cul-de-sac, and
• The sensitive, small -village context of Doohamlet.
In short, while a CEMP has been submitted, it:
• Allocates an unrealistically short period (1 month) to the bulk earthworks phase involving -26,000 m3 of material;
• Does not adequately address the impacts of routing all construction traffic through the existing residential cul-de-sac;
and
• Relies on largely generic mitigation measures that are not sufficiently tailored to the constrained access and the
proximity of existing dwellings in a small village.
These shortcomings mean the CEMP does not fully demonstrate that construction -phase impacts on the village will be
acceptably controlled,
2. The CEMP has identified a key surface water pathway which raises Appropriate Assessment concerns
From the McCloy CEMP (Section 1.6 and Section 6):
• There are no water features on the site itself.
• The nearest watercourse is the Rossollus watercourse (approx. 70 m south and 85 m northwest).
• This flows north into the Major Lough Stream (-660 m north) and then into Major Lough (-4 km west).
• The proposed surface water drainage system will discharge to the Rossollus watercourse, — This creates a new
hydrological pathway from the construction site (and later the operational development) to the wider surface water
network.
The CEMP correctly notes that this discharge represents a potential pathway for the transport of contaminants (silt,
hydrocarbons, concrete washings, etc.) during construction.
Relevance to Appropriate Assessment:
Even though the main European sites in County Monaghan (Kilroosky Lough Cluster SAC and Sliabh Beagh SPA) are not
immediately downstream, the following AA -relevant points arise:
• New discharge pathway - The development introduces a direct discharge to the Rossollus watercourse that does not
currently exist. Any failure of silt control or pollution prevention during the large-scale cut operations (-26,000 m3) could
send sediment or pollutants downstream.
• Scale of earthworks - The very large volume of cut material significantly elevates the risk of silt -laden runoff, especially
during the intensive earthworks phase (which the CEMP programmes for only one month),
• Distance and dilution - While Major Lough is -4 km away and the European sites are further afield, AA screening still
requires consideration of whether pollutants could reach a European site in concentrations that could affect qualifying
interests (particularly water -dependent habitats or species). The absence of a formal AA Screening Report means this
pathway has not been properly assessed.
• Operational phase - Once constructed, the surface water system will continue to discharge treated runoff to the
Rossollus. The long-term water -quality implications (and any residual risk) also need to be considered in AA terms.
• Precautionary principle - Irish AA case law and guidance (and the Habitats Directive) require that where a potential
pathway exists and effects cannot be excluded beyond reasonable scientific doubt, Stage 2 Appropriate Assessment
(NIS) is required. The CEMP's mitigation measures, while useful, cannot be relied upon at screening stage to conclude
no likely significant effects".
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The application creates a new hydrological pathway to the Rossollus watercourse / Major Lough system. Combined with
the very large volume of proposed cut material, there is a clear potential for construction -phase impacts on water quality.
No Appropriate Assessment Screening Report (or Natura Impact Statement) has been submitted.
In the absence of a proper AA screening that examines this pathway, it is not possible to conclude that the development will
not have a significant effect on any European site.
This is a valid ground for seeking refusal (or at minimum a full AA Screening Report) under the Habitats Directive and the
relevant objectives of the Monaghan County Development Plan 2025-2031.
3. Problems with the proposed road access to this site
There are multiple problems with the proposed vehicular access into this site:
• The proposed vehicular access does not open directly onto the R183. Instead, it is designed to discharge all traffic from
the 28 dwellings into an existing residential cul-de-sac to the north.
• This intensifies use of an existing junction that the applicant's own Road Safety Audit acknowledges has "Legacy
shortcomings" (pre-DMURS geometry).
• The hierarchy of roads is reversed: a new estate road is being forced to rely on a substandard cul-de-sac entrance rather
than providing a proper, upgraded access onto tjie regional road.
• Sightline improvements, if required, appear to fall outside the red -line boundary and may not be deliverable.
• Pedestrian and cycle connectivity (including any required footpath link towards the primary school) remains inadequate,
• Construction traffic and long-term operational traffic will place additional pressure on a road network that was never
designed for this volume of additional movements.
In short, the access strategy is one of the weaker elements of the proposal and does not meet normal standards for a multi-
unit residential development of this scale.
1.8 Assessment of response to Item 8 - Assessment of response to Third -Party Submissions
The applicant's response to the original third -party objections (including those of our clients) is dismissive of the core
planning issues. It fails to engage meaningfully with:
• The unzoned status of the majority of the site:
• The leapfrogging of lands closer to the village core:
• The cumulative impact of two concurrent large applications in a small Tier 4 village:
• The absence of a Social Infrastructure Audit:
• The excessive cut -and -fill required; and
• The precedent that would be set for further unplanned expansion outside the settlement envelope.
There are four particular issues which the SFI submission fails to engage with:
s. Cumulative impact of two concurrent large-scale applications
The applicant's response to the third -party grounds fails to address, or even acknowledge, the cumulative impact of the
present application (reg. ref. 25/60481- 28/29 dwellings) when considered alongside the concurrent application reg. ref.
25/60489 (44 dwellings on a 1.87 ha site at Doohamlet).
Taken together, the two schemes would deliver approximately 72-73 new dwellings in a short period within a small, recently
elevated Tier 4 village. This quantum is wholly disproportionate to the existing scale, character and service capacity of
Doohamlet. It represents leapfrogging of sequential development opportunities closer to the village core, places
unsustainable pressure on local infrastructure (roads, water, wastewater, community facilities and primary school capacity),
and would fundamentally alter the social and physical character of the settlement.
