DRAFT FINGAL COUNTY DEVELOPMENT PLAN 2017-2023

SUBMISSION RELATING TO FORMER RACECOURSE & ADJOINING LANDS, , 15

PART A: FORMER RACECOURSE - LANDS SOUTH OF THE N3 PART B: RAILWAY SITE - LANDS NORTH OF THE N3

On behalf of: FLYNN & O’FLAHERTY CONSTRUCTION

April2016

1.0 INTRODUCTION

1.1 Purpose of Submission

On behalf of Flynn & O’Flaherty Construction (hereafter F&OF) the following submission to the proposed Draft Fingal County Development Plan 2017-2023 is made in respect of the former and adjoining lands, Castleknock, .

The purpose of the current submission is to identify the policies and objectives of the Draft Fingal Development Plan that relate to the F&FO’F lands at the former Phoenix Park Racecourse and north of the N3 and to suggest “Amendments” that will facilitate the ongoing development of the lands over period 2017-2023 and beyond.

1.2 Lands Subject of this Submission

Figure 1 identifies the location and extent of the F&OF lands. The overall F&OF land holding comprises 42.8ha.

The F&O’F lands are described in detail within Section 2.0 to 4.0 below. However, for clarity and to reflect their very different planning considerations, this submission divides the lands into two parts as follows: -

 PART A: Former Phoenix Park Racecourse – Lands south of the N3 - 37.9ha.

 PART B: Railway Site – Lands north of the N3 – 4.9ha. (This area is part of the lands referred to in the Draft Development Plan as the “Navan Road Parkway” Local Area Plan lands).

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2.0 SUBJECT LANDS - OVERVIEW

The development of the former Phoenix Park Racecourse (PPR) has been ongoing since 2004. The original planning permission granted was granted under F02A/1255 (Bord Ref: PL06F.202469) and provided a comprehensive masterplan, based on the Phoenix Park Former Racecourse and Adjacent Lands Action Area Plan 2000, to guide the future development of the lands. The permission included 2310 residential units (townhouses and apartments), 2no. local service centres and a site reserved for a primary school. The development proposed included the large 7.1ha public park.

As required by the Action Area Plan 2000 the development also provided for the delivery of significant infrastructure and public transport gains.

In particular, the new Navan Road Parkway railway station was facilitated and paid for by F&OF. The railway station opened in January 2008. The facility includes a surface car park which is retained by F&OF.

F&OF also constructed and funded the new grade separated junction on the N3. This junction provides access to the railway station/ car park. It will also provide access to the PPR lands to the south of the N3 when the internal road within the PPR site is connected to this junction.

The zoning based on the Action Area Plan 2000 provided for a large public park as part of the masterplan. The location of the park was decided by the Council to mitigate the perceived impact of the loss of the racecourse lands and to provide a “visual break” when viewed from the N3. Lands zoned as open space in the original Action Area Plan were also allocated for active open space and 7 acres were transferred to St. Brigid’s GAA Club. These lands (outlined below) are now part of the GAA club complex and include an all-weather full size GAA pitch as well as other grass pitch areas.

The main elements of the development areas south and north of the N3 respectively are described below and illustrated on Figure 1, as follows:-

Former Phoenix Park Racecourse – Lands South of the N3 (Part A) 1. Cedarhurst / Millrace Apartments & Houses (Phase 1 - Complete) 2. Fairhaven Housing (Phase 2 – Under Construction) 3. Remainder of lands (Permission Granted/ Undeveloped).

Railway Site - Lands North of the N3 (Part B) 4. Railway Station Site (western portion) 5. Attenuation Areas (central portion) 6. Ashtown Business Centre (eastern portion).

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Context

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Submission to Draft Fingal Development Plan 2017 2017 Plan Development Fingal Draft to Submission Figure 1 Site Location and and Location Site 1 Figure

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3.0 FORMER PHOENIX PARK RACECOURSE – LANDS SOUTH OF THE N3 (PART A)

For the purposes of this submission, the main PPR site (i.e. lands to the south of the N3) is divided into three parcels as described below.

3.1 Cedarhurst / Millrace Apartments (Phase 1 - Complete)

Development on the lands within the former Phoenix Park Racecourse which was completed prior to the property collapse of 2008/09 comprised 546 residential units within what can be referred to as the Phase 1 development. It includes the following addresses:-

 1 - 9 Phoenix Park Avenue  1 - 8 Surehaven Lawn  1 - 17 Surehaven Road  1 - 77 Rosanule  1 - 75 Glenesky Square  1 - 60 Cloonlara Sqaure  1 - 24 Phoenix Park Way  1 - 38 Millrace Court  1 - 16 Cedarhurst Green  1 - 6 Millrace Lawn  1 -53 Cedarhusrt Road  1 - 147 Millrace Road  149 - 164 Millrace Road

This area also includes the as yet undeveloped sites adjacent to the Castleknock Road/ Ashtown Roundabout which includes the Arnott House site.

