Statement of Consistency

STATEMENT OF CONSISTENCY

FOR A

BUILD TO RENT (BTR) RESIDENTIAL DEVELOPMENT AT ‘MARMALADE LANE’, DUNDRUM, DUBLIN 16.

PREPARED BY

ON BEHALF OF

1 Wyckham Land Limited

SEPTEMBER 2020

CONTENTS

1. INTRODUCTION ...... 3 2. NATIONAL & REGIONAL PLANNING POLICY ...... 6 3 LOCAL PLANNING POLICY ...... 40 4 CONCLUDING REMARKS ...... 49

1. INTRODUCTION

On behalf of the applicant, 1 Wyckham Land Limited, this Statement of Consistency accompanies a planning application to An Bord Pleanála for a proposed Strategic Housing Development on lands located at Marmalade Lane, Gort Muire, Dundrum, Dublin 16, in accordance with Section 5 of the Planning and Development (Housing) and Residential Tenancies Act 2016.

The site is located to the east of Gort Muire, Carmelite Centre, and is accessed from Wyckham Avenue, off Wyckham Way. The application site includes lands formerly part of/owned by the Gort Muire Carmelite Centre and is located adjacent to Protected Structures (RPS No. 1453). It comprises an open field having formerly been used as agricultural lands. The boundaries are delineated by modern post and rail fencing with some mature trees along the boundaries. There are no built structures on the site.

The development will comprise a ‘Build to Rent’ (BTR) apartment development consisting of 7 no. blocks ranging in height up to 9 storeys (and including two levels of basement/undercroft located in the northern portion of the site). 628 no. apartments are proposed comprising 279 no. 1 -beds 318 no. 2-beds & 31 no. 3-beds.

All residential units provided with associated private balconies/terraces to the north/south/east/west elevations. The BTR development will also include Resident Support Facilities & Resident Services & Amenities (total floor area c.3897 sq.m) including reception, parcels/delivery area, store areas, co- working spaces, residents lounge, games room, cinema/function room, music room, dining area, meeting room, gym, dog grooming, breakout areas, management offices and showroom. The development also includes a creche (c.620 sq.m), ‘Grab ‘n go’ retail unit (c.18 sq.m) and café (c.143 sq.m). Provision of 278 no. car parking spaces, 1,354 no. cycle parking spaces and 21 no. motorcycle spaces.

Vehicular/pedestrian/cyclist accesses including from Wyckham Avenue and including improvement works to the existing Carmelite Centre access road and entrance.

All associated site development works, open spaces, roof gardens, landscaping, boundary treatments, plant areas, waste management areas, cycle parking areas, and services provision (including ESB substations).

The main development statistics relating to the development are summaries below:

Development Proposal Statistics No. of apartments 628 no. as follows: - 279 no. 1 bed (44%) - 318 no. 2 bed (51%) - 31 no. 3-bed (5%) Residential facilities / Mixed Uses Creche (620 sq.m) Grab n go retail (18 sq.m) Café (143 sq.m)

Co-working spaces (877sq.m) Reception (105 sq.m)

Games room (243 sqm) Music room (23sq.m) Cinema/ function room (132 sq.m) Meeting room (83 sq.m) Parcel room (68 sq.m) Dog grooming (46 sq.m) Private Dining (135 sq.m) Gym (478 sq.m) Residents lounge (52 sq.m) Shared stores (318 sq.m) Breakout spaces (1104 sq.m) Management offices (154 sq.m) Showroom (79 sq.m) Site Area Gross Site Area: 4.0305 ha Net site area: 3.4918 ha

Net site area is Gross site area minus the following: - Wyckham Avenue, - Existing Carmelite Centre access road and adjoining areas (within application site)

Gross Residential Density: 156 per hectare

Net Residential Density: 180 units per hectare Plot Ratio 1: 1.41 based on the gross area Site Coverage 26.19 % based on the gross area Building Height Up to 9 storeys Aspect 41% single aspect 59% dual aspect Open Space Gross open space provision (comprising the public open spaces, communal open spaces (at grade), and pedestrian parades) totals c.24,185 sq.m or 2.42ha (c.19,606.5 sq.m + 4,578.58 sq.m). This represents c.69% of the net site area.

The net open space provision (i.e. the public and communal open spaces (at grade) minus the pedestrian parades) is c.13,137 sq.m (c.1.3ha) (4,578.58 sq.m + 8,559 sq.m) which represents 37% of the net application site area. Carparking 278 no. car spaces

• 26 of these are for GoCar Cycle parking 1354 no. bicycle spaces Motorcycle 21 no. motorcycle spaces Vehicular Access From Wyckham Avenue

This Statement of Consistency demonstrates that the proposal is in accordance with the relevant national planning policy, guidelines issued under Section 28 of the Planning and Development Act 2000 (as amended), and with local planning policy. It should be read in conjunction with the accompanying detailed documentation prepared McGill Planning, Scott Tallon Walker Architects, NMP Landscape Architects, Punch Consulting Engineers, Digital Dimensions, Altemar Ecology, Axis Consulting Engineers, CMK Horticulture and Arboriculture Ltd, IES Consulting Engineers, Global Apartment Advisors, Molloy Associate Conservation Architects, Moore Group Archaeological and Environmental Services.

2. NATIONAL & REGIONAL PLANNING POLICY

The key national and regional policies and guidelines (including Section 28 Guidelines) relevant to the proposed development are as follows:

• Ireland 2040 Our Plan - National Planning Framework (2018); • Regional Spatial and Economic Strategy 2019- 2031; • Guidelines for Planning Authorities on Urban Development and Building Heights (2018); • Guidelines for Planning Authorities on Sustainable Urban Housing: Design Standards for New Apartments (2018); • 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 Manual for Urban Roads and Streets (2019); • Guidelines for Planning Authorities on Childcare Facilities (2001); • Smarter Travel – A New Transport Policy for Ireland (2009-2020); • The Planning System and Flood Risk Management (2009). • Climate Action Plan 2019

PROJECT IRELAND 2040 OUR PLAN - NATIONAL PLANNING FRAMEWORK (2018) The National Planning Framework (NPF) is the Government’s plan to cater for the extra one million people that is anticipated to be living in Ireland. The Eastern and Midland Region (including Dublin) will, by 2040, be a Region of around 2.85 million people, at least half a million more than today.

The NPF Strategy includes the following aims:

• Supporting the future growth and success of Dublin as Ireland’s leading global city of scale, by better managing Dublin’s growth to ensure that more of it can be accommodated within and close to the city. • Enabling significant population and jobs growth in the Dublin metropolitan area, together with better management of the trend towards overspill into surrounding counties. • Targeting a greater proportion (40%) of future housing development to be within and close to the existing ‘footprint’ of built-up areas. • Making better use of under-utilised land and buildings, including ‘infill’, ‘brownfield’ and publicly owned sites and vacant and under-occupied buildings, with higher housing and jobs densities, better serviced by existing facilities and public transport.

This major new policy emphasis on renewing and developing existing settlements aims to prevent the continual expansion and sprawl of our cities. This aim for Compact Growth promotes “Making better use of under-utilised land and buildings, … with higher housing and jobs densities, better serviced by existing facilities and public transport.” This approach not only makes better use of land but it can also have a “transformational difference” to towns and villages bringing new life and footfall to an area and contributing to the viability of services, shops and public transport, and by increasing the housing supply, enables more people “to be closer to employment and recreational opportunities, as well as to walk or cycle more and use the car less” (section 2.6).

As a result of this new policy approach, and as set out in section 4.5, there is a recognition that infill, and brownfield development is more challenging to deliver across multiple streams including land management and integration within existing communities who prefer the status quo to be maintained. As a result, to enable development a flexible approach to planning policies and standards needs to be “focusing on design led and performance-based outcomes, rather than specifying absolute requirements in all cases… 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.” In particular Section 4.5 highlights that “general restrictions 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 location, e.g. city/town centre, public transport hub, inner suburban, public transport corridor, outer suburban, town, village etc.” It highlights that there “should also generally be no car parking requirement for new development in or near the centres of the five cities, and a significantly reduced requirement in the inner suburbs of all five.”

The NPF projects that 550,000 additional homes will be required by 2040 to meet future demand. These new homes should be located in places that can support sustainable development and in cities and larger towns where large scale housing exists. To achieve this housing target, we will need to build inwards and upwards and apartments will need to become a more prevalent form of housing. The NPF also states that that “to avoid urban sprawl and the pressure that it puts on both the environment and infrastructure demands, increased residential densities are required in our urban areas”. Key National Policy Objectives which relate to this site are set out below:

National Policy Objective Evaluation of Consistency National Policy Objective 4 The proposed development will create a high- Ensure the creation of attractive, liveable, quality, attractive and liveable place for residents. well designed, high quality urban places that are home to diverse and integrated communities that enjoy a high quality of life and well-being.

National Policy Objective 11 The proposal is located within the existing area of In meeting urban development Dundrum, within the metropolitan area of Dublin requirements, there will be a presumption in City. favour of development that can encourage more people and generate more jobs and The site is c. 600m from the Ballinteer stores with its activity within existing cities, towns and range of local shops and chemists. In addition to this villages, subject to development meeting neighbourhood centre, the site is c.750m (10 appropriate planning standards and minutes’ walk) from the Dundrum Town Centre and achieving targeted growth 1.5km (15 minutes’ walk) from SuperValu shopping centre.

Dundrum village centre has a library, banks, and other services, which combined with the Dundrum town centre, results in a vibrant area which hosts many desirable residential and commercial amenities with multiple cafes, bars, restaurants, food retailed and leisure facilities such as gyms.

Beacon Hospital and the employment hub of Sandyford are just over 1km to the east.

The site is well connected with public transport services. Dublin bus routes 44, 44B and 116 serves the site along Sandyford road and routes 14, 14C, 75 and 175 serving the site along Wyckham Way. The site is 750m-950m from Balally Luas station and 1.4km from Kilmacud station on the Green Luas line.

National Policy Objective 13 It is clear that there is a strong emphasis towards In urban areas, planning and related increased building heights in appropriate locations standards, including in particular building within existing urban centres and along public height and car parking will be based on transport corridors. As such it is respectfully performance criteria that seek to achieve submitted that the proposed building height is in line well-designed high quality outcomes in with government guidance and emerging trends for order to achieve targeted growth. These sustainable residential developments. standards will be subject to a range of tolerance that enables alternative solutions to be proposed to achieve stated outcomes, provided public safety is not compromised and the environment is suitably protected.

