BMC SID Planning Report 02.06

Planning Report

for a Strategic Infrastructure

Development in respect of a GIS

Substation and Underground

Transmission Lines

at the Former Clyde House,

IDA Blanchardstown Business and

Technology Park, Snugborough Road,

Blanchardstown, Dublin 15.

On behalf of

June 2020

Planning & Development Consultants,

63 York Road,

Dún Laoghaire,

Co. Dublin.

www.brockmcclure.ie

Barnageeragh 110kV GIS Substation and Transmission Lines– SID Planning Report

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1 INTRODUCTION ......................................................................................................................................... 2 1.1 WIDER DEVELOPMENT AREA .................................................................................................................... 3 1.2 THE APPLICANT ...................................................................................................................................... 3 1.3 DESIGN TEAM ......................................................................................................................................... 4

2 SITE CONTEXT ............................................................................................................................................ 5 3 PROPOSED DEVELOPMENT ...................................................................................................................... 5 4 RATIONALE FOR DEVELOPMENT ............................................................................................................. 6 5 PRE-APPLICATION CONSULTATIONS ....................................................................................................... 7 6 PLANNING HISTORY .................................................................................................................................. 8

6.1 SUBJECT SITE ......................................................................................................................................... 8 6.2 ADJOINING SITES ................................................................................................................................... 11

6.2.1 Cloghran Substation – Hexagon Building, IDA Blanchardstown Business and Technology Park, Snugborough Road, Blanchardstown, Dublin 15. ....................................................................................... 11 6.2.2 Snugborough Substation - Unit 1, Block 4B, IDA Business Park, Ballycoolin, Dublin 15. ............. 12

7 NATIONAL & REGIONAL PLANNING CONTEXT ....................................................................................... 12 7.1 GOVERNMENT STATEMENT ON THE ROLE OF DATA CENTRES IN IRELAND’S ENTERPRISE STRATEGY (2018) ....... 12 7.2 PROJECT IRELAND - NATIONAL PLANNING FRAMEWORK (2040) ................................................................. 13 7.3 REGIONAL SPATIAL AND ECONOMIC STRATEGY (2019-2031) ..................................................................... 14

8 STATUTORY PLANNING CONTEXT .......................................................................................................... 16 8.1 FINGAL COUNTY DEVELOPMENT PLAN 2017-2023 .................................................................................... 16

9 HERITAGE CONSIDERATIONS ................................................................................................................. 19 10 APPROPRIATE ASSESSMENT SCREENING ............................................................................................. 19 11 REQUIREMENT FOR EIAR ........................................................................................................................ 20 12 CONCLUSION ........................................................................................................................................... 20


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1 INTRODUCTION We, Brock McClure Planning and Development Consultants, 63 York Road, Dún Laoghaire, Co. Dublin, are instructed by the Applicant, Equinix Ireland Limited, Unit 6/7, Kilcarbery Business Park, New Nangor Road, Dublin 22, D22FV12, to submit this application for a strategic infrastructure development comprising a 2 storey 110kV gas insulated switchgear (GIS) substation and 2 no. underground transmission lines. A determination was made by An Bord Pleanála on the 23 April 2020 confirming that the proposed development is considered strategic infrastructure development. This application is made in accordance with Section 182A(1) of the Planning and Development Act, 2000 (as amended). This planning application relates to the following proposed development: 11okV GIS Substation

The proposed 2 storey 110kV Gas Insulated Switchgear (GIS) substation known as ‘Barnageeragh’ comprising 2 no. 110kV transformer bays within a GIS room, cable entry room, generator room, relay room, battery room, workshop, toilet, store room, mess room, hoist space and stair cores (c.1,055sqm total gross floor area) with an overall height of c.15m located within a compound (c.1,655sqm in area). The compound is surrounded by a c.2.6m high palisade fence. The substation will serve the data centre permitted under Reg. Ref. FW18A/0032 and further revised under Reg. Ref. FW19A/0176.

