Statement of Consistency with Planning Policy

Transcription

1 Statement of Consistency with Planning Policy In respect of PROPOSED MIXED USE DEVELOPMENT AT THE FORMER CIE LANDS, 2-4 CARNLOUGH ROAD, CABRA, DUBLIN 7 Prepared by John Spain Associates On behalf of CREKAV TRADING GP LIMITED December Fitzwilliam Place Dublin 2 Telephone: (01) Facsimile: (01) info@johnspainassociates.com

2 1.0 INTRODUCTION 1.1 On behalf of the applicant, Crekav Trading GP Limited, 7 th Floor College House, Townsend Street, Dublin 2, we hereby submit this Statement of Consistency with Planning Policy to accompany a Strategic Housing Planning Application to An Bord Pleanála under Section 4 of the Planning and Development (Housing) and Residential Tenancies Act 2016 in relation to a proposed mixed use development at the Former CIE lands, Carnlough Road, Cabra, Dublin The proposed development will comprise of the provision of 420 no. residential units comprising 419 no. apartments (93 no. 1 bed, 260 no. 2 bed and 66 no. 3 bed units) and 1 no. 3 bed house at No. 4 Carnlough Road. The proposed development also includes a neighbourhood centre comprising of 4 no. retail units (2,895.5 sq.m.) including convenience supermarket with ancillary off licence, office (101.6sq.m.), community centre (441.8 sq.m.), creche (328.3 sq.m.) 402 no. car parking spaces (374 no at basement levels (298 no. to serve the residential units and 76 no. to serve the retail units) and 28 no. at surface level (20 no. to serve the residential units and 8 no. to serve the retail units) and 484 no. bicycle parking spaces (368 no. at basement level and 116 no. at surface level) on a site of 3.86 hectares. 1.3 This Statement of Consistency with Planning Policy has been prepared to specifically address the requirements of the Regulations and the Guidelines issued by An Bord Pleanála. The proposed residential development has been prepared in accordance with the Ministerial Guidelines, the requirements of the Dublin City Council Development Plan This Statement of Consistency also includes details in respect of the proposed development in relation to the site location and context, the development description and the relevant planning history and compliance with the development plan policies. 1.5 The development has been the subject of a number of pre-application meetings with the Planning Authority and a Section 247 pre-application consultation with An Bord Pleanála, in compliance with Section 5 (2) of the Planning and Development (Housing) and Residential Tenancies Act Details of the pre-application meetings and details of the Part V proposal are summarised in this report. 1.6 The applicant is committed to delivering a high quality residential development in this location with a good mix of unit types, complemented by high quality landscaping which has regard to the existing site features and the established character of the area. For further detail on the design approach please refer to the architectural drawings, design statement and the landscape drawings and statement which accompany this planning application. 1.7 This statement of consistency should be read in conjunction with the accompanying detailed documentation as follows: Strategic Housing Development Application Form; Application fee cheque 75, Digital copy CD; Letter of Consent (CIE and Crekav Limited Partnership) Part V Proposal; Copy of Site Notice; Copy of Newspaper Notice; Environmental Report prepared by John Spain Associates; John Spain Associates 2 Planning and Development Consultants

3 Statement of Consistency prepared by John Spain Associates; Material Contravention Statement prepared by John Spain Associates; ABP Response Documents prepared by John Spain Associates; Architectural Drawings prepared by Plus Architecture Architectural Design Statement including Landscape Report prepared by Plus Architecture Housing Quality Assessment and Schedule of Areas prepared by Plus Architecture CGI s prepared by 3DDB Engineering Drawings prepared by OCSC Consulting Engineers Engineering Services Report prepared by OCSC; Site Specific Flood Risk Assessment prepared by OCSC; Traffic Impact Assessment prepared by OCSC; Construction Management Plan prepared by Marlet Inward Noise Assessment prepared by AWN Traffic Assessment prepared by ILTP Daylight / Sunlight Analysis prepared by 3DDB; Archaeological Assessment prepared by Niall Colfer; AA Screening prepared by Roger Goodwillie; Energy Statement and Associates Drawings prepared by In2; M & E Utilities Report and associated drawings prepared by In2; Landscape and Visual Impact Assessment prepared by Mitchells and Associates 1.8 For details of compliance with the quantitative standards for residential units as set down in the Apartment Guidelines 2015, the Quality Housing for Sustainable Communities and the Development Plan please refer to the Schedules Document prepared by Plus Architects. 2.0 SITE LOCATION AND CONTEXT 2.1 The subject site comprises of approximately 3.86 hectares of brownfield lands. The site is bound to the north by the rear gardens of existing residential dwellings along Faussagh Avenue, to the south by Cabra Road, to the east by the Heuston / Connolly Railway line, and the west by the rear gardens of existing residential dwellings along Carnlough Road. 2.2 The site is a brownfield site and has the benefit of an extant planning permission, Reg. Ref. 2387/16 for 320 no. apartments and 3,259 sq.m. of commercial space including a local supermarket. The site was previously used as a CIE rail yard and sidings associated with the rail line located along the eastern boundary of the site. 2.3 The site is located in close proximity to a number of public transport routes and is well served by the existing road network. The site is located off the Cabra Road which directly links to the Navan Road south west of the subject site. Cabra Road is designated as a Quality Bus Corridor (QBC) which provides for a high quality Dublin Bus transport route to the City Centre. The subject site is also located within 500m of the proposed Bus Rapid Transport (BRT) route which runs along the Old Cabra Road. This rapid bus route will link Blanchardstown to UCD through the City Centre. 2.4 The Cabra station for the recently opened Luas Cross City is situated approximately 600m east of the subject site. The Luas line links the subject site to the City Centre and the Luas network. 2.5 The site is also located adjacent to a potential railway station on the Heuston / Connolly Rail line. John Spain Associates 3 Planning and Development Consultants

4 2.6 The subject site is located within an established residential area which is characterised by a mix of unit types and sizes. The area is well served by existing services and facilities including retail units, shops, a public library, schools and sporting facilities. Figure 1: Location of the subject site outlined in red. 3.0 DESCRIPTION OF THE PROPOSED DEVELOPMENT Introduction 3.1 The proposed development comprises of the construction of 420 no. residential units comprising of 1 no. 3 bed house located at number 4 Carnlough Road and 419 no. apartment units comprising of 93 no. one bed, 260 no. two bed and 66 no three bed units. 3.2 The proposed development is set out within 8 no. blocks as follows: Block A: Provision of 74 no. units (15 no. 1 bed, 49 no. 2 bed and 10 no. 3 bed units. The block ranges in height from 4 no. storeys to 8 no. storeys. Ground floor includes the provision of neighbourhood centre at ground floor level comprising of 4 no. retail units (2,895.5 sq.m.) including convenience John Spain Associates 4 Planning and Development Consultants

5 supermarket with ancillary off licence, and office (101.6sq.m.). A loading bay / service yard is located to the rear of Block A along the western boundary of the site. Block B: Provision of 28 no. units (27 no. 2 bed and 1 no. 3 bed). The height of Block B is 4 no. storeys c. 12 m. The ground floor provides for creche unit of sq.m. Block C: Provision of 24 no. residential units (1 no. 1 bed, 15 no. 2 bed and 8 no. 3 bed). Block C is 4 no. storeys in height. Block D: Provision of 93 no. units (27 no. 1 bed, 54 no. 2 bed and 12 no. 3 bed units. Block D ranges in height from 2 no. storeys to 8 no. storeys c. 24m. Block E: Provision of 24 no. units (5 no. 1 bed, 11 no. 2 bed and 8 no. 3 bed) and is 4 no. storeys in height. Block F Provision of 96 no. units (29 no. 1 bed, 55 no. 2 bed and 12 no. 3 bed). The height ranges from 2 no. storeys to 8 no. storeys. Block G: Provision of 80 no. units (16 no. 1 bed, 49 no. 2 bed and 15 no. 3 bed) and is 4 no. storeys in height, c. 12m. Block H: Community Building comprising of resident gym, concierge, post room, meeting room, and drop in. The proposed building is part single part 2 no. storeys in height. 3.3 The proposed development includes a neighbourhood centre comprising of comprising of 4 no. retail units (2,895.5 sq.m.) including convenience supermarket with ancillary off licence, office (101.6sq.m.). Unit sq.m.; Unit sq.m. and Unit sq.m., and Unit 2 (1,704 sq.m) to accommodate a local supermarket with ancillary off licence. A creche of sq.m. and community centre of 441.8sq.m. are also proposed to serve the development. 3.4 A total number of 402 no. car parking spaces will be provided (374 no at basement levels (298 no. to serve the residential units and 76 no. to serve the retail units) and 28 no. at surface level (20 no. to serve the residential units and 8 no. to serve the retail units) and 484 no. bicycle parking spaces (368 no. at basement level and 116 no. at surface level. 3.5 The development also includes the provision of 4,507 sq.m. (12%) of public open space and 3,039 sq.m. of communal open space provided through a series of courtyards, communal areas and larger public recreational spaces. 3.6 The subject site has the benefit of an extant permission, Reg. Ref. 2387/16 for the provision of 320 no. residential units and c. 3,259 sq.m. of commercial floor space including a local supermarket laid out over 8 no. four storey blocks. 3.7 The proposed development is submitted in response to the change in both government and local policy for increased heights within the city centre under the new development plan and the advice in new government policy which results in an increase in the number of units on site to 419 no. apartments and 1 no. house in 9 no blocks up to 8 no. storeys. 3.8 The proposed development will be accessed off Carnlough Road. A pedestrian access point will be provided off Faussagh Avenue which will connect through the site to Carnlough Road. 3.9 The proposed development is a strategic infill site which has significant potential in planning and development terms to accommodate a denser and more sustainable form of development having regard to its strategic location. It is envisaged that the John Spain Associates 5 Planning and Development Consultants

6 proposed development will provide a well-designed development to the site which will significantly enhance the vitality and viability of the area. Design Rationale 3.10 The Architectural Design Statement sets out a comprehensive design rational for the proposed development The proposed design rationale has been carefully considered and has evolved over a number of pre planning meetings with Dublin City Council. The design includes the following: Improvements to the materials and quality of the design Improvements to the public realm and landscaping of the development Improvements to the Block form in response to good urban design criteria. Improvements to the boundary treatment to allow for more secure development Improvements to the internal layout of the scheme in terms of access and pedestrian links 3.12 It is considered that the proposed scheme makes best use of the strategically located on an infill brownfield site providing for much needed residential accommodation within the city. Proposed Accommodation 3.13 The proposed development comprises 34,353.4 sq. metres of development. The breakdown of accommodation is as follows: Residential Accommodation 3.14 The residential component of the development consists of 420 no. residential units comprising of 1 no. 3 bed house and 419 no. apartment units The apartment units are broken down into 9 no. Blocks varying in height from 4 no. storeys to 8 no. storeys. The proposed unit mix for the apartment units comprise of 93 no. one bed (22.2%), 260 no. two bed (62%) and 66 no. three bed (15.8%) The proposed apartments have been designed to fully accord with the Sustainable Urban Housing: Design Standards for New Housing. A full Housing Quality Assessment is submitted which provides details on compliance with all relevant standards including private open space, room sizes, dual aspect, storage etc The proposed residential element of the scheme will also provide 4,507 sq.m. (12%) of public open space and 3,039 sq.m. of communal open space in total distributed throughout the scheme which include, playground, passive recreational space and active recreational space. The proposed landscaping has been design to enhance the overall quality of the scheme and integrate the various elements of the scheme together including the community centre, retail units and residential accommodation. Full details of the design of the open space is outlined in the Landscape Report prepared by Plus Architecture which accompanies this planning application. John Spain Associates 6 Planning and Development Consultants