National Policy Objective 27 Walking and cycling are prioritised throughout the Ensure the integration of safe and scheme with minimal vehicular access into the convenient alternatives to the car into the scheme and a high quality public realm. design of our communities, by prioritising walking and cycling accessibility to both This design has helped to create a safe pedestrian existing and proposed developments and friendly environment with numerous pedestrian and integrating physical activity facilities for all cycle routes through the scheme. This will make ages. walking and cycling attractive with good links into the wider area with its range of existing facilities and very good public transport. National Policy Objective 33 The proposed density is considered appropriate for Prioritise the provision of new homes at this site which is located within the established locations that can support sustainable residential area of Dundrum, in close proximity to the development and at an appropriate scale of Dundrum town centre and Ballinteer Stores. provision relative to location.

National Policy Objective 35 The proposed development will provide a high Increase residential density in settlements, density residential scheme on former institutional through a range of measures including lands within the existing built up area of Dundrum. reductions in vacancy, reuse of existing buildings, infill development schemes, area The proposal will bring this under-utilised site back or site-based regeneration and increased into use and will increase the residential density of building heights. the area.

EVALUATION OF CONSISTENCY The subject site is located within the metropolitan area of Dublin City which is identified for significant residential growth over the next two decades.

The proposed development seeks to deliver a significant quantum of residential development at a site that is located within a well-established suburban location within walking distance of a multitude of services, public transport options and amenities.

In addition to retail and employment locations, the site is well located with respect to primary and secondary schools. Secondary education centres St. Tiernan’s community school and Wesley college will have direct pedestrian connection to the site. Ballinteer Secondary school, and St. Benildus college are also present at an accessible distance of the site. 8 Primary schools fall within the 5- minute drive time catchment of the site.

Subject to formal agreement with DLRCC Ballawley Park and Playground will be accessible from the proposed development providing its residents access to multiple playgrounds and recreational area. Marley Park is within 2.4km of the site providing an additional wide range of outdoor recreation facilities. In addition, the site is 1.4km from dlr Meadowbrook Leisure (14 minutes’ walk) which has a gym, swimming pool, astro pitches.

The proposed development will provide for a high quality residential scheme through the design and the materials and finishes proposed. In addition, the proposed units are in meet the apartment size requirement as stated in the Apartment Guidelines.

Development of these lands is considered to be fully in accordance with the recommendations of the NPF.

REBUILDING IRELAND – ACTION PLAN FOR HOUSING AND HOMELESSNESS 2016 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. It was based on 5 no pillars. Pillar 3 – Build More Homes aims to increase the output of private housing to meet demand at affordable prices.

EVALUATION OF CONSISTENCY The proposed development is consistent with Pillar 3 to build more homes. The proposed development provides for 628 no. new build to rent apartment units. The provision of the 628 no. residential unit will add to a housing stock of the area and cater to the increasing demand for this existing urban area.

REGIONAL SPATIAL AND ECONOMIC STRATEGY 2019-2031 Under the Local Government Reform Act 2014 the Regional Planning Framework has been revised with the previous Regional Authorities/Assemblies (ten in total) now replaced with 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.

The Regional Spatial and Economic Strategy was adopted on the 28th June 2019 and is a strategic plan and investment framework to shape the future development of the eastern regional to 2031 and

beyond which is a new concept in Irish Planning tying spatial planning to economic factors. The region covers nine counties, Longford, Westmeath, Offaly, Laois, Louth, Meath, Kildare, Wicklow, and Dublin. The vision for the region is to “create a sustainable and competitive Region that supports the health and wellbeing of our people and places, from urban to rural, with access to quality housing, travel and employment opportunities for all.”

The RSES will support the implementation of Project Ireland 2040 – the National Planning Framework (NPF) and National Development Plan (NDP). It addresses employment, retail, housing, transport, water services, energy and communications, waste management, education, health, sports and community facilities, environment and heritage, landscape, sustainable development and climate change. The vision for the RSES is to create a sustainable and competitive region that supports the health and wellbeing of our people and places, from urban to rural, with access to quality housing, travel and employment opportunities for all. The RSES identifies that the Dublin Metropolitan Area is “to realise ambitious compact development targets at least 50% of all new homes within or contiguous to the existing built up area in Dublin and at least 30% in other metropolitan settlements.”

The RSES also sets out 16 Regional Spatial Objectives which align with the 3 key principles of the RSES and have been development to ensure that positive strategic environmental outcomes occur. Ten of which, the most relevant to this site, are set out below.

This document also identifies the public transport network ambitions for 2027 and the settlement strategy for the region. Dublin city and its suburbs are at the top of this hierarchy in terms of the need to ensure highly concentrated development in this highly accessible area.

Figure 1 Dublin Metropolitan Area

Figure 2 Public Transport Network for 2027

In section 4.4 of the RSES identifies that in order to achieve compact growth 50% of housing needs to be provided within or contiguous to the build-up area of Dublin City and suburbs. To achieve this the Metropolitan Area Strategic Plan identifies strategic residential and employment corridors along key public transport corridors, both existing and proposed. It also includes, in RPO 4.3 “support the consolidation and re-intensification of infill/ brownfield sites to provide high density and people intensive uses within the existing built up area of Dublin City and suburbs and ensure that the development of future development areas is co-ordinated with the delivery of key water infrastructure and public transport projects.”

Figure 3 Settlement Strategy

The guiding principles for growth in the Dublin Metropolitan area are set out in section 5.3 and include

• Compact sustainable growth and accelerated housing delivery – To promote sustainable consolidated growth of the Metropolitan Area, including brownfield and infill development, to achieve a target to 50% of all new homes within or contiguous to the built-up area of Dublin City and suburbs, and at least 30% in other settlements. To support a steady supply of sites and to accelerate housing supply, in order to achieve higher densities in urban built up areas, supported by improved services and public transport. • Integrated Transport and Land use – To focus growth along existing and proposed high quality public transport corridors and nodes on the expanding public transport network and to support the delivery and integration of ‘BusConnects’, DART expansion and LUAS extension programmes, and Metro Link, while maintaining the capacity and safety of strategic transport networks. • Metropolitan Scale Amenities – To enhance provision of regional parks and strategic Green Infrastructure, to develop an integrated network of metropolitan scale amenities, and to develop greenways/blueways along the canals, rivers and coast, as part of the implementation of the National Transport Authorities’ Cycle Network Plan for the Greater Dublin Area.

It also identified at RPO 5.3 that “Future development in the Dublin Metropolitan Area shall be planned and designed in a manner that facilitates sustainable travel patterns, with a particular focus on increasing the share of active modes (walking and cycling) and public transport use and creating a safe attractive street environment for pedestrians and cyclists.”

MASP Housing and Regeneration policy objective RPO 5.4 states that “Future development of strategic residential development areas within the Dublin Metropolitan area shall provide for higher densities and qualitative standards as set out in the ‘Sustainable Residential Development in Urban Areas’, ‘Sustainable Urban Housing; Design Standards for New Apartments’ Guidelines, and ‘Urban Development and Building Heights Guidelines for Planning Authorities’”

EVALUATION OF CONSISTENCY The subject development seeks to provide for residential development on a key urban infill site and to increase densities, heights and urban consolidation in this inner suburban location. The proposed development therefore is compliant with the overall policies and objectives of the RSES in this regard.

Dundrum has access to high quality public transport including excellent high frequency bus services and the green line Luas. It has excellent potential to promote sustainable mobility and achieve the vision of ‘walkable’ communities.

This proposed development will open up new links for the community through the Gort Muire lands creating new public open spaces and pedestrian and cycle connectivity that does not currently exist.

The proposal is for a Build to Rent development which will enhance the tenure mix in this area in line with the requirements of the RSES.

URBAN DEVELOPMENT & BUILDING HEIGHTS: GUIDELINES FOR PLANNING AUTHORITIES, 2018 The Guidelines set out national planning policy guidelines on building heights in urban areas in response to specific policy objectives set out in the National Planning Framework and Project Ireland 2040. There is a presumption in favour of high buildings at public transport nodes and state that it is Government policy to promote increased building height in locations with good public transport services.

Under Section 28 (1C) of the Planning and Development Act 2000 (as amended), Planning Authorities and An Bord Pleanála are required to have regard to the guidelines and apply any specific planning policy requirements (SPPR’s) of the guidelines in carrying out their function. SPPRs as stated in the Guidelines, take precedence over any conflicting, policies and objectives of development plans, local areas plan and strategic development zone planning schemes.

The Guidelines emphasise the policies of the NPF to increase levels of residential development in urban centres and increase building heights and overall density by both facilitating and encouraging the development of increased heights and densities by Local Authorities and An Bord Pleanála. It identifies the need to focus planning policy on “reusing previously developed “brownfield” land, building up urban infill sites”.

They place significant emphasis on promoting development within the existing urban footprint utilising the existing sustainable mobility corridors and networks. “In order to optimise the effectiveness of this investment in terms of improved and more sustainable mobility choices and enhanced opportunities and choices in access to housing, jobs, community and social infrastructure, development plans must actively plan for and bring about increased density and height of development within the footprint of our developing sustainable mobility corridors”. It goes on to highlight that “the preparation of development plans, local areas plans, and Strategic Development Zone Planning Schemes and their implementation in the city, metropolitan and wider urban areas must therefore become more proactive and more flexible in securing compact urban growth through a combination of both facilitating increased densities and building heights”.

Policy Evaluation of consistency Section 3.1 Development Management Principles The proposed development seeks to deliver a significant residential development at a site that is highly accessible in In relation to the assessment of individual terms of public transport with the Luas stop at Balally less planning applications and appeals, it is than 1km walk from the site and the area also served by high Government policy that building heights frequency bus services. must be generally increased in appropriate urban locations. There is therefore a The proposed development is also less than 1km from presumption in favour of buildings of Dundrum Town Centre the main retail and employment hub increased height in our town/city cores and in the area. The site also benefits from close proximity to 2 in other urban locations with good public large schools and a variety of other social infrastructure. transport accessibility. Planning authorities must apply the following broad principles in Furthermore, we note the following: considering development proposals for buildings taller than prevailing building • The proposed development secures the NPF heights in urban areas in pursuit of these objective of compact urban growth around high guidelines: quality public transport,

• The development accords with National Policy • Does the proposal positively assist Objective (NPO) 33 in delivering an appropriate scale in securing National Planning of sustainable residential development at a highly Framework objectives of focusing accessible location and that is provided with development in key urban centres significant social infrastructure and amenities. and in particular, fulfilling targets • The development accords with NPO 35 in achieving related to brownfield, infill higher density through increased building height of development and in particular, generally 3-9 storeys. effectively supporting the National Strategic Objective to deliver

compact growth in our urban • The development accords with NPO 13 in terms of centres? increasing building height and reducing car parking • Is the proposal in line with the to provide a high quality and high amenity residential requirements of the development development that at the same time achieves plan in force and which plan has compact urban growth at an accessible location. taken clear account of the • The development accords with NPO 27 in providing requirements set out in Chapter 2 of a development that is well served in terms of social these guidelines? infrastructure and convenience all within walking • Where the relevant development distance of the new homes, which reduces the need plan or local area plan pre-dates for the car and which also facilitates alternative these guidelines, can it be modes of transport (Luas, bus and cycle) to get to the demonstrated that implementation city centre and local district centres (Dundrum Town of the pre-existing policies and Centre, Sandyford and Carrickmines) for wider objectives of the relevant plan or services and employment. planning scheme does not align with and support the objectives and The policies and objectives of the DLRCC Development Plan (2016) as they relate to the subject lands are not considered policies of the National Planning to align or efficiently support the objectives and policies of the Framework? 2018 NPF and related Section 28 Guidelines.