Underground Transmission Line - Cable No. 1 Cable No. 1 will extend from the proposed 110kV substation located at Clyde House, IDA Blanchardstown Business and Technology Park to the Cloghran Substation (permitted under Reg. Ref. FW11A/0104 and amended under Reg. Ref. FW12A/0083) located at the Hexagon Building, IDA Blanchardstown Business and Technology Park, Snugborough Road, Blanchardstown, Dublin 15. Cable No. 1 will follow a route originating at the proposed Barnageeragh substation extending south and eastwards along the internal road of the IDA Blanchardstown Business and Technology Park. The route then turns north eastwards on the Snugborough Road (R843) before terminating at the Cloghran Substation to the west of Snugborough Road. Underground Transmission Line - Cable No. 2 Cable No. 2 will extend from the proposed 110kV substation located at Clyde House, IDA Blanchardstown Business and Technology Park north east towards the 110kV Snugborough Substation (permitted under Reg. Ref. FW16A/0159 and amended under Reg. Ref. FW17A/0103) located at Unit 1, Block 4B, IDA Business Park, Ballycoolin, Dublin 15. Cable No. 2 will follow a route originating at the proposed Barnageeragh substation extending south and eastwards along the internal road of the IDA Blanchardstown Business and Technology Park. The route then turns north eastwards on the Snugborough Road (R843) and continues around the Snugborough Road roundabout and into the IDA Business Park, Ballycoolin before terminating at the Snugborough Substation to the west of Ballycoolin Business Park Road. The proposed underground transmission lines cover a distance of c.0.845kilometres (Cable No. 1) and c.1.415kilometres (Cable No. 2) between the existing and proposed substation. The development includes all associated and ancillary site development and construction works, services provision, connections to the substations, road/footpath access, minor revisions to the landscaping and boundary treatment works permitted under Reg. Refs. FW18A/0032 and revised under Reg. Ref. FW19A/0176, vehicular access and provision of 3 no. car parking spaces in the substation compound.


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This Application Report is intended to:

• Provide a detailed description of the proposal for the benefit of the Board; • Specify the rationale behind the subject development; and • Identify its compliance with relevant statutory documentation.

We now request that the Board review the content of the application package and consider the proposal on its merits.

1.1 Wider Development Area The proposal subject of this planning application forms part of a wider development site, which has been the subject of several planning applications. A full planning history is detailed in Section 6 of this report for clarity and context purposes. To date, permission was granted at Clyde House for the sub-division of the site/building into two separate developments comprising Clyde House 1 to the south and Clyde House 2 to the north of the site (Reg. Ref. FW17A/0168 refers). Planning permission was subsequently granted under Reg. Ref. FW17A/0205 for the demolition of Clyde House 1. Permission was granted under Reg. Ref. FW18A/0030 and FW19A/0176 to construct a data centre development on the southern half of the former Clyde House 1 site. The subject proposal will support the energy requirements of the permitted data centre and will form part of the transmission network for the wider area. The proposed design and layout of the substation and underground cabling works have been the subject of detailed discussions with various stakeholders including IDA, EirGrid, ESB Networks and Fingal County Council. The building is located within an IDA Business Park. Under the terms of the lease to Equinix Ireland Limited, a lessee is entitled to connect to IDA infrastructure, as required. Letters of consent have been obtained from all relevant landowners including IDA and Fingal County Council. We note that lands identified on the accompanying maps being in the ownership of Dublin City Council have recently been transferred to Fingal County Council. The letters of consent are enclosed herein.

1.2 The Applicant Our Client, Equinix Ireland Limited, is an experienced provider of data centre services, operating over 175 centres in 44 locations across the world. In Ireland, Equinix operates data centres in Northwest Business Park (2no.), Citywest and Kilcarbery Park, the latter being hubs for 175+ companies. The Equinix Dublin Metro International Business ExchangeTM (IBX®) data centres consist of four buildings with approximately 130,000 square feet (12,000+ square meters) of colocation space. The Dublin colocation facilities enable customers to be part of a highly connected digital ecosystem, including INEX, the Irish lnternet exchange. Hundreds of technology companies have established bases in Dublin over the last two decades, attracted by its business-friendly environment. This has enabled the city to become a leading player in the global technology sector. The four sites in Dublin have become the gateway to the United States, as U.S-based content companies must host EU customer data within Europe. Equinix has implemented various renewable energy technologies and sustainability practices on its data centre platform. In 2015, the company made a long-term pledge to power all its data centre sites with clean and renewable energy. By 2016, 56% renewable energy coverage was achieved and the company remains on target to achieve renewable goals.


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Equinix has been involved in the development of the subject site since 2017. Following the acquisition of the Clyde House 1 site, permission was granted for 3 no. data halls. Having regard to their involvement at the subject site and extensive knowledge within the sector, they are committed to the delivery of the highest quality ICT infrastructure. Equinix Ireland Limited is and will be responsible for the design and construction of the proposed substation and cabling works. The substation will then be transferred to EirGrid who will undertake its operational management and contribution to the grid network. General maintenance and repair works will be undertaken by ESB Networks.

1.3 Design Team

The scheme now before the Board has evolved following input from the following design team:

• Brock McClure Consultants (Planning Consultants) • RKD (Design Architects) • Suir Engineering (Consulting Engineers) • Malachy Walsh and Associates (Design Engineers) • Reliqua Ltd. (Archaeology Consultants)

Other stakeholders consulted as part of this application include EirGrid and ESB Networks.