7 Retail / Café / Creche Accommodation 3.18 Having regard to the zoning of the site Z3, as a neighbourhood centre, the proposed development include the provision of 5 no. retail units as follows: Unit 1(Retail): sq.m. Unit 2 (Convenience Supermarket with ancillary off licence): 1,704 sq.m. Unit 3 (Retail): sq.m. Unit 4 (Retail): sq.m. Unit 5 (Office): sq.m Unit 2 is proposed as a local supermarket (including off-licence), units 1, 3, 4 and 5 are proposed as smaller retail units that can accommodate a variety of compatible uses such as café, restaurant, shop or office (max 300sq.m.) in accordance with the Z3 permissible uses listed in the Development Plan The precedent of a local supermarket retailer on site was established in granting planning permission under Reg. Ref. 2387/16. The proposed local supermarket will act as an anchor to the development and will provide for a range of food and household items to the wider community which is currently lacking in such services. The provision of a retail supermarket at this location will decrease expenditure leakage outside the area and will support other smaller retail / café / restaurant uses, thus creating a neighbourhood centre in accordance with the Z3 zoning objective The proposed retail units will be located within Block A on the southern end of the site at the main access point to the development off Carnlough Road. This area of the development will accommodate the ancillary uses including creche and community centre for use within the wider community The proposed development will provide for a creche of sq.m. Based on the average requirement of 3-5sq.m. per child, the proposed creche can accommodate up to approximately 65 no no. childcare spaces which is considered to adequately meet the requirement generated by the proposed development. The proposed crèche is located on the ground floor of Block B. A private open space area is located to the rear of Block B to serve the creche. Community Centre 3.23 The proposed development include the provision of a sq.m. community centre located on the southern portion of the site within the neighbourhood centre zoning. The community centre will be part single part 2 no. storeys in height and will provide for a high quality facility for the use of both the future residents and the wider local area The community centre will provide for a resident concierge, post room, meeting room, gym, community hall and drop in centre. It is intended that the community centre will cater for various community function, sports classes, activities such as dance, art, music and various training services. The community centre is intended to serve the wider community and will aid in the integration of the new scheme with the existing residential area. John Spain Associates 7 Planning and Development Consultants

8 Open Space and Landscaping 3.25 Detailed consideration has been given to the provision of public open space and landscaping within the development. The landscaping masterplan for the site has incorporated a number of different landscaped areas, such as courtyards, play areas, passive open space and active open space. The proposed landscaping significantly enhances the overall quality of the scheme, improving the natural environment and incorporation of the scheme within the wider area A landscape report prepared by Plus Architects accompanies this application and provides details of how the site is utilised in terms of open space provision, landscaping and planting. This report also provides details of boundary treatments, site lighting and trees and highlights the detailed consideration that was given to all aspects of the open space strategy. The landscape plan is considered to be robust and gives careful consideration to the site layout and existing conditions, while providing usable open space for the future residents and the wider community The proposed residential element of the scheme will also provide 4,507 sq.m. (12%) of public open space and 3,039 sq.m. of communal open space in total spread throughout the scheme which include, playground, passive recreational space and active recreational space There is an existing laneway to the north of the site between No s 19 and 21 Faussagh Avenue. The opening of this laneway was explored to provide pedestrian access through the site. However, due to the changes in site levels and noncompliance with Part M that this link cannot be provided. In addition, this area contains a public services mains, therefore needed to remain accessible for any future works In addition, this area contains a public service main and ESB duct therefore works cannot be undertaken to bring the levels to an acceptable gradient. In the interest of public safety, this area will remain gated with no formal access to the site, expect ESB access. Height 3.30 The proposed development will vary in height from part single / 2 no. storeys to 8 no. storeys. The height and massing of the development has been given careful consideration and is considered appropriate having regard to the site s strategic location adjacent to high quality public transport whilst also respecting the more sensitive residential boundaries to the north and west Particular regard has been given to the existing residential dwellings, ensuring the height of the proposed blocks do not impinge on the residential amenity obtained within the existing units. The proposed Blocks B, C E, and G will remain at 4 no. storeys as per the previously permitted development, Reg. Ref. 2387/ The Community Building, Block H will be part single part 2 no. storeys in height in order to respect the built form of the existing residential dwelling along Carnlough Road. The proposed residential house unit at no. 4 Carnlough Road will also be 2 no. storeys in height Block A will be part 4 no. storey part 8 no. storey in height. The height of the buildings along the eastern boundary with the railway line, Blocks D and F, will increase to a John Spain Associates 8 Planning and Development Consultants

9 maximum of 7 no. storeys with an 8 no. storey set back level. The height increase is a result of the topography of the site and levels of the site below the existing residential units. The site is also capable of utilising such height along the eastern boundary due to the presence of the rail line and the low sensitivity of this boundary. The 7 no. storeys with 8 no. storey set back buildings will act as a bookend to the development and create a strong boundary along the eastern boundary with the rail way line which will reduce noise impact and enclose the scheme creating a sense of place. Materials and Finishes 3.34 A variety of materials are proposed within the development to provide visual interest and to create a distinct sense of place. Light yellow clay brick and red clay brick will be the predominant material uses on the elevations. The parapets, coping and flashings will be naturally painted zinc sheeting, while the exterior face in the internal courtyard will be finished in white rendered insulation above the ground level limestone plinth A simple palate of materials is proposed using brick as the principle materials on all facades to break down the massing of the building. Full details of the proposed material and finishes are set out in the Architectural Design Statement prepared by Plus Architecture. Car and Bicycle Parking 3.36 The site will be accessed from the south of the site off Carnlough Road. The basement is access off the internal road which runs along the eastern boundary of the site It is proposed to provide a total of 402 no. car parking spaces (374 no at basement levels (298 no. to serve the residential units and 76 no. to serve the retail units) and 28 no. at surface level (20 no. to serve the residential units and 8 no. to serve the retail units) to serve the proposed development, 3.38 The development plan states that a maximum of 1 no space per unit should be provided in car parking zone It is considered that due to the proximity of the site to extensive public transport links and the nature of the development as an apartment rental scheme that the proposed car parking provision is appropriate in this instance The proposed development will provide for and 484 no. bicycle parking spaces (368 no. at basement level and 116 no. at surface level). This results in a provision of 1:no. space per residential unit and an additional 65 no. spaces to serve the retail units and visitor spaces. It is considered that the level of bicycle parking spaces provided is sufficient to serve the proposed development. unit 3.41 Full details of the traffic and transport requirements are set out in the transport report prepared by ILTP Consultants. Site Services 3.42 It is proposed to retain the existing foul drainage connection for the community building and the 1 no. house fronting Carnlough Road. A new manhole to Irish Water John Spain Associates 9 Planning and Development Consultants

10 standards will be constructed on this connection pipe, incorporating a broadstrap facility The foul drainage the remainder of the proposed development, retail and residential units, will collect in a below-ground gravity drainage network of 225mm-diameter pipes The foul drainage system will drain by gravity to a proposed pumping station located at the northern end of the site. The rising main from the pumping station will discharge to a standoff manhole within the site. From there, a gravity foul drain will connect to existing foul sewerage on Bannow Road The site is divided into two sub-catchments: Catchment A to the south and Catchment B to the north. An underground attenuation facility will be provided in each catchment, with hydrobrake flow control limiting the discharge to equivalent greenfield runoff rates, calculated in accordance with the requirements of the Greater Dublin Strategic Drainage Study Regional Drainage Policy Volume 2 New Development (GDSDS-RDP Volume 2). The surface water for this development will discharge at a rate of 1.55 l/s/ha which is a reduced rate and above the normal 2.0 l/s/ha required It is proposed to supply the proposed development from the existing 24-inch cast iron watermain in Ratoath Road (R805). A new 150mmdiameter watermain will be constructed along Swilly Road and Carnlough Road to the site entrance A bulk meter will be provided at the site entrance. The retail unit at Carnlough Road will be supplied via a boundary box meter. All other retail and residential units will be supplied via the internal water tank room Further details regarding access and servicing are provided in the enclosed report by OCSC Consulting Engineers A Utilities report was also prepared by IN2 Engineering. This report sets out the provision of ESB Infrastructure, telecoms networks infrastructure, and natural gas infrastructure. Access 3.50 The principle entrance to the development will be located off the Carnlough Road. The basement will be accessed through this entrance point along the internal roadway located on the eastern boundary of the development Pedestrian access is provided at the northern end of the site off Faussagh Avenue. There is also a pedestrian route proposed along the eastern boundary of the site which connects Carnlough Road with Faussagh Avenue Further details regarding access and servicing are provided in the enclosed report by OCSC Consulting Engineers. Construction and Waste Management 3.53 The siting of construction activities and storage piles will be noted including the the location of sensitive receptors and prevailing wind directions in order to minimise the potential for significant dust nuisance. In addition, site management good practise will include the ability to respond to adverse weather conditions by either restricting John Spain Associates 10 Planning and Development Consultants

11 operations onsite or using effective control measures quickly before the potential for nuisance occurs: During working hours, technical staff shall be on site and available to monitor dust control methods as appropriate; Complaint registers will be kept on site detailing all telephone calls and letters of complaint received in connection with construction activities, together with details of any remedial actions carried out; It is the responsibility of the contractor at all times to demonstrate full compliance with the dust control conditions herein; At all times, the procedures put in place will be strictly monitored and assessed The waste manager will have overall responsibility to oversee, record and provide feedback to the client on everyday waste management at the site. Authority will be given to the waste manager to delegate responsibility to sub-contractors, where necessary, and to coordinate with suppliers, service providers and sub-contractors to prioritise waste prevention and salvage For further detail, see enclosed Construction and Demolition Waste Management Plan prepared by Marlet. Flood Risk Strategy 3.56 A Flood Risk Assessment has been prepared by OCSC Consulting Engineers. The report concludes that the subject site is outside the area of potential risk for fluvial flooding. The available data shows that the site is outside the area of potential risk for tidal flooding The available data on pluvial flooding and overland flow has been assessed and mitigation measures have been proposed. The existing water services infrastructure provides a risk of flooding if it was to fail. However, if this was to occur it would become overland flow and so would be dealt with in a similar fashion to pluvial flooding The flood risk represented by ground water is negligible and no further mitigation is required. Housing Quality 3.59 The proposed development has been designed to fully accord with the all relevant guidelines and quantitative standards. This is addressed in the attached Housing Quality Assessment submitted. Noise 3.60 An inward noise assessment has been undertaken by AWN. The results of the assessment have concluded that during daytime periods, internal noise levels are calculated to be within acceptable levels for living spaces with windows closed at all facades taking account of the proposed glazing recommended for the development. During night time periods, internal noise levels are calculated to be within acceptable levels for bedrooms with windows closed at the most exposed facades along the eastern boundary taking into account of the recommended glazing specification. John Spain Associates 11 Planning and Development Consultants