3.2 Fairhaven Housing (Phase 2 – Under Construction)

The site is currently active with housing construction having recommenced in 2014 with the Fairhaven housing development. The original PPR site did not include a 4 acre site on the Castleknock Road which was occupied by a Garden Centre. However, this site was subsequently acquired and integrated into the overall Fairhaven development which is under construction.

Since development has recommenced on the site, inexcess of 70 of 140no. units are complete / under construction within the predominantly own door housing development. In excess of 40 of the units are sold and occupied. A recent permission has increased the number of units in this area to 161 units. A further permission to complete the area immediately on the right hand side of the Castleknock Road entrance into the site will be submitted in the immediate future. The

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undeveloped lands to the east of the Castleknock Road entrance will also be the subject of an application in the near future.

3.3 Remainder of Lands (Permission Granted/ Undeveloped)

The remainder of the PPR lands (c. 23.8 ha) are undeveloped. Permission exists for the development of all of these lands for a mix of residential, commercial, hotel and community uses all accessed from a central route, Phoenix Park Avenue, connecting the Castleknock Road access with the N3 interchange. The principle permissions are Reg. Refs. F02A/1255 (the parent permission) and F08A/1292 (the ‘Park Village’ permission) and these permissions extend until August 2018.

Under the original parent permission residential development is permitted in the form of housing units along the southern boundary of the lands and adjoining the established Chesterfield and Deerpark developments further to the south. In addition a series of apartment blocks are permitted within a central spine through the middle of the site and south of the proposed large public park.

The permitted Park Village development is located along the south western and western boundary of the large public park and comprises 9no. urban blocks incorporating a mix of residential, hotel, retail/ commercial, medical and restaurant units and community facilities. The lands further to the west of the Phoenix Park Avenue/ N3 interchange access were identified for residential development.

To date approximately one third of the large central public park (totalling c.7.1 ha) has been partly levelled and planted at the eastern end adjacent to the Phase 1 apartments. As currently permitted the central public park defines the northern boundary of the permitted residential development and the northern and eastern boundaries of the Park Village developments.

Permission was also granted to the Minister of Education & Science in April 2008 for the development of an 8 classroom primary school on the western boundary of the lands adjoining the St. Brigid’s GAA grounds (Reg. Ref. F08A/0137). The new primary school was permitted on a site of 1.23 ha with an access road provided directly from the N3 interchange. This permission expired in 2013.

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4.0 RAILWAY SITE - LANDS NORTH OF THE N3 (PART B)

The narrow strip of land between the N3 and the railway line and within the ownership of F&O’F has an area of 4.9 hectares. For description and land use planning purposes, it can be treated as 3 separate areas as described below.

4.1 Railway Station Site (Western Portion)

Development on the lands to the north of the N3 includes the new railway station and associated car park which was developed by F&O’F (0.6ha). A further area (c.1ha) of undeveloped lands is located directly to the west. These lands are accessible from the N3 Interchange built by F&OF as part of the overall development and connected to the main body of the former Phoenix Park Recourse site by the overbridge.

Photo 1: Railway Station Site North of the N3

4.2 Attenuation Areas (Central Portion)

This strip of land (2ha) includes attenuation ponds which were permitted as part of the overall PPR development. They have no further development potential apart from visual amenity and habitat enhancement.

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4.3 Ashtown Business Centre Site (Eastern Portion)

The eastern end of the northern lands includes a development site (c.1.3ha) located to the west of the entrance to the Ashtown Business Centre. These lands are accessible from the N3, are physically and functionally separated from the railway station and are available for development.

Photo 2: Attenuation Areas and Ashtown Business Centre Site

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5.0 F&O’F PROPOSALS FOR THE COMPLETION OF THE SITE

Development on the F&O’F lands north and south of the N3 slowed after 2008 but recommenced in 2014 with the Fairhaven scheme which is currently ongoing. The major infrastructure investments in the Railway Station and the N3 Interchange are complete. The residential elements of the masterplan are well advanced and approximately one third of the site is complete or under construction.

F&OF intend to continue with the development of the lands over the coming years and, based on anticipated economic growth, strong demand for housing and improved funding conditions, it is anticipated that significant progress will be made towards the completion of the site within the period of the forthcoming Development Plan (i.e. up to 2023).

F&OF intend to engage in detailed preplanning discussions with Fingal County Council over the coming months to discuss aspects of the existing and approved masterplan which will need to be adjusted. The following general points are noted as background information to inform the Fingal Development Plan review.

5.1 Lands South of N3 (Part A)

 Density/ Overall Yield – The overall residential yield on the PPR site is likely to remain consistent with the original approved masterplan and is anticipated to end up at between 2000 to 2500 units, depending on the ultimate proportion of houses and apartments respectively.