Figure 1 - Site Location Map


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2 SITE CONTEXT The subject site is brownfield in nature and formed part of an overall site known as Clyde House. The site was subdivided into Clyde House 1 and 2. The southern portion of the site (subject site – Clyde House 1) was demolished to facilitate the permitted development of 3 no. data halls. The wider development site is characterised by the tree lined Blanchardstown Road North to the west of the site and the internal estate roads to the south and east of the site. Clyde House 2 is located to the north of the overall site. The substation is located in the south eastern corner of the overall site and fronts the internal estate roads to the east and south.

The proposed transmission lines cover a distance of c.0.845kilometres and c.1.415kilometres respectively between the two existing substations and are located within the IDA Blanchardstown Business and Technology Park and the IDA Business Park, Ballycoolin. Clyde House is located c.2.5km north east of the N3/M3 and Blanchardstown Town Centre. Blanchardstown Business Technology Park is an important employment centre in the County and contains a variety of businesses including worldwide companies (PayPal, IBM, Xerox, etc.) as well as educational facilities such as Institute of Technology Blanchardstown. The surrounding area is characterised by a mix of light industrial uses and offices with excellent connectivity to the N2, N3 and M50. Blanchardstown is home to a several large ICT and pharmaceutical companies and is a key location for foreign direct investment that is facilitated by IDA Ireland. The location of the permitted data centre and proposed substation is wholly appropriate having regard to the symbiotic nature of existing data centres clustered in the wider area and energy demands arising from the ICT sector.

3 PROPOSED DEVELOPMENT

The proposed development comprises a 2 storey substation and underground transmission lines. The substation and compound are located at the Former Clyde House, IDA Blanchardstown Business and Technology Park, Snugborough Road, Blanchardstown, Dublin 15. The underground transmission lines are located along the existing road network in the IDA Blanchardstown Business and Technology Park, Snugborough Road (R843), Snugborough Road Roundabout and the Ballycoolin Business Park Road. The underground transmission lines will travel between the proposed 110kV substation located at Clyde House, IDA Blanchardstown Business and Technology Park to two existing substations to the north east. The Cloghran Substation (permitted under Reg. Ref. FW11A/0104 and amended under Reg. Ref. FW12A/0083) is located at the Hexagon Building, IDA Blanchardstown Business and Technology Park, Snugborough Road, Blanchardstown, Dublin 15. The substations forms part of the Amazon Data Centre development and is bounded to the south east by trees fronting the Snugborough Road. The substation is bounded on all other sides by the remainder of the data centre development. The Snugborough Substation (permitted under Reg. Ref. FW16A/0159 and amended under Reg. Ref. FW17A/0103) is located at Unit 1, Block 4B, IDA Business Park, Ballycoolin, Dublin 15. This substation forms part of the K2 Data Centre development and is bounded by internal industrial estate roads to the north east and south east. The underground transmission lines/cable routes are fitted with joint bays, chambers and link boxes at intermittent locations along the routes. We refer to the engineering and architectural drawings accompanying this application for more information.


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The substation building is rectangular in form and comprises 2 no. 110kV transformer bays within a GIS room, cable entry room, generator room, relay room, battery room, workshop, toilet, store room, mess room, hoist space and stair cores across two storeys. The steel monopitch portal frame building will be clad in horizontally laid composite panels in signal black colour to provide visual contrast to the lighter grey industrial buildings seen in the wider area. The façade treatment takes visual cues from the existing substations at Snugborough to the north east of the overall site. The contemporary, refined and paired back design approach is reflective of the sector serving modern ICT businesses. The surrounding road network provides verdant tree lined routes throughout the area. In keeping with this, landscape treatments in the form of shrub/tree planting on the southern and eastern perimeter of the substation help to visually assimilate the structure into the wider business estate.

The extent of the subject site is detailed below:

Figure 2 - Site Layout Plan

4 RATIONALE FOR DEVELOPMENT

The rationale for development derives from the energy requirements of the permitted data centre at Clyde House. The substation and cabling works will form part of the transmission network for the wider area.

Although ancillary to the permitted data centre, the substation and cabling works are essential to the daily operations of the facility and in turn the wider transmission network on which companies rely upon to conduct their daily business. ICT is an essential part of modern business and daily life by providing fast and reliable communications between users. ICT contributes to a more efficient way of working and learning facilitating remote access while also reducing the need to travel thus contributing to a more sustainable and efficient environment.


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The proposal will assist in meeting demand growth in the sector, strengthen the network and improve the quality of supply for all users.

Notwithstanding the operational requirements of the data centre in terms of size, scale and format, the substation has been sensitively designed having regard to the surrounding built environment as referred to above in Section 3. The location of the underground transmission lines minimise impact on existing underground services and provide the least disruption to neighbouring properties. It is noted that the location and design of the proposal has been carefully considered in line with EirGrid specifications. The site is ideally located with no potential flood risk identified. We refer to the Flood Risk Assessment prepared by Malachy Walsh and Partners for more information.

