School Demand Assessment

In respect of

Proposed Strategic Housing Development

at

Murphystown Way, Dublin 18

Prepared for

Murphystown Land Developments DAC

Prepared by

John Spain Associates

September 2020

39 Fitzwilliam Place, Dublin 2 Telephone: (01) 662 5803 E-mail [email protected] Web: www.jsaplanning.ie School Demand Assessment Murphystown Way SHD

1.0 INTRODUCTION

1.1 On behalf of the applicant, Murphystown Land Developments DAC, John Spain Associates have been instructed to prepare a School Demand Assessment in relation to a proposed Strategic Housing Development on a site at Murphystown Way, Dublin 18.

1.2 The application site has an area of c. 2.54 hectares and is zoned Objective A – ‘to protect and-or improve residential amenity’ and Objective F – ‘to preserve and provide for open space with ancillary active recreational amenities’ under the Dún Laoghaire-Rathdown Development Plan 2016-2022. The site itself is currently greenfield. There is an established site access from Murphystown Way and the site boundary with the roadway is currently defined by a concrete wall, with a section of a rubble wall and part of the reconstructed Glencairn House boundary wall located along the south eastern boundary, to the west of the Luas Line.

1.3 The proposed development comprises the construction of 249 no. apartments in three no. blocks, with heights over a basement level ranging from part 4, part 5, part 6, part 7, part 8 and including a landmark element of part 12 / part 13 storeys, located on the north eastern portion of the site adjacent to the Luas line. A residential amenity space of 450 sq.m is included within Block 1. The proposal includes provision for a childcare facility, over two levels, and ancillary outdoor play area, located below Block 3 with a GFA of c. 550 sq.m and a communal central courtyard with an area situated between the apartment blocks. An area of public open space is proposed on the northern part of the site, which will connect to the permitted open space in the adjacent Glencairn SHD development, which is currently under construction.

1.4 Access to the underground car parking is to be provided for the development off the new link road connecting to Murphystown Way. The proposal will deliver the first section of this new link road, which will ultimately connect Murphystown Way to Sandyford on the opposite side of the M50, in accordance with long-term roads objective of the Development Plan. The proposal includes a proposed access to the future development site to the north, i.e. the proposed school site as discussed below.

1.5 A c. 1.15 hectare site to the west (part of the overall landholding) has been identified as a suitable location for a future primary school, as required under the recently adopted Ballyogan and Environs LAP 2019-2025. The applicant has entered into discussions with the Department of Education and Skills in respect to this future primary school site. The Department confirmed in subsequent correspondence that in principle the site designated for the primary school was acceptable to them, as referenced in the Planning Report and Statement of Consistency and included in Appendix 1. They have not indicated a timeframe for bringing forward a planning application on the site, and we understand that they monitor this based on existing provision in the area and based on existing and forecast demand.

1.6 The Design Statement and site layout plans provide further detail in respect to the proposed school site. A buffer zone of c. 20m between the development site and school site is proposed on the northern part of the site to facilitate future extension of the Link Road objective to Sandyford by the Planning Authority.

1.7 It should be noted that the requirement for a School Demand Assessment did not form part of the specific information identified to be submitted with any application in An Bord Pleanála’s Pre-application Consultation Opinion. Notwithstanding this, the report has been

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prepared in response to DLRCC’s Opinion, submitted to An Bord Pleanála as part of the SHD pre-application consultation process, which identified that a School Demand Assessment should be submitted with any future submission or application.

1.8 As the proposed development incorporates a childcare facility with a GFA of 550 sq.m, which is in excess of the requirements arising for a development of this scale under the Childcare Guidelines 2001 (see Planning Report / Statement of Consistency for further details), a childcare demand assessment has not been prepared to accompany the application.

2.0 RELEVANT PLANNING POLICY CONTEXT

2.1 The key planning policy provisions of national and location policy as it relates to the proposed development and this School Demand Assessment is set out below.

