Poolbeg Peninsula and the lure of its vacant lands has rarely been out of the news headlines.
Reclaimed from the sea over a century and a half as the industrial city spread eastwards into the marshlands of Dublin Bay, some 34 hectares, or 84 acres of the lands are now billed to play a starring role in helping soothe the country’s housing crisis.
Dublin City Council two weeks ago hailed the authorisation by Simon Coveney, the Minister for Housing, Planning, and Local Government, to designate the Poolbeg West lands a strategic development zone (SDZ) that will fast track the development of 3,000 new homes across a large swathe of the peninsula.
The city council said it would immediately kick start consultations with politicians and the public to secure some sort of planning scheme before the end of the year.
The huge lands offer the opportunity to tackle the housing crisis by building homes in “an extremely attractive area” in a south-east corner of the capital, the council said.
But new concerns have now been raised about the speed and potentially the number of housing units that can be completed under the ambitious plan following an Irish Examiner examination of a key 2009 report written by a senior inspector at the Environmental Protection Agency — the EPA.
The report includes observations on landfill gasses emitted on some of the derelict lands.
Around a third of the proposed Poolbeg West strategic development includes the Irish Glass Bottle site, so-called because it housed a manufacturing plant for glass containers that at one time included eight production lines and two furnaces.
Manufacturing on the site of 10 hectares, or almost 25 acres, stopped in 2006, leaving the new owners the task to clean it of industrial metals, including arsenic and heavy fuel oils, used in making bottles over the previous 40 years.
The new owners of the site attracted attention from the start. The purchase for €412m at the height of the property boom in 2006 for a piece of undeveloped contaminated land in the southern Dublin docklands near Ringsend, was in itself an eye-catching transaction.
The price paid meant the developers could only make money if the site received planning permission for heavy residential and commercial office use.
Any other permission could fail to make healthy returns. The role of the old Dublin Docklands Development Authority (DDDA) — set up almost a decade earlier —was the focus of controversy.
The planning authority had a big say in deciding the master plan for swathes of land across the northern and southern docklands on the Liffey.
Here it was now getting involved in a spot of property speculation in its own back yard. With developers and financiers Bernard McNamara and Derek Quinlan, it bought the Glass Bottle site, paying over €100m for its share of just over a quarter stake.
The development company, called Becbay, with Mr McNamara as the majority shareholder, then set out to clean up the site of its industrial metals legacy.
But some of the worst fears voiced by critics in 2006 of the DDDA’s involvement were realised when Ireland was hit by one the world’s worst property market busts. Eventually, the lands lost up to 90% of their boom-time value.
But before the site had slipped into the State’s control, the Becbay owners had completed the clean–up of the industrial contaminants across the 25 acres.
The Environmental Protection Agency (EPA) is the statutory independent government body which monitors clean-ups of industrial wastes and, in the jargon of the planners, an Integrated Pollution Control licence was “surrendered”, in late 2009.
That meant that Becbay had shown it had cleared the site of the environmental pollutants linked to the manufacturing legacy on the site.
From 2006, soils had been shipped from the site to two decontamination facilities in Germany for disposal.
Writing in his 11-page report on the Glass Bottle site in late September 2009, the EPA inspector found “the main factory building, warehouses, offices, workshops, storage sheds, and concrete hardstand areas” had all been removed.
But the report also highlighted another previous role played by the Glass Bottle site, and that of the other Poolbeg lands beyond, that was not part of the Integrated Pollution Control licence over the site — namely the legacy of the peninsula as a main Dublin municipal waste tip.
Older residents knew that parts of the Poolbeg lands were used as a main Dublin tip head for the city’s waste. Dublin Corporation maps showed the Glass Bottle site was reclaimed from Dublin bay prior to 1965, with the southern part of the site reclaimed around 1966.
Dublin City operated a landfill, dumping waste in a layer of up to six metres at Ringsend. For 30 years up to its closure in 1978, methane-producing household waste was dumped on the tip across some of the Poolbeg lands.
The fill reclaimed land from Dublin Bay. Before 2006, the Glass Bottle site may have held up to five metres of old domestic waste placed directly on the beach, according to the senior inspector at the EPA.
Dublin City Council told the Irish Examiner in recent days that as part of the Becbay clean-up of the industrial waste that two metres of the “legacy landfill” was removed.
The EPA inspector in his 2009 report found the Becbay owners had complied with their obligations to clean the site of industrial metals.
The EPA, in October 2009, wrote to Bernard McNamara at Becbay Limited informing him the agency had accepted the “surrender” of the licencing conditions.
The inspector’s report made clear that following the clean-up there was “no indication of contamination” left from the manufacturing of glass bottles.
