Planning observation: Dublin City Council rejected a planning application by a charity to open up a supervised injection facility (SIF) on Merchant’s Quay – the heart of Dublin city centre’s drug problem.
I think the Council got it wrong: a SIF could reduce overdoses, deaths, needle littering, and public injecting. It’s a humane, decent response to an addiction crisis that isn’t going away.
The charity appealed the decision to An Bord Pleanála. I was the only local councillor to put in a supportive observation, but we won – Merchant’s Quay Ireland secured planning permission.
Here’s the submission I sent in:
I am writing as an elected local representative for the area in question and in support of Merchant Quay Ireland’s appeal. I believe Dublin City Council were wrong in their rejection of the application and that a medically supervised injection facility pilot is vital for the area.
In their decision, Dublin City Council stated the facility would have injurious element on the residential community and tourism industry. Existing public injecting and drug needle waste is already having such an effect and a facility such as this would doubtlessly improve this problem, improving both residential and commercial amenity.
Crucially, this is a pilot. I do not want this to be the only facility in the city or country – we need to establish this system nationally and across the city if it is successful. The Council’s reasoning in its rejection would make any pilot facility in any location impossible, leaving Dublin and the country with an ongoing public injection and overdose crisis.
At its core, the Council’s decision presumes that such a centre would increase anti-social behaviour in the area, with negative consequences for local residents and the burgeoning tourist industry.
(a) This ignores the current reality in the area, which sees high levels of anti-social behaviour, crime and public injecting. Local businesses are regularly subject to drug users overdosing in their toilets, overdoses regularly take place on the street and in nearby lanes, and people are seen injecting publicly, often leaving contaminated needles and related drug litter on the street, posing a danger to children in particular.
A facility such as this would necessarily remove the problem of public injecting, overdosing and needle litter, as all of this would now take place in a controlled, indoor setting. Ideally there would be no need for such a facility, but the alternative to this centre is not no drug use, but public drug use.
(b) The Council’s decision assumes that an increase in anti-social behaviour will follow from the operation of this centre. The planning department appear to take at face value the submissions which contain such concerns. This assumption is not backed up by evidence from the 90+ supervised injection facilities operating around the world.
Tested research from existing facilities in other countries should trump speculative perceptions, however sincere. 2001 and 2003 studies in the Netherlands showed a reduction in what they call “nuisance crime” following the opening of a SIF. A 2004 study from Switzerland showed no change. A summary report of existing research by the European Monitoring Centre for Drugs and Drug Addiction found evidence of reduced crime.
Such research should be the basis for planning decisions on whether a facility will have a negative, positive or negligible impact on local communities.
(c) Extra space for queuing at the facility, along with the presence of security staff, is a particularly welcome step which will improve the public realm for residents, tourists and those accessing services alike. This will also reduce existing problems in the immediate area.
Consideration as a national facility
The facility is explicitly defined as a pilot by the HSE, with other centres to follow should this one be a success. The Council’s decision treats the facility as a “national facility”, which is inappropriate.
There is no evidence internationally of people travelling far distances to access such facilities, nor is this an anticipated service the applicant mentioned.
It simply does not seem credible that those in the depths of heroin addiction in another city would “commute” to this facility – or have the means to easily do so. Cork’s heroin users aren’t going to take a train to Dublin just to shoot up.
The facility does not exist as the only place to inject heroin – the alternative is to do so at home, in toilets, or on the street. This facility will likely reduce such impacts in the immediate surrounds and Dublin city centre, but it is unlikely to draw in people from outside the city in substantial numbers.
The Council’s “paramount concern” that this facility will draw in people in addiction “nationally” is completely unreasonable, given the nature of drug addiction.
The facility is a pilot. It is true that it would not be appropriate for this to be the only such facility in the city or country in the long run, but a pilot site is necessary to get a wider national scheme established.
Impact on tourism
The city lists impact on tourism as one of the reasons for rejecting the application. Yet a letter from Fáilte Ireland notes that they do not object in principle to a MSIF, merely that local businesses have raised concerns about anti-social behaviour.
Such concerns have been demonstrated in international research to be without evidence, so this objection does not stand, unless the planning process places speculation above research.
Other city objectives
The Dublin City Development Plan states that its social purpose is to complement the ‘Local Economic and Community Plan’.
220.127.116.11 (11) of the Local Economic and Community Plan states that one of its high level goes is to “tackle the causes and consequences of the drugs crisis and significantly reduce substance misuse across the city through quality, evidence-informed actions.”
This decision flies in the face of this high-level goal, embedded in the development plan, especially given that the applicant provided a host of international evidence and application in an Irish context to support the application.
The Council’s rejection states: “Although an 18 month trial period may be a necessary duration to carry out a trial for a MSIF, it is considered that it is also a period of time which is sufficient to contribute to a significant deterioration in neighbourhood amenities.”
This ignores that, should the project be a visible or complete failure (unlikely given the vast experience elsewhere), the government has specific provision to withdraw the operating license for the facility at any time.
Concentration of services
The Council’s rejection emphasises that there is an overconcentration of services in this part of the city. This is, in part, true. However:
(a) A major purpose of a facility such as this is to link social, medical, and housing supports to those in addiction. A degree of colocation is thus necessary.
(b) The applicant has stated in their application that they will move their night café service should the application be accepted. This would mean a welcome net zero increase in the number of services concentrated in the immediate area, as the night café (a de facto shelter) is moved elsewhere.
(c) As a representative for the area, it is clear to me that some of the concentration is a result of that being where the demand is. Homeless shelters are unreasonably concentrated in Dublin 8, but are more footloose – they can and should be relocated to wherever is best in the city centre. Services such as this, however, are different: they have to follow demand to a more local extent. If there is a concentration of people in drug addiction in an area, it stands to reason that the services should also have some degree of concentration there.
The Council’s rejection rightly makes repeated reference to residential amenity under the development plan, but does not seem to acknowledge that those who would directly be served by this medical facility are local residents too. Residential amenity and needs should not be interpreted in such a way as to exclude or dehumanise Dubliners who are struggling with addiction. Future service users are likely local residents too, who should be included socially: a core objective of the city development plan (2.1 – vision).