12 Daylight / Sunlight Access 3.61 A shadow analysis and sunlight / daylight assessment has been carried out by 3DDB. The report assessed the proposed public spaces within the development. The report indicates that all of the proposed public outdoor spaces meet the BRE Guidelines The shadow analysis also assessed the impact of the proposed development on the surrounding residential properties. The report states that the proposed development would not result in any significant impact on the level of sunlight received in the rear gardens of the neighbouring properties The daylight / sunlight report also includes details of the internal lighting conditions received in Block A. The report notes that in general there will be a good quality of daylight in the interior rooms of Block A with a significant improvement on the levels of daylight from the already granted scheme (Reg. Ref. 2387/16). Sustainability / Energy 3.64 An energy statement has been prepared by IN2 Engineering. The report confirms that the proposed development will comply with Part L regulation for the apartments. Visual Impact Assessment 3.65 A Visual Impact Assessment has been prepared by Mitchells and Associates. The report concludes that the design of the scheme is a unified and integrated response which successfully rises to this challenge. The photomontages illustrate an elegant balance between the issues of height, mass, density and the functionality required of contemporary housing in an urban environment and the sensitivities involved in placing it within an ageing low-rise housing area that was once considered to be in the suburbs In all of the views (except View 2) the proposed scheme sits fairly easily within its neighbouring low-rise context. In View 2 the proposed scheme is seen almost totally without its low-rise neighbours and can be seen almost in isolation. The impact is significant but positive a function of the inherent design quality of the scheme. Where the proposed scheme is seen in context of the existing housing, the assessment of impact is naturally more guarded given the inevitable contrasts and of course the potential sensitivities of those currently living in the area. Appropriate Assessment 3.67 An Appropriate Assessment Screening Report has been prepared by Roger Goodwille. The conclusion of the AA Screening Report is that the proposed project will not have any significant effects on any European sites. As such it can be concluded that the development either on its own or in-combination with other developments will have no impact on designated sites As it is concluded that there will be no risk of significant negative effects on any designated sites as a result of the proposed project, either alone or in combination with other plans or projects, the Appropriate Assessment Process, preparation of a Natura Impact Statement is not required. John Spain Associates 12 Planning and Development Consultants

13 Archaeological Assessment 3.69 An Archaeological Assessment has been prepared by Niall Colfer which accompanies this request for pre application consultation. The report concludes that an element of caution should be introduced in relation to development on site due to the course of the Bradogue River though the northern end of the site. The presence of the river highlights the potential for archaeological structures or features associates with rivers to survive. As such, it is recommended that licenced test trenching be undertaken as a condition to the planning application. Ground Investigation 3.70 OCSC have advised that the existing ground conditions comprise of spoil from railway works. The applicant is willing to accept a condition similar to that on the previous permission, Reg. Ref. 2387/16 which states that: In the event that hazardous soil, or historically deposited waste is encountered during the construction phase, the contractor must notify Dublin City Council and provide a Hazardous / Contaminated Soil Management Plan, to include estimated tonnages, description of location, any relevant mitigation, destination for disposal/treatment, in addition to information on the authorised waste collector(s). Road Upgrades 3.71 An indicative road layout is proposed to upgrade the Carnlough Road / Cabra Road junction by providing a new signalised junction including new controlled pedestrian crossings. Discussions have taken place with the City Council Road department with regards to their requirements for its implementation with DMURS. The proposed indicative layout is to be agreed with the City Council prior to commencement on site. The applicant is willing to accept a condition similar to that attached to the final grant of permission on Reg. Ref. 2387/16 which states: All roads and transport infrastructure, including new signalised junction with pedestrian crossing for the R146 Cabra Road/ Carnlough Road junction, works to Carnlough Road to facilitate turning lanes, new road marking etc. as indicated on the roads drawings and site layout plan shall be agreed in writing with the Environment and transportation Department prior to commencement of any development. All costs to facilitate these works shall be at the expense of the developer These works will be carried out for and on behalf of the City Council subject to condition. John Spain Associates 13 Planning and Development Consultants

14 4.0 PLANNING HISTORY 4.1 The subject site has the benefit of an extant planning permission for 320 no. residential dwelling and 3,259sq.m. of retail / commercial floorspace. The precedent of such development is therefore established on site. The proposed development provides for a similar layout to the previously permitted scheme. The current proposal improves the overall quality of design and amenity value within the development by providing higher densities, building heights and enhanced materials and open space areas. The overall nature of the development has been significantly improved while having regard to the previously permitted extant development on site. 4.2 A review of the relevant site history is set out below: Reg. Ref.: 2387/ Planning permission was granted by Dublin City Council on 29 th March 2017 subject to 25 no. conditions for the provision of 320 no. residential units and c.3,259 sq.m GFA of commercial floor space. The height of the development was 4 no. storeys and ranged over 8 no. Blocks. 4.4 This application retains the principle of the development and the overall block layout however provides for amendments to increase the overall number of units on site and increase the height and density of the development in line with new policies and objectives for the provision of residential development, increased densities and increased building heights adjacent to public transport nodes while improving the overall quality and level of amenity provided. Reg. Ref. 2204/ Planning permission was withdrawn for the provision of 387 no. apartments and 2,965 sq.m. GFA of commercial floor space on the subject site. The development proposed a building height of 4 no. storeys throughout the development. Reg. Ref. 4173/09 PL 29N Planning permission was granted on 28 th June 2010 for a reduction in unit number of site from 458 no. as previously granted by Dublin City Council on 27 th January 2010 to 388 no. units.. The application also contained a crèche of 660 square metres. Reg. Ref. 2569/08 - PL 29N An Bord Pleanála refused planning permission on 23 rd April 2009 overturning the decision of Dublin City Council to grant planning permission for a revised proposal of PL 29N Reg. Ref. 3884/06 on the site involving 443 dwelling units plus crèche, community centre and shops, on a 3.85 hectare landholding. Reg. Ref. 3884/06 - PL 29N An Bord Pleanála granted permission on 18th September 2007 for a development comprising crèche, two retail units, civic centre, apartments and houses. The scheme granted by Dublin City Council was at a density of 108 units per hectare. The Bord decision reduced this to 322 apartments and eight houses (330 units) at a height of 7 no. storey s. John Spain Associates 14 Planning and Development Consultants

15 Reg. Ref. 5000/ Dublin City Council refused planning permission on 18th November 2005 for a residential development comprising of 523 units reaching up to eight storeys in height. 5.0 NATIONAL AND REGIONAL PLANNING POLICY 5.1 The key provisions of national (including relevant Section 28 guidelines) and regional planning policy as it relates to the proposed development is set out in the following sections. The key policy and guidance documents of relevance to the proposed development are as follows: National Spatial Strategy (2002); Draft National Planning Framework 2040; Rebuilding Ireland Action Plan for Housing and Homelessness; Draft Sustainable Urban Housing: Design standards for New Apartments; Guidelines for Planning Authorities 2017; Regional Planning Guidelines for the Greater Dublin Area ( ); Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (2009), and the accompanying Urban Design Manual; Delivering Homes, Sustaining Communities (2008) and the accompanying Best Practice Guidelines- Quality Housing for Sustainable Communities; Quality Housing for Sustainable Communities (2007); Design Standards for New Apartments (2015); Design Manual for Urban Roads and Streets (2013); Guidelines for Planning Authorities on Childcare Facilities (2001); Smarter Travel A New Transport Policy for Ireland ( ); The Planning System and Flood Risk Management (2009); Birds and Habitats Directive Appropriate Assessment; Retail Planning Guidelines (2012) National Spatial Strategy (2002) 5.2 The National Spatial Strategy (NSS) was published on 28th November The NSS provides a broad planning framework for the location of development in Ireland over the next 20 years. The key objective of the National Spatial Strategy is to provide an overarching planning framework for the Country and to result in the achievement of more balanced regional development. 5.3 The NSS provides for increasing urbanisation of the population and achievement of critical mass in large multi-faceted urban areas. The National Spatial Strategy (NSS) is a twenty-year planning framework designed to achieve a better balance of social, economic, physical development and population growth between regions. 5.4 One of the core objectives of the NSS is the consolidation of the Greater Dublin Area (GDA) in a manner which protects local character and amenity through the achievement of higher development densities at sustainable locations proximate to public transport and services. The NSS supports the consolidation of the GDA in order to limit the spread of the GDA into surrounding counties and to ensure the efficient operation of the public transport system. 5.5 The proposed development is located approximately 3km from the City Centre and adjacent to a number of public transport routes, including a proposed BRT and the John Spain Associates 15 Planning and Development Consultants

16 Cross City Luas. The proposed development seeks to deliver an appropriate density and form of residential development, on this brownfield, which is located within an existing urban area. As such the development of these lands is considered to be fully in accordance with the recommendations of the National Spatial Strategy. 5.6 The Government is currently in the process of finalising the new National Planning Framework for the Country. Having regard to the Climate Change Agenda and the need to further reduce CO2 emissions it is likely that an increased emphasis will be put on integrating land use and transportation and consolidation of the Dublin Metropolitan Area, which the proposed development adheres to. Draft National Planning Framework (NPF) The Draft National Planning Framework is the Government s plan to cater for the extra one million people that will be living in Ireland, the additional two thirds of a million people working in Ireland and the half a million extra homes needed in Ireland by As a strategic development framework, Ireland 2040 sets the long-term context for our country s physical development and associated progress in economic, social and environmental terms and in an island, European and global context. 5.9 National investment planning, the sectoral investment and policy frameworks of departments, agencies and the local government process will be guided by these strategic outcomes in relation to the practical implementation of Ireland The NPF sets out the importance of development within existing urban areas by making better use of under-utilised land including infill and brownfield and publicly owned sites together with higher housing and job densities, better services by existing facilities and public transport Objective 3a of the Draft NPF states that it is a national policy objective to deliver at least 40% of all new homes nationally within the built up envelope of existing urban settlements. The proposed development is a strategically located green field site in the centre of an existing urban settle adjacent to high quality public transport and in close proximity to the city centre. The proposed development is therefore compliant with the objective of the draft NPF Objective 4 states ensure the creation of attractive, liveable, well designed, high quality urban places that are home to diverse and integrated communities that enjoy a high quality of life and well being. The proposed development will provide for a high quality residential scheme through the design quality and materials and finishes proposed. In addition, the proposed units are in excess of the minimum apartment size requirement as stated in the Apartment Guidelines and provision for well orientated spacious units The proposed development also includes the provision of residential amenity such as vast open space areas, community centre, gym, meeting room, concierge and a neighbourhood centre comprising of a civic square, 4 no. retail/ café units including a convenience supermarket with ancillary off licence and a creche It is considered that the proposed development provides for the creation of an attractive, high quality, sustainable new neighbourhood within the existing built ip area of the city. The provision of the new sustainable development is therefore consistent with the NPF objective. John Spain Associates 16 Planning and Development Consultants