National Planning Framework

2.2 The NPF includes the following relevant objectives:

NPC 31- Prioritise the alignment of targeted and planned population and employment growth with investment in:

• A childcare/ECCE planning function, for monitoring, analysis and forecasting of investment needs, including identification of regional priorities; • The provision of childcare facilities and new and refurbished schools on well located sites within or close to existing built-up areas, that meet the diverse needs of local populations; • The expansion and consolidation of Higher Education facilities, particularly where this will contribute to wider regional development, and • Programmes for life-long learning, especially in areas of higher education and further education and training where skills gaps are identified.

2.3 The recent preparation of the BELAP, as discussed below, would have had regard to the above objective and was informed by consultation with the Department of Education and Skills.

Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (2009)

2.4 These guidelines were published by the Department of the Environment, Heritage and Local Government in order to set out the key principles that should be adopted within developments and used by the Planning Authorities both in writing their Development Plans and in assessing new developments.

2.5 The Guidelines state that Planning Authorities should ensure efficient and integrated provision of schools, childcare, community centres, healthcare facilities and district/neighbourhood centres are made available for the wider community. We note the following requirements set out in the Guidelines that relate to schools:

• Schools: “No substantial residential development should proceed without an assessment of existing schools’ capacity or the provision of new school facilities in tandem with the development.” This is further clarified as

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requiring applications for 200+ units to be accompanied by a report detailing the school capacity of the area and the impact of the development.

The Provision of Schools and the Planning System – A Code of Practice for Planning Authorities (2008)

2.6 The guidelines issued by the Department of Education and Science and the Department of the Environment, Heritage and Local Government (2008) for the provision of Schools outlines the following core objectives for the effective integration of schools and development planning systems:

• Schools provision should be an integral part of the evolution of compact sustainable urban development and the development of sustainable communities; • The provision of any new schools (both primary and post-primary) should be driven by and emerge from an integrated approach between the planning functions of planning authorities and the Department of Education and Science; and • Local authorities, as planning authorities, will support and assist the Department in ensuring the timely provision of school sites.

Dún Laoghaire Rathdown County Development Plan 2016-2022

2.7 The following policy is included in the Development Plan regarding schools:

• Policy SIC8 Schools: “It is Council policy to ensure the reservation of primary and post-primary school sites in accordance with the requirements of the relevant education authorities and to support the provision of school facilities and the development / redevelopment of existing schools throughout the County”

2.8 Accordingly, we note that the Development Plan zoning maps for this area of the County includes a Primary School (PS) symbol at Kilgobbin South and at the site of the Holy Trinity National School in Mimosa-Levmoss. These local schools’ objectives have subsequently been reviewed and updated during the preparation of the BELAP, as discussed below. We also note that the Legionaries of Christ Lands, to the north of the M50 within the Sandyford UFP area, includes an objective, SLO 112, which relates to the provision of a primary and post-primary school in this location (see Figure 1 below).

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Figure 1: Extract from Land Use Zoning Map from 2016-2022 CDP (Applicant’s lands circled in Red)

CDP Objective 112- Primary and Post Primary School Site

Ballyogan & Environs Local Area Plan 2019-2024

2.9 In relation to education policy, section 8.3.2 of the BELAP states the following:

“As part of the preparation of the LAP, the Planning and Building Unit of the Department of Education and Skills (DES) was consulted on any existing or anticipated capacity issues in respect of school place provision at both primary and post-primary level within the BELAP area and immediate areas of influence. The Department advised that in addition to the current schools provision and the post-primary school for which permission has been sought, and on the basis of the population projections provided by DLR, that one additional post-primary school and potentially up to three additional primary schools would be needed.

It is proposed to identify three sites within the BELAP area, but not to specify whether they be primary or post-primary schools at this time. It is proposed to work in conjunction with developers and the DES to ascertain the most suitable location of these site for a second post-primary school, and to further work to bring forward a fourth site if needed and considered appropriate.

On the basis of existing CDP policy, proximity to residential growth areas and existing population centres, access to sustainable transport links, opportunities for co-location with compatible uses such as open space, the sites selected for schools within the BELAP lands are at Kilgobbin South, Glencairn North, and Racecourse South.”

