And Residential Tenancies Act 2016 Inspector's Report ABP-304469-19
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S. 4(1) of Planning and Development (Housing) and Residential Tenancies Act 2016 Inspector’s Report ABP-304469-19 Strategic Housing Development 253 no. apartments and associated works. Location Greenacres, Longacre and Drumahill House, Upper Kilmacud Road, Dundrum, Dublin 14. Planning Authority Dun Laoghaire Rathdown County Council Applicant Crekav Trading GP Ltd Prescribed Bodies Irish Water NTA TII An Taisce County Childcare Committee ABP-304469-19 Inspector’s Report Page 1 of 62 Observer(s) See Appendix 1 Date of Site Inspection 27th June 2019 Inspector Ciara Kellett ABP-304469-19 Inspector’s Report Page 2 of 62 Contents 1.0 Introduction .......................................................................................................... 4 2.0 Site Location and Description .............................................................................. 4 3.0 Proposed Strategic Housing Development .......................................................... 5 4.0 Planning History ................................................................................................... 8 5.0 Section 5 Pre Application Consultation ................................................................ 9 6.0 Relevant Planning Policy ................................................................................... 11 7.0 Third Party Submissions .................................................................................... 16 8.0 Planning Authority Submission .......................................................................... 20 9.0 Prescribed Bodies .............................................................................................. 29 10.0 Environmental Impact Assessment (EIA) Preliminary Assessment ............. 31 11.0 Appropriate Assessment ............................................................................. 32 12.0 Assessment................................................................................................. 34 13.0 Recommendation ........................................................................................ 51 14.0 Reasons and Considerations ...................................................................... 51 15.0 Conditions ................................................................................................... 52 16.0 Appendix 1 .................................................................................................. 61 ABP-304469-19 Inspector’s Report Page 3 of 62 1.0 Introduction 1.1.1. This is an assessment of a proposed strategic housing development submitted to the Board under section 4(1) of the Planning and Development (Housing) and Residential Tenancies Act 2016. 2.0 Site Location and Description 2.1. The site is located off the R826 Upper Kilmacud Road, Dundrum, Co. Dublin. The site is to the south of this road almost midway between the Drummartin Link Road to the east and Overend Avenue to the west. Dundrum Town Centre is c.1km to the south-west of the site and the LUAS stops, Balally and Kilmacud, are c.800m to the south-west and south-east respectively. Sandyford Business Park is c.2km to the south-east and the M50 Motorway is accessed via the Drummartin Link Road c.2km to the south. 2.2. The Upper Kilmacud Road area is primarily a residential area comprising mostly of two storey semi-detached and detached dwellings. In addition, there are a number of recently constructed and permitted apartment blocks further along and in the vicinity of Upper Kilmacud Road. The Airfield Heritage Gardens and Family Farm is located to the immediate west and south of the site. To the immediate east of the site lies the Holywell Housing estate comprising a mix of detached, semi-detached and terraced dwellings. A row of 9 dwellings known as Drumahill bound the lower eastern edge of the site, while a well-established green area with mature trees and hedgerows serving Holywell and Drumahill residential developments bounds the upper eastern half of the site. Considerable mature tree cover characterises the residential properties and the public open space in this housing estate. 