The building height limits set down in the Building Heights Strategy and density range of 35-50 units per ha under Policy Section 3.2 Development Management RES5 are considered unduly restrictive and limit the potential Criteria for increased residential development at this highly accessible location, which is contrary to the principles of the NPF. In the event of making a planning application, the applicant shall demonstrate These policies also conflict with SPPR 1 of the Building Heights to the satisfaction of the Planning Authority/ Guidelines which states that plans should “not provide for An Bord Pleanála, that the proposed blanket numerical limitations on building height. “ development satisfies the following criteria: The site is well connected with public transport services. At the scale of relevant city/town: Dublin bus routes 44, 44B and 116 serves the site along -The site is well served by public transport Sandyford road and routes 14, 14C 75 and 175 serving the site with high capacity, frequent service, and along Wyckham Way. The site is c.900m from Balally Luas good links to other modes of public station. transport. Furthermore, the application site is located within “Corridor- F (Arklow – Wicklow – Greystones – Bray – Cherrywood – Dundrum – Dun Laoghaire – Dublin City Centre)”, in the inner metropolitan area. There are multiple upgrades in this area to both the DART and through bus connects all of which aim to create a modal shift to other modes of transport other than reliance on cars.

It is c. 600m from the Ballinteer stores with its range of local shops and chemists. In addition to this neighbourhood centre it is c.750m (10 minutes’ walk) from the Dundrum Town Centre, with its wide range of shopping facilities, restaurants and services, 1.5km (15 minutes’ walk) from SuperValu shopping centre, 1.4km from dlr Meadowbrook Leisure (14 minutes’ walk) which has a gym, swimming pool, astro pitches.

The site is also within a 15 minute walk of Dundrum village centre which has a library, banks, and other services, which

combined with the Dundrum town centre, results in a vibrant area which hosts many desirable residential and commercial amenities with multiple cafes, bars, restaurants, food retailed and leisure facilities such as gyms. Beacon Hospital and the employment hub of Sandyford is just over 1km to the east.

The site is also well located with respect to primary and secondary schools. Secondary education centres St. Tiernan’s community school and Wesley college will have direct pedestrian connection to the site. Ballinteer Secondary school, and St. Benildus college are also present at an accessible distance of the site. 8 Primary schools fall within the 5-minute drive time catchment of the site.

Ballawley Park and Playground will, subject to DLRCC agreement, be accessible from the proposed development providing its residents access to multiple playgrounds and recreational area. Finally, Marlay Park is within 2.4km of the site providing an additional wide range of outdoor recreation facilities.

The proposed development will provide for a high quality residential scheme through the design and the materials and finishes proposed. In addition, the proposed units meet the apartment size requirement as stated in the Apartment Guidelines.

• 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 is in line with government guidance and emerging trends for sustainable residential developments. At the scale of district/ neighbourhood/ The proposed development responds very positively to its street; context by fully incorporating the natural elements of the site - The proposal responds to its overall natural particularly the mature trees and hedgerows into a and built environment and makes a positive comprehensive landscape and open space design. This contribution. ensures that future residents will have direct access to a wide - The proposal is not monolithic and avoids variety of large open spaces for various recreational uses. long, uninterrupted walls of building. - The proposal enhances the urban design The development respects the built environment giving the context for public spaces and key historic buildings within the Carmelite Centre a new context thoroughfares. and opening them up to the public. In turn this helps create a - The proposal positively contributes to the unique sense of place and identity for the new development mix of uses and/ or building/ dwelling that is grounded in the history of the area. typologies. At the same time the development reflects the highly accessible and strategic location of the site. The site has the opportunity to create an appropriate scale of development that properly defines this location.

The architectural design is modern and visually interesting with a variety of designs and varying heights and finishes proposed. It is an innovative, attractive design appropriate for this location.

It is considered that the breaking up of the proposal into 7 blocks, along with the variation in heights from 3 rising at the southern edge rising up to 9 storeys in the centre of the site will ensure that this proposed development is not monolithic.

The proposal is largely a car free development which provides significant communal and public open space. A key design feature of this proposal is the future potential (subject to DLRCC agreement) to opening up of Ballawley Park to the wider community of Dundrum and Ballinteer by providing new pedestrian links through the development.

The development will significantly increase and improve the overall mix of residential types within the Dundrum/Ballinteer area as a whole and will establish a self-contained and self- sufficient, sustainable new urban community.

At the scale of the site/building: The submitted Sunlight/Daylight Report demonstrates that on - Maximise access to natural daylight, the 21st of March for the Proposed Scheme, all amenity areas ventilation and views and minimise receive more than 2 hours of sunlight on over 50% of their overshadowing and loss of light. area, thus exceeding the BER recommendations.

A Shadow, Daylight & Sunlight Impact Report has been prepared by Axiseng Consulting Engineers which confirms the following:

• There is no reduction in the garden spaces of adjoining residential properties at Parkvale & Wesley receiving sunlight as a result of the proposed development, and they will continue to receive 2 hours of sunlight on 21 March, and therefore are compliant with BRE guidance. • More than half of all proposed and existing amenities area situated between development buildings continue to receive 2 hours of sunlight on 21st March and therefore is comply with BRE’s 2011 guidance. • Garden and Open spaces situated outside the Carmelite Order Building Site continue to receive 2 hours of sunlight on 21 March and therefore the development is in compliance with the BRE’s 2011 guidance document Site Layout Planning for Daylight and Sunlight recommendation. • In relation to daylighting the vast majority of habitable rooms analysed are in line with guidance for living spaces having a minimum daylight factor of 1.5%. Less than 2.45% of living rooms do not achieve the minimum ADF target, with these rooms falling just slightly below the recommended levels. Furthermore, these rooms are mainly at lower levels or with balcony overhangs and yet still receive a good level of daylight. Specific Assessments: A wind study has been prepared and the general layout and -Specific impact assessment of the micro- height range is considered not to create any adverse climatic effects such measures to avoid/ conditions at ground level or within balconies, subject to mitigate such micro-climatic effects and, standard mitigation at certain locations such as the provision where appropriate, shall include an

assessment of the cumulative micro-climatic of canopies near main entrances, and specific landscape effects where taller buildings are clustered. measures. -Development locations in proximity to sensitive bird/bat areas need to consider the An EIAR and AA Screening Report (with all associated surveys) potential interaction of the building location, has been completed and submitted with the application. materials, and artificial lighting. -Relevant environmental assessment The EIAR concludes that the development will not result in requirements. any significant negative impact on the environment subject to mitigation measures.

The AA Screening Report concludes that there is no potential for meaningful connectivity to any other European Sites. Significant effects on any European sites as a result of the proposed Project can be ruled out and potential significant effects on European sites have been excluded at a preliminary screening stage.

SPPR 3 This proposal is in accordance with the NPF and associated It is a specific planning policy requirement Section 28 Guidelines, in terms of make the optimal that where; 1. an applicant for planning residential return of zoned, serviced and highly accessible permission sets out how a development land which is appropriately located in close proximity to public proposal complies with the criteria above; transport employment and social infrastructure. and 2. the assessment of the planning authority concurs, taking account of the wider strategic and national policy parameters set out in the National Planning Framework and these guidelines; then the planning authority may approve such development, even where specific objectives of the relevant development plan, local area plan or planning scheme may indicate otherwise.

EVALUATION OF CONSISTENCY It is considered that the subject site is an appropriate site for a development with heights up to 9 storeys. The proposal responds to its overall natural and built environment and it makes a positive contribution to the urban context, creating a new urban signpost within the Dundrum area.

The proposed development is set out in seven residential blocks located along two primary axis within the site. The materials and finishes of the proposed blocks will be designed to a high architectural standard. The materials and finishes have also been considered with regard to the surrounding existing pattern of development and material pallet in the locality. It is considered that the proposed development is in keeping with the character and building fabric of the area and will respect the adjoining protected structures.

The proposed development provides for significant new public open spaces within a scheme which is predominantly car free. It is respectfully submitted that the proposed development has had regard to the planning policy framework as set out in the building height guidelines and National Planning Framework. The provision of residential development at this location in blocks up to 9 storeys in height is supported by the height guidelines which encourages increased density and building heights. The proposed development complies with such objectives therefore is considered to be in accordance with the provisions of national policy guidelines.

GUIDELINES FOR PLANNING AUTHORITIES ON SUSTAINABLE RESIDENTIAL DEVELOPMENT IN URBAN AREAS, 2009

The guidelines set out the key planning principles to be reflected in development plans and local area plans, to guide the preparation and assessment of planning applications for residential development in urban areas.

The Guidelines elaborate a range of high-level aims for successful and sustainable residential development in urban areas. These are assessed against the proposed scheme as follows:

GUIDANCE EVALUATION OF CONSISTENCY

Prioritise walking, cycling and public The application site will be served by high quality walking transport, and minimise the need to and cycling links connecting the site to the surrounding use cars; environs including Dundrum Town Centre and the nearby bus and Balally Luas stop.

The development can provide (subject to DLRCC approval) a previously unavailable new connection between Dundrum/Ballinteer and Ballawley Park and Sandyford village. This will be in the form of a car-free public street where pedestrians and cyclists can travel safely through the heart of the scheme.

There are only 278 no. car parking spaces allocated as part of this scheme spaces and 21 no. Motorcycle spaces. While a total of 1,354 no. bicycle parking spaces are provided. Deliver a quality of life which residents The scheme has been designed to the highest residential and visitors are entitled to expect, in standard. All units accord with the quantitative and terms of amenity, safety and qualitative standards sets down in the national apartment convenience; guidelines and the DLRCC County Development Plan.

Future residents will live in a uniquely safe residential environment with streets free of cars and a multitude of access options to social infrastructure, open spaces and public transport in the area. Provide a good range of community The development will consist of apartments with the and support facilities, where and when following residential facilities: gym, creche, café, they are needed and that are easily residential amenities area, games room, music room, accessible; cinema/function room, and co-working space .