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2.10 Policy BELAP COM4 – School Provision of the BELAP relates to existing and proposed schools’ provision, see Figure 2 below for map-based representation of this, with the objective reading as follows:

“To continue to work with the Department of Education and Skills to ensure the timely delivery of Primary and Post-Primary schools in the BELAP area. Three schools’ sites have been identified within the BELAP area at Kilgobbin South, Glencairn North, and Racecourse South as shown on Figure 11.1. The landowner/developers of these sites shall enter discussions with the Department of Education and Skills prior to entering pre- planning with the Planning Authority to agree phasing for the delivery of the school.”

Figure 2: Extract of BELAP Specific Local Objectives Figure 11.1 (Subject Site Circled in Yellow)

3.0 SCHOOL PROVISION ANALYSIS

3.1 “The Provision of Schools and the Planning System – A Code of Practice for Planning Authorities (2008)” published by the Department of Education and Science and the Department of the Environment, Heritage and Local Government, sets out best practice approaches that should be followed by planning authorities in ensuring that the planning system plays its full part in facilitating the timely and cost-effective roll-out of school facilities by the Department of Education and Science and in line with the principles of proper planning and sustainable development.

3.2 In respect of identifying requirements for primary schools in the future, the “Code of Practice” outlines that the Department of Education and Science will assume that an average of 12% of the population is of primary school-going age.

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3.3 In respect of secondary schools’ provision, the “Code of Practice” identifies that the procedure for establishing demand for new second-level schools may in some cases be more complex as it involves not just an assessment of likely population growth but also an appraisal of the capacity of existing post-primary schools, coupled with an assessment of the enrolment patterns in existing and anticipated 'feeder' national schools.

3.4 Planning Authorities are required to anticipate the demand for new schools’ infrastructure using this methodology.

3.5 The “Identification and Suitability Assessment of Sites for Primary and Post Primary Schools” Guidance has been prepared to assist in the identification and the assessment for suitability of new sites for Primary Schools. The guidance is intended for use in conjunction with relevant design guidelines and technical guidance documents produced by the Department of Education and Skills and other appropriate stakeholders.

3.6 Whilst the technical guidance document provides helpful information on the physical suitability requirements of school sites, it does not provide assistance with determining when a school site may be required. This guidance is set out within the ‘Provision of Schools and the Planning System’ code of practice document produced by the Department of Education and Science1.

3.7 Section 2.3 of the BELAP sets out that based on an analysis of the 2016 Census, the BELAP area accommodates a population of just over 9,500, which equates to 4.4% of the County’s population. Section 5.1.2 sets out the capacity for additional population growth and states:

“To determine the potential future population based on this availability of zoned lands, an objective methodology would be to take the 84 hectares of ‘Undeveloped’ and ‘Under Construction’ land within the Plan area, apply an average residential density of 50 units per hectare to the remainder in line with CDP policy and a household size equivalent to the national average.

Employing this methodology indicates a potential increase - from the 2016 (Census) baseline and allowing for an amount of development in the interim - of 4,300 new homes and 12,040 additional people. This represents a 125% increase in population from 9,526 to a potential population of around 21,500. In reality, however, due to site constraints, competing non-residential land uses, and shifting demographics within the existing housing stock, it is likely that a somewhat lower population will be achieved. Nevertheless, in broad terms it is clear that planning for an overall doubling of the existing population – a 100% increase – represents a reasonably objective scenario.”

3.8 Based on the above, the BELAP plans for a potential increase in population of c. 9,526 by 2025.

3.9 With an average primary school-going age cohort of 12% of the population (as per the Department of Education methodology for calculating school demand), the additional primary school-going population which would be required to be planned for within the BELAP area equates to c. 1,143 no children (9,526 / 100 x 12).

