Statement of Consistency with Planning Policy. Proposed Student Accommodation Development. January 2018

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1 Statement of Consistency with Planning Policy Former "Matts of Cabra" public house and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Proposed Student Accommodation Development Prepared for Labinies Limited by IMG Planning Limited 75 Fitzwilliam Lane Dublin 2 January 2018

2 1. Introduction This statement has been prepared on behalf of Labinies Limited of 24 Lower Baggot Street, Dublin, D02 EW26, to accompany an application to An Bord Pleanála for a proposed strategic housing development on the site of the former "Matts of Cabra" public house and lands to the rear on Fassaugh Avenue, Cabra, Dublin 7. This statement is made in accordance with Section 8 (1) (a) (iv) of the Planning and Development (Housing) and Residential Tenancies Act 2016 and has been prepared in accordance with the requirements of the Planning and Regulations 2001 to 2017 (as amended by Planning and Development (Strategic Housing Development) Regulations 2017) and the Strategic Housing Development: Section 4 Applications to An Bord Pleanála - Guidance for Applicants issued by An Bord Pleanála. This statement demonstrates that the proposed development is consistent with the relevant national, regional and local planning policy and guidelines issued under section 28 of the Planning and Development Acts 2000 to Nature and Extent of the Proposed Development The proposed development comprises: 1. The demolition of the former Matts of Cabra" public house and associated structures 2. The construction of a mixed use development comprising student accommodation consisting of 208 no. ensuite student accommodation bedrooms: 198 no. bedspaces in 32 no. house units (ranging in size between 4 and 8 single bed ensuite rooms) in a linked four and five storey building 10 no. single bed ensuite studio rooms in a three storey building 3. The construction of associated facilities including a central access lobby, a central hub, recreation spaces, administration areas at basement and ground floor levels 4. The construction of sq. m. of retail floor space in 2 no. units fronting onto Fassaugh Avenue sq. m. on the basement, ground and first floors of the four/five storey building and sq. m. on the basement and ground floors of the three storey building 5. The construction of a vehicular access onto Fassaugh Avenue and the provision of a vehicle set down in front of the four/five storey building and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 1

3 6. Other site development works including landscaped gardens and open amenity areas, a roof garden on the Fassaugh Avenue side of the linked four/five storey building, the provision of 9 no. surface car parking spaces (including 1 no. disabled space), 114 no. cycle parking spaces, a covered bin store, an ESB substation and switch room and the formation of a public plaza on the Fassaugh Road frontage including the provision of 2 no. visitor car parking spaces. 3. National and Regional Policy and Guidelines The provisions of national and regional policy, including guidelines issued under section 28, insofar as they relate to the proposed development are set out in the sections that follow. 3.1 National Planning Policy and Guidelines National Spatial Strategy The National Spatial Strategy seeks to achieve a better balance of social, economic, physical development and population growth between regions. It sets out a national context for spatial planning which informs regional planning guidelines and strategies, as well as county and city development plans and strategies. The Strategy also seeks to secure increased urbanisation of the population and the achievement of critical mass in large multi-faceted urban areas. One key objective of the Strategy is the consolidation of the Greater Dublin Area in a manner that protects local character and amenity through the achievement of development of higher densities at sustainable locations proximate to public transport and services. The Strategy supports the consolidation of the Greater Dublin Area in order to limit its spread in the hinterland and to ensure the efficient operation of public transport. The subject site is located within one of the key population growth areas in the Metropolitan Area of the Greater Dublin Area and is served by the LUAS and numerous other public transport services. The proposed development will deliver a density and form of development that is appropriate to its location and urban context that provides for new sudent accommodation on a brownfield site in a highly accessible location. The proposed development is therefore considered to be fully in compliance with the recommendations of the National Spatial Strategy Ireland 2040 Our Plan: Draft National Planning Framework One of the Key Elements of the Draft National Planning Framework published in September 2017 is proposals to secure more compact forms of urban development in all types of settlements, to reduce sprawl and to provide more choice, with a new national infill development target to accommodate 40% of the urban growth within existing built-up areas on brownfield lands. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 2