The development is well located in relation to existing/planned social infrastructure in the area in particular Dundrum Town Centre and Ballawley Park, it is a central location to Dublin, Wicklow/Dublin Mountains to the south and Dublin Bay to the north east. Present an attractive, well-maintained The layout of development has been designed to enhance appearance, with a distinct sense of the accessibility of the site and through the site. All of the place and a quality public realm that is routes through the development will provide increased easily maintained; connectivity to the area which is well overlooked. The

public realm proposed is high quality with a range of different spaces meeting varying needs throughout the development.

Are easy to access for all and to find There is one vehicle access into the site off Wyckham one’s way around; Avenue which leads into the heart of the development. There are additional pedestrian/ cycle access routes potentials into and through the site with a central landscaped area along with other landscaped character areas ensuring that the layout is logical, direct, interesting and wayfinding uncomplicated. A pedestrian link surrounds the development providing an open space network. Promote the efficient use of land and The proposal seeks to import best practice of energy, and minimise greenhouse construction/engineering techniques and use of energy gas emissions; efficient materials to maximise energy capacity and minimise impacts of climate change in accordance with current buildings regulations. Provide a mix of land uses to minimise The site is zoned for residential development which is transport demand; proposed. Support services in terms of the gym, creche, co-working space, cinema/function room, meeting room, and private dining with high quality outdoor spaces are also provided. The scheme is within 10 minute walk of Dundrum Town Centre and has ease of access to a variety of existing facilities in the Dundrum/ Ballinteer and Sandyford area. Promote social integration and provide A range of unit sizes is proposed for the scheme including accommodation for a diverse range of 1, 2 and 3 bedroom apartments. This mix of residential household types and age groups; unit types results in the mix in the general area being significantly improved. Enhance and protect the green The site comprises of an underutilised greenfield site. The infrastructure and biodiversity; and proposal will result in a significant improvement in the green landscaping and biodiversity of the area as the level of green infrastructure will be increased significantly. It will provide further connection to Ballawley Park (subject to DLRCC approval). Enhance and protect the built and The proposed development does not have any protected natural heritage. structures on the site, but it is located in close proximity to a range of protected structures. The proposal has been designed to ensure a sympathetic composition in relation to these buildings as well as the more modern surrounding buildings. An Architectural Heritage Assessment and an Archaeological Assessment are included within the EIAR. The layout of the site enhances the visibility of the neighbouring structures.

The Guidelines support a plan-led approach to the location, scale and nature of major residential development, as per the Planning and Development Act.

A sequential approach to the development of land is recommended with zoning to extend outwards from the centre of an urban area, and undeveloped and infill lands closest to the core and public transport routes being given preference.

The Guidelines promote urban design to create places of high quality and distinct identity, to provide connectivity, permeability, safety, legibility and sense of place.

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.

To ensure sustainable communities the Guidelines stress that community facilities are also to be provided for.

EVALUATION OF CONSISTENCY In relation to schools we note the following located in the immediate area, with even greater choice in a slightly wider district (not listed below): 1. St Tiernan’s Community School 2. St Attractas Junior National School 3. St Olafs National School 4. Queen of Angels Primary School 5. Taney National School 6. Holy Cross National School 7. Wesley College 8. Gaelscoil Na Fuinseoige 9. Ballinteer Educate Together National School 10. Ballinteer Community School 11. Scoil Naithi 12. Our Lady’s Girls’ National School 13. Na Maighdine Muire Girl

In relation to childcare facilities there are also many crèches and playschools within the area including: 1. Dundrum Montessori School and Afterschool 2. Handprints Montessori Preschool 3. Rathdown Community Playgroup 4. Clever Clogs Creche and Montessori 5. Care-Well Day Nursey and Montessori School 6. Once Upon a Time-Dundrum 7. Cool Kids Crèche Limited 8. Ballinteer Playschool 9. Absorbent Minds 10. Broadford Montessori Pre School 11. Naionra Dhun Droma 12. Naionra Naithi 13. Hillview Community Resource Centre

14. Little Willow Academy 15. Little Minnows Creche – Ballinteer 16. Narnia Nursery School

In relation to community centres, healthcare facilities and neighbourhood centre uses we note the site is within c. 500m of Dundrum Town Centre, which is a retail area, has a variety of community facilities including gyms, restaurants, shops and other leisure facilities. It is also worth noting the high quality facilities provided as part of this development such as the gym concierge and media rooms, games room and hot desk spaces.

In relation to density the subject lands are considered ‘adjacent to Public Transport Corridors’ under the Guidelines given the lands are located within c. 750-950 m of Balally Luas stop and within 300m of bus stops on Wyckham Way and the R826.

The Guidelines recommend minimum net densities of 50 units per hectare at such locations. The proposed density of the scheme is 180 units per ha net which is consistent with the guidelines and with similar SHD schemes granted by ABP in recent times.

URBAN DESIGN MANUAL – A BEST PRACTICE GUIDE, 2009 The Urban Design Manual is the accompanying document to the Sustainable Residential Development in Urban Areas document which provides policy guidance for the creation of successful neighbourhoods having regard to the 12 point criteria. The proposal complies with the following design criteria:

1. Context –How does the development respond to its surroundings? Evaluation of consistency The development seems to have evolved The site is strategically located beside Wyckham Way naturally as part of its surroundings. providing access to the M50 Motorway, Sandyford Road, the R117, Drummartin Road and the Balally Luas stop and Kilmacud Luas stop (Both Green Line). The proposed buildings continue the established building within Wyckham Avenue which comprise of high density apartments.

The massing of the development is in keeping with the surrounding buildings. The proposal sits comfortably within the setting of the surrounding built development and park land. Appropriate increases in density respect The proposal reflects the significant increases in the form of buildings and landscape densities and scale achieved in this area with the around the site’s edges and the amenity development of the Wyckham by-pass and the enjoyed by neighbouring users. adjoining apartment blocks, and indeed Dundrum Form, architecture and landscaping have Shopping Centre itself in the 2000s. been informed by the development’s place and time. The proposed development reflects a renewed trend for higher densities and scale on accessible and well serviced urban sites throughout Dublin City as promoted in the NPF and the RSES.

The site is unique in its context being originally within the grounds of the Gort Muire Carmelite Centre which

prior to the suburbanisation of the area, had established a complex of institutional buildings of scale and prominence in the South Dublin landscape.

The current proposal reflects and elaborates on this precedent providing a residential development that is modern not just in terms of design and density but also in terms of promoting a car free living environment with significant and safe open spaces for future residents.

The site is of an appropriate size and landscaping to facilitate the scale and layout of apartments proposed. The development positively contributes to The proposal is a striking design and layout which the character and identity of the reflects the historic institutional character of the lands neighbourhood. and the principles of large buildings set within a generous open space setting.

It will remove a vacant, underutilised site and transform it to a development that will contribute positively to the neighbourhood. Appropriate responses are made to the The development has been designed around the nature of specific boundary conditions. existing institutional buildings, the neighbouring schools and creating the potential for future links and access to Ballawley Park and the wider Sandyford area. This 9 storey building creates a new urban signpost for the area and a focal point at the centre of the new public street connecting Ballinteer/Dundrum to Ballawley and Sandyford (subject to DLRCC approval). The remainder of the scheme steps down to the south to 3 storeys nearest the existing residential estates. There are a number of existing mature trees that will be retained, which will significantly contribute to the landscaping of the scheme.

2. Connections – How well connected is the new development Evaluation of consistency There are attractive routes in and out for The site is accessed directly off Wyckham Avenue pedestrians and cyclists. which has existing connections to the existing pedestrian/cyclist network. The development can also provide new access points to Ballawley Park (subject to DLRCC approval), Wesley Lawns/Greenmount Lane, and to St. Tiernan’s Community School (subject to Dept of Education approval). The development is located in or close to The scheme will be located within c.750m of a mixed-use centre. Dundrum Town Centre and 500m to the Ballinteer stores. The development’s layout makes it easy The site is within 300m of several bus stops and 750 for a bus to serve the scheme. m – 950m from the Green Luas Line (Balally stop).

The layout links to existing movement Dedicated and safe pedestrian/cyclist permeability routes and the places people will want to through and around the site is enshrined in the get to. specific design and layout proposed. A new car-free public street will run through the centre of the site creating new connection potential with Ballawley Park (subject to DLRCC approval) and to the adjoining school and sports grounds (St Tiernan’s Community School) (subject to Dept of Education approval). The development can therefore provide direct connection between existing suburban areas that are currently poorly connected.

Appropriate density, dependent on The density accords with national guidelines which location, helps support efficient public promote higher density development in established transport. residential areas close to high quality public transport and local services. The lower levels of private car parking within this BTR scheme also enables this development to support the efficient use and maximise the sustainable use of public transport.

3. Inclusivity – How easily can people use and access the development? Evaluation of consistency New homes meet the aspirations of a The residential estates south of Gort Muire are range of people and households. predominantly large family houses with a poor typology mix to meet current/future needs of a diversifying population. The proposed BTR scheme will overall improve the mix of 1, 2 and 3 bed units on offer to the area and will facilitate a wider range of homeowners including individuals, couples, small families and empty nesters. Design and layout enable easy access by The proposal has been designed for ease of access all. throughout the site in accordance with Part M of the building regulations. There is a range of public, communal The scheme will provide a variety of open spaces, and/or private amenity spaces and public, communal and private amenity spaces for a facilities for children of different ages, range of different ages including children, adults and parents and the elderly. the elderly.

Outdoor gym equipment will be provided throughout along with an identified running route. Areas defined as public open space that The open spaces will be publicly accessible. Crossings have either been taken in charge or to these spaces will be denoted by a change in the privately managed will be clearly defined, landscaping and also through the provision of accessible and open to all. boundary walls/ fences. New buildings present a positive aspect to The layout is designed to maximise visual and physical passers-by, avoiding unnecessary physical fluidity throughout the scheme. From the CGI’s it can and visual barriers. be seen that the scheme will enhance the streetscape.

4. Variety – How does the development promote a good mix of activities? Evaluation of consistency Activities generated by the development The proposal will provide for a much more contribute to the quality of life in its sustainable housing mix within the area and will locality. increase population creating additional demand for educational, sports and retail services all of which are provided close to the development. Uses that attract the most people are in A variety of open spaces are provided throughout the the most accessible places. scheme and will be easily accessible to residents and the public. Neighbouring uses and activities are The area is characterised by residential uses; as such compatible with each other. the proposed use is compatible with the surrounding area. Housing types and tenure add to the A variety of apartments are provided which will choice available in the area. further improve the range of unit types in the area available to various household types. Please refer to the accommodation schedule for more information. Opportunities have been taken to provide The scheme is within 750m of Dundrum Town Centre, shops, facilities and services that it is therefore unnecessary to provide additional complement those already available in shops and services on site. the neighbourhood.

