Re: Draft Planning Scheme 2013 for the North Lotts and Grand Canal Dock

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Thomasina Griffith
5 years ago
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1 DRAFT SUBMISSION Re: Draft Planning Scheme 2013 for the North Lotts and Grand Canal Dock Dear Sir/Madam I wish on behalf of the North Port Dwellers Association of Unit C, Liffey Trust Centre, Sheriff Street Upper, Docklands, Dublin 1 to make a submission in relation to the above Draft Planning Scheme. 1.0 The Association The Association is the representative body for most of the residents of the following streets. New Wapping Street Castleforbes Road Mayor Street Upper Alexander Terrace Abercorn Road Irvine Cottages Irvine Court Irvine Terrace Church Street East Church Avenue Church Row Church Place Castleforbes Square Canon Hall The residents of Mayor Street Upper, New Wapping Street and Castleforbes Road are particularly impacted as they form the only long established residential community at the heart of the North Lotts Section of the Dockland s SDZ. The Association is generally welcoming of the publication of the Draft Scheme in the hope that it will advance the completion of the construction of an area which could be regarded as the largest ghost estate in the country. That said the Association have a number of concerns as set down below which need to be addressed. 2.0 Text Overall The Association is concerned that much of the language used in the document, is essentially aspirational and does not provide the certainty that third parties should expect in a Planning 1

2 Scheme. It appreciates that flexibility is required in such schemes to meet changing economic circumstances but that a degree of certainty is required particularly in the case where a close interrelationship exists between new development and existing established development. As an appeal process will not be available to the members of the Association it is vital that at this stage their residential amenities are fully protected and can be seen to be protected. 3.0 Impacts on Residential Amenity Overlooking, Overshadowing and Visual Obtrusion The Draft Scheme sets out various building heights coupled with diagrammatic plan forms. However there is no technical shadow study that would assess the impact on existing property over different times of the year and at different times of the day. It is evident that there would be a very serious loss of amenity to houses on New Wapping Street and Mayor Street Upper, as well as Castleforbes Road and Sherrif Street, which would have gardens and elevations cast in shadow for substantial periods of the day throughout the year. Although the impact from overlooking is difficult to fully assess in the absence of building elevations it is clear from development to date where extensive glazing is used to both modern office and residential development and that there would be a serious loss of amenity. The Draft Scheme refers to variety in height and mentions mews type units. The Association notes that this variety was achieved very successfully in lands developed by the Dublin Docklands Development Authority (DDDA) on the former Bord Gais site. Locations adjacent to existing residential property and directly across the road from such property would be suitable locations for this variety in scale and lessen the negative amenity impacts set out above. The Association notes that the block plans shown have narrow building widths which are at odds with the office and residential widths that have been developed to date (and indeed with the office typologies discussed in Paragraph 4.1.4). Large floor plates will probably be demanded by the office market in the future. The effect of the narrow blocks is to show unrealistic internal open spaces but more importantly from the residents point of view gives a misleading footplate in terms of the buildings and their impact from overshadowing. (See sketch No. 1 as an illustration of this problem and bear in mind that an atrium building could be developed.). The Association considers that the height and scale should be reduced in the new buildings close to the junction of Mayor Street /New Wapping Street in particular. It would greatly improve the amenity issues but also achieve a better and more coherent three-dimensional urban design. A transitional scale should be provided at the interface of these lower buildings and the higher ones. 4.0 New Local Streets and Spaces The Association notes the desire for permeability but is concerned that many of the spaces might be indeterminate in character with poor self-policing characteristics. The nature of the spaces as being hard or green is not clear other than in the case of the two pocket parks, their individual use by vehicles, cyclists and pedestrians is not articulated and the Association would have concerns that the spaces might be too small and spread out to make a meaningful amenity impact for future residents and workers. It notes that pavement, cycleway, landscaping and carriage widths are not set out on 2

3 the cross sections on page 164 so that it is difficult to see what areas are being ascribed to the various movement spaces. These require clarification. Excise Walk is used as an exemplar but this space is based on linkage between commercial node points with a concentration of café/retail space on ground level and this cannot be replicated on every north/south axial route due to the number of such routes. The management of spaces is an important consideration and the management companies operating in the area have to date maintained a good standard on Mayor Square and Grand Canal Square however the City Council will presumably take many of these facilities in charge and the Association would be concerned that the addition of a multiplicity of small indeterminate spaces needs to be thought through with the relevant sections of the Council to ensure that the spaces can be maintained to a proper standard. 5.0 Green Infrastructure The Association is concerned that the Planning Scheme shows a reduction in the quantum of green space compared to that in the DDDA North Lotts Planning Scheme. That Scheme showed four pocket parks and they were included as a result of submissions by the Association and the community representatives on the Docklands Council. The Council Scheme has halved this number to two pocket parks, which is inadequate. This is one of the examples where the aspirational language disguises what is in effect a reduction in public open space provision. As a minimum the omitted two spaces should be re-instated. 6.0 Residential Use Again the Association notes the aspirational language in terms of social mix but sees little set out that would achieve the desired outcome. There are no figures set out for minimum social housing provision, reference is made to the Council s own Housing Strategy however that Strategy simply iterates support for the DDDA Strategy. As the DDDA will shortly be wound up there is a lacuna with respect of what the City Council s strategy is for the Docklands area. The Association considers that Docklands is one of the few areas in the Country that has to date achieved good results in meeting public policy with regard to social mix and would urge the Council to set a target of 15% minimum provision in all new residential development for social housing and articulate this clearly in the Planning Scheme. The desired mix between unit sizes is not set out such as minimum number of three-bedroom units etc. The use of own-door residential typologies, developed so successfully for social housing in the Grand Canal Dock area is not articulated as an objective and the Association would urge its inclusion. Private open space provision for residential use is not set out and again the Association would urge its inclusion. 7.0 Other Uses The Draft Scheme sets out no land use objectives for particular uses such as hotels, cultural, educational and health facilities in specific locations. This is in contrast with the previous DDDA Schemes which set out a number of these objectives. There seems to be an assumption that these types of facilities are not required on the basis that they are already in existence having been 3