5 PRE-APPLICATION CONSULTATIONS

In accordance with Section 182E of the Planning and Development Act 2000 (as amended), the Applicant had 2 no. pre-application consultation meetings with An Bord Pleanála on the 6 March 2019 and 4 February 2020 (Ref. ABP-301511-18 refers). The purpose of the meetings was to determine whether the proposed works were considered Strategic Infrastructure Development. The Applicant presented three underground transmission line routes to the Board. Two routes were preferred - Cloghran and Snugborough Substations. The Applicant confirmed that letters of consent from the various landowners involved would be obtained prior to lodgement of an SID application. The Board confirmed that an EIAR would not be required as the development is not of a relevant class requiring EIA. The Applicant agreed to provide an appropriate assessment screening report that would be included in the SID application. The Applicant confirmed that no overhead lines or no new roads were proposed as part of the subject development. All works relating to the underground cables would be within the existing road network. The Applicant submitted a letter to the Board on the 24 February 2020, outlining their desire to close the pre-application consultation process to allow for a determination to be issued. An Bord Pleanála Determination The Applicant received the Board’s determination in a letter dated 23 April 2020. The letter indicated that the proposed development was considered Strategic Infrastructure and an application should be made directly to the Board. The following prescribed bodies were identified in the determination:

• Minister for Housing, Planning and Local Government • Minister for Communications, Climate Action and Environment • Department of Culture, Heritage and the Gaeltacht • Fingal County Council (Planning Authority) • Transport Infrastructure Ireland • An Taisce • Heritage Council • Commission for Regulation of Utilities, Water and Energy • Health Services Executive


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The prescribed bodies listed above were contacted by this office and a copy of the application was sent to each body prior to lodgement of the application to the Board. We refer to the correspondence accompanying this application for more information. The Minister for Housing, Planning and Local Government was contacted by this office on the 28 April 2020. The Department’s representative confirmed that under Section 30 of the Planning and Development Act 2000 (as amended), the Minister’s Department would not be commenting on the application and that a copy was not required to be sent their office.

6 PLANNING HISTORY

6.1 Subject Site

FCC Reg. Ref. FW19A/0176 Permission was granted on the 5 February 2020 for modifications to the development permitted under FW18A/0032 principally comprising the following: alterations to existing rotunda retained on site; modifications to the 3 permitted data halls; omission of permitted 1st floor link bridge across the data halls; alterations to permitted ancillary plant areas; reduction in location and extent of flue stacks across the site; relocation of cycle parking spaces; reduced provision of car parking spaces and an increased provision of motorcycle parking spaces.


FCC Reg. Ref. FW18A/0032 Permission was granted on the 11 June 2018 for the following: modifications to demolition permitted under FW17A/0205 to incorporate the front rotunda section of existing building into new development; the construction of 3no. single level Data Hall buildings (c.19,687m2 GFA). Permission was granted subject to 14 no. conditions. Condition No. 14 in relation to development contribution levies was amended to €717,876.


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FCC Reg. Ref. FW18A/0030 Permission was granted on the 6 June 2018 for an additional 27 m² to the ESB substation, relocating the substation to the existing service yard, re-positioning the existing security gates from the bottom of the ramp to within the service yard; building new retaining walls and constructing a new 2m wide foot path around the substation; erecting a new 6.8 m high security fence adjacent to the substation. FCC Reg. Ref. FW17A/0205 Permission was granted on 12 January 2018 for the demolition of the southern section of Clyde House, once separated from Clyde House 2 as proposed under FW17A/0168. The area of demolition is identified as follows:


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FCC Reg. Ref. FW17A/0168 Permission was granted for the separation into two buildings of Clyde House to form Clyde House 1 and Clyde House 2. The separation consisted of the demolition of the current link between gridlines Q and R and the construction of external walls to both buildings creating a separation of approximately 8.3m between buildings. The demolition of part of a plant enclosure within the yard on the western side of the building and the demolition of a single storey kitchen extension attached to the existing canteen. Permission was also granted for the small reorganisation of car parking spaces to the north of Clyde House 2 and all associated site works.


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Figure 6 - Site Layout Plan 6.2 Adjoining Sites

In addition to the development referenced above, we refer to the two existing substations known as Cloghran and Snugborough which will connect to the proposed underground transmission lines.

6.2.1 Cloghran Substation – Hexagon Building, IDA Blanchardstown Business and Technology Park, Snugborough Road, Blanchardstown, Dublin 15.

FCC Reg. Ref. FW12A/0083 Retention permission was granted on 19 November 2012 subject to 3 no. conditions for minor adjustments to the 110kV electricity substation as granted under Reg. Ref. FW11A/0104 including the following: adjustment of substation compound levels; increase in length of the substation compound; increase in height of the parapet of the control building within the substation compound; adjustment to the transformer bay area due to the addition of a third transformer bay and an increase in size and repositioning of the client control building. FCC Reg. Ref. FW11A/0104 Permission was granted on 18 January 2012 subject to 5 no. conditions for a new AIS (Air Insulated Switchgear) 110kV electricity substation and ancillary site works.