5. Efficiency - How does the development make appropriate use of resources, including land? Evaluation of consistency The proposal looks at the potential of The overall net density of 180 units/ha is considered higher density, taking into account wholly appropriate for this site given the proximity to appropriate accessibility by public public transport and social infrastructure. transport and the objectives of good design. Landscaped areas are designed to provide The restriction on parking enables more landscaping. amenity and biodiversity, protect As a result, significant open space will be provided buildings and spaces from the elements across the entire scheme incorporating SuDS, and incorporate sustainable urban promoting biodiversity (through extensive additional drainage systems. planting and bat friendly lighting for example) and providing residential amenity. Buildings, gardens and public spaces are The majority of the apartments across the scheme are laid out to exploit the best solar dual aspect. All units and open spaces will enjoy orientation. sufficient sunlight and daylight provision. This is further demonstrated by the Shadow and Sunlight Impact Report. The scheme brings a redundant building There are no buildings on the application site. or derelict site back into productive use. Appropriate recycling facilities are Communal recycling facilities are provided in the bin provided. stores strategically located proximate to each apartment block.

6. Distinctiveness - How do the proposals create a sense of place? Evaluation of consistency The place has recognisable features so The development is designed along two axes with a that people can describe where they live tall 9 storey building creating the focal point of the

and form an emotional attachment to the development. Given that the scheme is car free (east place. of the turning area to the front of Block A) then the spaces between the blocks along each axis operates as a large single public space comprising a series of urban pockets, all with varying characteristics, and all interconnected by a series of full landscape link spaces. This will be a very bespoke development with a unique sense of place The scheme is a positive addition to the The site is currently vacant. The proposal will provide identity of the locality. an appropriate scale and quantum of residential development on a key site adjacent to Dundrum Town Centre and close to excellent public transport services.

The character and identity of the area is mixed with apartments and commercial development to the north and low density suburban estates to the south, but with generous public spaces and well provided for in terms of social infrastructure.

The proposed development will be a very positive addition to the area providing in the first instance a new public route for pedestrians and cyclists through the development and connecting the current poorly integrated areas of Ballinteer/Dundrum and Balally/Sandyford. The development will create a new focal point in the area marking the new connection. The layout makes the most of the The proposed layout adapts to the site boundaries opportunities presented by existing and its constraints and seeks to develop them as a buildings, landform and ecological feature within the new residential scheme. It also features to create a memorable layout. takes advantage of the existing trees along the southern boundary and retains these mature trees in order to develop an appropriate, high quality scheme.

The focal points of the development features the taller buildings at Marmalade Triangle and the main street providing a new connection to Ballawley Park (subject to DLRCC approval).

The proposal successfully exploits views Many views into the site are constrained due to a into and out of the site. combination of existing mature planting along the boundary of the site and within adjoining open spaces, and also due to existing building include the Carmelite Centre and apartment developments.

As a result, there is greater potential for building height to be achieved in general without significantly impacting views from some locations.

At the same time there is a need to mark and signpost the establishment of a new place within the existing milieu, particularly given that it will create a new street and pedestrian connection between existing settlements. For this reason, the inclusion of taller buildings within the centre of the site will create a new focal point within the wider views of the area.

There is a discernible focal point to the The taller buildings in the centre of the site, the scheme, or the proposals reinforce the central pedestrian street and main central open space role of an existing centre. – The Marmalade Triangle - are the focal points for the development, providing permeability and views into the and through the development.

7. Layout - How does the proposal create people friendly streets and spaces? Evaluation of consistency Layout aligns routes with desire lines to Pedestrian permeability across the scheme and create a permeable interconnected series between adjoining residential apartments blocks of routes that are easy and logical to within the scheme, and through to the apartment navigate around. communal facilities along is a key design outcome. A number of new links into the lands are provided for the first time. The layout focuses activity on the streets The apartment scheme provides frontages that by creating frontages with front doors contributes to passive surveillance of the public open directly serving the street. spaces within the scheme and pedestrian access The streets are designed as places instead paths. The design and shape of the 7 no. apartment of roads for cars, helping to create a blocks also encourages multiple viewpoints of the hierarchy of space with less busy routes open space to the rear, ensuring the passive having surfaces shared by pedestrians, surveillance is achieved. cyclists and drivers. Traffic speeds are controlled by design 278 car parking spaces are provided within the and layout rather than by speed humps. scheme but with cars diverted to the basement on entering the scheme from the north-west. This results in an apartment development without cars or vehicular road, but rather a network of open spaces between the blocks connecting a series of squares all designed with unique characteristics.

Block layout places some public spaces in The open space strategy for the scheme creates front of building lines as squares or multiple open space areas of varying uses and sizes. greens, and some semi-private space to This can be seen in the landscaping strategy by NMP the back as communal court. Landscape Architects.

8. Public Realm - How safe, secure and enjoyable are the public areas? Evaluation of consistency All public open space is overlooked by All spaces are overlooked by surrounding apartment surrounding homes so that this amenity is blocks. owned by the residents and safe to use.

The public realm is considered as a usable Creation of a car fee public realm for pedestrians and integrated element in the design of the cyclists to traverse unhindered is a central design development. outcome and will be unique to residential development in Ireland. By eliminating the car and the basement from the centre of the scheme, the landscaping and design of the public realm can be solely dedicated to providing the optimum for residents of all size in terms of recreational opportunities.

Children’s play areas are sited where they Play areas are provided as detailed in the landscape will be overlooked, safe and contribute to masterplan. In addition, there are existing play the amenities of the neighbourhood. facilities in Ballawley Park. There is a clear definition between public, Private open space is provided with balconies and semi-private, and private space. terraces. Communal open spaces for residents are located in courtyards next to each block and is clearly defined (in soft landscaping) from the public open spaces which comprise a series of parks interconnected by wide, car free, and fully landscaped pedestrian streets. Roads and parking areas are considered Within this unique scheme the private car is as an integral landscaped element in the eliminated from the core of the development design of the public realm. allowing the main streets to be fully dedicated to pedestrians and cyclists (albeit with the provision for service/emergency vehicles to get to individual blocks).

9. Adaptability - How will the buildings cope with change? Evaluation of consistency Designs exploit good practice lessons, N/A. This is an apartment development. such as the knowledge that certain house types are proven to be ideal for adaptation. The homes are energy-efficient and Yes, design practices and proposed materials will equipped for challenges anticipates from reduce the effects of climate change. a changing climate. Homes can be extended without ruining N/A the character of the types, layout and outdoor space. The structure of the home and its loose fit N/A design allows for adaptation and subdivision, such as the creation of an annex or small office. Space in the roof or garage can be easily N/A converted into living accommodation.

10. Privacy and Amenity - How does the scheme provide a decent standard of amenity? Evaluation of consistency Each home has access to an area of Yes, each unit has its own private open space in useable private outdoor space. accordance with the minimum residential standards as per the national apartment guidelines. The design maximises the number of The majority have dual aspect which accords with homes enjoying dual aspect. national policy. Homes are designed to prevent sound All units will be designed to prevent sound transmission by appropriate acoustic transmission in accordance with building regulations. insulation or layout. Windows are sited to avoid views into the Adequate separation distance between opposing home from other houses or the street and windows is achieved and overlooking is not adequate privacy is affordable to ground considered an issue of the development particularly floor units. in relation to adjoining development. The homes are designed to provide All apartments are designed in accordance with adequate storage including space within national design standards on storage areas. the home for the sorting and storage of recyclables.

11. Parking – How will the parking be secure and attractive? EVALUATION OF CONSISTENCY Appropriate car parking is on-street or The underground parking is secure and readily within easy reach of the home’s front accessible for all residents who choose to use this door. facility. This is a highly accessible location so the demand for car storage is reduced in locations such as these. This is in line with current NPF policy. Please see the Traffic and Transport Assessment for further details. Parked cars are overlooked by houses, All of the parking is either visible from the apartments pedestrians and traffic, or stored securely, or is within a secure underground car park. with a choice of parking appropriate to the situation. Parking is provided communally to 95% of the car parking is in a communal underground maximise efficiency and accommodate car park visitors without the need to provide additional dedicated spaces. Materials used for parking areas are of Yes, the highest quality materials will be used similar quality to the rest of the throughout the scheme. development. Adequate secure facilities are provided for Dedicated bicycle parking is provided throughout the bicycle storage. scheme. There are 1,354 no. bicycle parking spaces provided in line with the Design Standards for New Apartments.

12. Detailed Design – How well thought through is the building and landscape design? Evaluation of consistency The materials and external design make a The proposed development uses a controlled palette of positive contribution to the locality. materials. Please see the architect’s drawings for further details. The landscape design facilitates the use of The open spaces will be provided once all the the public spaces from the outset. apartments blocks are completed.

Design of the buildings and public space This can be achieved and will be provided by the estate will facilitate easy and regular management company. maintenance. Open car parking areas are considered as Parking is predominantly at underground level and is an integral element within the public limited in favour of providing high quality landscaped realm design and are treated accordingly. open space. Care has been taken over the siting of Bin stores are located discretely around the site. No flues, vents and bin stores. other flues or vents are proposed.

QUALITY HOUSING FOR SUSTAINABLE COMMUNITIES: BEST PRACTICE GUIDELINES FOR SUSTAINABLE COMMUNITIES, 2007 The Department’s policy statement Delivering Homes, Sustaining Communities, Guidance provides the overarching policy framework for an integrated approach to housing and planning. 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 policy statement is accompanied by Best Practice Guidelines that promotes quality sustainable residential development in urban areas having regard to the following:

• promote high standards in the design and construction and in the provision of residential amenity and services in new housing schemes; • encourage best use of building land and optimal 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 schemes 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.

The following criteria indicate the 7 no. essential requirements new residential developments should have regard to when carrying out development:

EVALUATION OF CONSISTENCY Socially & Environmentally Appropriate The scheme will provide an appropriate mix of 1, 2 “The type of accommodation, support and 3 bedroom apartments. The proposal seeks to services and amenities provided should be integrate usable open spaces distributed appropriate to the needs of the people to be throughout a number of character areas and all accommodated. The mix of dwelling type, size interconnected. All open spaces will be overlooked and tenure should support sound social, by adjoining dwellings. environmental and economic sustainability policy objectives for the area and promote the development of appropriately integrated play and recreation spaces.”