4 In regard to student housing, the Draft National Planning Framework recognises that demand for student accommodation exacerbates the demand pressures on the available supply of rental accommodation in urban areas in particular and that in the years ahead, student accommodation pressures are anticipated to increase. It states that the location of purpose built student accommodation needs to be as proximate as possible to the centre of education, as well as being connected to accessible infrastructure such as walking, cycling and public transport. The National Student Accommodation Strategy supports these objectives. The proposed development complies with the objectives of the Draft Framework in regard to student accommodation in that it will contribute to reducing the pressure on demand for rental accommodation in the area and in the city as a whole. The development is located proximate, in terms of the built up area of Dublin, to DCU and the DIT Grangegorman campus, and is easily accessible to walking, cycling and public transport infrastructure Action Plan for Housing and Homelessness The Action Plan for Housing and Homelessness, which was published in July 2016 as part of the Government s Rebuilding Ireland initiative, seeks to address existing issues of housing supply and homelessness in Ireland through five so called Pillars. Student accommodation forms part of Pillar 4: Improving the Rental Sector, wherein the provision of student accommodation is identified as a key action. Under the Student Accommodation section, it is stated that the student population in Ireland is to grow to 193,000 students by The provision of well-designed and located student accommodation is identified as being key to relieving pressure on the private rental sector. Under the Action Plan it is a Key Action to support greater provision of student accommodation. It is also stated that a national student accommodation strategy will be produced that will set out a framework for delivering more student accommodation and set out actions for reducing the cost of funding such projects. The Action Plan states that new planning guidance will be provided to planning authorities and An Bord Pleanála, describing potential uses for student accommodation outside the academic year in order to increase the economic viability of student accommodation proposals. It is submitted that the proposed development responds to the recognised need, at national level, for additional, dedicated student accommodation and is consistent with policy in this regard National Student Accommodation Strategy The National Student Accommodation Strategy published in July 2017 was developed by the Department of Housing, Planning and Local Government and the Department of Education and Skills to introduce measures to support the increased delivery of purpose built student accommodation. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 3

5 The report highlights that there is a pressing need for purpose built student accommodation in Dublin and that demand (30,298 bed spaces) vastly outstrips existing supply (12,432 bed spaces) and it is forecasted that even if all proposed developments are constructed there will be a demand for 17,771 bedspaces in 2019 and 13,569 bedspaces in is also pressuring an already strained private rental sector (PRS). Citing a current provision of just in the capital and with demand at, the shortfall in provision currently stands at 17,866 bed spaces. This situation is only expected to marginally improve between now and It is suggested in the Strategy that increasing the provision of purpose built student accommodation nationally will contribute to addressing the rental crisis in Dublin and in other rental pressure zones around the country: it is a fair extrapolation to make that every four students housed in either purpose built student accommodation or in digs will free up an additional housing unit in the private rented sector that would otherwise have been occupied by students. The impact of an additional 21,000 student accommodation bed spaces, in addition to an additional 1,500 digs spaces, will free up at least an additional 5,000 rental units for the wider residential rental sector. The proposed development accords with the National Student Accommodation Strategy for the provision of purpose built student accommodation and will contribute to meeting the undersupply of such accommodation in Dublin as highlighted in the strategy Circular PL 8/2016 APH 2/2016 Issued in July 2016 the Circular states that Local Authorities should assist in the development of student accommodation projects through their planning and development functions, including through the co-ordination of necessary infrastructural provision and appropriate pre-planning engagement. It further states that a flexible approach should be applied in respect of any planning conditions related to use and occupation of student accommodation as the Department recognises that a steady cash flow income throughout the year needs to be established for student accommodation by being able to generate income from multiple sources including students and short term visitor lets. Student accommodation can play a significant role in providing affordable accommodation for tourists and visitors in major urban areas during the peak summer demand period. The Circular also includes sample conditions for student accommodation, relating to use both during academic term time and outside term time. The proposed development also accords with the policy set out in the Circular. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 4

6 3.1.6 Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas The role of these Guidelines is to ensure the sustainable delivery of new development. The Guidelines focus on the provision of sustainable residential development, including the promotion of layouts that: Prioritise walking, cycling and public transport, and minimise car usage; Are easy to access for all users and to find one s way around; Promote the efficient use of land and of energy, and minimise greenhouse gas emissions; and Provide a mix of land uses to minimise transport demand. The Guidelines also 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 a new residential development at a variety of scales of development and in various settings. The Guidelines support a plan-led approach to development as provided for in the Planning and Development Acts Section 2.1 of the Guidelines notes 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 that: the sequential approach as set out in the Department s Development Plan Guidelines (DoEHLG, 2007) specifies that zoning shall be 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 site is undeveloped land close to a number of public transport routes. The development of the site would be in compliance with the Guidelines. 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 ancillary facilities for the residents of the development and is proximate and well connected to a wide range of existing retail, commercial and community facilities. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 5