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6.2.2 Snugborough Substation - Unit 1, Block 4B, IDA Business Park, Ballycoolin, Dublin 15.

FCC Reg. Ref. FW17A/0103 Retention permission was granted on 4 September 2017 subject to 3 no. conditions for modifications to the 110kv GIS (Gas Insulated Sub-Station) permitted under Reg. Ref.:FW16A/0159 as follows: The sub-station is reduced in size to c.968sq.m and reduced in height to c. 13.5m. Associated internal and external (elevational) modifications. Provision of a 4.5m high fire walls between the permitted transformers. Provision of a mini pillar and local sub-station and ancillary works. FCC Reg. Ref. FW16A/0159 Permission was granted on 7 February 2017 subject to 17 no. conditions for the removal of an existing car park and provision of an electricity substation compound to serve the data centre (granted under FCC Ref. FW15A/0117). Works include a 110kv GIS (gas insulated substation) building (2-storey); an MV (medium voltage) building (single storey); 4 no. transformer bays and ancillary site works. Total GFA (gross floor area) of buildings c. 1,363.2 sq.m.

7 NATIONAL & REGIONAL PLANNING CONTEXT The Government Statement on The Role of Data Centres in Ireland’s Enterprise Strategy, The National Planning Framework and Regional Spatial and Economic Strategy for the East and Midlands Region, are referred to in the following sections and set out key policy compliance points regarding the proposed development.

7.1 Government Statement on The Role of Data Centres in Ireland’s Enterprise Strategy (2018)

The Department of Business, Enterprise and Innovation released a statement on the Role of Data Centres in Ireland in 2018 in which it sets out the role and significance of data centres in Ireland’s wider enterprise policy objectives. The statement outlines the presence of data centres in Ireland has raised the Country’s visibility internationally as a technology-rich, innovative economy. The statement goes onto state that data centres directly contribute to job creation and generate significant added economic benefit by providing a range of services to other firms. A significant proportion of existing, permitted and proposed data centres are located in the Dublin Region. The statement notes that “The potential cost benefits which could be provided by data centres are dependent on location, existing network capacity and the infrastructure required to supply the site.” Having regard to the subject site connecting to existing substations in the area, the transmission connection is considered a more efficient and sustainable approach to the growth and expansion of the national grid. The statement goes onto note “A consistent and supportive whole of government approach will be brought to the realisation of the transmission and distribution assets required to support the level of data centre ambition that we adopt.” The Covid-19 pandemic has highlighted the urgent need for improvements in ICT and the roll-out of high speed broadband nationwide. Many bricks and mortar businesses are already trading and conducting business online to safeguard and continue daily operations. Across all sectors, work environments will be permanently altered with employees expected to continue working from home following the pandemic. The need for high quality data centres and associated substations is therefore essential to the recovery of the Country and economy post-Covid-19.


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7.2 Project Ireland - National Planning Framework (2040)

The National Planning Framework (NPF) is the Government’s high-level strategic plan for shaping the future growth and development of our country out to the year 2040. The NPF sets out that the Eastern and Midland Region of Ireland will, by 2040, be a Region of around 2.85 million people, at least half a million more than today. Compliance with Key National Policy Objectives The following National Policy Objectives are considered to apply to the site. National Policy Objective 47: “In co-operation with relevant Departments in Northern Ireland, strengthen all-island energy infrastructure and interconnection capacity, including distribution and transmission networks to enhance security of electricity supply.” National Policy Objective 55: “Promote renewable energy use and generation at appropriate locations within the built and natural environment to meet national objectives towards achieving a low carbon economy by 2050.” National Policy Objective 64: “Improve air quality and help prevent people being exposed to unacceptable levels of pollution in our urban and rural areas through integrated land use and spatial planning that supports public transport, walking and cycling as more favourable modes of transport to the private car, the promotion of energy efficient buildings and homes, heating systems with zero local emissions, green infrastructure planning and innovative design solutions.” Under the National Strategic Outcome 5 – A Strong Economy Supported by Enterprise, Innovation and Skills, Ireland is being prompted as a suitable international destination for ICT infrastructure. “Ireland is very attractive in terms of international digital connectivity, climatic factors and current and future renewable energy sources for the development of international digital infrastructures, such as data centres. This sector underpins Ireland’s international position as a location for ICT and creates added benefits in relation to establishing a threshold of demand for sustained development of renewable energy sources. There is also greater scope to recycle waste heat from data centres for productive use, which may be off-site.”

It is our considered view that the current proposal together with development permitted to date, complies with and exceeds the vision of the National Planning Framework on the following basis:

• The proposal makes the most efficient use of the site. The substation is proposed on the existing brownfield site while the underground cabling will be carried out beneath the existing road network.