Architecturally Appropriate The design and layout of the scheme creates a “The scheme should provide a pleasant living liveable and visually pleasing residential environment, which is aesthetically pleasing environment. and human in scale. The scheme design solution should understand and respond The design is appropriate and mindful of the urban appropriately to its context so that the edge context, the site constraints, and architectural development will enhance the character of the adjoining residential areas neighbourhood and respect its cultural heritage.” Accessible & Adaptable The dwellings in this scheme are highly accessible to “There should be ease of access and all due to the provision of lifts within the scheme. circulation for all residents, including people The landscaping is clearly laid out and level ensuring with impaired mobility, enabling them to people can use it easily. move as freely as possible within and through the development, to gain access to buildings This scheme limits the access of vehicles in the and to use the services and amenities scheme creating a safe, pedestrian dominated provided. Dwellings should be capable of development. A single vehicular access and only 278 adaptation to meet changing needs of no. car parking spaces will be provided. Several residents during the course of their lifetime.” pedestrian/cyclist connections area provided and there will be 1,354 no. bicycle parking spaces

Safe, Secure & Healthy The scheme provides good segregation of vehicle “The scheme should be a safe and healthy and pedestrian/cyclists with the vast majority of the place in which to live. It should be possible for site free from cars. pedestrians and cyclists to move within and through the area with reasonable ease and in A very safe walking and cycling environment will be safety. Provision for vehicular circulation, provided for residents with a network of paths including access for service vehicles, should located around the development. not compromise these objectives.” Public Open Space shall be overlooked as far as practicable to achieve maximum passive Affordable surveillance. “The scheme should be capable of being built, managed and maintained at reasonable cost, having regard to the nature of the development.” Durable The scheme endeavours to use the best available “The best available construction techniques materials and construction techniques in order to should be used, and key elements of minimise the level of refurbishment over the construction should have a service life in the lifetime of the scheme. order of sixty years without the need for abnormal repair or replacement works. Resource Efficient The scheme is considered to accord with the “Efficient use should be made of land, aforementioned sustainable development infrastructure and energy. The location principles. should be convenient to transport, services and amenities. Design and orientation of dwellings should take account of site topography so as to control negative wind effects and minimise the benefits of sunlight, daylight and solar gain; optimum use should

be made of renewable sources of energy, the use of scarce natural resources in the construction, maintenance and management of the dwellings should be minimised.”

SUSTAINABLE URBAN HOUSING: DESIGN STANDARDS FOR NEW APARTMENTS, 2018

The Apartment Guidelines 2018 promote sustainable housing, by ensuring that the design and layout of new apartments provide satisfactory accommodation for a variety of household types and sizes, including families with children over the medium to long term. The guidelines provide for updated guidance on apartment developments in response to the National Planning Framework and Rebuilding Ireland.

In relation to appropriate locations for apartment developments and increased density the Guidelines 3 urban location types. “Central and/or Accessible Urban Locations” are identified as those which can accommodate large scale, and higher density developments and wholly comprises apartments. Such locations are within 15 mins walk of significant employment locations and 10 mins walk of Luas, DART and/or high frequency bus services.

The subject site is located within an “Accessible Urban Location” due to its proximity to high capacity urban public transport stop in the form of the Luas Green Line (Balally stop) along with its accessibility to a high frequency bus route both of which are within 5-10 minute walk of the site. The site is also within 10 minutes’ walk of Dundrum town centre which is a significant employment hub. As a result, the apartment scheme and proposed density is considered appropriate for this location.

The Guidelines outline a number of Specific Planning Policy Requirements (SPPRs) which are design standards that apartment developments nationally are expected to adhere to. SPPR 1 – 6 outline the standards that apply to private apartment development in relation to mix, unit size, aspect, floor to ceiling heights, and units per core.

However, for Build to Rent developments, which are identified as such in planning, there are relaxations of several of these SPPRs. The expectation is the minimum unit size (SPPR 3) which we note this proposal accords with as per the Housing Quality Audit submitted with the application.

SPPR 7 outlines the requirements for BTR developments and is assessed below:

SPPR 7 Evaluation of consistency BTR development must be: (a) Described in the public notices associated with a The current proposal is for a Build to Rent planning application specifically as a ‘Build-To- apartment development for long term rental and Rent’ housing development that is clearly identified as such in the statutory unambiguously categorises the project (or part planning notices. of thereof) as a long-term rental housing scheme, to be accompanied by a proposed The applicant accepts that conditions will be covenant or legal agreement further to which added in the granting of permission requiring the appropriate planning conditions may be development to remain owned and operated by attached to any grant of permission to ensure an institutional entity for at least 15 years and that that the development remains as such. Such no individual residential units are sold or rented conditions include a requirement that the separately for that period. development remains owned and operated by

an institutional entity and that this status will The BTR proposal includes residential support continue to apply for a minimum period of not facilities and amenities including a residential less than 15 years and that similarly no amenities area, creche, grab n go, café, co-working individual residential units are sold or rented space, games room, music room, cinema/function separately for that period; room, meeting room, dog grooming, private (b) Accompanied by detailed proposals for dining, gym, residents lounge, shared stores, supporting communal and recreational breakout spaces amenities to be provided as part of the BTR development. These facilities to be categorised as: (i) Resident Support Facilities - comprising of facilities related to the operation of the development for residents such as laundry facilities, concierge and management facilities, maintenance/repair services, waste management facilities, etc. (ii) Resident Services and Amenities – comprising of facilities for communal recreational and other activities by residents including sports facilities, shared TV/lounge areas, work/study spaces, function rooms for use as private dining and kitchen facilities, etc. For proposals that qualify as specific BTR development in accordance with SPPR 7: (i) The development proposed 44% 1- (i) No restrictions on dwelling mix beds; 51% 2-beds and 5 % 3-bed and all other requirements of apartments. these Guidelines shall apply, (ii) Notwithstanding that it is a BTR unless specified otherwise; scheme all units are provided with (ii) Flexibility shall apply in relation to the provision of a proportion of private open space and storage areas the storage and private amenity to standard within each unit. 5,135 space associated with individual sq.m of communal open space is also units as set out in Appendix 1 and provided. in relation to the provision of all of (iii) The development comprises 278 no. the communal amenity space as car parking spaces. This represents a set out in Appendix 1, on the basis parking ratio of 0.44 spaces per unit. of the provision of alternative, compensatory communal support This compares favourably to other facilities and amenities within the BTR schemes granted by ABP. In development. This shall be at the addition, a total of 1,354 bicycle discretion of the planning parking spaces are provided which authority. In all cases the equate to 2.16 spaces per unit and in obligation will be on the project compliance with national standards. proposer to demonstrate the (iv) This is noted and is not provided for. overall quality of the facilities provided and that residents will (v) Whilst most blocks have under 12 enjoy an enhanced overall units per core in some instances there standard of amenity; are up to 15 units per core. (iii) There shall be a default of minimal or significantly reduced car parking provision on the basis of

BTR development being more suitable for central locations and/or proximity to public transport services. The requirement for a BTR scheme to have a strong central management regime is intended to contribute to the capacity to establish and operate shared mobility measures; (iv) The requirement that the majority of all apartments in a proposed scheme exceed the minimum floor area standards by a minimum of 10% shall not apply to BTR schemes; (v) The requirement for a maximum of 12 apartments per floor per core shall not apply to BTR schemes, subject to overall design quality and compliance with building regulations.

DESIGN MANUAL FOR URBAN ROADS & STREETS (DMURS), 2019 The Design Manual for Urban Roads and Streets (DMURS), was first published in 2013 and has since been updated in May 2019. This document 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.

Evaluation of Consistency The proposed design approach successfully achieves the appropriate balance between the functional requirements of different network users whilst enhancing the sense of place. The implementation of a low parking and shared car provision actively promotes a modal shift to alternative forms of transport while also creating high quality public open space in the area. The scheme prioritises pedestrians and cyclists through the development using predominantly car free streets throughout. Vehicular access into the heart of the scheme is limited to emergency and service vehicles (controlled access). Permeability for cyclists and pedestrians is therefore prioritised.

GUIDELINES FOR PLANNING AUTHORITIES ON CHILDCARE FACILITIES, 2001 These guidelines state that Development Plans should facilitate the provision of childcare facilities in larger new housing estates with the standard minimum provision of one childcare facility with 20 places for each 75 dwellings.

Section 4.7 of the Sustainable Urban Housing Design Guidelines for New Apartments, 2018 states the following:

“Notwithstanding the Planning Guidelines for Childcare Facilities (2001), in respect of which a review is to be progressed, and which recommend the provision of one child-care facility (equivalent to a minimum of 20 child places) for every 75 dwelling units, the threshold for provision of any such facilities in apartment schemes 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 of the area. 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.”

Evaluation of Consistency In line with these guidelines a creche of 620 sq.m is proposed within this development which will cater for future demand created by the proposed development, which based on the 2001 Guidelines would be c.167 spaces.

SMARTER TRAVEL – A SUSTAINABLE TRANSPORT FUTURE: A NEW TRANSPORT POLICY FOR IRELAND 2009-2020 Key targets of this national sustainable transport policy include:

• To support sustainable travel, future population and employment growth will have to predominantly take place in sustainable compact urban areas or rural areas, which discourage dispersed development and long commuting • Work-related commuting by car will be reduced from a current modal share of 65% to 45%, which will mean that between 500,000 and 600,000 commuters will be encouraged to take means of transport other than car driver (of these 200,000 would be existing car drivers). Change in personal behaviour will also be necessary for other travel purposes as most travel relates to non- commuting. • Car drivers will be accommodated on other modes such as walking, cycling, public transport and car sharing (to the extent that commuting by these modes will rise to 55% by 2020) or through other measures such as e-working. • The total kilometres travelled by the car fleet in 2020 will not increase significantly from current total car kilometres.

Evaluation of Consistency The proposed development is in line with this overall vision for better integration between land-use and transport. The reduced car parking provision along with the site’s proximity to high-quality public transport – the Luas (Balally stop) and numerous bus stops ensure that there will be a modal shift amongst residence in this scheme to try alternative modes of transport and reduce reliance on the private car.

TRANSPORT STRATEGY FOR THE GREATER DUBLIN AREA 2016-2035 The NTA Strategy promotes the consolidation of the Metropolitan Dublin area (where the application is located) 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. This document identifies under its primary policy, in section 2.2 that “the Strategy must therefore, promote, within its legislative remit, transport options which provide for unit reductions in carbon emissions. This can most effectively be done by promoting public transport, walking and cycling, and by actively seeking to reduce car use in circumstances where alternative options are available.”

Evaluation of Consistency The application site is located within “Corridor-F (Arklow – Wicklow – Greystones – Bray – Cherrywood – Dundrum – Dun Laoghaire – Dublin City Centre)”, in the inner metropolitan area. There are multiple upgrades in this area to both the DART and through bus connects all of which aim to create a modal shift to other modes of transport other than reliance on cars.