17 5.14 Objective 10 of the Draft National Planning Framework states that there will be a presumption in favour of development that encourages more people, jobs and activity within existing urban areas, subject to development meeting appropriate planning standards and achieving targeted growth The NPF continues to state that: Although sometimes necessary to safeguard against poor quality design, planning standards should be flexibly applied in response to well designed development proposals that can achieve urban infill and brownfield development objectives in settlements of all sizes. This is in recognition of the fact that many current urban planning standards were devised for application to greenfield development sites and struggle to take account of evolved layers of complexity in existing built-up areas. In particular, general restriction on building height or universal standards for car parking or garden size may not be applicable in all circumstances in urban areas and should be replaced by performance based criteria appropriate to general locations e.g. city/ town centre, public transport hub, inner suburban, public transport corridor, outer suburban, town, village etc The proposed development is of a high quality design and provides for a high level of amenity within the scheme, therefore there is potential for flexibility and relaxation of certain standards in particular height and car parking due to the nature of the development and the location adjacent to public transport and within a well services existing urban environment. In this instance, it is considered that the proposed development is consistent with the overarching national planning policy to increase residential development at appropriate locations within the city Objective 11 of the National Planning Framework also states that: In urban areas, planning and related standards, including in particular building height and car parking will be based on performance criteria enabling alterative solutions that seek to achieve well-designed high quality and safe outcomes in order to achieved targeted growth and that protect the environment Objective 37 of the National Planning Framework continues to stress the importance of increased building heights stating: Increase residential density in settlements through a range of measures including reductions in vacancy, re-use of existing buildings, infill development schemes, area of site-based regeneration and increased building heights It is clear that there is a strong emphasis towards increased building heights in appropriate locations within existing urban centres and along public transport corridors. As such it is respectfully submitted that the proposed building height from single storey to 8 no. storeys is in line with government guidance and emerging trends for sustainable residential developments. Rebuilding Ireland Action Plan for Housing and Homelessness 5.20 Rebuilding Ireland was launched in 2016 with the objective to double the annual level of residential construction to 25,000 homes and deliver 47,000 units of social housing in the period to 2021, while at the same time making the best use of the existing John Spain Associates 17 Planning and Development Consultants

18 stock and laying the foundation for a more vibrant and responsive private rented sector Rebuilding Ireland is set around 5 no. pillars of proposed actions summarised as follows: Pillar 1 Address Homelessness: Provide early solutions to address the unacceptable level of families in emergency accommodation; deliver inter-agency supports for people who are currently homeless, with a particular emphasis on minimising the incidence of rough sleeping, and enhance State supports to keep people in their own homes. Pillar 2 Accelerate Social Housing: Increase the level and speed of delivery of social housing and other State supported housing Pillar 3 Build More Homes: Increase the output of private housing to meet demand at affordable prices. Pillar 4 Improve the Rental Sector: Address the obstacles to greater private rented sector delivery, to improve the supply of units at affordable rents. Pillar 5 Utilise Existing Housing: Ensure that existing housing stock is used to the maximum degree possible focusing on measures to use vacant stock to renew urban and rural areas The proposed development is consistent with Pillar 3 to build more mores. The proposed development provides for 420 no. new apartment which will add to the housing stock of the area and cater to the increasing demand for this existing urban area. Draft Sustainable Urban Housing: Design Standards for New Apartments; Guidelines for Planning Authorities 2017; 5.23 The Draft Sustainable Urban Housing Design Standards for New Apartment 2017 were published in December The guidelines provide for updated guidance on apartment developments in response to the Draft National Planning Framework and Rebuilding Ireland. These guidelines will supersede the 2015 Sustainable Urban Housing: Design Standards for New Apartments; Guidelines for Planning Authorities A key inclusion in the draft guidelines is the acknowledgement of the importance of key strategic brownfield sites in existing urban areas in close proximity to existing public transport facilities. The guidelines identify location is cities and town that may be suitable for apartment development having regard to the following: 1. Central and / or Accessible Urban Locations Generally suitable for small to large scale (will vary subject to location) and higher density development (will also vary), that may wholly comprise apartments, and includes: Sites within walking distance (i.e. up to 15 minutes or 1,000-1,5000m of principal city centres, or centrally located employment locations, that may include hospitals and third level institutions; Sites within reasonable walking distance (i.e. up to 10 minutes or 800-1,000m) to/from high capacity urban public transport stops (such as DART or Luas) Sites within easy walking distance (i.e. up to 5 minutes or m) to/from high frequency (i.e. min 10 minute peak hour frequency) urban bus services or where such services can be provided. John Spain Associates 18 Planning and Development Consultants

19 5.25 The subject development is located c. 600m from the Luas stations Cabra and Broombridge and c. 300m from the Quality Bus Corridor along the Cabra Road. The site is also in close proximity to Blanchardstown Town Centre, Blanchardstown Institute of Technology and James Connolly Hospital. The proposed development therefore falls into the central and / or accessible urban location category and is therefore extremely suitable for high density apartment developments The Draft Guidelines also note that in category 1, Central and / or Accessible Urban Locations, car parking provision may be wholly eliminated or substantially reduced. The guidelines state: In larger scale and higher density development, comprising wholly of apartments in more central locations that are well served by public transport, the default policy is for car parking provision to be wholly eliminated or substantially reduced. This may apply in very accessible areas such as in or adjoining city cores or at a confluence of public transport systems. These locations are most likely to be in cities, especially in or adjacent to (i.e within 15 minutes walking distance of) city centres or centrally located employment locations. This includes 10 minutes walking distance of DART or Luas stops or within 5 minutes walking distance of high frequency (min 10 minute peak hour frequency) bus service The subject development in accordance with the draft guidelines is also suitable for substantially reduced car parking provision. As such it is considered that the proposed development which provides 0.75 car parking spaces per unit is appropriate in this regard This planning application to An Bord Pleanála is accompanied by a Housing Quality Assessment document prepared by Plus Architects which demonstrates the compliance of the proposed development with the relevant quantitative standards required under the 2015 Apartment Guidelines The HQA illustrates in tabular format how each apartment within the development meet or exceed the relevant standards for example in respect to apartment size, internal areas, dimensions, private open space, dual aspect etc The Guidelines states that in developments of 100 units or more, the majority of units should exceed the minimum apartment size of 10%. 83.5% of the proposed units are at least 10% larger than the minimum standard The proposed apartment buildings and units are considered to be suitability located on the subject site, integrated within the landscape and well connected to adjacent facilities including public transport, and will provide a high quality development on the subject site. Regional Planning Guidelines for the Greater Dublin Area ( ) 5.32 The Regional Planning Guidelines (RPG) provide for the implementation of the National Spatial Strategy at a Regional level in the Greater Dublin Area (GDA). The Guidelines provide an overall strategic context for the Development Plans of each local authority in the Greater Dublin Area (GDA) The subject lands are located in the Metropolitan Area of the GDA. The Dublin Metropolitan Area is targeted for increased development, particularly those lands that John Spain Associates 19 Planning and Development Consultants

20 are readily acceptable by public transport and roads infrastructure. The Guidelines states that development within the existing urban footprint of the Metropolitan Area will be consolidated to achieve a more compact urban form, allowing for the accommodation of a greater population than at present, with much-enhanced public transport system, with the expansion of the built up areas providing for well-designed urban environments linked to high quality public transport networks, enhancing the quality of life for residents and workers alike. The proposed development provides a sustainable high quality residential environment on a key brownfield infill site within an existing urban area, adjacent to a high quality public transport corridor (Dublin Bus)., a proposed BRT and within a short distance to the Luas Cross City Line The guidelines also state that the policy emphasis for the metropolitan area is to gain maximum benefit from existing assets public transport, social, infrastructural through the continuation of consolidation and increasing densities within the existing building footprint of the City, suburbs and Consolidation and Large Growth towns The subject lands occupy a key brownfield infill site within an existing urban area. The proposed development is located along an existing public transport corridor for Dublin Bus and is connection to road network via the N3. The subject site is also located adjacent to a proposed BRT route along the Old Cabra Road. This route will connect Blanchardstown with UCD. The proposed development is also located within close proximity to the Luas Cross City line Cabra stop approximately 600m from the site The proposed development is consistent with the policy objectives of the Regional Planning Guidelines and in particular its emphasis on the consolidation of the urban area and the promotion of residential development close to existing services and transport links. The appropriateness of the site for residential development is reflected in the land use zoning objective and the existing pattern of development in the area It is noted that under the Local Government Reform Act 2014 that the Regional Planning Framework was altered. The Act resulted in the eight Regional Authorities and the two Assemblies being replaced by three Regional Assemblies. The Regional Authorities for the Greater Dublin Area The Dublin Region and the Mid-East Region have been replaced by the Eastern and Midland Regional Assembly. One of the main functions of these new Assemblies will include the formulation of Regional Spatial and Economic Strategies, which will replace the RPG s for However, the current Guidelines will continue to have effect until a regional spatial and economic strategy is prepared and adopted by the regional assembly. Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (2009) 5.38 The role of the Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas is to ensure the sustainable delivery of new development throughout the country The Guidelines provide guidance on the core principles of urban design when creating places of high quality and distinct identity. The Guidelines recommend that planning authorities should promote high quality design in their policy documents and in their development management process. In this regard, the Guidelines are accompanied by a Design Manual discussed below which demonstrates how design principles can be applied in the design and layout of new residential developments, at a variety of scales of development and in various settings. John Spain Associates 20 Planning and Development Consultants

