Statement of Consistency & Planning Report

DAVID MULCAHY PLANNING CONSULTANTS LTD

67 The Old Mill Race, Athgarvan, Co. Kildare D M PH: 045 405030/086 350 44 71 E-mail: [email protected] www.planningconsultant.ie

Company No: 493 133 Directors: D. Mulcahy & M. Mulcahy

STATEMENT OF CONSISTENCY & PLANNING REPORT

in support of application for

467 DWELLINGS, CHILDCARE FACILITY, GYM, CAFÉ, & RETAIL UNIT

on lands at

CRODAUN, CELBRIDGE, CO. KILDARE

Applicant: Crodaun Development Company Ltd

16th April 2020

David Mulcahy Ba. (Mod), MRUP, MSc. Urban Design Member of the Irish Planning Institute. Chartered Town Planner. David Mulcahy Planning Consultants Ltd

EXECUTIVE SUMMARY

KEY PLANNING CONSIDERATIONS Site Description 12.93Ha - red line boundary comprised of: 12.68 ha - undeveloped, greenfield lands owned by applicant 0.25Ha - proposed works on lands owned by Kildare Co. Co. to facilitate access. Zoning ‘New Residential’ zoning (10.74ha) ‘Open Space/Amenity’ zoning (1.935ha). Services ‘Ready to go’ site. Road Frontage Significant frontage onto regional road (Maynooth Rd) to east. Features Generally flat. Good quality hedgerow to west and part of eastern boundary. Poor quality hedgerow in the centre. Stream with overgrown planting to the south. Distance from Town c.1.8km via R405 Centre Community facilities Situated in close proximity to 2 no. post primary schools (one temporary); established neighbourhood centre, 3 supermarkets, and a large employment zone. Proximity to public • No.67, 67X, 67N (Maynooth- Dublin City) bus stops transport located outside and adjoining the lands. • Shuttle bus service from Salesian College to Hazelhatch train station (4k). • Dedicated cycle lane to Louisa Train Station in Leixlip (3.8k). Proposal 467 dwellings (houses and apartments) Childcare Facility, gym, café and retail unit.

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2 no. vehicular access points (involving works to the Maynooth Road) 2.068Ha landscaped park with kickabout area and pedestrian/running/cycle routes. Proposed Density Proposed net density of 43.46 units/Hectare (net of 1.935Ha of ‘F’ zoned lands to north). Public Open Space 1.933ha of public open space within the residential zoned lands (17.99%) Planning Gain • Significant amount of new housing to serve a wide range of household types. • Provision of 1.935 hectare landscaped park to the north. • Childcare facility, gym, local shop and café. Urban Design • Strong urban frontage to Maynooth Road • Gateway building entering Celbridge at north-east of site • Strong frontage to the park to the north • Permeable layout • Strong sense of place

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TABLE OF CONTENTS

1.0 Introduction.

2.0 Site Location & Description.

3.0 Planning History.

4.0 Proposed Development.

5.0 Consistency with ministerial planning guidelines & other relevant strategic planning policy.

6.0 Consistency with development plan & local area plan.

7.0 Conclusion.

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1.0 INTRODUCTION

David Mulcahy Planning Consultants Ltd have been instructed by Crodaun Development Company Ltd (‘applicant’) to prepare a planning report and statement of consistency to support a planning application to An Bord Pleanála concerning a proposed residential development for 467 dwelling units, childcare facility, gym and retail unit on lands measuring 12.68 hectares at Crodaun, Celbridge, Co. Kildare.

Given that the scheme contains over 100 dwelling units this application is being made directly to An Bord Pleanála under the Strategic Housing Planning and Development (Housing) and Residential Tenancies Act 2016.

The purpose of this report is to describe the planning context including receiving environment, planning history, outline the proposed development and demonstrate how the proposal is consistent with the relevant s.28 planning guidelines and local policies and objectives (statement of consistency).

The lands in question (12.68 hectares) are predominantly zoned ‘New Residential’ (10.74 hectares) with approximately 1.93 hectares zoned for ‘Open Space/Amenity’ at the north end. The lands are under freehold ownership of the applicant. Additional lands owned by Kildare County Council (measuring 0.25 hectares) are included within the red line boundary of the application site (12.93 hectares) as they are required to facilitate access.

The lands are generally flat and are greenfield in nature, with the current use being for agriculture (pastoral). The lands are largely free of any constraints, apart from internal hedgerows. There is a stream along the southern boundary, known as Kilwoghan Stream1.