Section 7 states that “the implementation of the Strategy will facilitate a more efficient use of land within the GDA. By focussing public transport investment, and investment in the cycling and pedestrian network, into the city centre, major suburban centres and hinterland growth towns, the Strategy will complement national, regional and local planning policy by promoting and enabling the consolidation of development into higher order centres… In terms of the provision of housing, the Strategy will directly enable the sustainable development of strategically important residential sites, particularly in Metropolitan Dublin, where demand is highest.”

This proposed development, due to its location to the Green line, is in line with the ambitions of this policy.

GUIDELINES FOR PLANNING AUTHORITIES ON THE PLANNING SYSTEM AND FLOOD RISK MANAGEMENT, 2009 These guidelines require the planning system 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.

The Guidelines 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.

Evaluation of Consistency The development is not located within proximity to the Irish Sea and is therefore not considered to be at significant risk of coastal flooring. The site is located some c. 6km from Dublin Bay. The study indicates that the development is not at risk from a 1 in 1000 year coastal event.

The site is also situated outside the Flood Zones A and B. Please see the Site Specific Flood Risk Assessment by Punch for a full assessment.

CLIMATE ACTION PLAN 2019 The Department of Communications, Climate Action and Environment published the Climate Action Plan 2019, which aims to make Ireland a leader in responding to climate disruption. This Action Plan acknowledges the impact of climate change and that the window of opportunity to act is fast closing and that decarbonisation is now a must if the world is to contain the damage and build resilience in the face of such a profound challenge. The Action Plan includes the following objectives: • Increase reliance on renewables from 30% to 70% adding 12GW of renewable energy capacity • Increase attention to Energy and Carbon ratings in all aspects of managing property assets. • Make growth less transport intensive through better planning, remote and home-working and modal shift to public transport.

• A target of 55% renewable power and at least 500,000 electric vehicles on the road by 2030. • Reduced travel distances and greater proximity to employment and services, which will enable a greater proportion of journeys by bike or on foot (zero emissions) • Greater urban density, which when combined with the point above, will ensure more viable public transport (less emissions per person than by individual vehicle) • Greater sustainable mode share, which will enable cities and towns to densify, as development will not be dependent on road capacity nor car parking requirements, and less land will be required for the latter • Closer proximity of multi-storey and terraced buildings, which will require less energy and make renewables-based systems of energy distribution such as district heating, or area-wide technology upgrades, more feasible

The Action Plan notes that the built environment accounted for 12.7% of Ireland’s greenhouse gas emissions in 2017 and it is therefore important that we improve the energy efficiency of our buildings. Ireland’s dispersed settlement pattern and low population density are identified as challenges specific to Ireland that need to be addressed reduce transport emissions. Actions to address spatial planning and urban form of development are required to aid the transition to a low carbon and climate resilient society. Evaluation of Consistency The proposed high density development will provide housing within the existing built up area and help to counter to counter urban sprawl into greenfield areas outside the city. The future population of this development will help to support bus services and existing facilities in the area and make providing further bus services and facilities to the area more viable. This in turn will help to reduce greenhouse gas emissions from transport and help Ireland to achieve our climate change goals.

A reduced car parking ration has been provided to encourage the modal shift away from private cars to more sustainable modes of transport such as walking, cyclist and public transport. In reflection of this modal shirt a total of 1,354 no. bicycle parking spaces are provided within the scheme. The scheme will also facilitate e-scooters and e-bike charging (as detailed in letters from such providers appended to the Mobility Management Plan).

3 LOCAL PLANNING POLICY

DUN LAOGHAIRE RATHDOWN COUNTY DEVELOPMENT PLAN 2016-22

The site is located within the administrative area of Dun Laoghaire Rathdown County Council and is therefore subject to the land use policies and objectives of the County Development Plan 2016-2022.

Core & Settlement Strategy The central focus of the Core Strategy is on ‘residential development and in ensuring that there is an acceptable equilibrium between the supply of zoned, serviced land for residential development and the projected demand for new housing, over the lifetime of the Plan’. A key strand of the overall Settlement Strategy focuses on the ‘continued promotion of sustainable development through positively encouraging consolidation and densification of the existing urban/suburban built form – and thereby maximizing efficiencies from already established physical and social infrastructure.’ In addition, the ‘Ongoing incremental infill and densification of the existing urban areas’ is expected to generate significant additional residential quantum particularly where sites are located close to public transport and services.

Evaluation of Consistency Dundrum is designated a “Major Centre” in the Core Strategy Map (Figure 1.1). The subject site is located within an area identified in Figure 1.3 of the Core Strategy as part of a 410 ha area of serviced land that is expected to deliver 18,000 residential units. The proposed development will provide 628 no. residential units on this site which will contribute to the delivery of housing in the existing built up area of Dundrum.

The proposed development, on zoned and serviced land accords with the Core and Settlement Strategy for future significant residential growth in the County.

Zoning The site is zoned ‘Objective A’ (To protect and/or improve residential amenity). Residential and the ancillary uses proposed are all permitted uses. #

Zoning Objective A ‘To protect and/or improve residential amenity’ Permitted in Principle Assisted Living Accommodation, Open Space, Public Services, Residential, Residential Institution, Travellers Accommodation. Open for Consideration Allotments, Bring Banks/Bring Centres, Carpark, Caravan Park-Holiday, Caravan Park-Residential, Cemetery, Community Facility, Childcare Service, Cultural Use, Doctor/Dentist etc., Education, Embassy, Enterprise Centre, Funeral Home, Garden Centre/Plant Nursery, Guest House, Health Centre / Healthcare Facility, Home Based Economic Activities, Hotel/Motel, Household Fuel Depot, Industry-Light, Part Off-License, Office Based Industry , Offices less than 200sq.m., Petrol Station, Place of Public Worship, Public House, Restaurant, Service Garage, Shop Neighbourhood, Sports Facility, Tea Room/Café, Veterinary Surgery.

Evaluation of Consistency The proposed development will provide a residential scheme on this land zoned for residential development. The proposal is therefore considered to be acceptable in principle on these lands.

In addition to the land use zoning, the zoning map identifies trees for protection and protected structures within the vicinity of the subject site.

There are a number of significant mature trees along the boundaries of the site which in the main are being retained and will form part of the landscape masterplan for the site. The application includes a tree survey and arboricultural assessment in this regard.

Whilst there are no protected structures on the subject site it is adjacent the ‘Gort Muire Centre’ (RPS No. 1453) which is listed in the Record of Protected Structures in Appendix 4 of the Plan. The protected structure is described as ‘water gardens, garden walls and farm building complex, house, ornamental ironwork, conservatory and water tower’. It is noted that the walled garden and farm building complex formed part of a recent SHD permission for apartment development on lands to the north-west of the site, and which is understood to be under construction. The remaining elements of the protected structure are located within the remaining Carmelite Centre lands adjacent the application site. These include the main original house, conservatory, water tower and water gardens. The proposed development will be located directly adjacent the water tower (a 19th century folly of a medieval tower) which will be located on the western side of the main entrance to the scheme. The architectural heritage impact of the proposed development is assessed in the EIAR.

The Gort Muire lands are also subject to a “Institutional” designation. Policy RES5 states:

“Where distinct parcels of land are in institutional use (such as education, residential or other such uses) and are proposed for redevelopment, it is Council policy to retain the open character and/or recreational amenity of these lands wherever possible, subject to the context of the quantity of provision of existing open space in the general environs.”

Section 2.1.3.5 states

“It is recognised that many institutions in Dun Laoghaire-Rathdown are undergoing change for various reasons. Protecting and facilitating the open and landscaped ‘parkland’ settings and the activities of these institutions is encouraged. Where a well-established institution plans to close, rationalise or relocate, the Council will endeavour to reserve the use of the lands for other institutional uses, especially if the site has an open and landscaped setting and recreational amenities are provided. Where no demand for an alternative institutional use is evident or foreseen, the Council may permit alternative uses subject to the zoning objectives of the area and the open character of the lands being retained.”

Sections 2.1.3.5 and 8.2.3.4(xi) elaborate a range of other objectives where an institution plans to cease or rationalise related to master planning, public open spaces provision and landscape provision. The key objectives of these two sections are outlined in the table below.

Section 2.1.3.5 Evaluation of Consistency A minimum open space provision of 25% of As detailed on Page 18 of the Landscape Design the total site area (or a population based Statement prepared by NMP Landscape Architects provision in accordance with Section 8.2.8.2 the gross open space provision (comprising the whichever is the greater) will be required on public open spaces, communal open spaces (at Institutional Lands. This provision must be grade), and pedestrian parades) totals c.24,185 sq.m sufficient to maintain the open character of or 2.42ha (c.19,606.5 sq.m + 4,578.58 sq.m). the site with development proposals structured around existing features and This represents c.69% of the net site area (measured layout, particularly by reference to retention as c.3.49 ha, excluding the existing access route into of trees, boundary walls and other features the Carmelite Centre from Wyckham Avenue). This as considered necessary by the Council. open space provision provides for retention of a significant number of trees and natural boundaries as Note: This objective is repeated in Section is required by the Development Plan. 8.2.3.4 (xi) The net open space provision (i.e. the public and communal open spaces (at grade) minus the pedestrian parades) is c.13,137 sq.m (c.1.3ha) (4,578.58 sq.m + 8559 sq.m) which represents 37% of the net application site area. These open spaces include the Marmalade Triangle at the heart of the site and a number of other open spaces dispersed throughout the development.

Average net densities should be in the The proposed development will provide a density of region of 35 - 50 units p/ha. In certain 180 uph, which is in line with the NPF and the 2018 instances, higher densities will be allowed Apartment Guidelines. where it is demonstrated that they can contribute towards the objective of The proposed development will provide a high- retaining the open character and/or quality environment for both residents and the wider recreational amenities of the lands. area. The scheme will facilitate connections through to Ballawley Park (subject to DLRCC approval) which will both increase the permeability of the site and provide a more direct route to the Park for existing residents living in the area. Section 8.2.3.4 (xi) Evaluation of Consistency The principal aims of any eventual The proposed development will provide a redevelopment of these lands will be to sustainable residential development within close achieve a sustainable amount of proximity to existing facilities, services, amenities development while ensuring the essential and public transport links. setting of the lands and the integrity of the main buildings are retained. There are no existing buildings on the subject site. The proposed development is located adjacent to the Gort Muire Centre which contains protected structures. The proposed scheme has been designed to ensure that these protected buildings will not be negatively impacted by the proposed development. In order to promote a high standard of The proposed development includes an overall site development a comprehensive masterplan layout plan, and a variety of CGIs and illustrations should accompany a planning application for which demonstrates the relationship between the institutional sites. Such a masterplan must

adequately take account of the built proposed development and the existing built and heritage and natural assets of a site and natural heritage on the site and adjacent to the site. established recreational use patterns. It is noted that the subject site was never formally landscaped and never formed part of the formal recreational amenity area for the Carmelite Centre Public access to all or some of the lands may The proposed development will facilitate a public link be required. through the site from Wyckham Avenue to Ballawley Park (subject to DLRCC approval). The scheme will very much be an “open” development with free access for the wider community. On Institutional Lands where existing school The subject site does not include any existing school uses will be retained, any proposed buildings. St. Tiernan’s Community School is located residential development shall have regard north of the site, but the development of the subject to the future needs of the school and allow site will not impact on future expansion of the school. sufficient space to be retained adjacent to There are further undeveloped lands north of the the school for possible future school school which provide a more suitable location for any expansion/ redevelopment. necessary school expansions. With regard to the subject development site it is noted that it originally formed part of the Gort Muire Carmelite Centre landholding. However, it remained as a fenced off, agricultural field during that time and was never formally landscaped as part of the attendant grounds of the main complex of buildings. Equally it never formed part of the formal recreational amenity area for the Carmelite Centre.