21 5.40 These Guidelines support a plan-led approach to development as provided for in the Planning and Development Act Section 2.1 of the Guidelines note that the scale, location and nature of major new residential development will be determined by the development plan, including both the settlement strategy and the housing strategy The Guidelines reinforce the need to adopt a sequential approach to the development of land and note in Section 2.3 and the sequential approach as set out in the Departments Development Plan Guidelines (DoEHLG, 2007) specifies that zoning shall extend outwards from the centre of an urban area, with undeveloped lands closest to the core and public transport routes being given preference, encouraging infill opportunities Having regard to the above, the subject infill brownfield site is zoned Z1 and Z3 within the Dublin City Development Plan The Development Plan adopted a sequential approach when zoning the land for development therefore the location of the site and the zoning pertaining to the development is appropriate for the subject proposal relating to this planning application Sustainable neighbourhoods require a range of community facilities, and each district/neighbourhood will need to be considered within its own wider locality, as some facilities may be available in the wider area while others will need to be provided locally. The proposed development provides retail / café / restaurant and local supermarket at ground floor level. In addition, a community centre and creche will be provided within the development. The proposed land uses will form part of the neighbourhood centre in accordance with the Z3 zoning objective on the site The subject lands are located adjacent to Public Transport Corridors in the context of the densities required under the Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (2009). These areas are defined as being located within 500 metres walking distance of a bus stop, or within 1km of a light rail stop or a rail station The subject site is located within 200m walking distance of a bus stop and a proposed BRT route connecting Blanchardstown to UCD. The proposed development is also approximately 600m from proposed Cabra station on the Luas Cross City line Section 5.8 of the Guidelines recommends that in general, minimum net densities of 50 dwellings per hectare, subject to appropriate design and amenity standards, should be applied within public transport corridors, with the highest densities being located at rail stations / bus stops, and decreasing with distance away from such nodes. The proposed density of the site is c.108 no. units per hectare The proposed density is in excess of the recommended minimum of 50 units per hectare. The subject site is located on a number of high quality public transport routes (Luas, Bus, proposed BRT) and is located within an existing district centre therefore has the capacity to achieve higher densities to complement the surrounding services. The proposed density is therefore considered appropriate due to the location adjacent to high quality public transport provision, the existing urban environment and context of the site The guidelines clearly state that increased densities should be provided on site within 500m of a bus stop and within 1km of a proposed light rail stop. The subject John Spain Associates 21 Planning and Development Consultants

22 development fits within this criteria, therefore is considered appropriate for higher densities It is clear that it is national policy to promote increased densities in excess of 50 no. units per hectare on zoned lands adjacent to public transport corridors. To achieve this increased density in a sustainable manner requires increased building heights to make the most of the zoned residential lands. As such, in order to sustainably deliver increased densities for residential development within existing urban areas, within increasing urban sprawl then increased heights must be considered in appropriate locations In response to the national policy initiatives, the proposed development provides for an appropriate density at c. 108 no. units per hectare which can only be achieve through the provision of increased building heights up to 8 no. storeys, 24m. It is considered that if the proposed development should comply with the national policies for increased densities in close proximity to high quality public transport services, then an increased height up to 24m in accordance with the Building Height objective for Rail nodes (including Luas stops) within the Dublin City Development Plan should also be applied. As such, it is considered that the proposed building height of up to 24m, 8 no. storeys and density of 108 no. units per hectare proposed is appropriate for the subject site and in compliance with National Policy The proposed development incorporates design principles such as c. 484 no. bicycle parking spaces, and pedestrian links connecting the proposed development with the existing urban area at both Carnlough Road and Faussagh Avenue and to the adjacent public transport corridors. The proposed pedestrian and cycle links enable easy access through the site and to the existing services and facilities within the area in line with the sustainable development policies The layout is highly accessible for future occupants as well as the existing community with a permeable layout both internally and externally as new linkages are provided to surrounding land uses. The layout is considered to be legible, with a clear distinction in design, character and treatment between distributor, local and shared surface streets The Guidelines also provide advice on the core principles of urban design when creating places of high quality and distinct identity. The Guidelines are accompanied by a Design Manual which demonstrates how design principles can be applied in the design and layout of new residential developments, at a variety of scale of development and in various settings In respect to pre-application consultations with the Planning Authority the design team had regard to the advice set down in the In Practice section of the Urban Design Manual (2009), which recommends the following approach: 5.55 Development Brief: An analysis of the site has been carried out which includes reviewing the local development plan, flooding information, utilities and services etc Site Analysis: The characteristics of the subject lands and surrounding context has been established and potential linkages and vistas to adjoining lands has been analysed Concept Proposals: This planning application is accompanied by a Design Statement which outlines the concept design proposal. The Design Statement outlines the John Spain Associates 22 Planning and Development Consultants

23 progression of the scheme design in terms of land use and density range, boundary conditions and connections which is discussed in greater detail below Pre-planning: Extensive pre planning discussions were held with Dublin City Council. Details of these meetings are detailed in appendix 1 of this Statement of Consistency The Design Manual sets out a series of 12 criteria which it recommends should be used in the assessment of planning applications and appeals. The 12 criteria are discussed in detail below This pre-application consultation request is accompanied by a Design Statement, prepared by Plus Architects, which demonstrates how the proposed development has regard to and has been developed in accordance with best practice in respect to urban design. The Design Statement should be read in conjunction with this Statement of Consistency and with the plans and particulars accompanying this submission. Urban Design Manual A Best Practice Guide (2009) 5.61 The Design Manual sets out a series of 12 criteria which it recommends should be used in the assessment of planning applications and appeals. The 12 no. criteria are assessed as follows: Context: How does the development respond to its surroundings? 5.62 Response: The subject site is infill brownfield site located within an existing residential urban area and in close proximity to a number of public transport routes including Dublin Bus route along the Cabra Road, a proposed BRT along the Old Cabra Road and within 600m of the Luas Cross City Line The Urban Design Manual outlines that a development should evolve naturally as part of its surroundings, and increases in density should respect the form of buildings around the site s edges. The Manual also recommends that the development should positively contribute to the character and identity of a neighbourhood; and should present appropriate responses to the nature of specific boundary conditions The proposed layout and design responds to the immediate context through the careful siting and positioning of the building footprint and respect for existing residential areas. The proposed development has been designed to respond to the existing character of the area and the specific site constraints. In keeping with the overall building form of the area the proposed development ranges in height from 2 no. storeys similar to the surrounding residential properties to the west on Carnlough Road to 8 no. storeys along the eastern boundary with the railway line which provides the context for additional height along the eastern boundary and the residences located further to the east on the other side of the railway line (on Quarry Road), which includes a four storey apartment buildings with setbacks to five storeys The proposed height and urban form of the overall development relates to the existing urban context in a positive manner stepping down in height at appropriate locations to the west to make a more appropriate transition and scale to the development towards existing properties The layout of the proposed dwellings links the proposed streets and spaces through the architectural design and overall landscaping of the development. The John Spain Associates 23 Planning and Development Consultants

24 development provides for suitable separation distances to adjoining properties and provides appropriate boundary treatments on site to protect the residential amenity and landscape character of the area The development will be finished in materials of a high quality design to ensure it represents its own character while at the same time integrate with the existing local character of the area. Connections: How well is the new neighbourhood / site connected? 5.68 Response: The layout of the development will also provide for connections to the Carnlough Road to the south and Faussagh Avenue to the north and will provide for a range of retail units (including a local supermarket) as well as a community centre and crèche which will allow the proposed development to integrate with the existing facilities in the area The internal network of the development will consist of a series of internal roads, shared surfaces, footpaths and cycle routes which will connect which will connect the proposed development with the surrounding area The proposed development will open up the site in terms of accessibility and connectivity within the area and will increase permeability in a north south direction between Carnlough Road to the south and Faussagh Avenue to the north. Inclusivity: How easily can people use and access the development? 5.71 Response: The proposal will include for a new purpose-built access off Carnlough Road near to the junction with the Cabra Road. This new access replaces the existing access of the Cabra Road which is located immediately adjacent to the junction with Carnlogh Road. The proposed access is therefore in a better location to the existing access to the development. The proposed development also includes additional pedestrian and cycle linkage to Faussagh Avenue to the north. This provide good linkages to local service and to the new Luas Cross City station at Cabra The proposed development will provide a variety of vehicle, pedestrian and cycle routes throughout the site. The internal road network provides for a clear navigable route throughout the development with a series of cycle paths and footpaths to increase the overall level of connectivity and permeability for future residents The development will provide for disabled car parking spaces and all communal areas and house types are designed to be accessible to all. Variety: How does the development promote a good mix of activities? 5.74 Response: The proposed development includes a community centre, retail units including a local supermarket as well as a crèche and a high quality network of public open space. It is considered that the proposed development provides for the necessary ancillary land uses required for this new residential community, whilst having regard to the significant range of community, commercial and social infrastructure in the immediately surrounding area, which are readily accessible e.g. Tesco, Spar as well as Library located to the south on the Navan Road The proposed community centre space will provide for a range of activities which will benefit the area such as for example fitness classes, yoga, dance classes and other John Spain Associates 24 Planning and Development Consultants

25 related activities. The community centre could also be utilised for other social events such as community gatherings, meeting and functions The proposed development also provides for a sustainable mix of dwellings which will attract a range of new occupiers in of different life cycle stages. The proposed residential development provides for a mix of 1 no., 2 no. and 3 no. bedroom units varying in size and style to accommodate a range of occupants. Efficiency: How does the development make appropriate use of resources, including land? 5.77 Response: The proposed development is located on a predominant vacant infill site in an existing urban area. The proposed density of the site is 108 no. units per hectare makes efficient use of these valuable mixed use residential zoned lands and includes an appropriate quantum of public open space, connectivity to the existing high quality public transport network and a range of retail and community uses The proposed density is in excess of the recommended minimum of 50 units per hectare. The subject site is located on a high quality public transport route and is located within an existing district centre therefore has the capacity to achieve higher densities to complement the surrounding services. The proposed density is therefore considered appropriate due to the location adjacent to high quality public transport provision, the existing urban environment and context of the site The layout and orientation of the scheme has been designed Plus Architecture to have regard to aspect and views and ensure dwellings and areas of open space achieve light throughout the day. Distinctiveness: How do the proposals create a sense of place? 5.80 Response: The proposed development will foster a strong sense of place through the carefully considered mixture of uses and the high quality of design exhibited throughout the development. Streets and public areas will benefit from carefully considered landscaping and planting, while busier public areas such as the proposed neighbourhood centre will include high quality hard and soft landscaping The sense of place will be strengthened by the inclusion of extensive areas of active and passive green space for the enjoyment of residents and others, all of which will benefit from passive surveillance from surrounding residential units to encourage a safe sense of place, discourage anti-social behaviour and facilitate effective community policing. Strong visual and physical connections are prioritised between the propose residential units and the proposed recreational areas, open spaces and other uses, while secondary connections will link the scheme with the surrounding areas including schools, shops and other community facilities The proposed scheme is designed to provide a distinctive sense of place through appropriate architectural detailing to assist in the respectful integration of the external building facades including the modulation of openings and fenestration in a manner that harmonises with current local proportions and rhythms. In addition the proposal will provide a sensitively considered soft landscape design for the development, which assists in the integration and screening of the buildings within the existing context The proposed development will provide for a series of landscaped areas. These areas will each have a separate designated purpose within the scheme. The John Spain Associates 25 Planning and Development Consultants