However, his report touches on issues involving the legacy of the lands as a municipal dump and highlighted potential challenges with building certain types of homes on the site.
“Landfill gas emissions where observed on site will require suitable engineering design by developers for gas mitigation and control at design stage,” the inspector wrote.
“Development of low density housing with gardens directly on top of the site would present a risk from ground gas.
"This may be difficult to resolve with engineering measures. However, the development of buildings with ventilated lower floors raised above ground level would be more acceptable and established engineering methods could be used to bring this risk within acceptable levels.
“Waste deposits are present beyond the boundary of the Becbay property. Even if all remnants of the landfill material were removed from the site, the buildings would require soil gas barrier systems to protect new buildings from undisturbed landfill in adjoining areas.”
The inspector’s report said the municipal waste by itself didn’t prevent the surrendering of the so-called Integrated Pollution Control licence but that “the suitability or otherwise of the site for further development of the site beyond the existing status will be a matter for the relevant planning authority”.
In July 2009, as the EPA prepared its final report on the Glass Bottle site, the agency received a submission from Michael Doak, one of the country’s leading hydro-geologists.
A number of years earlier Mr Doak had worked as an EPA inspector. He continues to lecture part time at TCD and is also highly knowledgeable about the clean up of sites in Dublin, Belfast, and Cork, as well as in Britain.
Mr Doak submitted an objection to the surrendering of the licence conditions over the Glass Bottle site on the grounds that though the site was cleared of the legacy of its industrial past — contaminants from the making of glass bottles — that its legacy as a main municipal waste dump and high levels of methane and other landfill gasses remained on the site.
He said that because of the observed high levels in parts of site of “the methane ground gas pollutant” that “the future end use” of the site should be carefully considered by the EPA.
The EPA inspector in his 2009 report found Mr Doak’s submission “cogent” and agreed in general terms with Mr Doak’s observations for “best practice” in cleaning up “contaminated sites prior to development”.
The inspector said, however, that the surrender of the licence conditions was an interim measure and separate from any future planning permission.
“The issues of the site extractions are still with us,” Mr Doak told the Irish Examiner this week.
Mr Doak described the EPA process in 2009 as showing that the Glass Bottle site was free of industrial contaminants. He said the report was not, however, to be read as clearing the site for “end-use” for house building.
“The  report shows there is a risk from the decades-old municipal wastes on the site,” Mr Doak said.
It is his expert opinion that there needs to be an assessment of the risk of emissions, including methane and other landfill gasses, across the whole Poolbeg Peninsula before any permission for fast-tracked permission under the SDZ should go ahead.
He said his second concern is his belief that there hasn’t been a sufficient analysis conducted in recent years of the lands beyond the Glass Bottle site that were also once used for industrial uses.
The scale of risk has not yet been determined, he said.
“What needs to be done is a comprehensive assessment of all the lands, which will take at least a year,”said Mr Doak.
New technology would help identify “the footprints” of gas emissions from the old municipal dump but any study “has to be done properly and match EPA best practice”, he said, despite the country’s urgent need to provide new housing.
However, Mr Doak still doubts that the lands can be easily developed, as the landfill waste below could likely present challenges to building quickly on the lands.
Green Party leader Eamon Ryan,, who has reviewed the 2009 EPA report, said the inspector’s report raises “concerns” about the current SDZ plan quickly to build housing on the lands.
“The EPA says there is an issue when the legacy of the lands as a municipal dump is taken into account” and that certain types of housing and homes with gardens are ruled out in relation to the Glass Bottle site, Mr Ryan told the Irish Examiner.
“The inspector himself says that ‘development of low-density housing with gardens directly on top of the site would present a risk from ground gas’,” Mr Ryan said.
He added that the key objective remains to build a high-quality and sustainable housing development.
“We have got to get the planning right and this includes finding how to manage the gasses from the waste dump,” Mr Ryan said. “The minister seems to indicate that he wants the development completed quickly. The EPA report of 2009 appears to suggest that this may not be possible.
“You cannot ignore what the EPA is saying. It does not indicate that this is an easy site to develop.”
The Irish Examiner asked Dublin City Council whether it had concerns over the Poolbeg West development in light of the EPA 2009 report about building certain types of housing units and gardens on the Glass Bottle site because of the gas emissions given the legacy of the site and of the wider Poolbeg peninsula as a municipal dump.
The newspaper asked the council whether it had concerns about the speed and costs which houses could be built across the Poolbeg lands, in light of the detailed 2009 EPA report, even under a fast-tracked SDZ planning process.
A Dublin City Council spokesman said: “We do not have concerns about the concept of building residential on the Glass Bottle site as any remediation works required to deal with the landfill legacy issues, would, of course, be duly undertaken in advance of any construction. We are not in a position to elaborate any further on this at this stage.”
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