1 The spelling of Kilwoghan Stream is based on OPW Eastern CFRAM Study HA09 Hydraulic Report from 2015 (for the Celbridge and Hazelhatch areas) and is different from the spelling of Kilwogan Lane.

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The applicants are experienced developers some of whom live in Celbridge and have carried out significant housing developments in the town previously. They aim to provide a high-quality housing scheme that will represent a significant positive contribution to Celbridge town providing options for a variety of households.

For clarity this report addresses: • Statement of Consistency with development plan, local area plan and s.28 Ministerial Guidelines (s5.0 and s.6.0) • Material Contravention Statement (s.6.3.3) • Housing Mix Statement (s.6.1.3)

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2.0 SITE LOCATION & DESCRIPTION

2.1 Location

The subject lands are located to the north of Celbridge town in the Townland of Crodaun. Specifically, the lands are located west of the Maynooth Rd (R405) and north of Kilwoghan Stream (which runs to the north of Kilwogan Lane) see Fig Nos. 1 and 2 below.

Site Location

Town Centre

Fig No.1 Map showing location of subject lands in Crodaun, Celbridge (Source: MyPlan.ie - OSI Licence No.EN 0080915)

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M4 Motorway

Site

Maynooth Rd (R405)

Kilwogan Lane

Fig No.2 Location Map showing location of subject lands and surrounding context (Source: MyPlan.ie - OSI Licence No.EN 0080915). Red line is indicative only.

2.2 Site Description

The subject site is triangular in shape, narrowing at the northern end. Its measures 12.68 hectares2 and is relatively flat.

The site is comprised of 3 no. vacant fields divided by hedgerows. The quality of these dividing hedgerows has found to be of a poor quality following a site inspection by an arborist – please refer to the arboricultural impact report prepared by The Tree File Ltd.

The site contains a number of ESB overhead wires and associated support poles.

There is a small stream running along the southern boundary of the site (Kilwoghan Stream). There is woodland thicket/regenerative scrub either side of the stream.

2 Net of the lands in the ownership of Kildare Co. Co. to the east of the site (0.25Ha).

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The eastern boundary of the site is defined by a row of mature trees at the south end. The remainder of this boundary is defined by fencing.

The western boundary of the site is defined by a mature hedgerow, including some mature specimen trees (oak).

The site has extensive frontage onto the adjoining public road (Maynooth Road, R405) to the east which is within the 50kph posted speed limit.

School (temp)

School M4 Business Park

Site

Residential

Fig. No.3 Aerial view of subject lands (source: Google Earth, April 2019). Red line indicative only.

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Fig. No.4 View of site taken from midway point along eastern boundary (June 2019)

Fig No.5 View of site from north-east of site at roundabout junction (June 2019).

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Fig No.6 Existing mature hedgerow along the eastern boundary of the site facing the Maynooth Rd (southern portion) – dated June 2019. Note pedestrian and cycle lane, along with public lighting.

Fig No.7 View of scrubland north of Kilwoghan Stream with thicket to the south side (November 2018).

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Fig No.8 Mature trees along the western boundary of the site (November 2018)

2.3 Ownership

The subject lands (12.68Ha) are owned in their entirety by the applicant - Crodaun Development Company Ltd. The red line boundary of the application also includes lands in the ownership of Kildare County Council as works are proposed to the Maynooth Road (0.25Ha) in order to facilitate access. A letter of consent from the council is included with the application.

2.4 Adjoining Lands & Land Uses in the Vicinity

North The M4 Business Park is located to the north of the site on the opposite side of the roundabout junction. A temporary Educate Together post primary school (Celbridge Community School) is located opposite Salesian College.

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West

There is a large post primary school located to the north west of the site – Salesian College. The school caters for boys and has an enrolment of 700+ pupils. There are agricultural fields situated to the west of the site.

South There is a narrow strip of land to the south of the subject site. This strip of land is in third party ownership and therefore is outside the legal interest of the applicant. This strip of land fronts onto Kilwogan Lane (L5054), a relatively narrow road with no road markings or footpaths. Kilowgan Lane provides access to agricultural lands west of the subject site.

There is mature residential housing to the south side of Kilwogan Lane (‘Castle Village’ and ‘Thornhill Court’). Thornhill is a two storey apartment complex.

East The R405 Regional Road (Maynooth Road) runs along the east side of the site. There is a strip of lands owned by Kildare County Council between the subject site and this road at the northern end of the site.