26 proposed development will provide for a south facing public space which will include a five a side pitch as well as active open space for children. Other open space areas are of high quality and more contemplative areas which can cater for older persons of the new residential community The proposed development will also provide for a mix of unit sizes, and useable active open space area. There is a variety and mix of unit types, heights and design, with a mix of apartment buildings and houses, proposed throughout the scheme, thereby providing a good sense of place on site The proposed development will also provide for a civic outdoor amenity space which will act as a new focal point within the retail area and will create a strong sense of place and identity for the new residential community in this portion of the subject site linking the retail to the community building. Layout: How does the proposal create people-friendly streets and spaces? 5.86 The Urban Design Manual states that how the site is laid out is one of the key determinants of successful places, and that the layout of a neighbourhood can help to determine an area s character and sense of place. Positive indicators include a permeable interconnected series of routes that are easy and logical to navigate around, active street frontages with front doors directly serving the street, traffic speeds controlled by design and careful location of public and communal open spaces Response: The proposed layout of the development provides for a straightforward, easily accessible and easily navigable network of places. The access arrangement creates an easily accessible development and improves the connectivity of the site with the surrounding area Defensible space has been accommodated in the masterplan at a minimum of 2m deep and should be provided where ground floor residential uses are proposed. This is to give privacy and security to residents in ground floor units. The boundary between ground floor defensible and amenity space to ground floor residential accommodation and the public realm should be constructed from a combination of a wall or railing with a planted structure, with reference to Secured By Design standards and recommendations The proposed masterplan provides for a legible, permeable layout together with a varied use of materials and finishes, engender a definitive sense of place in a new residential community. The structure of the masterplan is based on the principles of best practice urban design including permeability, connectivity and legibility as set out above. Public Realm: How safe, secure and enjoyable are the public areas? 5.90 Response: The development also includes the provision of 4,507 sq.m. (12%) of public open space and 3,039 sq.m. of communal open space in total spread throughout the scheme which include, playground, passive recreational space and active recreational space The layout and design of the proposed development has been influenced by the level of security and overlooking to be provided by the future residents. The design of the development has been carefully considered so as to provide a high level of passive surveillance on both the area of open space and public access areas. The design of John Spain Associates 26 Planning and Development Consultants

27 the dwellings provide for a direct frontage onto all public areas ensuring the provision of a safe, secure and enjoyable residential development The location layout and usability of the proposed public open spaces are of the highest quality and will contribute positively to the residential amenity of future residents. The open space provision for the entire scheme was carefully considered by the design team. The landscaping proposals have been formulated having careful regard to the surrounding development, to the aspect within the public open space areas and to the recreational needs of the future residents of the proposed development The proposed four main areas of open space has also taken into account the requirement for passive surveillance and have been designed to ensure a number of the residential units overlook this space. The location of the play space areas ensures that it is adequately overlooked by residential units to ensure a safe and secure environment is maintained An outdoor civic space (Carnlough Square) will also be provided. This will act as a focal space for the retail/community space and the new residential community. This proposed civic space will be overlooked by the public road way and the community building It is therefore considered that the proposed design and layout of the overall development provides for a high quality safe and enjoyable area to reside. Adaptability: How will the buildings cope with change? 5.96 Response: In relation to the proposed residential units, all of the dwellings meet or exceed the minimum standards for residential unit size. The development provides a mix of 1, 2, and 3 bedroom units that can be easily reconfigured to adapt to the changing life cycles and personal needs of each resident The overall architectural style is contemporary and reflects the modern requirements to balance lighter, airier elevations with the need to satisfy energy reducing objectives. Similarly, all proposed house types incorporate generous space standards so as to provide for adaptable living requirements. Privacy / Amenity: How do the buildings provide a high quality amenity? 5.98 Response: In relation to the apartment element of the scheme, each unit is provided with an area of useable private open space in the form of a terrace or balcony which meets or exceeds the relevant apartment guidelines standards. All of the dwellings meet or exceed the Section 28 Guidelines unit size requirements. The design of dwellings has also had due regard to the siting and orientation of the development in order to maximise the solar gain and natural light aspect of each dwelling The development provides for adequate separate distances between dwellings. This maintains a high level of privacy and amenity obtained by residents, and reduces the level of overlooking and overshadowing. Parking: How will the parking be secure and attractive? Response: A total of 402 no. car parking spaces (374 no at basement levels (298 no. to serve the residential units and 76 no. to serve the retail units) and 28 no. at surface level (20 no. to serve the residential units and 8 no. to serve the retail units) John Spain Associates 27 Planning and Development Consultants

28 and 484 no. bicycle parking spaces (368 no. at basement level and 116 no. at surface level) The proposed development is located approximately 600km from the Cabra LUAS station which will allow good access to the new development to the wider rail network which allow for reverse community to also take place. Therefore, the proposed development will be well served by connections to LUAS and the wider rail network The objective is to provide a sustainable level of car parking having regard to the location of the subject site in close proximity to the city centre and is excellently served by LUAS and numerous bus routes. Detailed Design: How well thought through is the building and landscape design? Response: The proposed design of the development has been subject to a number of pre-application consultations between the design team and the Planning Authority The designed scheme seeks to harmonise and integrate the development within the existing landscape and the broader community. The design rationale employed mitigates potential negative effects on the landscape character of the area by: Providing specific built facilities for the overall community including: a community centre; crèche; and shops; The introduction of significant public through routes for cyclists and pedestrians, directly linking Faussagh Avenue with the southern end of Carnlough Road and the Cabra Road. The inclusion of public open spaces including play facilities and a communal garden/allotments area within the scheme design which will have a very positive impact on the both new and existing communities and serve to help in socially linking the two It is considered that the proposed scheme makes best use of the strategically located on a vacant brown field site and makes appropriate response to the site characteristics and zoning The landscape strategy aims to integrate the new built development with the existing landscape and create a high quality public realm incorporating a significant civic space. Throughout the scheme a series of attractive and usable open spaces are creates that respond to the needs of the anticipated users Given the subject site s current vacant condition and the well-considered design, the proposed development represents a significant positive impact on the existing local environment. The proposed community facilities within the scheme, its open spaces, play areas and the public permeability designed into it offer significant benefits for the broader area as well as for the proposed new development itself In all the open spaces the levels have been carefully considered to accommodate easy circulation and create suitably flat areas for activities and uses. Careful consideration of the levels within the site have been central to the site and landscape design with the aim to provide for universal access, wherever possible. John Spain Associates 28 Planning and Development Consultants

29 Delivering Homes, Sustaining Communities (2008) The Department s policy statement Delivering Homes, Sustaining Communities, Guidance provides the overarching policy framework for an integrated approach to housing and planning. The statement notes that demographic factors will continue to underpin strong demand for housing, which in turn will present considerable challenges for the physical planning of new housing and the provision of associated services. The quality of the housing environment is stated as being central to creating a sustainable community Sustainable neighbourhoods are areas where an efficient use of land, high quality design, and effective integration in the provision of physical and social infrastructure combine to create places people want to live in The Delivering Homes, Sustaining Communities policy statement is accompanied by Best Practice Guidelines entitled Quality Housing for Sustainable Communities. The purpose of these Guidelines is to promote high standards in the design and construction and in the provision of residential and services in new housing schemes. They encourage best use of building land and optimal utilisation of services and infrastructure in the provision of new housing; point the way to cost effective options for housing design that go beyond minimum codes and standards; promote higher standards of environmental performance and durability in housing construction; seek to ensure that residents of new housing scheme enjoy the benefits of first-rate living conditions in a healthy, accessible and visually attractive environment; and provide homes and communities that may be easily managed and maintained This planning application is accompanied by a Housing Quality Assessment document prepared by Plus Architecture which demonstrates the consistency of the proposed development with the relevant standards in the Quality Housing for Sustainable Communities document and the County Development Plan where relevant. Design Manual for Urban Roads and Streets (DMURS) (2013) The Design Manual for Urban Roads and Streets (DMURS), 2013, sets out design guidance and standards for constructing new and reconfiguring existing urban roads and streets in Ireland. It also outlines practical design measures to encourage more sustainable travel patterns in urban areas DMURS aims to end the practice of designing streets as traffic corridors, and instead focus on the needs of pedestrians, cyclists, and public transport users. The Manual sets out design guidance and standards for constructing new and reconfiguring existing urban roads and streets in Ireland. Incorporating good planning and design practice and focus on the public realm, it also outlines practical design measures to encourage more sustainable travel patterns in urban areas. The principle design guidance of DMURS has been considered in the design of this development. As demonstrated in the Design Statement and Planning Report accompanying this consultation request, the proposed development seeks to prioritise pedestrian and cyclists throughout and around the site in accordance with the policies set out in DMURS DMURS notes that permeable layouts provide more frequent junctions which have a traffic calming effect as drivers slow and show greater levels of caution. The proposed development promotes pedestrian links and connections within the site, thus linking both the future residents and the wider community to key public transport John Spain Associates 29 Planning and Development Consultants

30 routes. The proposed development also provides for 444 no. bicycle parking spaces which will encourage and emphasise sustainable modes of transport within the development. Guidelines for Planning Authorities on Childcare Facilities (2001) Guidelines for Planning Authorities on Childcare Facilities (2001) indicate that Development Plans should facilitate the provision of childcare facilities in appropriate locations. These include larger new housing estates where planning authorities should require the provision of a minimum of one childcare facility with 20 places for each 75 dwellings. The threshold for provision should be established having regard to existing location of facilities and the emerging demography of the area where new housing is proposed. The Guidelines advise that sites should be identified for such facilities as an integral part of the pre-planning discussions The proposed development at 402 no. units therefore sets a requirement of 112 no. childcare spaces. However, for the purpose of this assessment, it is considered that 1 bed units should be discounted from this calculation due to the single nature of the unit. Therefore, taking only the proposed 2 and 3 no. bed units (326 no. units), the proposed development would result is a requirement for 86 no. childcare spaces The following definition of Childcare is included in the Guidelines: In these Guidelines, "childcare" is taken to mean full day-care and sessional facilities and services for pre-school children and school-going children out of school hours. It includes services involving care, education and socialisation opportunities for children. Thus services such as pre-schools, naíonraí (Irish language playgroups), day-care services, crèches, playgroups, and after-school groups are encompassed by these Guidelines. Conversely childminding, schools, (primary, secondary and special) and residential centres for children are not covered by these Guidelines The proposed development will provide for a creche of sq.m. Based on the average requirement of 3-5sq.m. per child, the proposed creche can accommodate up to approximately 65 no no. childcare spaces which is considered to adequately meet the requirement generated by the proposed development. Smarter Travel A Sustainable Transport Future: A New Transport Policy for Ireland The Government has committed in Smarter Travel A Sustainable Transport Future: A New Transport Policy for Ireland to reducing the total share of car commuting from 65% to 45%, a rise in non-car trips by 55% and that the total vehicle miles travelled by the car fleet will not increase. The key targets are as follows: John Spain Associates 30 Planning and Development Consultants