 Design – The detailed design of the development is under constant review and will be updated to take into account any new requirements arising from new planning guidelines and building regulations. In particular, the scheme will include the principles contains in the Sustainable Urban Housing Guidelines (2009) and the Design manual for Urban Roads and Streets (DMURS).

 Chesterfield & Deerpark Boundary Houses – On completion of Fairhaven and other Phase 1 infill sites, the next phase of housing will be the Chesterfield and Deerpark housing (3 storeys) along the southern boundary of the site. The general form of the permitted housing at this location is unlikely to change as this boundary requires 2-3 storey development to respect the adjoining housing areas.

 Parkside Apartments – The general form of the apartment blocks adjacent to the public park are also unlikely to change materially from the approved plans and will be completed as economic factors permit.

 Other Non-residential uses/ Local Centre – The Local Centre at the western end of the site which was approved in 2008 under the Park Village development included c4,000sq.m

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of retail and commercial floorspace. This quantum of provision remains reasonable. Plots close to the N3 Interchange lend themselves to commercial uses such as the permitted hotel building.

 Completion of Phoenix Park Avenue – The internal link road, Phoenix Park Avenue, connecting the Castleknock Road access and the N3 interchange and on to the Railway Station will be completed as a priority.

 Park – The park will be delivered in tandem with housing and in consultation with Fingal County Council.

 School Site – The Department of Education and Science had previously applied for and were granted permission for a school on the site but the project was delayed due to the economic downturn. F&OF will consult with DoES in relation to the delivery of the primary school on the site as required in the Draft Development Plan.

5.2 Lands North of the N3 (Part B)

In relation to the lands north of the N3 the proposals are broadly as follows: -

 Railway Station Site – F&OF have a significant development site (1.6ha) at this location which was anticipated as part of the original masterplan and provision was made for this in the construction of the railway station and the associated surface car park which is retained in the ownership of F&OF. Fingal County Council supported the concept of a landmark building at this location and encouraged F&OF to make provision to remove the surface car park and incorporate it into a commercial development. The potential uses for this site would be commercial uses such as headquarters offices or a hotel.

 Attenuation Areas – The central portion of the northern lands are unsuitable for development due to their narrow configuration and the attenuation infrastructure for the PPR site. These lands can be retained and the attenuation and amenity function of these can be enhanced as part of the development of the northern lands.

 Ashtown Business Centre Site – The lands (1.3ha) at the eastern end of the site have access to be existing entrance from Ashtown Business Centre and these lands could be developed for a range of commercial/ employment uses.

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6.0 DRAFT DEVELOPMENT PLAN SUBMISSION - PART A (LANDS SOUTH OF N3)

6.1 Draft Zoning & Map Based Objectives

Figure 2 below is an extract from the Map 13 of the Draft Fingal Development Plan 2017 – 2023 and identifies the location and extent of the Part A lands and the relevant map based objectives.

Under the Draft Development Plan the Part A lands south of the N3 are zoned as follows:

‘RA Residential Area: Provide for new residential communities subject to the provision of the necessary social and physical infrastructure.

RS Residential: Provide for residential development and protect and improve residential amenity.

OS Open Space: Preserve and provide for open space and recreational amenities.’

There are two map based objectives relating to the subject lands south of the N3.

The Draft Plan requires the preparation of a masterplan for the RA zoned lands during the lifetime of the Plan and states: -

‘Phoenix Park Masterplan Facilitate delivery of residential, commercial and community facilities along with open space in a phased manner.’ (Page 101).

A map based objective identifies a proposed school site.

6.2 Amendments Sought for Part A Lands (South of N3)

The following Amendments are sought to the Draft Development Plan. The Amendments sought in this submission are number on Figure 2 for ease of reference.

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AMENDMENT SOUGHT #A1 Amend the zoning of the Fairhaven (Phase 2) to reflect the current development status of these lands which are complete / under construction.

Amend zoning as follows: -

From: ‘RA Residential Area: Provide for new residential communities subject to the provision of the necessary social and physical infrastructure.’

To: ‘RS Residential: Provide for residential development and protect and improve residential amenity.’

The planning basis for Amendment #A1 is that the Fairhaven (Phase 2) site is the subject of a grant of permission for a residential development that is currently under construction. Furthermore in excess of 40 of the dwellings within the Fairhaven development are complete and occupied by new homeowners with a further 30 units under construction. The Fairhaven (Phase 2) site comprises a developing residential community and the current status of the lands should be reflected in the land use zoning. On this basis the ‘RS Residential’ is the most suitable zoning objective for the Fairhaven lands.

AMENDMENT SOUGHT #A2 Remove the requirement for a Masterplan (MP13.A) from the Part A (lands south of the N3) the development of which has been approved and is the subject of extant planning permissions.