4 developed under the aegis of DDDA or that they are found in surrounding areas. However the Association is acutely aware that public health facilities are non-existent in the North Docks Area and that there is an emerging problem with regard to school provision for the new population where children are being sent outside the area for their education, which does not seem to be recognised as an issue by the Department of Education and Skills. The Council should re-examine the Scheme in this respect and not leave the area to be developed totally by the market without adequate provision of social facilities through specific zoning. It cannot rely on such lower value uses being achieved in mixed zonings on land that is controlled by the private sector as seems to be the policy set out in objective CD Use Ratios The Draft Scheme refers to ratios between commercial and office use however it is not clear whether this is based on land area as it was in the Docklands Schemes or on building area. (Office development makes a more efficient use of land area). This is a critical distinction and needs clarification as the Scheme is unclear and the Association would fear that the mixed-use nature of the area might be skewed towards office development and lose the mixed use nature already successfully achieved notably south of the River. It does not see any argument for changing the ratios set out in the DDDA Planning Schemes that are based on land area and urges their retention. The Scheme itself acknowledges the success of the mixed-use achieved in many parts of Docklands. The Association is aware of the judicial review outcome on the mixed use issue on individual sites in the Finlay-Geoghegan judgement and the Council would be well advised to ensure absolute clarity on what is being proposed for individual sites and the basis of the percentage calculation. 9.0 Pavilion Blocks at City Block 2a and 2c. /Events. The Association members have experienced considerable disamenity from the private use of the Royal Canal Linear Park adjacent to the National Conference Centre. Not only have they been prevented from accessing what is supposed to be a public space they have had to endure excessive noise disturbance, traffic and inebriated persons late at night. The proposal to use City Block 2 area for events virtually right beside the existing houses is totally unacceptable to the residents. There are more than sufficient event space at the Point Village and Grand Canal Square. The residents do not consider the City Council have a good record in managing events and fear a repeat of the disamenity that has occurred with events in Smithfield Community Involvement in Developing the Area. The Association is very concerned that with the demise of the DDDA Council (which had direct input into the planning and application of policies under the DDDA Masterplan), that their views will be ignored, that they will be side lined and the development sector given free rein. Although it appreciates that the Master Plan policies may no longer apply (unless legislation retains it in some form), nonetheless there should be a forum for resident s involvement. It would have welcomed a clear policy or objective to this effect. It notes that An Bord Pleanala have made it a condition of planning approval in a number of instances that a community liaison committee be established where large developments directly impact residents and the City Council should indicate that it will include similar conditions in approvals issued under the Scheme as a very minimum. 4

5 It notes Chapter 4.3 on Community Development and the objectives set out but none of these objectives are achievable without the active participation of the community. Appropriate administrative structures inclusive of community representatives must be set up and an objectine to this effect included in the Scheme Traffic and Movement The Association welcomes the commitment in relation to residents parking and the emphasis given to sustainable transport however they are concerned that the increased traffic circulating in the area will be loaded onto existing streets and no provision made for traffic management that would lessen impacts on existing residents. There is no traffic hierarchy diagram that would indicate that the Council have thought through the circulation of traffic within the area and how to minimise its impact. The Planning and Development Act is specific in relation to the contents required in a Planning Scheme and Section 168 (2) (d) and includes proposals relating to transportation, including public transportation, the roads layout, the provision of parking spaces and traffic management. There is no clear idea indication of what existing roads will be used or whether new routes carry vehicular traffic. The residents of the six houses within City Block No 2 on Mayor Street Upper have a particular problem in that they are located directly to the back of the footpath and suffer from Luas noise and vibration. Their situation would be greatly improved if substitute parking spaces were provided for them in the redevelopment of this block at underground or ground level and the footpath converted to pocket front gardens and the parking spaces to pavement. They have ownership rights to both this section of Mayor Street and to the lane to the rear of their houses and would be willing to enter into negotiations with the Council and developers to achieve this outcome. They would welcome an objective in the Planning Scheme to this effect Final Comment The Association urges the City Council to address the above submission in a positive manner. The submission is borne out of experience in living with planning and development issues since the start of urban renewal work in Docklands. A key consideration is providing confidence that the detail is sufficient in the Planning Scheme so that the community in turn can have confidence in the planning and physical outcome. Otherwise the only means of challenging future planning decisions is by way of judicial review which the Association would be extremely reluctant to undertake. It is not convinced that there is sufficient detail at present to give that confidence but looks forward to the production of a final Scheme that will meet the level of detail required and the concerns set out above. Yours etc. 5

6.0 Development of Amenities,

6.0 Development of Amenities, conservation of architectural heritage and other features This chapter outlines the Area's significant potential to provide for amenities of city wide and local importance