• The overall development which includes a permitted data centre is appropriately located in west Dublin with excellent connectivity to the N2, N3 and M50.


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• The proposal will contribute to the emerging digital infrastructure of the area that helps to support a strong Irish economy through its enterprise, skills and innovation sectors.

• The proposal will continue to maintain high quality international connectivity, that Ireland is quickly becoming renowned.

Having considered the above, it is submitted that the current proposal will deliver on key objectives contained within the NPF.

7.3 Regional Spatial and Economic Strategy (2019-2031)

The Regional Spatial and Economic Strategy for Eastern and Midland Regional Assembly (RSES) has recently been published and adopted. The RSES provides a:

• Spatial Strategy - To manage future growth and ensure the creation of healthy and attractive places to live, work, study, visit and invest in.

• Economic Strategy - That builds on our strengths to sustain a strong economy and support the creation of quality jobs that ensure a good living standard for all.

• Metropolitan Strategy - To ensure a supply of strategic development areas for the sustainable growth and continued success and competitiveness of the Dublin Metropolitan Area.

• Investment Framework - To prioritise the delivery of key enabling infrastructure and services by government and state agencies.

• Climate Action Strategy - To accelerate climate action, ensure a clean and healthy environment and to promote sustainable transport and strategic green infrastructure.

Key RSES Provisions Blanchardstown/Fingal is identified as falling within the Dublin Region of the RSES. The Growth Strategy for the Eastern and Midlands Region is to:

• Support the continued growth of Dublin as our national economic engine. • Deliver sustainable growth to the Metropolitan area. • Target growth to regional growth centres of Athlone, Drogheda and Dundalk. • Support vibrant rural areas with a network of towns and villages. • Facilitate the collaboration and growth of the Dublin – Belfast Economic Corridor.


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• Embed a network of Key Towns through the region to deliver sustainable regional development.

• Support the transition to a low carbon, climate resilient and environmentally sustainable region.

One of the Guiding Principles for Investment Prioritisation in Placemaking for Enterprise Development is to “Align to national strategy and approach for data centres – right location for use and energy demand.” RPO 8.25 of the RSES states that Local authorities shall:

• Support and facilitate delivery of the National Broadband Plan. • Facilitate enhanced international fibre communications links, including full interconnection

between the fibre networks in Northern Ireland and the Republic of Ireland. • Promote and facilitate the sustainable development of a high-quality ICT network throughout

the Region in order to achieve balanced social and economic development, whilst protecting the amenities of urban and rural areas.

• Support the national objective to promote Ireland as a sustainable international destination for ICT infrastructures such as data centres and associated economic activities at appropriate locations.

• Promote Dublin as a demonstrator of 5G information and communication technology.

Section 5.5. of the RSES states the following in relation to Energy: “Development of the energy distribution and transmission network in the Region will enable distribution of more renewable sources of energy to facilitate future energy demand in strategic development areas along with the roll-out of the Smart Grids and Smart Cities Action Plan enabling new connections, grid balancing, energy management and micro grid development, see also Chapter 10 Infrastructure for more information on Infrastructure and Energy.” RPO 10.20: “Support and facilitate the development of enhanced electricity and gas supplies, and associated networks, to serve the existing and future needs of the Region and facilitate new transmission infrastructure projects that might be brought forward in the lifetime of this Strategy. This Includes the delivery of the necessary integration of transmission network requirements to facilitate linkages of renewable energy proposals to the electricity and gas transmission grid in a sustainable and timely manner subject to appropriate environmental assessment and the planning process.” RPO 10.22: “Support the reinforcement and strengthening of the electricity transmission and distribution network to facilitate planned growth and transmission/ distribution of a renewable energy focused generation across the major demand centres to support an island population of 8 million people.” RPO 10.23: “Support EirGrid’s Implementation Plan 2017 – 2022 and Transmission Development Plan (TDP) 2016 and any subsequent plans prepared during the lifetime of the RSES that facilitate the timely delivery of major investment projects subject to appropriate environmental assessment and the outcome of the planning process, in particular: Support the installation of additional transformer capacity and increased circuit capacity to meet Dublin demand growth to strengthen the network for all electricity users and improve the security and quality of supply.”

It is submitted that the current proposal and wider development site is supportive of the growth strategy and enables growth of the metropolitan region of the RSES. Specifically, the development has the potential to strengthen the electricity transmission in the area.


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8 STATUTORY PLANNING CONTEXT The statutory planning context governing the site generally relates to:

• Fingal County Development Plan 2017-2023 The provisions of this document as they relate to the subject site are briefly outlined below.