7 The subject site would be considered to be adjacent to Public Transport Corridors in the context of the densities required under the Guidelines as it is located with c. 1 kilometre walking distance of the Cabra LUAS stop on Fassaugh Road. The proposed development incorporates design principles such as shared surfaces within the development that prioritise walking and cycling. Ancillary facilities for the benefit and use of the residents of the development are provided within the proposed development to comply with the Guidance. In providing a mix of uses within the development, including a childcare facility, the sustainability of the proposed development is increased as it reduces the need for additional trip generation and provides services within walking distances of people s homes. The layout is highly accessible for all users, with a permeable layout both internally and externally. Linkages are provided to the surrounding roads and streets and by extension, to public transport routes. The layout is legible, with a clear distinction in between pedestrian routes and public and semi-private open spaces. The Guidelines also provide guidance on the core principles of urban design when creating places of high quality and distinct identity. The Guidelines are accompanied by a Design Manual that 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. In respect to pre-application consultations with the Planning Authority, the applicant s design team had regard to the advice set down in the In Practice section of the Design Manual that recommends the following approach: 1. Development Brief An analysis of the site was carried out that included a review of local planning policies and objectives, the provision of services and access, and flood risk information. 2. Site Analysis The characteristics of the site and its surrounding context were established and potential pedestrian and cyclist links, key views and vistas to from and to the site, and building heights were analysed. 3. Concept Proposals An initial concept proposal responding to the parameters established by the development brief and site analysis was prepared describing aspects of the proposed development such as land use(s), range of development density, building height, and connections to the surrounding area. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 6

8 4. Pre-Planning Pre-planning consultations are designed to respond to the concept design and to encourage an interactive process. As set out the, the proposed development is the result of beneficial consultation on the composition and layout of the proposed development Urban Design Manual - A Best Practice Guide In responding to the opportunities and constraints of the site and its context, this section sets out the objectives and establishes a suitable approach to the site layout, public routes and connectivity; reviews the overall massing and the distribution of height across the site to respond to its urban location, context, orientation and residential amenity; and provides for an appropriate mix of uses. The main issues raised in the Urban Design Manual are summarised below: 1. Context: How does the development respond to its surroundings? The key objective is to create a contemporary campus style student environment of high quality with an established management company in place, including a full-time manager and support staff with a focus on student welfare and learning. The facility will be gated and closed at night, but open during the daytime. The overall objective is that the development will make a positive contribution to the location and to Cabra as a whole. The proposed buildings are appropriate in scale to the wider local environment and comply with Dublin City Council development standards for a development of this nature. The scale of the buildings is broken down into blocks to avoid visual monotony. The buildings are located on the site to avoid the residential boundaries and avoid unnecessary overshadowing and overlooking. The higher elements are located towards the railway line and are angled to form an internal landscaped environment within the site. The form and nature of the proposal promotes an appropriate intensification of a brownfield back-site and will bring a vibrancy and energy to this area. The presence of local retail will increase the activity of the street frontage in this area. 2. Connections: How well connected is the new neighbourhood? Because of its geometry the site is laid out as a cul-de-sac. Every effort however has been made to design a street frontage of colour and activity to physically and visually connect the new development with the local streets. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 7

9 With the incorporation of street level active retail frontages and a vibrant and active ground plane within the scheme, the development will form an integral element of the local centre of this part of Cabra. 3. Inclusivity: How easily can people use and access the development? The design of the primary circulation space within the site is based on the DMURS shared surface standards. Priority is given to pedestrian use of the space, with the very limited vehicular movements relegated to secondary importance. An active external social space is also provided to the western side of the main buildings optimising orientation and privacy for the students to socialise and interact. The link section of the two principal blocks is designed as a hub from which shared services are accessed and as the entrance to the lower ground floor social spaces within the development. These include games, dining and entertainment zones that will bring residents of the development together to foster a communal and social environment in which students can mix and relax. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 8

10 The design of the buildings incorporates a varied palette of materials and colour presenting the wider development as a contemporary and progressive addition to the wider streetscape. 4. Variety: How does the development promote a good mix of activities? Student housing is not a form of development where the profile of the users is diverse; however in a settled residential community the incorporation of a stand-alone development catering to young residents should add vibrancy and activity to the adjoining neighbourhood. The incorporation of appropriate local scale retail uses will help form a link between the residents of the scheme and the wider community. The design of the project with visual interest in the geometry, colour and diversity of the architecture will add to the local streetscape and enhance the vibrancy of the street frontages. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 9