There is a dedicated cycle lane and public footpath on the west side of the Maynooth Road where the site is situated. Public lighting is also provided along the (eastern) edge of the site on the southern and very northern end of the Maynooth Road, with public lighting on the opposite side of the Maynooth Road further north.

The lands to the east of the Maynooth Road are in residential use and agricultural use. The agricultural lands are zoned for residential development and are the subject of a current application for strategic development housing (ABP- 306504).

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Employment lands Temp Post Primary School

Post Primary School SHD App

Site

2 storey housing

Castletown 2 storey housing

2 storey apts

Fig No.9 Location Map showing surrounding context (Source: MyPlan.ie - OSI Licence No.EN 0080915). Red line is indicative only.

Fig No.10 Existing tree planting outside the eastern boundary of the site facing the Maynooth Rd (northern portion) – dated June 2019. Note pedestrian and cycle lane with traffic light crossing point.

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Fig No.11 Transition along eastern boundary from hedgerow boundary to fencing (below level of the road) with trees on outside on land owned by KCC. June 2019

Fig No.12 Raised junction on Kilwogan Lane at south east corner of the site to facilitate pedestrian and cycle crossing. June 2019.

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Fig No.13 Kilwogan Lane to the south of the site (taken at entrance to Thornhill Court). May 2019.

Fig No.14 Two storey apartments in Thornhill Court to the south side of the site (eastern end). May 2019.

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2.5 General Area

The subject lands are situated between the built-up edge of Celbridge and educational/industrial development (M4 Business Park) further north which has occurred around the roundabout junction serving the link road to the M4. The proposed new Luftansa Technik development is now under construction north- west of the M4 Business Park on the Maynooth Road. There is a need to tie the isolated educational and industrial development back into the town.

2.6 Proximity to Public Transport

2.5.1 No.67, 67X, 67N Bus Services

There is a bus stop located on the Maynooth Road to the east of the site (No.67 route). The lands are also located approximately c.140m from 2 no. sheltered bus stops on the No. 67 route opposite the entrance to Salesian College – map below.

The No.67 route provides high quality public transport to Celbridge town centre, Lucan, Liffey Valley Shopping Centre and Dublin City in an easterly direction and Maynooth in a westerly direction – see route below. This bus service allows for students to access third level education in both Maynooth and Dublin City Centre. It also allows for shopping to be carried out in Celbridge town centre and Liffey Valley.

The No.67 Bus Timetable shows that this is a very frequent bus service which operates every day of the week. Buses leave Maynooth at 5.25am and continue until 23.30pm with two buses running per hour. Buses leave Dublin City at 6.23am and continue until 23.23pm with two buses running per hour.

In addition, the two stops are served by the 67X and 67N buses. The 67X is a service which operates from Monday to Friday between Salesian College and

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UCD Belfield (mornings only) and from UCD Belfield to Salesian College (evenings only).

The 67N is a Nitelink service from Dublin City to Celbridge Main Street from 12am – 4am.

In summary the lands are served by high quality public transport in the form of a convenient and frequent bus service.

Site

Bus Stops

Fig No.15 Map showing location of lands relative to No.67, 67X bus stops (Source: MyPlan.ie - OSI Licence No.EN 0080915).

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Fig.16 Bus stop to east of site on Maynooth Road June 2019

2.5.2 Hazelhatch Train Station Shuttle Bus

There is a dedicated shuttle bus service from Salesian College adjoining the subject lands which provides transportation to Hazelhatch Train Station (c.4k distance) starting with the 7.10am train and continuing through to the 19.05pm train with services running throughout the day. This bus service is provided by Birchall Transportation Ltd.

2.5.3 Louisa Bridge Train Station, Leixlip

There is a dedicated pedestrian and cycle lane from the subject lands to Louisa Bridge Train Station in Leixlip which is only c.3.8 kilometres from the subject lands. This line services Blanchardstown (for Shopping Centre), Drumcondra (for Airport access) and Connolly Station (for city centre). The train service is very frequent with trains to Dublin City starting at 6.27AM and running through to 23.17PM. Services from Dublin City to Leixlip running from 5.27Am to 23.10PM.

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Cycle Path

Louisa Train Station

Site

Fig No.17 Cycle route from subject lands to Louisa Train Station (3.83km).