1 Now the Department of Education and Skills

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3.10 Based on an average post-primary school-going age cohort of 8.5% of the population (as per the Department of Education methodology for calculating school demand), the additional post-primary school-going population which would be required to be planned for within the BELAP area equates to c. 810 no. children (9,526 / 100 x 8.5).

3.11 There are a number of schools within the BELAP area and the wider catchment, particularly within a c. 2-4km radium from the subject site. The names and locations of the primary and secondary schools are listed in Appendix 1 and illustrated in the Figure 3 and 4 below. The schools are based upon school lists published by the Department of Education and Skills and the BELAP maps.

3.12 The research identifies 7 no. primary schools within 2km of the subject site, and given the highly accessible location, it is considered appropriate to consider the wider context up to 4km, where there are an additional 26 no. primary schools (see Figure 3). The Department of Education and Skills provide details on enrolment figures and the enrolment figures for primary schools in 2019/20 was 11,474 no. spaces.

3.13 The research identifies 3 no. secondary schools within 2km of the subject site, with a further 10 no. within 4km (see Figure 3). The enrolment figures for secondary schools in 2019/20 was 6,927 no. spaces.

Figure 3: Locations of Primary and Secondary Schools proximate to the subject site

4km

Subject Site

2km

Legend Primary Schools Secondary School

Source: Google Earth and Department of Education

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Figure 4: Extract of Figure 8.2 of the BELAP

3.14 There is also a new post primary school planned for the Mimosa-Levmoss lands (permitted under Reg. Ref.: D18A/1171 & ABP Ref.: PL06D.304843), adjacent to the Holy Trinity National School, which would cater for approximately 1,000 students. It is understood this will provide a permanent location for the Stepaside Educate Together Secondary School.

3.15 In addition, as noted above, the following additional school sites are proposed within the BELAP following the Planning Authority’s and Departments assessment of the likely need arising within the area:

• Kilgobbin South – identified in the CDP and BELAP • Racecourse South – identified in the BELAP • Glencairn North – identified in the BELAP (i.e. the northern part of the subject lands which has been identified following discussions with the Department and pre-application discussions with the Planning Authority) • Legionaries of Christ Lands, Sandyford- Identified under SLO 112 in the CDP for a primary and post-primary school. These lands are to the north of the Glencairn North site.

3.16 The proposed school at Glencairn North is located north of the subject site. A c. 1.15 hectare site to the west (part of the overall landholding) has been identified as a suitable location for a future primary school, as required under the recently adopted Ballyogan and Environs LAP 2019-2025. The applicant has entered into discussions with the Department of Education and Skills in respect to this future primary school site, who confirmed in subsequent correspondence that in principle the site designated for the primary school was acceptable.

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3.17 The total number of primary school pupils enrolled in the schools currently amounts to 11,474, with the total number of secondary school pupils amounting to 6,927. The combined total is 18,401 of school going age. On this basis it is considered the increased demand from the population projects, as identified by the BELAP, of 1,143 primary and 810 secondary can be accommodated within the existing and planned school provision in the area.

3.18 The proposed development provides for a total 249 no. units comprising 66 no. 1 bed units and 163 no. 2 bed units, and 20 no. 2 bed units with a study. The maximum occupancy for the development is calculated as 864 no. persons based on the following breakdown:

• 1 bedroom units: 66 x 2 people per unit = 132 no. persons • 2 bedroom units: 183 x 4 people per unit = 732 no. persons

3.19 Based on the primary school age cohort representing 12% of the total population (based upon the methodology employed by the Department of Education and Skills), the proposed development with its estimated capacity for 864 new residents will create additional demand for 104 no. primary school places. This figure represents a high-end estimate as it is based upon the assumption of maximum occupancy with the development, and it is likely not all units will be occupied families.

3.20 Based on the post primary school age cohort representing 8.5% of the total population (based upon the methodology employed by the Department of Education and Skills), the proposed development will create additional demand for c. 73 no. secondary school places. As above, this figure represents a high-end estimate as it is based upon the assumption of maximum occupancy with the development, and it is likely not all units will be occupied families.