31 Future population employment growths will predominantly take place in sustainable compact forms which reduces the need to travel for employment and services; 500,000 more people will take alternative means to commute to work to the extent that the total share of car commuting will drop from 65% to 45%; Alternatives such as walking, cycling and public transport will be supported and provided to the extent that these will rise to 55% of total commuter journeys to work; The total kilometres travelled by the car fleet in 2020 will not increase significantly from current levels; A reduction will be achieved on the 2005 figure for Greenhouse gas emissions from the transport sector Key to the achievement of these targets is better alignment between land-use and transport to minimise travel demand. The subject site is located adjacent to a Dublin Bus route along the Cabra Road, a proposed BRT line linking Blanchardstown to UCD and is within 600m of the Luas Cross City line. Thus, the principle of a residential development at a density in excess of 50 units per hectare in this location would be in accordance with the principles set down in Smarter Travel. Transport Strategy for the Greater Dublin Area This strategy has been prepared by the National Transport Authority. The Vision of this strategy is for Dublin to be a competitive, sustainable city-region with a good quality of life for all by The Strategy includes five overarching objectives to achieve the vision which are as follows: Build and strengthen communities Improve economic competitiveness Improve the built environment Respect and sustain the natural environment Reduce personal stress The Strategy sets out measures to achieve the vision and objectives for the GDA. These include better integration of land use planning and transportation, consolidating growth in identified centres, providing more intensive development in designated town and district centres and control parking supply The strategy builds on previous strategies and investment programmes, and for this reason several major infrastructure schemes that are included in the government s Transport 21 investment framework are included in all of the strategy options The proposed residential development, which provides for a density in excess of 100 no. units per hectare, adjacent to existing good quality public transport, in particular the Dublin Bus Corridor along Cabra Road, the proposed BRT along the Old Cabra Road and the proximity to the Luas (600m) is considered to be consistent with the vision and objectives of the Transport Strategy for the GDA. John Spain Associates 31 Planning and Development Consultants

32 Guidelines for Planning Authorities on The Planning System and Flood Risk Management (November 2009) The Planning System and Flood Risk Management Guidelines were published by the Minister for the Environment, Heritage & Local Government in November 2009 under Section 28 of the Planning & Development Act 2000 (as amended). The Planning system and flood risk management guidelines require the planning system at all levels to avoid development in areas at risk of flooding, particularly floodplains, unless there are proven wider sustainability grounds that justify appropriate development and where the flood risk can be reduced or managed to an acceptable level without increasing flood risk elsewhere; adopt a sequential approach to flood risk management when assessing the location for new development based on avoidance, reduction and mitigation of flood risk; and incorporate flood risk assessment into the process of making decisions on planning applications and planning appeals The SSFRA was prepared to comply with current planning legislation, in particular the recommendations of The Planning System & Flood Risk Management - Guidelines for Planning Authorities. In order to comply with these Guidelines a Flood Risk Assessment and a Site Specific Flood Risk Assessment has been prepared by JBA Consulting Engineers The purpose of the Guidelines is to introduce comprehensive mechanisms for the incorporation of flood risk identification, assessment and management into the planning process. The document goes on to state that: Planning authorities will ensure that only developments consistent with the overall policy and technical approaches of these Guidelines will be approved and permission will be refused where flood issues have not been, or cannot be, addressed successfully and where the presence of unacceptable residual flood risks to the development, its occupants or users and adjoining property remains The Guidelines outline two Justification Test processes by which development proposals considered to be in areas of moderate or high flood risk should be assessed by planning authorities. The Plan-Making Justification Test should be applied by a planning authority at the plan preparation and adoption stage where it is intended to zone or otherwise designate land for development which is at moderate or high risk of flooding. The Development Management Justification Test is applied when the planning authority is considering a planning application for development in an area which may be vulnerable to flooding The Guidelines identify three geographical areas known as Flood Zones within which the likelihood of flooding is in a particular range. These zones are seen as a key tool in flood risk management. The three types or levels of flood zones are defined as follows: Flood Zone A where the probability of flooding from rivers and the sea is highest (greater than 1% or 1 in 100 for river flooding or 0.5% or 1 in 200 for coastal flooding); Flood Zone B where the probability of flooding from rivers and the sea is moderate (between 0.1% or 1 in 1000 and 1% or 1 in 100 for river flooding and between 0.1% or 1 in 1000 year and 0.5% or 1 in 200 for coastal flooding); and Flood Zone C where the probability of flooding from rivers and the sea is low (less than 0.1% or 1 in 1000 for both river and coastal flooding). Flood Zone C covers all areas of the plan which are not in zones A or B. John Spain Associates 32 Planning and Development Consultants

33 5.132 In order to comply with these Guidelines a Site Specific Flood Risk Assessment has been prepared by OCSC Consulting Engineers and is submitted with this application The report concludes that the subject site is outside the area of potential risk for fluvial flooding. The available data shows that the site is outside the area of potential risk for tidal flooding The available data on pluvial flooding and overland flow has been assessed and mitigation measures have been proposed. The existing water services infrastructure provides a risk of flooding if it was to fail. However, if this was to occur it would become overland flow and so would be dealt with in a similar fashion to pluvial flooding The flood risk represented by ground water is negligible and no further mitigation is required In line with the Planning Guidelines the detailed FRA has applied and passed the Justification Test. As a result, it is concluded that the site is in compliance with the core principles of the Planning System and Flood Risk Management Guidelines and has been subject to a commensurate assessment of risk. Birds and Habitats Directive Appropriate Assessment Under Article 6 (3) of the EU Habitat Directive and Regulation 30 of SI no. 94/1997 European Communities (Natural Habitats) Regulations (1997) any plan or project which has the potential to significantly impact on the integrity of a Natura 200 site (i.e. SAC or SPA) must be subject to an Appropriate Assessment. This requirement is also detailed under in the Planning and Development Acts ( ) An Appropriate Assessment Screening Report, prepared by Roger Goodwille, is submitted with this planning application. The report establishes that none of the habitats and species listed as qualifying features in the Natura 2000 site designations will be affected by the proposed development and it has been assessed that the development of the project will not result in any likely significant effects on Natura 2000 sites. The Report concludes that there will be no risk of significant negative effects on any Natura 2000 site, as a result of the proposed development, either alone or in combination with other plans or projects, and therefore, Stage 2 of the Appropriate Assessment Process, a Natura Impact Statement, is not required In addition, an Environmental Impact Assessment Screening Statement has been prepared to accompany this planning application. The Environmental Report ruled out the requirement of an EIAR in respect of the proposed development as it is sub threshold. Retail Planning Guidelines (2012) The Department of Environment, Heritage and Local Government published Retail Planning Guidelines in April The aim of the Guidelines is to ensure that the planning system continues to play a key role in supporting competitiveness in the retail sector for the benefit of the consumer in accordance with proper planning and sustainable development. John Spain Associates 33 Planning and Development Consultants

34 5.141 The Guidelines emphasise that enhancing the vitality and viability of city and town centres in all their functions through sequential development is an overarching objective in retail planning The Guidelines have five key policy objectives, namely: Ensuring that retail development is plan-led; Promoting city/town centre vitality through a sequential approach to development; Securing competitiveness in the retail sector by actively enabling good quality development proposals to come forward in suitable locations; Facilitating a shift towards increased access to retailing by public transport, cycling and walking in accordance with the Smarter Travel Strategy; and Delivering quality urban design outcomes With regard the sequential test, the guidelines state: The order of priority for the sequential approach is to locate retail development in the city/town centre (and district centre if appropriate), and only to allow retail development in edge of centre or out of centre locations where all other options have been exhausted. The promotion of a critical mass in city and town centres through the location of appropriate retail and other complementary uses within and adjoining their prime shopping areas will contribute significantly to the vibrancy and vitality of such centres The subject site is located within a defined neighbourhood centre under the Z3 zoning objective centre and thus is an appropriate location for further retail and commercial floorspace. John Spain Associates 34 Planning and Development Consultants

35 6.0 LOCAL PLANNING POLICY AND ASSESSMENT 6.1 The application site is located within the Dublin City Council administrative boundary therefore is subject to the policies and objectives of the Dublin City Development Plan The relevant policies are set out in this section. Zoning Objective 6.2 The subject application site is located across two zoning objectives, Z1 (Sustainable Residential Neighbourhoods) in the northern portion, and Z3 (Neighbourhood Centres) in the southern portion. 6.3 The Z1 zoning objective is to protect, provide and improve residential amenities. Residential is a use listed as being permissible on Z1 zoned lands. 6.4 The Z3 zoning objective is to provide for and improve neighbourhood facilities. Residential, childcare facility, community facility, part off-licence and shop (neighbourhood) are listed as permissible uses. 6.5 The development plan states that the neighbourhood centres should provide for local facilities such as convenience shops, hairdressers, hardware etc. These local centres may also be anchored by a supermarket type development of between 1,000 sq.m. and 2,500 sq,m, of net retail floorspace. They are form a focal point for a neighbourhood and provide a limited range of services to the local population within 5 minutes walking distance. Neighbourhood centres provide an essential and sustainable amenity for residential area and it is important that they should be maintained and strengthened where necessary. Neighbourhood centres may include an element of house, particularly at higher densities, and above ground floor level. 6.6 The proposed mixed use development for residential and retail, including supermarket with ancillary off -licence are therefore in compliance with the zoning objectives on the application site. John Spain Associates 35 Planning and Development Consultants

36 Figure 2: Extract of Zoning Map E Dublin City Development Plan John Spain Associates 36 Planning and Development Consultants

37 Height 6.7 Dublin City Council Height Strategy sets out a building height of 16m for residential development in the outer city. Blocks B, C, E, and G are 4 no. storeys and approximately 12m in height which is in accordance with the height policy for the area. The Community Building is part single part 2 no. storeys and approximately 8.2 m in height which is also in accordance with the height policy. 6.8 The remainder of the buildings on site range in height from 2 no. storeys to 8 no. storeys, approximately 24m. Block A ranges in height from 4 no. storeys to 8 no. storeys, c. 24m, Block D ranges in height from 2 no. storeys to 8 no. storeys, c. 24m and Block F ranges in height from 2 no. storeys to 8 no. storeys, c. 24m. 6.9 The development plan sets out that building height up to 24m will be permitted in areas within 500m of existing and proposed Luas, mainline, DART, DART Underground and Metro Stations. The subject site is located approximately c.600m (by direct line) from the Cabra stop on the Luas Cross City Line, which is just outside the 500m catchment. Location of Subject Site Figure 3: Extract from Luas Cross City route map 6.10 However, it should be noted that the Section 49 Special Development Contribution Scheme for the Luas Cross City applies to areas within a 1km catchment of the proposed Luas line. It is considered that if the proposed development is within the catchment to which the development contribution applies to facilitate for the Luas Cross City works, then the same policies should apply to the site as areas within the Rail Hub catchment (500 m from existing and proposed Luas) which would allow a height of up to 24m at this location. John Spain Associates 37 Planning and Development Consultants

38 Location of Subject Site Figure 4: Extract from the Section 29 Luas Cross City Development Contribution Scheme Map 6.11 In addition, the subject site is located adjacent to a proposed BRT which will link Blanchardstown to UCD. BRT s are not listed as a category for increased heights of up to 24m. However, the service that is provided will be as efficient and direct as the proposed Luas line. As such, it is considered that due to the abundance of public transport services within the proximity of the site, the location of the site within the Section 49 Development Contribution catchment, and the clear directive in Government Policy to provide for increased densities in location adjacent to quality public transport nodes, that the proposed building height of 24m is appropriate for this location. John Spain Associates 38 Planning and Development Consultants