11 5. Efficiency: How does the development make the appropriate use of resources, including land? The subject site is an existing brownfield site situated in an established community. The proposed density of the development complies with the requirements of the Dublin City Council Development Plan for student housing and also appropriate given the proximity to local high quality transport connections. The site is walking distance from the currently emerging new DIT campus at Grangegorman. The location of student housing at this location is a small element within the wider and relatively homogenous Cabra residential community. This will add diversity and variety into the community. Bernard Seymour Landscape Architects commentary responds to the design of the public spaces in greater detail landscape zones are provided to boundaries and the position of buildings is designed create a buffer to the adjacent residential areas and form a private and animated landscape for the residents of the site. The detailed design of the buildings incorporates considerations of solar gain and aspect in the buildings and public spaces. Bedrooms are designed with an eastern aspect, while living spaces are generally orientated to the western elevation to capitalise on evening sun. This proposed development brings a much needed residential scheme to a derelict brownfield site and intensification and appropriate use of a site in the heart of an established residential community. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 10

12 6. Distinctiveness: How does the proposal create a sense of place? The massing and design of the built elements of the development seek to form a distinct identity for the complex and in particular, the use of a varied palette of materials and colour. A strong architectural form is proposed at the entrance to the development to promote a positive identity for the scheme and create a visual connection with the adjoining streetscape. The focal point of the central hub and the quality internal and external spaces are reached from and controlled by this actively managed zone. 7. Layout: How does the proposal create people friendly streets and spaces? The approach to landscaping is to provide an integrated solution, which will enhance and complement the building design. The intention is that the main paved area will be a shared surface throughout, giving priority to pedestrian and bicycle movement, but making provision for service and emergency vehicles as the need arises. Soft landscaping in the form of additional tree planting along both the eastern and western boundaries, specimen trees in key locations including the main entrance, selected under storey planting and ground cover will combine to present a considered environment, with the residents at its heart. The individual blocks are designed with own door access, which arranges the overall scheme into a series of identifiable houses and sub-communities. This follows best practice for the layout of student housing development. The design of shared surfaces is pedestrian-led, with secondary priority for vehicular movement. Large numbers of cycle spaces are provided for the residents with the provision of high quality planting to enhance all vistas within the development The applicant is committed to creating a high quality experience for the students with the provision of large fitness, dining and recreation spaces at lower ground floor level. These are generously provided with large planted lightwells to ensure these spaces are bright and dynamic. To promote visual interest and variety there is a distinct difference in character between the two external amenity spaces proposed, with the western space provided with more seating areas and games equipment; and the eastern space is designed as a shared surface with a more urban / pedestrian street presentation, but is terminated with a sports area at it s northern end (also open to the west). 8. Public Realm: How safe, secure and enjoyable are the public areas? All public spaces are visually controlled by the central hub and overlooked by the residential blocks. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 11

13 The shared surface allows the optimal use of the site area and a minimal impact of vehicular movements on the design of the public space. 9. Adaptability: How will the buildings cope with change? The proposed environment is an individual and purpose designed facility, which will bring life and street level activity to an established neighbourhood. Predominantly living space, there is a built in flexibility in the layout, particularly with multiple core arrangement that will allow for adaptive reuse in the future. In addition new energy initiatives can be introduced in the future through the existing vertical and horizontal pathways within the building envelope and potentially as part of the roofscape. 10. Privacy and amenity: How does the scheme provide a decent standard of amenity? A minimum of 30 metres separates the building facade of the proposed 4 storey block to the rear of the adjoining houses on St. Attracta s Road, which increases towards the southern end of the site, where a 3 storey and 4 storey with setback block forms the main entrance to the development. Bedrooms are arranged along the eastern facade and a new boundary wall and screening at ground level in combination with considered tree screening, will mitigate and reduce the potential for overlooking. The active living spaces are orientated onto the railway side in order to provide separation. 11. Parking: How will the parking be secure and attractive? Minimal parking is provided which is designed as ancillary to the shared surface and minimise its visual impact on the landscaping. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 12