3.21 Having regard to these estimated figures for additional primary and secondary school demand, the considerable school provision (both existing and planned) in the surrounding area of the subject site, and the accessibility of the site to further schools via frequent and convenient public transport, it is considered reasonable to estimate that the additional population can be accommodated within the existing and planned school infrastructure.

3.22 The Department of Education and Skills will bring forward proposals for new schools on the various identified sites within the BELAP area, and Sandyford to the north, as the need arises based on their forecasting process. Thus, it is respectfully submitted that it is appropriate for the Board to grant permission for the proposed development in the context of existing and planned school provision in the area.

4.0 CUMULATIVE IMPACT ASSESSMENT

4.1 It is recognised there are a number of recent developments permitted in the area and under construction (as listed in Appendix 2). Of particular reference is the adjoining site at Glencairn (ABP: 302580-18) which was granted permission in December 2018 for 341 no. residential units and is currently under construction, and also the substantial residential development under construction at Clay Farm Phase 1 and 2, Ballyogan Road.

4.2 These developments were recognised within the BELAP as permitted schemes (BELAP Table 5.3) and as identified above, as part of the BELAP, additional school sites are proposed following the Planning Authority’s and Department of Education and Skills assessment of the likely need arising within the area. These schools will be brought

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forward by the Department of Education and Skills as the need arises. Therefore, having regard to the above assessment, there is a significant number of existing primary and secondary schools in the area, and a number of planned schools, to cater for the existing permitted developments and projected future population increase in the area, and the proposed demand expected to be generated from the proposed development.

4.3 Therefore, there are no cumulative impacts identified and no mitigation measures are proposed in this regard.

5.0 SUMMARY AND CONCLUSION

5.1 An analysis of the school demand and capacity in the area has been undertaken as part of this application. The review of existing and planned primary and secondary school facilities within area has found that there is a significant number of existing primary and secondary schools in the area, and a number of planned schools, to cater for the projected future population increase in the area, and the proposed demand expected to be generated from the proposed development.

5.2 Having regard to these estimated figures for additional school demand, the considerable school provision (both existing and planned) in the surrounding area of the subject site, and the accessibility of the site to further schools (particularly secondary) via frequent and convenient public transport, it is considered reasonable to estimate that the additional population can be accommodated within the existing and planned school infrastructure in the area / accessible to the subject lands.

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Appendix 1 – List of Primary and Secondary Schools

Table A.1 List of Primary Schools School Enrolment 2019/2020 St. Mary’s Mixed National School, Lambs Cross, Sandyford 265 Mount Anville Primary School, Lower Kilmacud Road 474 Oatlands Primary School, Stillorgan Road 456 St Olaf’s Primary School, Balally Drive, Dundrum 509 Taney Parish Primary School, Sydenham Villas, Dundrum 434 St Brigid’s National School, Merville Road, Stillorgan 101 St Attractas Junior National School, Meadowbrook, Dundrum 343 St Attractas Senior National School, Meadowbrook, Dundrum 356 Gaelscoil Shliabh Rua, Ballyogan Court, Ballyogan 236 Holy Trinity National, Glencairn, Leopardstown 578 Gaelscoil Thaobh Na Coille, Kiltgobbin 458 Kilternan Church of Ireland National School, Kilternan 211 Our Lady of Wayside, Kilternan 320 Stepaside Educate Together National School, Belarmine 337 St. Raphaelas Primary School, Leopardstown, Stillorgan 444 Queen of Angels Primary School 314 Our Lady’s Girls National School 297 Our Lady’s Boys National School 283 Scoil Naithí, Ballinteer 237 Holy Cross National School, Dundrum 301 St Theresas Primary School 444 Booterstown National School 89 Carysfort National School 596 All Saints National School, Blackrock 55 Guardian Angels National School, Blackrock 441 Gaelscoil Laighean, Blackrock 12 Kill O’ The Grange National School, Blackrock 217 Hollypark Girls National School, Foxrock 568 Hollypark Boys National School, Foxrock 623 St Brigids Boys National School, Foxrock 484 St Brigids Girls National School 536 St Laurences Boys National School 447 Goatstown Stillorgan Educate Together National School 8 Total 11,474