8.1 Fingal County Development Plan 2017-2023 The key provisions of the Fingal County Development Plan as they relate to the site and proposal are set out below. The subject site is located on lands zoned HT – High Technology with an objective to “Provide for office, research and development and high technology/high technology manufacturing type employment in a high quality built and landscaped environment.” The vision for this zoning is to “Facilitate opportunities for high technology, high technology and advanced manufacturing, major office and research and development based employment within high quality, highly accessible, campus style settings. The HT zoning is aimed at providing a location for high end, high quality, value added businesses and corporate headquarters. An emphasis on exemplar sustainable design and aesthetic quality will be promoted to enhance corporate image and identity.” Permissible uses associated with HT zoning are set out in Figure 7 below.

Figure 7 - Permissible Uses under HT Zoning

Substations and transmission lines are considered to fall broadly under the use class of ‘Utility Installations’ which are permissible under the ‘HT’ zoning. In this instance, the proposed development complies with the site’s zoning.


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Figure 8 – Zoning map with subject site identified in red

Objective EN06: “Encourage and facilitate the development of renewable energy sources, optimising opportunities for the incorporation of renewable energy in large scale commercial and residential development.” Objective EN22: “Facilitate energy infrastructure provision at suitable locations, so as to provide for the further physical and economic development of Fingal.” Objective IT01: “Promote and facilitate the sustainable delivery of a high quality ICT infrastructure network throughout the County taking account of the need to protect the countryside and the urban environment together with seeking to achieve balanced social and economic development.” Objective IT02: “Require appropriate modern information technology, including a carrier neutral, multi-duct infrastructure servicing every unit, to be incorporated into the overall design and layout of all new developments in Fingal, where feasible.” Objective ED27: “Promote the continued growth of the ICT sector in Fingal by creating high quality built environments offering a range of building sizes, types and formats, supported by the targeted provision of necessary infrastructure. Objective ED28: “Engage and collaborate with key stakeholders, relevant agencies, and sectoral representatives to develop the ICT sector in Fingal and to ensure that the economic potential of the sector is secured for the benefit of the local economy, and national economy.” Objective ED109: “Ensure that a range of industrial and/ or manufacturing units, in terms of size, scale, format and arrangements, is provided for to adequately respond to enterprise requirements in different economic sectors.” Objective ED110: “Proactively respond to the needs of enterprises undertaking pharmaceutical, data centre, food production and logistics activities that require bespoke building facilities to meet their specific manufacturing requirements.”


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Objective ED111: “Ensure that proposals for industrial and/ or manufacturing buildings demonstrate regard to the relevant development standards.”

The cluster of existing ICT facilities in Blanchardstown makes the subject site an ideal location for the proposed development. The proposal which connects to the existing Cloghran and Snugborough substations promotes the most efficient and sustainable use of the site, enhancing the physical and economic development of Fingal and the Greater Dublin Area. As referred to in Section 3 above, the contemporary design of the substation is in keeping with the form and design of existing substations in the wider area. We reiterate that the proposal has been carefully designed with specialist input from EirGrid and ESB Networks from conception through to lodgement of this planning application.

In accordance with the development management standards set out in Chapter 12 of the County Plan, we note the following: Access to the substation is facilitated via the internal business park estate road. A gated entrance is located to the north east of the substation. Three no. vehicular spaces are provided to the north of the substation, out of view of the internal road. The compound to the north of the substation provides sufficient space for vehicles to manoeuvre safely in and out of the site. It is envisaged that ESB Networks personnel will maintain the substation, as required. They will be responsible for the upkeep of the substation and removal of waste, as necessary. The proposal is set back from the internal estate road in excess of 7m, as set out in the County Plan. A landscaped buffer area comprising a green palisade fence, gravel strip, grass verge and shrub/tree planting is proposed and permitted around the public facing elevations of the substation. No signage is proposed as part of this development. The substation is contemporary in both form and design. The horizontally laid composite panel cladding will be finished in signal black colour. This attractive and durable finish provides visual contrast with the lighter grey industrial buildings seen in the wider area. The substation takes visual cues from the surrounding area to ensure consistency of design is achieved within the business park. In this regard the height and scale of the substation reflects the Snugborough substation to the north east of the site. The orientation of the substation with the narrow southern elevation facing the estate road reduces the perceived scale of development. The shrub/tree planning to the south will assist in visually ameliorating the development with the wider area. A high level of safety and security is achieved through the provision of a 2.6m high green palisade fence fixed to a concrete plinth base. The substation is served by water supply, foul water drainage and surface water/storage drainage systems connecting to existing lines located to the south on the internal estate road. Storm water will drain from the roof and paved areas to a petrol interceptor before being attenuated and discharged to the local sewer. Tree/shrub and grass verge planting along the substation perimeter will reduce surface run-off thus assisting natural water drainage on site.