14 12. Detailed Design: How well thought through is the building and landscape design? The proposed external materials are a combination of a brick base to the buildings and selected flat coloured panels over this base. The palette of colours will be muted with random accents of green across the facades to provide interest. The windows will be double glazed and have integrated security and safety measures. The external spaces around the buildings are designed principally for pedestrian use, although limited access will be provided for visitor cars and service related and emergency vehicles. The accommodation blocks run north / south, with the morning sun on the east facing bedroom elevations, while all the living space are confined to the west side, including outdoor amenity space which enjoy the evening sun. The external area along the railway is accessed through the reception area to maintain reasonable observation across this amenity area. Along the length of the eastern boundary, a new brick wall is proposed to be built within the site in addition to tree planting which will assist in providing visual screening and separation onto the gardens and houses to the east. The shared surface will be carefully detailed by DMOD Architects and Bernard Seymour Landscape Architects, providing considered use of paving, interesting street furniture, lighting and a basketball area at the southern end of this linear circulation route Delivering Homes, Sustaining Communities 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 an 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 a new housing scheme enjoy the benefits of first-rate living and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 13

15 conditions in a healthy, accessible and visually attractive environment; and provide homes and communities that may be easily managed and maintained. The application includes schedules prepared by DMOD Architects that demonstrate the compliance of the proposed development with the relevant standards and provisions of City Development Plan Design Manual for Urban Roads and Streets (DMURS) The Design Manual for Urban Roads and Streets (DMURS) sets out design guidance and standards for constructing new and reconfigured existing urban roads and streets. It also sets out practical design measures to encourage more sustainable travel patterns in urban areas. The Transport Services and Mobility Management Report prepared by CS Consulting Group that is submitted with this application provides further detail in respect of the compliance of the proposed development with the provisions of DMURS Smarter Travel A Sustainable Transport Future; A New Transport Policy for Ireland The Government has committed in Smarter Travel 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: Future population and employment growth will predominantly occur in sustainable compact forms to reduce 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 the 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 within convenient access to the LUAS public transport corridor and is also well served by Dublin Bus services. Thus, the principle of student accommodation 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 The Planning System and Flood Risk Management (November 2009) The Guidelines provide mechanisms for the incorporation of flood risk identification, assessment and management into the planning process.... They ensure a consistent approach throughout the country requiring identification of flood risk and flood risk and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 14

16 assessment to be key considerations when preparing development plans, local area plans and planned development. The core objectives of Guidelines are to: Avoid inappropriate development in areas at risk of flooding Avoid new developments increasing flood risk elsewhere Ensure effective management of residual risks for development permitted in floodplains Avoid unnecessary restriction of national, regional or local economic and social growth Improve the understanding of flood risk among relevant stakeholders; and Ensure the requirements of EU and national law in relation to the natural environment and nature conservation are complied with for flood risk management. The key principles of the Guidelines are to apply the Sequential Approach to the planning process i.e. Avoid the risk, where possible Substitute less vulnerable uses, where avoidance is not possible; and Mitigate and manage the risk, where avoidance and substitution are not possible Where the Sequential Test s avoid and substitute principles are not appropriate then the Guidelines propose that a Justification Test be applied to assess the appropriateness, or otherwise, of particular developments that are being considered in areas of moderate or high flood risk. A Flood Modelling Report on the site prepared by McElroy Associates to investigate the flood risk posed to the proposed development is submitted herewith. The report concludes that there is a minimal risk from Pluvial Flooding and no risk of fluvial damage or tidal flooding. Further, it t is considered extremely unlikely that ground water levels on site will rise above ground level and cause flooding Bird and Habitat Directive Appropriate Assessment The proposed development has been screened for Appropriate Assessment in accordance with the requirements of Article 6(3) of the EU Habitats Directive (92/43/EEC). Due to the location of the subject premises some distance from any Natura 2000 site; the nature and extent of the proposed development, i.e. the construction of a development on a brownfield site in an existing established built-up area, it is considered that there will be no adverse environmental impacts on the nearest Natura 2000 sites. Accordingly, no Appropriate Assessment is required in this instance. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 15