Amendment #A2 is sought on the basis that the nature, scale and layout of development on the remaining undeveloped lands within the former Phoenix Park Racecourse has been considered and approved under the a series of planning permissions as described within this submission. These permissions extend to 2018.

Where necessary appropriate amendment applications will be made to ensure the design and layout of the development is in accordance with current standards however the broad layout and development parameters established by the live permission on the site are approved. The site organisation and masterplan has already been established through the Action Area Plan 2000 which setout the key infrastructure. Subsequently the planning permission Reg. Ref. F02A/1255 reinforced the Action Area Plan including the layout, uses, general heights etc. On this basis these is no requirement for a masterplan and such a requirement has the potential to result in delays in the delivery of housing and the completion of development on the lands within the former Phoenix Park Racecourse. The requirement for a Masterplan should be removed on this basis.

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7.0 DRAFT DEVELOPMENT PLAN SUBMISSION – PART B (LANDS NORTH OF N3)

7.1 Draft Zoning and Map Based Objectives

Figure 2 identifies the location and extent of the Part B lands and the relevant map based objectives contained within Map 13 of the Draft Fingal Development Plan 2017 – 2023.

The Part B lands north of the N3 are zoned ‘HT High Technology” with the objective being: -

‘HT High Technology: Provide for office, research and development and high technology/ high technology manufacturing type employment in a high quality built and landscaped environment.’

This zoning is acceptable and no Amendment is sought.

The Part B lands north of the N3 are also identified as being subject to the preparation of a Local Area Plan (LAP 13.B) as follows: -

‘Navan Road Parkway Local Area Plan  Protect the existing and proposed Regional Drainage Infrastructure traversing the lands north of the N3 in any future development.  Provide for a comprehensive surface water attenuation and SuDs scheme for the entirety of the LAP lands. This shall fully integrate with the drainage arrangements for the former Phoenix Park racecourse development opposite.  Provide for on-site surface water attenuation ponds which shall be developed as high quality landscaped features of the site.  Ensure that new development is of high design quality reflecting the landmark and visually sensitive status of this location. Views northwards to Dunsink environs shall be provided by means of visual breaks and adequate separation of the new buildings.  Provide for a detailed phasing of construction of development in the LAP in tandem with the delivery of transport and drainage infrastructure.  Provide a footbridge over the N3 at an appropriate location between Auburn Avenue junction with the N3 and the Navan Road Parkway Interchange.  Facilitate pedestrian access from Coolmine Rugby Club grounds over the Canal adjacent to the Navan Road Parkway Railway Station. (Page 101).’

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7.2 Amendments Sought for Part B Lands (North of N3)

The following Amendments are sought to the Part B lands and are numbered within Figure 2 for reference.

AMENDMENT SOUGHT #B1 Remove the requirement for a Local Area Plan (LAP 13.B) from the Ashtown Business Centre site as this site is accessible to the N3 and forms a logical extension of the Ashtown Business Centre.

Amendment #B1 is sought on the basis that the Ashtown Business Centre site (1.3ha) is a ready- to-go development site with existing access to the N3 via the established entrance to the Ashtown Business Centre. This site forms a logical extension of the Ashtown Business Centre and can be developed in the short term. There is no necessity for a Local Area Plan to guide development on this site which is essentially a standalone location and a Development Plan objective of this type has the potential to delay the development of these lands. On this basis these lands should be removed from the requirement for a Local Area Plan.

AMENDMENT SOUGHT #B2 Remove the requirement for a Local Area Plan (LAP 13.B) from the Railway Station Site which has existing access from the N3 Interchange and directly adjoins an existing main line railway station.

The Railway Station Site comprises an area of 1.6ha and currently comprises the railway station car park and an area of undeveloped lands to the west. This site is highly accessible to public transport via the Navan Road Parkway Station and to private cars via the N3 Interchange. F&O’F and Fingal Co Co have previously discussed proposals for a landmark development at this location comprising office or hotel type uses. The inclusion of these lands within the proposed Local Area Plan (LAP 13.B) boundary creates unnecessary uncertainty regarding the timeframe for the development of the lands. On this basis the Railway Station Site should be removed from the requirement to provide a Local Area Plan.

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#B2

#B1 #A2

#A1

Submission to Draft Fingal Development Plan 2017 - 2023

Figure 2 Draft Zoning Objectives Map & Amendments Sought 15

8.0 CONCLUSION

As an outcome to this submission we seek that amendments #A1, #A2, #B1 and #B2 are incorporated into the forthcoming Fingal Development Plan 2017 – 2023.

If you require any further information in relation to any aspect of the above, please do not hesitate to contact us.

Please keep us informed of progress in relation to the Development Plan Review process.

______BMA PLANNING April 2016

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