39 Location of Subject Site Figure 5: Extract of Proposed BRT route from Blanchardstown to UCD Residential Development Standards Residential Development Houses 6.12 Section of the Development Plan outlines a number of standards for residential developments. The following standards are of relevance to the subject site Private Open Space 6.13 A minimum standard of 10 sq.m. private open space per bed space will normally be applied by way of private gardens to the rear or side of a house. A single bedroom represents one bed space and a double bedroom represents two bed spaces. Generally, up to sq.m. of rear garden area is considered sufficient for houses in the city The proposed house unit at No. 4 Carnlough Road will provide 63 sq.m. of private open space which is in accordance with the standard sq.m. as noted in the development plan. John Spain Associates 39 Planning and Development Consultants

40 Separation Distances 6.15 At the rear of dwellings, there should be adequate separation between opposing first floor windows. A separation of 22m is offered roughly between the rear of 2 storey dwellings but this may be relaxed if it can be demonstrated that the development is designed in such a way as to preserve the amenities and privacy of adjacent occupiers. Careful positioning and detailed design of opposing windows can prevent overlooking with shorter back to back distances and windows serving halls and landings do not require the same degree of privacy as habitable rooms The proposed residential dwelling is a replacement of previously existing houses at No. 2 and No. 4 Carnlough Road. The proposed unit follows the existing building line of development on Carnlough Road The community building is located at the closest point 7.6m from the rear of the existing residential units and 17.3m at a max. The community building is single storey in height at this location therefore does not create any significant overbearing impact on the proposed and existing residential units along Carnlough Road. Residential Development - Apartments 6.18 Section of the Dublin City Development Plan sets outs the standards for apartments which are based upon the apartment standards set out in the Department of Environment, Community and Local Government Guidelines entitled Sustainable Urban Housing; Design Standards for New Apartments Guidelines for Planning Authorities (December 2015) The Housing Quality Assessment submitted with this planning application sets out compliance with the guidelines for apartment standards. Dual Aspect 6.20 Dual aspect apartments maximise the availability of sunlight and should be provided where possible. It is a specific planning policy requirement in the 2015 Department Guidelines that the minimum number of dual aspect apartments that may be provided in any single apartment scheme shall be 50%. In certain circumstances, usually on inner urban sites, this may be further reduced to an absolute minimum of 33% where it is necessary to ensure good street frontage and subject to a high quality design. Ideally 3 bedroom apartments should be dual aspect Where single aspect apartments are provided, the provision of south facing units should be maximised with west or east facing single aspect units also being acceptable. Living spaces in apartments should provide for direct sunlight for some part of the day. North facing single aspect apartments may be considered, where overlooking a significant amenity such as a public park, garden or formal space, or a water body or some other amenity feature. Particular care is needed where windows are located on lower floors that may be overshadowed by adjoining buildings and/or balconies The proposed development provides for 64.4% of dual aspect units which is in accordance with the standards set out in the development plan. John Spain Associates 40 Planning and Development Consultants

41 Open Space Private Open Space 6.23 Private open space shall be provided in the form of gardens or patios/ terraces for ground floor apartments and balconies at upper levels. The primary balcony should be located adjacent to the main living areas to extend the apartments living space. The minimum depth of private amenity open space (balcony or patio) shall be 1.5m and the minimum size shall be as follows: Studio unit: 4 sq.m. 1-bedroom unit: 5 sq.m 2-bedroom unit: 7 sq.m. 3-bedroom unit: 9 sq.m All of the proposed apartment units meet or exceed the private open space standards. Full compliance is set out in the HQA which is submitted as part of this planning application. Communal Open Space 6.25 In addition to providing private open space, new apartments schemes must also provide for communal open space. This may be in the form of sheltered roof gardens, communal landscaped areas at ground floor level. Communal open space is calculated at the following rate: Studio unit: 4 sq.m. 1-bedroom unit: 5 sq.m 2-bedroom unit: 7 sq.m. 3-bedroom unit: 9 sq.m Development proposals shall also demonstrate that the communal open space complies with the objectives set out below: Will be soft and/or hard landscaped with appropriate plant species and landscaping materials such as those with good resistance to accidental damage and low maintenance characteristics Is secure for residents and benefits from passive surveillance Considers the needs of children in particular in terms of safety and supervision. In schemes of 25 or more units small play spaces of sq.m. are considered suitable for toddlers and children up to the age of six, with suitable play equipment, seating for parents/ guardians, and within sight of the apartment building. For larger schemes of 100 or more apartments, play areas of sq.m. for older children and young teenagers should be provided. Is wheelchair accessible Achieves good sunlight penetration Have appropriate arrangements for maintenance and management such as a conveniently accessed garden maintenance and storage area with water and drainage connections The proposed development will provide for 3,039sq.m. of communal open space in excess of the minimum standards (2,888 sq.m.). Full details of the landscaping of the John Spain Associates 41 Planning and Development Consultants

42 open space is provided in the landscape report prepared by Plus Architecture included within the Design Statement. Unit Mix 6.28 The Development Plan sets out specific guidance in terms of unit mix. The plan states that no more than 25-30% 1 bed units should be provided and no less 15% than of the units should be provided as 3 bed units The proposed development provide for 93 no. 1 bed units (22%), 260 no. 2 bed units (62%) and 66 no. 3 bed units (16%) which is consistent with the Development Plan requirement. Density 6.30 There is no specific guidance in terms of density set out in the development plan. The proposed development provides for a density of 108 units per hectare in accordance with national and regional policies which promotes increased densities for site located along public transport routes. Childcare Facilities 6.31 The Development Plan states that for new residential developments, one childcare facility should be provided unless there are significant reasons to the contrary. A benchmark provision of one childcare facility per 75 no. dwellings (and a pro-rata increase for developments in excess of seventy five houses) Any modification to the indicative standard of one childcare facility per 75 no. dwellings should have regard to the following relevant criteria: The make up of the proposed residential area, i.e. an estimate of the mix of community that the housing area seeks to accommodate (if an assumption is made that 50% approximately of the housing area will require childcare, then in a new housing area of 75 no. dwellings, approximately 35 no. will need childcare. One facility providing a minimum of 20 childcare places is, therefore, considered to be a reasonable starting point on this assumption. Other assumptions may lead to an increase or decrease in this requirement). The results of any childcare needs analysis carried out as part of the city childcare strategy or carried out as part of the development plan in consultation with the city childcare committees, which will have identified areas already served or alternatively, gap areas where there is under provision, will also contribute to refining the base figure. This is a guidance standard and will depend of the particular circumstances of each individual site. Consideration of childcare facilities should be raised as early as possible in pre-planning discussions for larger housing developments It should be noted that the Section 28 Apartment Guidelines 2015 state that: Notwithstanding the Department s Planning Guidelines for Childcare Facilities, which are currently subject to review and recommend the provision of one childcare facility (equivalent to a minimum of 20 child places) for every 75 dwelling units, the threshold for provision in apartment scheme should be established having regard to the scale and unit mix of the proposed development and the existing geographical distribution of childcare facilities and the emerging demographic profile for the area. John Spain Associates 42 Planning and Development Consultants

43 6.34 The proposed development at 402 no. units therefore sets a requirement of 112 no. childcare spaces. However, for the purpose of this assessment, it is considered that 1 bed units should be discounted from this calculation due to the single nature of the unit. Therefore, taking only the proposed 2 and 3 no. bed units (326 no. units), the proposed development would result is a requirement for 86 no. childcare spaces It should also be noted that the Draft Sustainable Urban Housing: Design Standards for New Apartment; Guidelines for Planning Authorities 2017 clarify this position noting that One bedroom or studio type units should not generally be considered to contribute to a requirement for any childcare provision and subject to location, this may also apply in part or whole, to units with two or more bedrooms The proposed development will provide for a creche of sq.m. Based on the average requirement of 3-5sq.m. per child, the proposed creche can accommodate up to approximately 65 no no. childcare spaces which is considered to adequately meet the requirement generated by the proposed development Taking into account the high number of childcare facilities in the surrounding area and the generously sized creche provided on site. It is considered that the proposed development adequately meets the future demand. Car Parking / Bicycle Parking 6.38 The subject site is located in zone 2 as indicated in Map J of the Dublin City Development Plan The Development Plan states that a maximum car parking requirement in zone 2 is 1 no. space per residential dwelling; 1 space per 100 sq.m GFA for retail supermarkets exceeding 1,000 sq.m GFA; 1 space per 275 sq.m GFA for other retail and 1 space per 250 sq.m GFA for cultural and recreational buildings The proposed development will provide for a total of 402 no. car parking spaces (374 no at basement levels (298 no. to serve the residential units and 76 no. to serve the retail units) and 28 no. at surface level (20 no. to serve the residential units and 8 no. to serve the retail units) and 484 no. bicycle parking spaces (368 no. at basement level and 116 no. at surface level) 6.41 The proposed bicycle parking is compliance with the development plan standards The rationale for reduced car parking standards is set out within the traffic and transport report prepared by ILTP which accompanies this application. Public Open Space 6.43 Section of the Dublin City Development Plan requires that in new residential developments, 10% of the site area shall be reserved as public open space The proposed development provides for 4,507sq.m. (12%) of public open space which is in excess of the 10% requirement. Off Licence and Part Off Licence 6.45 Section of the Development Plan states that in considering planning application for a part off licence in a shop, the following criteria shall be applied: John Spain Associates 43 Planning and Development Consultants

44 The number and frequency of such facilities within a 1km radius of the proposed development The amenities of properties in the nearby residential areas; The floor area used for the display of alcohol products is subsidiary to the main use of the shop and that area should be no more than 10% of the total floor area; The location of the display area of alcohol products shall be in an unobtrusive position, not near the entrance or windows of the shop and preferable to the rear of the premises; The area for the display of alcohol products shall be detailed on the floor plans and the display of alcohol products shall be limited to this area only; The area for the display of alcohol products should be secure and monitored 6.46 The proposed ancillary off-licence will be located within the anchor convenience supermarket within Block A of the development. The area of the alcohol sales will be limited to 99 sq.m. (6%) and will be located to the rear of the convenience store as delineated on the site layout plan. The provision of alcohol sales is a requirement in modern supermarket convenience stores and is recognised as a standard provision in such supermarkets In addition, an assessment has been carried out to identify all off-licences within a 1km radius of the proposed development. It was established that 4 no. premises are within 1km of the development, therefore it is evident that there is not an overconcentration of such uses in the area. Figure 6: Locations of off-licences within a 500m radius and 1km radius of the subject site 6.48 This justification was previously accepted in the granted of the extant permission on site, Reg. Ref. 2387/16. The Planners Report states that: John Spain Associates 44 Planning and Development Consultants