17 A report which contains information required for the competent authority to undertake a screening exercise for Appropriate Assessment, has been prepared by Emer Sexton, is submitted with the application. It provides information on and assesses the potential for the proposed development to significantly affect European sites. Following an analysis of the proposed development and potential relationships with European sites, it is the opinion that there will be no likelihood of significant effects on any European sites and no impacts to European site integrity, either alone or in combination with other plans or projects and therefore an Appropriate Assessment is not required. 4. Regional Planning Policy 4.1 Regional Planning Guidelines for the Greater Dublin Area (June 2010) The Regional Planning Guidelines (RPG s) aim to enhance economic strength, employment, education and population whilst ensuring the physical consolidation of the Metropolitan area. The following are the key objectives in so far as they relate to the proposed development: Consolidation of the urban centres located within the Metropolitan Area; Development of brownfield sites, in urban centres throughout the Metropolitan Area, especially those along public transport corridors; Delivery of well designed urban environments enhancing the quality of life for residents and workers alike; and Greater use of sustainable transport modes through the integration of land use and transport planning The Guidelines will continue to have effect until the Regional Spatial and Economic Strategy for the Eastern and Midland Region currently being prepared has been and adopted by the Eastern and Midland Regional Assembly. The subject site is located within the Metropolitan Area of the Greater Dublin Area. The Dublin Metropolitan Area is targeted for increased development, particularly those lands that are readily acceptable by public transport and roads infrastructure. The Guidelines state that: development within the existing urban footprint on the Metropolitan Area will be consolidated to achieve a more compact urban form, allowing for the accommodation of a greater population that at present, with much-enhancing public transport system, with the expansion of the built up areas providing for well-designed unban environments linked to the high quality public transport networks, enhancing the quality of life for residents and workers alike. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 16

18 The proposed development provides a sustainable high quality residential environment in close proximity to high quality public transport (LUAS and Dublin Bus) and will enhance the quality of life in the area. In respect of Dublin City, the Guidelines state that: A core element of the RPGs is the importance of integration of land use, employment and transport. Within the City, as the national hub of employment and transport, it is critical that the policy of encouraging high quality new housing within the core of the gateway continues. The City, with a large young population inflated by students, migration and a young mobile workforce, has lower occupancy rates, particularly in the inner City; which drives higher housing demand per head of new population. The importance of the detailed urban plans and guidelines in setting clearly the template for successful infill and regeneration development needs to continue, taking the long term perspective. New transport hubs at metro stations and along the interconnector route line give these locations high accessibility and mobility and this needs to be capitalised on where possible. The subject site is in a key location on the LUAS line and will provide new student housing in the city in accordance with the above strategic objective. 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. 4.2 Transport Strategy for the Greater Dublin Area The National Transport Authority s strategy published in April 2012 promotes transport measures that support the GDA in meeting its potential, as a competitive, sustainable city-region with a good quality of life for all. At the heart of the Strategy is the requirement for land use planning and transport planning to be considered in unison. Fundamental to future land use planning will be the consolidation of development areas to enable service by various modes of traffic. The need to consolidate and concentrate development in a manner that allows the effective provision of public transport is a central theme throughout the Strategy. The proposed development, which seeks to redevelop a disused brownfield site within walking distance of the LUAS, is considered a wholly appropriate form of development in the context of supporting the objectives of the Strategy. 5. Local Planning Policy: Dublin City Development Plan The subject site is located within the functional area of Dublin City Council. The development of the site is therefore informed by the policies and objectives of the City Development Plan that came into effect on 21October and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 17

19 5.1 Plan Vision The over-riding Vision for the City as set out in the Development Plan is: Within the next 25 to 30 years, Dublin will have an established international reputation as one of Europe s most sustainable, dynamic and resourceful city regions. Dublin, through the shared vision of its citizens and civic leaders, will be a beautiful, compact city, with a distinct character, a vibrant culture and a diverse, smart, green, innovation-based economy. It will be a socially inclusive city of urban neighbourhoods, all connected by an exemplary public transport, cycling and walking system and interwoven with a quality bio-diverse green space network. In short, the vision is for a capital city where people will seek to live, work, experience, invest and socialise, as a matter of choice. The Vision is expressed in a Strategy that seeks to facilitate the sustainable development of the City as a vibrant and vital place in which to live, work and visit. 5.2 Student Accommodation Policies The City Council recognises that to plan for future expansion of third-level institutions and to accommodate growth in the international education sector, there is a need for appropriately located high-quality, purpose-built and professionally managed student housing schemes, which can make the city s educational institutions more attractive to students from Ireland and abroad, and can also become a revitalising force for regeneration areas. It is therefore the policy of the City Council (QH31): To support the provision of high-quality, professionally managed and purpose-built third-level student accommodation on campuses or in appropriate locations close to the main campus, in the inner city or adjacent to high-quality public transport corridors and cycle routes, in a manner which respects the residential amenity and character of the surrounding area, in order to support the knowledge economy. Proposals for student accommodation shall comply with the Guidelines for Student Accommodation contained in the development standards. The proposed development is evidently is compliance with this policy 5.3 Employment, Enterprise and Economic Development Sectors Policy It is therefore the policy of the City Council (CEE19): To promote Dublin as an International Education Centre/Student City, as set out in national policy, and to support and encourage provision of necessary infrastructure such as colleges (including English Language Colleges) and high-quality, custom-built and professionally-managed student housing. and and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 18