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Table A.2 List of Secondary Schools School Enrolment 2019/2020 Rosemont Secondary School, Enniskerry Road, Sandyford, 182 Mount Anville Secondary School School, Mount Anville Road 698 Loreto College Foxrock 519 Wesley College, Balally 928 St Tiernan’s Community School, Balally, Dublin 16 345 Oatlands College, Stillorgan Road 545 Balinteer Community School, Balinteer, Dublin 407 St Raphaelas Secondary School, Leopardstown, Stillorgan 569 Stepaside Educate Together Secondary School 214 Newpark Comprehensive School, Newtown Park Avenue 861 Clonkeen College 575 Rockford Manor Secondary School 277 St Benildus College 807 Total 6,927

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Appendix 2 – Relevant Planning Permissions in Proximity to the Application Site

Reg. Ref.: Location Description Decision ABP Ref.: Glencairn, Demolition of an existing Granted by ABP 302580-18 Murphystown house and the construction of on the 20nd Way, Dublin 18 243 no. apartments, 98 no. December 2018 homes, childcare facility and associated site works. The application site is located adjacent to Glencairn House, which is a protected structure under RPS Ref. No. 1643. The Record of Protected Structures identifies the following

An EIAR was submitted with the application, notwithstanding that the development fell below the mandatory threshold of 500 no. units and 10 ha within a built-up area.

Reg. Ref.: Glencairn House, Provision of a new single Granted by D17A/0913 Murphystown storey dwelling and garage for DLRCC on the Way, Dublin 18 embassy staff within the 18th January 2018 existing walled garden, including vehicular access through a new opening in the walled garden; Provision of a new boundary wall, and a new security gate entrance with security hut on the existing avenue. Reg. Ref.: Lisieux Hall, Residential development of Granted by ABP D16A/0547 & Murphystown 69 units, comprising 17 no. on 03rd of August ABP Ref.: PL Road, houses and 52 no. 2017 06D.248082 Leopardstown, apartments with all Dublin 18 associated site works. There is a live (protected structure). Lisieux application on this Hall, is a Protected Structure site for a SHD under RPS Ref.: 1662. development for 200 apartments under ABP Ref.: 307415-20. A decision is due by the 13/10/2020 Reg. Ref.: Central Park The construction of 3 no. Grant of D19A/0457 (Block N site), office buildings ('N1'; 'N2' and permission issued Leopardstown 'N3') ranging in height from 6 by DLRCC on the Road, Dublin 18 to 8 storeys, over lower

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ground floor and basement 26th of February level. The total GFA of office 2020 floorspace proposed is c.47,216 sq.m. Reg. Ref.: Phase 1 Clay A seven-year planning Granted by ABP D15A/0247 & Farm, Ballyogan permission for a residential on the 06th of ABP Ref.: Road, Dublin 18 development of 410 no. September 2016. PL06D.246601 residential units and a childcare facility with all Substantially associated site works. complete with the exception of part of Phase 1C.

ABP Ref.: Phase 1C Clay 192 no. apartments to replace Granted by ABP 304288-19 Farm, Ballyogan and supersede 56 no. on the 31st of July Road, Dublin 18 apartments permitted under 2019 Reg. Ref.: D15A/0247 & ABP Ref.: PL06D.246601 ABP Ref.: Phase 2 Clay 927 no. residential units (355 Granted by ABP 301522-18 Farm, Ballyogan no. houses and 572 no. on the 3rd of Road, Dublin 18 apartments), a August 2018 neighbourhood centre containing a childcare facility and 2 no. retail units, the associated section of the Clay Farm Loop Road from the bridge road link with Phase 1 to the south western site boundary, associated internal roads, pedestrian and cycle paths, open space, and all associated site and infrastructural works.

An EIAR was submitted with the application as it exceeded the threshold of 500 dwellings

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