2. Overdevelopment given the zoning / status of the lands
The Office of the Planning Regulator has consistently cautioned against over -zoning and excessive growth in lower -tier
Monaghan settlements that is not commensurate with their size, function and infrastructure. The simultaneous advancement
of two large schemes of this magnitude in Doohamlet runs directly counter to those concerns and to the Core Strategy's
requirement that growth in Tier 4 villages be limited and plan -led. The applicant's silence on this cumulative dimension is a
material deficiency in the Further Information response.
3. Visual Impact Assessment
No adequate Visual Impact Assessment has been submitted with either the original application or the Significant Further
Information, Given the scale of the proposed development, the extent of cut -and -fill required (approximately 26,000 m3 net
cut), and the location of the site on elevated ground on the edge of a small rural village, a proper Visual Impact Assessment
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(including photomontages from key public viewpoints) is necessary to allow the Planning Authority to fully assess the visual
consequences of the proposal,
Furthermore, the applicant has failed to address the cumulative visual impact of the two concurrent schemes (reg. ref.
25/60481 and reg. ref. 25/60489). The simultaneous introduction of approximately 72-73 new dwellings, involving significant
regrading of the natural drumlin topography on the periphery of Doohamlet, would have a transformative and largely
negative effect on the visual character and landscape setting of the village. This cumulative visual impact has not been
assessed or even acknowledged in the Further Information response.
4. Appropriate Assessment /surface water pathway
The Further Information response is also silent on the implications of the proposed surface water discharge for Appropriate
Assessment, The McCloy CEMP confirms that the development will create a new hydrological pathway by discharging
surface water to the Rossollus watercourse (approximately 70 m from the site), which flows into the Major Lough Stream
and ultimately Major Lough.
Combined with the very large volume of proposed cut material (approximately 26,000 m3 net), this new pathway gives rise
to a clear potential for construction -phase (and residual operational -phase) impacts on water quality. No Appropriate
Assessment Screening Report has been submitted. In the absence of a proper screening exercise that examines this pathway
in accordance with the Habitats Directive and relevant national guidance, it is not possible to conclude that the development
will not have a significant effect on any European site. Mitigation measures contained in the CEMP cannot be relied upon at
the screening stage to reach a conclusion of no likely significant effects.
For these reasons, the applicant's response to the third -party submissions remains incomplete and fails to demonstrate that
the proposed development, either individually or in combination with the concurrent application, would be in accordance
with the proper planning and sustainable development of the area.
2.0 Conclusion
The Significant Further Information submitted in respect of planning application reg. ref. 25/60481 fails to overcome the
fundamental deficiencies identified in the original third -party objection and raises additional material concerns. The
proposed development remains:
• Largely located on unzoned agricultural land outside the settlement envelope of Doohamlet;
• Contrary to sequential development and anti -sprawl policies of the Monaghan County Development Plan 2025-2031;
• Disproportionate in scale for a small Tier 4 village, particularly when considered cumulatively with the concurrent
application reg. ref. 25/60489 for 44 dwellings (together delivering approximately 72-73 new homes);
• Unsupported by robust, site -specific evidence of social housing need of this quantum at this location;
• Reliant on extensive cut -and -fill (approximately 26,000 m3 net cut) that permanently alters the natural drumlin
landscape;
• Poorly integrated with the existing rural village character; and
• Unsupported by any adequate Visual Impact Assessment, including any assessment of the cumulative visual impact of
the two concurrent schemes on the character and setting of Doohamlet.
In addition, the applicant's response is silent on the cumulative impact of the two concurrent large-scale applications and
on the status of the subject lands in light of the interventions of the Office of the Planning Regulator, which has repeatedly
sought the removal or significant reduction of peripheral and excess residential zonings in County Monaghan to ensure
consistency with the Core Strategy, the sequential approach and national compact -growth objectives.
Significant technical and environmental deficiencies also remain unaddressed. The proposed access strategy routes all
traffic through an existing residential cul-de-sac of limited capacity. The Construction Environmental Management Plan
allocates an unrealistically short period to the bulk earthworks phase and fails to provide robust, site -specific controls for
this constrained access arrangement. The development creates a new hydrological pathway by discharging surface water
to the Rossollus watercourse, yet no Appropriate Assessment Screening Report has been submitted to examine the potential
for significant effects on European sites. No Visual Impact Assessment has been provided to allow proper evaluation of the
individual or cumulative visual effects of the two schemes on the village.
In the absence of a robust demonstration of housing need under Section 15,8.10 of the Monaghan County Development Plan
2025-2031 that satisfies the sequential and infrastructure tests, and having regard to the cumulative, access, landscape,
environmental and Appropriate Assessment concerns set out above, the proposed development remains contrary to the
proper planning and sustainable development of the area.
For these reasons, and having regard to the detailed grounds set out in the original objection and in this response, it is
respectfully submitted that planning permission should be refused,"
BPS Planning & Development Consultants I www.bpsplanning.ie
FURTHER INFORMATION STAGE THIRD PARTY PLANNING OBJECTION VS. MONAGHAN COUNTY COUNCIL PLANNING APPLICATION, REG. REF. 2560481
3.0 Finally
We request that this submission be fully considered in the assessment of the application.
If you need to contact BPS, please use the details on our letterhead.
Best wishes,
Brendan Buck MIPI
Managing Director
BPS Planning & Development Consultants LTD
BPS Planning & Development Consultants I w ww.bpsplanning,ie