20 To recognise that there is a need for significant extra high-quality, professionally managed student accommodation developments in the city; and to facilitate the highquality provision of such facilities. The proposed development is evidently is compliance with this policy 5.4 Development Management Criteria Zoning Objective Two zoning objectives apply to the subject site (see Figure 1 below) the majority of the site is zoned Objective Z1 : to protect, provide and improve residential amenity, and that part of the site adjacent to Fassaugh Avenue is zoned Objective Z3 : to provide for and improve neighbourhood facilities. Objective Z1 Objective Z3 Figure 1: Extract Map E: Dublin City Development Plan Residential use is permitted in principle under zoning objective Z1. Appendix 21 of the Development Plan clarifies that residential also includes student accommodation and build to let schemes. Residential and neighbourhood shops are permitted in principle under zoning objective Z3. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 19

21 The proposed development therefore complies with the zoning objectives that apply to the subject site Building Height For the purposes of defining maximum building heights, the city as a whole is defined as low-rise except for those areas specifically designated as mid-rise or high-rise. The subject site is not in one of these designated areas, so it is considered to fall within the low-rise area. The low-rise category is further differentiated between Inner City, Rail Hubs and Outer City. However, importantly, the Plan states that: All areas are considered to be in the low-rise category unless the provisions of a LAP/SDZ/SDRA indicate otherwise. In the absence of the subject site being within a LAP/SDZ/SDRA, building height policy for this area of the city in the Development Plan is up to a maximum of 16 metres. As the highest building on the site is 15 metres above ground level, the proposed development complies with building height policy Plot Ratio The indicative plot ratio standard varies from on Z1 zoned land to on Z3 zoned land. The plot ratio of the proposed development is 1.67, which complies with the indicative standard for both zoning objective Z1 and Z Site Coverage The indicative site coverage standard varies from 45% 60% on Z1 zoned land to 60% on Z3 zoned land. The site coverage of the proposed development is 35.4, which complies with the indicative standard for both zoning objective Z1 and Z Guidelines for Student Accommodation 1. The City Council supports the provision of high-quality, professionally managed, purpose built third-level student accommodation, either on campus or in accessible locations adjacent to quality public transport corridors and cycle routes, in a manner which respects the residential amenities of the locality. The proposed development meets the requirements in these regards in that it is in a highly accessible off-campus location and has been designed to ensure that residential amenities of the locality are respected. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 20

22 2. Student accommodation should make a positive contribution to the built environment, in terms of design quality, scale, height and the relationship to adjacent buildings. As demonstrated in this statement and the architectural and landscape drawings submitted herewith, the proposed development is of a high quality design that relates positively to the character of the area. 3. The external layout, including any necessary security arrangements should be designed to avoid isolating developments from the surrounding community. Given the proportions and configuration of the site, the connections of the site to the surrounding area have been optimised in the layout. 4. The student accommodation should be designed to give optimum orientation in terms of daylight to habitable rooms. Given the nature of student occupancy, the residential standards in relation to dual aspect may be relaxed. Proposed developments shall be guided by the principles of Site Layout Planning for Daylight and Sunlight, A guide to good practice (Building Research Establishment Report, 2011). The design of the buildings incorporates considerations of solar gain and aspect in the buildings and public spaces. Bedrooms are designed with an eastern aspect, while living spaces are generally orientated to the western elevation to capitalise on evening sun. 3. Adequate open space of suitable orientation should be provided within developments for the amenity of students, which can include terraces, courtyards and roof gardens, where appropriate. All proposals must provide appropriate indoor and outdoor communal and recreational facilities for students at a combined level of at least 5-7 sq. m. per bedspace. The provision of indoor communal space is particularly important for schemes with a high proportion of studio units, to allow students to interact outside the studio room (in study rooms, tv rooms etc). Where accommodation is provided on-campus, communal facilities will be assessed on a case-by-case basis having regard to the level of and access to on-campus amenity. A total of 2,304 sq. m. of indoor and outside communal and recreational facilities as set out in the that accompanies this application. This equates to an average of just over 11 sq. m. per bedsapace. 6. In assessing proposals, the planning authority will have regard to the pattern and distribution of student accommodation in the locality, and will resist the overconcentration of such schemes in any one area, in the interests of achieving, a sustainable mix of development, whilst also providing for successful urban regeneration, good public transport/cycling/walking connectivity, and the protection of residential amenity. The applicant will be requested to submit evidence to demonstrate that there is not an overconcentration of student accommodation within an area, including a map showing all such facilities within 1 kilometre of a proposal. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 21