2.3. The site itself comprises three individual plots of land, Greenacres, Long Acre and Drumahill House. The Greenacres land forms the bulk of the site and bounds the Airfield estate to the west and south. This portion of land was subject to previous planning applications and there is an extant permission on this portion of the site for apartment blocks. Vehicular and pedestrian access exists from the Upper Kilmacud Road and the site presently accommodates a two/two-and-a-half storey house, known as “Green Acres”, set within the grounds. Historically, this house was used as ABP-304469-19 Inspector’s Report Page 4 of 62 a convent. The grounds are somewhat overgrown, and they include mature and semi-mature, predominantly deciduous trees of varying quality. A narrow strip of land known as Long Acre runs to the east of the Greenacres site. This strip of land formed a boundary between the Greenacres site and the 9 houses known as Drumahill, as well as Drumahill House itself. The site of Drumahill House now forms part of the overall site. The Drumahill House is a 1930s style dwelling that appears to have been recently vacated with an access onto Upper Kilmacud Road. 2.4. The overall site now comprises a total site area of c.1.76 Hectares and slopes gently towards the south. It is characterised by well-established mature trees along all boundaries and is screened from Upper Kilmacud Road and the surrounding dwellings as a result. Neither Greenacres nor Drumahill House are Protected Structures. 2.5. Appendix A includes maps and photos. 3.0 Proposed Strategic Housing Development 3.1. The proposed development provides for the following: • Demolition of 2 no. houses and ancillary buildings on site • Construction of 3 no. apartment blocks ranging in height from 4 to 6 storeys, comprising 253 no. apartments and associated tenant amenity space o 25 units provided for Part V in Block B • A crèche of 236 sq.m, with associated external play space and 5 staff car parking spaces • 212 no. car parking spaces resulting in a rate of 0.8 spaces per unit, 7 motorbike parking spaces, and 348 no. bicycle spaces at basement level plus 52 visitor bike spaces at ground level (totalling 400 bicycle spaces). ABP-304469-19 Inspector’s Report Page 5 of 62 • The apartment mix is as follows: Apartment type No. Percentage 1 bed apartment 115 45 2 bed apartments 115 45 3 bed apartments 23 9 Total 253 100 • 2 vehicular and pedestrian accesses off Upper Kilmacud Road – one directing cars and cyclists to the underground basement parking area and the other for visitors, emergency vehicles, drop-off and set-down area. The accesses are in the approximate location of the existing accesses serving Greenacres and Drumahill House • Pedestrian access to the Holywell estate • Landscaping and boundary treatment • ESB Substation • Cycle lane along Upper Kilmacud Road 3.2. Development Parameter Summary Parameter Site Proposal No. of apartments 253 Site Area 1.76Ha Density 143.75 units per Ha Creche 236sq.m catering for 41 children Building Height All 3 blocks range from 4 – 6 storeys Site Coverage 25% Dual Aspect 59.7% dual/triple aspect Car Parking 212 spaces ABP-304469-19 Inspector’s Report Page 6 of 62 Bicycle parking 400 spaces Part V 25 units Public Open Space 3,833sq.m 3.3. In term of site services, a new water connection to the public mains is proposed, together with a new connection to the public sewer. An Irish Water Pre-Connection Enquiry in relation to water and wastewater connections has been submitted, as required. It states that subject to a valid connection agreement being put in place, the proposed connection to the Irish Water network can be facilitated. 3.4. In addition to the architectural, landscaping and engineering drawings, the application was accompanied by the following reports and documentation: • Application Form & Appendices • Newspaper Notice • Site Notice • Planning Report • Planning Statement of Consistency • Response to An Bord Pleanála Opinion • Cover Letter to ABP & Schedule • Cover Letter to DLRCC & Schedule • Landscape Design Report • Landscape Plan Register • Screening for Environmental Impact Assessment • Schools Demand Assessment • Part V Pack • Architectural Design Statement inc. Housing Quality Audit, Childcare Services assessment • Outline Construction Management Plan • Outline Construction & Demolition Waste Management Plan ABP-304469-19 Inspector’s Report Page 7 of 62 • Traffic Impact Assessment • Engineering Services Report • Site Specific Flood Risk Assessment • Mobility Management Plan • Operational Waste Management Plan • Building Lifecycle Report • Estate & Common Area Management Strategy • Daylighting and Sunlighting Analysis • Energy Analysis Report • Site Lighting Layout • Outline Construction Environmental Management Plan • Appropriate Assessment Screening Report • Ecological Impact Assessment • Arboricultural Report • Architectural Heritage Assessment • Access Report • Fire Safety Report • Landscape & Visual Impact Appraisal • Verified Visual Impact Images • Archaeology and Built Heritage Assessment 4.0 Planning History 4.1. There have been two recent planning applications on the Greenacres portion of the site. In summary: • ABP Ref. PL 06D.248265: ABP granted permission in September 2017 for 120 no. apartments in 2 blocks ranging in height from 2-5 storeys with a 6th ABP-304469-19 Inspector’s Report Page 8 of 62 storey penthouse/communal room on Block A, over basement parking,