It is noted that the original Carmelite Centre lands were extensive and previously several other plots were also sold for redevelopment. This includes the lands to the north of the Carmelite Centre which were developed for the Wyckham Bypass and associated apartment developments, and Wyckham Avenue

More recently the walled garden and farm buildings were sold and then granted permission for an SHD apartment development of 116 apartments (ABP-304590-19).

Nevertheless, the current proposal has been designed in recognition of the instructional objective related to adjoining Gort Muire Carmelite Centre lands that remain. The proposed development includes for significant public open space provision whilst the predominantly car free environment will provide a landscape public realm very characteristic of the original parkland setting of the Carmelite Centre. Compliance with the Institutional designation is further elaborated in the Material Contravention Statement submitted with this application.

One of the key planning gains with the proposed development is the potential to provide a new public access through the development allowing pedestrian and cyclist connectivity to Ballawley Park for adjoining communities. The scheme will very much be an “open” development with public access provided for the existing community to enter into the institutional lands and experience the protected buildings and general ambience for the first time, and also to have direct access to Ballawley Park (subject to DLRCC approval). This will be a significant benefit for the area where the private Carmelite Centre lands previously restricted access between the adjoining communities.

Given the above it is considered that the proposed development accords with the zoning and related objectives of the County Development Plan.

Sustainable Residential Communities Policies & Standards Chapter 2 confirms that in additional to significantly increasing the supply of housing in the County the other vital characteristics of new development will be: ensuring an appropriate mix, type and range of housing; and, promoting the development of balanced sustainable communities.

Policy Evaluation of Consistency Policy RES3 The proposed density of 180 units per ha is It is Council policy to promote higher appropriate for this location close to public residential densities provided that proposals transport and services and complies with Policy ensure a balance between the reasonable RES3. protection of existing residential amenities and the established character of areas, with the need to provide for sustainable residential development. In promoting more compact, good quality, higher density forms of residential development Policy RES4 The proposed development will provide It is Council policy to improve and conserve residential units within the existing built up area housing stock of the County, to densify existing of Dundrum which will densify the area and built-up areas, having due regard to the support existing facilities and services. amenities of existing established residential communities and to retain and improve The proposed development also includes a residential amenities in established residential number of residential amenities including a communities. crèche, gym, café, co-working space, cinema/function room, meeting room, games room, music room, residents lounge, private dining, and residential amenity area. Policy RES5 The proposal includes for significant open space Where distinct parcels of land are in provision. In addition, the predominately car free institutional use (such as education, residential development will provide a landscape public or other such uses) and are proposed for realm very characteristic of the original parkland redevelopment, it is Council policy to retain the setting of the Carmelite Centre. open character and/or recreational amenity of these lands wherever possible, subject to the context of the quantity of provision of existing open space in the general environs. Policy RES7 The provision of a mixed apartment scheme will It is Council policy to encourage the further improve the mix of residential types in the establishment of sustainable residential Dundrum area in accordance with Policy RES7 communities by ensuring that a wide variety of housing and apartment types, sizes and tenures is provided within the County in accordance with the provisions of the Interim Housing Strategy. Policy RES8 The scheme will provide 10% of the total units as It is Council policy to promote the provision of Part V social housing in accordance with Policy social housing in accordance with the projects RES8. outlined in the Council’s Interim Housing Strategy and Government policy as outlined in the DoECLG ‘Social Housing Strategy 2020’.

Policy RES9 The range of apartment types can provide a viable It is Council policy to support the concept of housing option for older people and empty independent and/or assisted living for older nesters in accordance with Policy RES9. people and people with disabilities/mental health issues. In this regard the Council will support the provision of specific purpose-built accommodation, or adaptation of existing properties, and will promote opportunities for elderly householders to avail of the option of ‘downsizing’ within their community Policy RES14 In accordance with Policy RES14 and Planning for It is Council policy to plan for communities in Sustainable Communities the proposed accordance with the aims, objectives and development can achieve the following: principles of ‘Sustainable Residential • A sustainable community that integrates Development in Urban Areas’ and the into the existing community and that accompanying ‘Urban Design Manual – A Best provides for the housing needs of people Practice Guide’. In all new development growth in all stages of their lifecycle. areas, and in existing residential communities • A residential design that prioritises it is policy to ensure that proper community cycling, walking and public transport. and neighbourhood facilities are provided in • A residential layout that ensures high conjunction with, and as an integral levels of amenity, security and component of, major new residential convenience with open spaces and developments and proposed services provided on site or in proximity renewal/redevelopment areas, in accordance (e.g. Dundrum Town Centre). with the concept of sustainable urban villages • An attractive layout with a clear sense of outlined under Policy RES15. place and which is legible and permeable. • A highly efficient use of zoned land energy consumption. • Due respect for the natural and built heritage.

The proposed development of 628 no. apartments in a high quality scheme on a vacant greenfield site which is close to Dundrum Town Centre and public transport is an appropriate proposal that achieves the sustainable residential aims of the Development Plan.

Development Management The Development Plan’s development management objectives are set out in the table below:

Building Height Evaluation of Consistency Policy UD6 states that the The issue of building height policy is assessed in detail recommendations and guidance set out in the accompanying Material Contravention within the Building Height Strategy for the Statement. County (Appendix 9 of the Development Plan) will be adhered to.

Open Space Evaluation of Consistency Sections 8.2.8.2 and 8.2.8.3 of the The issue of Open Space provision is assessed in detail Development Plan outline quantitative in the accompanying Material Contravention and qualitative standards for public and Statement.

communal open space. For all developments of 5+ units 15 sq.m- 20 sq.m of Open Space per person is to be provided (based on 1.5 persons 1 and 2 bedroom units).

However, the Development Plan also states that an absolute default minimum of 10% of the overall site area may also be applied by the planning authority.

Car Parking Evaluation of Consistency Table 8.2.3 sets out the residential land The development comprises 278 no. car parking use car parking standards as follows: spaces representing a parking ratio of 0.44 spaces per unit. Residential Dwellings - 1 space per 1-bed unit and per 2-bed While this is below the DLR Development Plan unit recommendations of 1:1 parking space this policy has - 2 spaces per 3-bed unit + been superseded by sections 4.23 and 4.24 of the Sustainable Urban Housing Design Guidelines for New Apartments Apartments, 2018. - 1 space per 1 bed unit - 1.5 spaces per 2 bed unit This ratio also compares favourably to other BTR schemes granted by ABP. The adjoining Walled - 2 spaces per 3-bed unit+ Garden SHD proposal (non BTR) was granted with a (depending on design and location) parking ratio of 0.31 spaces per unit.

Cycle Parking Evaluation of Consistency The development plan points to the A total of 1,354 no. bicycle parking spaces are also standards set out in the Council Cycling provided which equate to 2.16 per unit. This exceeds Policy Guidelines and Standards for cycle the standards required. parking requirements. Table 4.1 of this documents sets out the cycle parking Secure bicycle parking is provided at surface with standards as 1 short stay space per 5 units Bicycle stands/shelters located near apartment and 1 long stay space per unit. building entrances in secure purpose-made enclosures distributed throughout. The proposed scheme has been designed to provide fully integrated and safe bicycle paths, allowing ease of access throughout and secure bike parking facilities as set out in DLRCC’s Standards for Cycle Parking and associated Cycling Facilities for New Developments.

The scheme achieves the Urban Design Principles set down in national policy (see Section 2.4 above) in accordance with Policy UD1.

Accordance with the quantitative standards for residential development as per Sections 8.2.3.1 – 3 of the Development Plan and outlined in the Housing Quality Audit submitted with the Design Statement prepared by Scott Tallon Walker.

The development is also in compliance with the following policies in the Development Plan: Policy RES4 – Existing Housing Stock and Densification Policy ST28 – Traffic noise Policy UD1 – Urban Design Principles Policy UD3 – Public Realm Design Policy UD7 – Urban Tree Planting Policy OSR5 – Public Open Space Standards Policy ORS14 – Play facilities Policy EI1 – Water supply and Appropriate Assessment Policy EI2 – Waste Water treatment and AA Policy E18 – Sustainable Drainage Systems Policy EI13 – Waste Plans Policy EI15 - Waste Prevention and Reduction Policy EI16 – Waste re use and recycling Policy EI21 – Light Pollution Policy CC7 – Energy Performance in New Buildings Policy CC9 – Sustainability in Adaptable Design Policy CC15 – Flood Risk Management

4 CONCLUDING REMARKS

It is respectfully submitted that the proposed development will provide an appropriate form of high- quality residential development for this residential zoned site and that is consistent with planning policy for the area and is an efficient use of lands which are accessible to public transport and existing/planned social infrastructure.

This statement has demonstrated the compliance of the development with the following:

• Ireland 2040 Our Plan - National Planning Framework (2017) • Regional Planning Guidelines for the Greater Dublin Area (2010 – 2022); • Guidelines for Planning Authorities on Urban Development and Building Heights (2018) • Guidelines for Planning Authorities on Sustainable Urban Housing: Design Standards for New Apartments (2018) • 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 Manual for Urban Roads and Streets (2013); • Guidelines for Planning Authorities on Childcare Facilities (2001); • Smarter Travel – A New Transport Policy for Ireland (2009-2020); • The Planning System and Flood Risk Management (2009). • Dun Laoghaire Rathdown Development Plan 2016- 2022 • Climate Action Plan 2019

Broad compliance is also demonstrated with the policies and provisions of the Dun Laoghaire Rathdown County Development Plan 2016-2022, such as the land use zoning, density, design standards for residential schemes, streets and open spaces.

In conclusion, it is respectfully submitted that the proposed development is consistent with the proper planning and sustainable development of the area, and with all relevant national, regional and local planning policies and guidelines.