23 A Student Accommodation Concentration Report is contained in this report in section below. 7. The following internal standards will apply to all proposals for student accommodation: i. Student accommodation to generally be provided by grouping study bedrooms in house units, with a minimum of 3 bed spaces with an overall minimum gross floor area of 55 sq. m up to a maximum of 8 bed spaces and a maximum gross floor area of 160 sq. m ii Single/ double occupancy studio units that provide en-suite bathroom facilities and kitchenettes/ cooking facilities will also be considered, with a minimum gross floor area of 25 sq. m. and a maximum gross floor area of 35 sq. m. Each of the proposed studio units are 25 sq. m. iii Shared kitchen/ living/ dining rooms shall be provided, based on a minimum 4 sq. m. per bed space in the house and town house unit, in addition to any circulation space. The shared kitchen/ living/ dining rooms provided in each house unit comply with this requirement proportionate to the number of bedrooms in the house. iv Minimum bedrooms sizes for house and town house units will be: Single study bedroom: 8 sq. m (with en-suite shower, toilet and basin: 12 sq. m) All single study bedrooms are ensuite and comply with this requirement. Twin study bedroom: 15 sq. m (with en-suite shower, toilet and basin: 18 sq. m) There are no twin study bedrooms within the proposed development. Single disabled study bedroom, with en-suite disabled shower, toilet and basin: 15 sq. m.) All disabled study bedrooms comply with this requirement. v. Bathrooms: Either en-suite with study bedrooms/ studio units or to serve a maximum of 3 bed spaces. All study bedrooms and studio units are ensuite. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 22

24 vi. All applications for student accommodation must be accompanied by documentation outlining how the scheme will be professionally managed including confirmation that all occupiers will be students registered with a third-level institution. A development management plan has been prepared and accompanies this application. As set out on the floor area schedules submitted with the application, the configuration of the proposed accommodation complies with and exceeds each of the relevant requirements. Each of the proposed 32 house units, which range from 4 bed units to 8 bed units, contain single study bedrooms, with each unit containing a shared kitchen/living room that exceeds the development plan standards. Studio units are also proposed in the three storey block that are 25 sq. m. each in accordance with the minimum Development Plan standard for such units and will be mainly for mature students Car Parking The maximum car parking standard for student accommodation in this area of the city is 1 space per 20 bed-spaces. In the case of the subject development (224 no bedspaces) this would equate to 12 spaces. 9 no. spaces, including 1 no. disabled space, are provided for the development. The proposed parking provision therefore complies with car parking policy Cycle Parking The cycle parking standard for student accommodation is 1 space per 2 bed-spaces. In the case of the subject development (208 no bedspaces) this would equate to 104 spaces. 114 no. spaces are provided for the development. The proposed parking provision therefore complies with cycle parking policy Student Accommodation Concentration Report The site of the proposed development is within walking and cycling distance of the DIT Grangegorman campus, and by LUAS and bus to the third level institutions in the city centre such as Trinity College Dublin, Royal College of Surgeons Ireland, the National College of Art and Design, National College of Ireland and Dublin Business School. Section of the City Development Plan describes the need to avoid an over concentration of student accommodation schemes in any one locality. It requires the provision of a map illustrating the location of student accommodation developments within 1 kilometre of the site of a proposed student accommodation development. This sets out the location of existing and approved purpose built student accommodation within 1 kilometre of the application site. and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7 Page 23

25 PROPOSED STUDENT ACCOMMODATION FASSAUGH AVENUE, CABRA, DUBLIN 7 STUDENT CONCENTRATION REPORT LUAS (stops) Bus Routes Local Shops/Services Proposed Shops/Services Approved student accommodation Existing student accommodation 1 KM Statement of Consistency with Planning Policy and lands to the rear, Fassaugh Avenue, Cabra, Dublin 7. Page 24