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9 HERITAGE CONSIDERATIONS We refer to the accompanying Archaeological Survey conducted by Reliqua Ltd. and note that the subject site and cable route locations do not appear to have any archaeological and/or cultural significance. There are no protected structures on or directly adjacent to the site. Similarly, there are no designated architectural conservation areas on or near the site. The archaeological monument (RMP DU013-014) and protected structure (RPS. No. 678) located approximately 60m to the south of the proposed substation will not be directly affected by the development. The monument which is defined under the County Plan as a ‘mound’ has been incorporated into a staff carpark serving the nearby industrial units. The mound appears to form a traffic island or roundabout of sorts. The archaeological assessment states that the mound is not recorded in earlier maps of the area and may be either a natural feature or a consequence of construction works in the vicinity. The archaeological monument (RMP DU014-025) located to the east of Ballycoolin Business Park estate road is a redundant monument and is no longer regarded as having archaeological significance. To this end, we conclude that the proposal will not impact directly or indirectly on any archaeological or cultural heritage in the area.

10 APPROPRIATE ASSESSMENT SCREENING This application is accompanied by a Stage 1 - Appropriate Assessment Screening Report prepared by Malachy Walsh and Partners Engineering and Environmental Consultants. The application has been screened for appropriate assessment in accordance with the Habitats Directive (92/43/EEC) and Birds Directive (79/409/EEC), as amended (2009/147/EC). The characteristics of the site pertaining to scale, size, potential physical changes, required resources/services, timescales and potential waste material were thoroughly assessed. Following the identification and characterisation of Natura 2000 sites within a 15km radius of the subject site and other projects, plans or activities relating to the site, the potential impacts arising from the development were assessed. The assessment was based on the following indicators: water quality; habitat loss; habitat alteration; habitat or species fragmentation; disturbance and/or displacement of species and cumulative/in-combination impacts. The report outlines that the subject site is located approximately 9km from the nearest Natura 2000 site at Rye Water Valley/Carton SAC, the 8 no. remaining sites (within 15m radius) are located in excess of 10km from the site. The report concludes that that the sites are not likely to be significantly affected by the proposal and can be screened out for appropriate assessment. The proposal is not therefore required to progress to Stage 2 - Natura Impact Statement of the Appropriate Assessment process.


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11 REQUIREMENT FOR EIAR

The proposed development does not fall under the categorisation of projects outlined in Annex I or Annex II of the EIA Directive. The application is not subject of an Environmental Impact Assessment Report (EIAR) given that it does not fall under any of the classes outlined in Schedule 5 Part 1 of the Planning and Development Regulations 2001 (as amended). Similarly, the proposal falls below the threshold requirements of Schedule 5 Part 2 of the Planning and Development Regulations 2001 (as amended) including the following: 3. Energy Industry (a) Industrial installations for the production of electricity, steam and hot water not included in Part 1 of this Schedule with a heat output of 300 megawatts or more.

10. Infrastructure projects (a) Industrial estate development projects, where the area would exceed 15 hectares. The proposed development (industrial installation) does not result in a heat output of 300megawatts or more. Furthermore, the proposed development located within an industrial estate does not exceed 15 hectares. In order to make a cumulative assessment of the overall site, it is necessary to calculate the overall site area. Taking the subject site (c.3.675ha) and Clyde House 1 (location of the permitted data centre – Reg. Ref. FW18A/0032 and FW19A/0176 refers), this equates to a site area of approximately 7ha, which is well below the threshold of 15 hectares for industrial estate development projects. We refer to the letter prepared by Malachy Walsh and Partners accompanying this application which supports the rationale that an EIAR is not required. It is noted that the Board considered that an EIAR was not required during the pre-application consultation process or in their determination accompanying this application.

We conclude that an EIAR is therefore not required in this instance.

12 CONCLUSION

Permission is being sought for the provision of a 110kV GIS substation and underground transmission lines between the proposed substation and the existing Cloghran and Snugborough substations.

The rationale for the provision of this development is to support the power demand associated with the permitted data centre and to facilitate the future growth and expansion of the national grid. The proposal will contribute to the emerging digital infrastructure of the area that helps to support a strong Irish economy through its enterprise, skills and innovation sectors. As demonstrated in this report and the accompanying drawings and documents submitted as part of this application, we note that the proposal is wholly in accordance with national, regional and local planning policy and guidance. The proposal makes the most efficient use of this brownfield site. The substation will serve the permitted data centre while the underground cabling will be carried out beneath the existing road network in an efficient and timely manner. The ground above will be returned to its previous state with as little disturbance to the surrounding properties and road network as possible.


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The proposal is a carefully considered project and has been reviewed and revised by a multi-disciplinary design team in conjunction with discussions with EirGrid and ESB Networks. In addition, the proposal has had the benefit of multiple pre-planning consultation meetings with An Bord Pleanála.

Having considered all of the above and given the importance of this strategic infrastructure, we trust that the Board will make a favourable decision on the application in due course.

BMC SID Planning Report 02.06

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