2.6 Celbridge

Celbridge has witnessed significant growth over the past 60 years from a population of 567 persons in 1951 to a population of 20,288 persons as recorded in the 2016 Census. As noted in the Celbridge LAP 2017-23:- • expansion in Celbridge since the 1950s has taken a suburban form extending out from the historic core. • The age profile of Celbridge includes a high percentage of children, young people and people in the working age cohorts. • Households in Celbridge have an occupancy rate of two to four persons predominantly, reflecting the high proportion of young families and is typical of the county average in 2016. • Houses represent 89% of the housing stock, while apartments represent 10.3%. • It is anticipated that there will continue to be a strong demand for family housing. The need for smaller housing units and apartments should be

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considered within each of the Key Development Areas to contribute to the achievement of an appropriate housing mix and to address an emerging demand for smaller units. [Underlined emphasis added]

2.7 Summary

• The subject lands are greenfield in nature and generally flat.

• The lands potentially form an important link between the town and the schools and employment lands to the north.

• The lands directly adjoin a large post primary school with another new post primary school to the north-east.

• The lands are located on a public transport corridor consisting of a high frequency bus service which serves Maynooth, Celbridge town and Dublin City.

• The lands are linked to Louisa Bridge Train station via dedicated pedestrian route and cycle track.

• There is a dedicated shuttle service from Salesian College adjacent to the site to Hazelhatch train station.

• The lands are located with convenient proximity to a wide range of services, amenities and employment within Celbridge town.

• The lands are located with convenient proximity to multi-national employers in Leixlip (accessible via cycle lanes i.e. Intel).

• Apartments should be considered in Key Development Areas in the Celbridge LAP.

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3.0 PLANNING HISTORY

3.1 Planning History

There are no known planning permissions associated with the subject lands.

3.2 In Vicinity

3.2.1 372 Unit Residential Development (ABP-306504)

A Strategic Housing Development application has been lodged by Ardstone Homes Ltd on 24th January 2020 for a residential development involving 372 residential units (218 no. houses, 154 no. apartments) and a childcare facility on lands (9.55Ha) to the east side of the Maynooth Road. The proposed layout involves 4 storey apartment buildings and housing facing onto the R405 and R449, with 2 storey dwellings behind.

3.2.2 Adult Training Centre (Reg. Ref. 18/1325) Conditional permission was granted in May 2019 to use Unit A11, Building A for use as an adult training centre (970sq.m) in M4 Celbridge business park.

3.2.3 Light Industrial Unit (Reg. Ref. 19/1229) Conditional permission was granted in February 2020 for construction of a Maintenance Station-Aviation Industry light industrial unit and associated works with a total floor area of 3,720sqm south of M4 and North of R405 in Moortown, Celbridge, Co. Kildare.

3.2.4 New Temporary School (Reg. Ref. 19/473) Conditional permission was granted in February 2020 for the construction of a new single storey temporary post primary school building at Celbridge Community School, Maynooth Road, Moortown, Celbridge, Co. Kildare. A traffic

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impact assessment was submitted as part of this application and the findings of same accepted by Kildare County Council3.

3.2.5 School Extension (Reg. Ref. 19/918) Conditional permission was granted in February 2020 for construction of new single storey ASD unit 659sq.m to rear of existing school along with associated works at Salesian College, Mooretown, Celbridge, Co. Kildare.

19/1229 19/473

18/1325

19/918 ABP 306504

Site

Fig No.18 Relevant planning applications in the vicinity of the site.

3.2.6 79 Dwellings Reg. Ref. 16/260 An Bord Pleanalá granted conditional permission in February 2017 to grant permission for 79 dwellings on lands approximately 300m south of the subject site at Thornhill (Aghards) Rd/Maynooth Rd – see map below.

3 Prepared by NRB Consulting Engineers who are the traffic consultants for the current proposal.

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Site

Ref. 16/260

Fig No.19 Location of permitted residential development in Thornhill south of subject lands.

3.3 Significant Permissions in the General Area

3.3.1 Intel Manufacturing Facility (ABP-304672-19) On 21st November 2019 conditional permission was granted by An Bord Pleanala for an extended and revised manufacturing facility (granted under An Bord Pleanála appeal reference number PL 09.248582; Kildare County Council planning register reference number 16/1229) including reconfigured and extended support buildings, water tanks and yards to provide for additional manufacturing capacity. The development will consist of buildings, site infrastructure and ancillary works, for the manufacture of integrated circuits. The manufacturing building will be developed over four levels and will have a floor area of 109,745 square metres. It is envisaged that up to 3,000 people will be employed in construction for four years and up to 6,000 at peak construction for a period of six months. When operational there will be an additional 1,600 full time permanent jobs on site.

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4.0 PROPOSED DEVELOPMENT

4.1 Introduction

The applicant seeks permission to build 467 dwellings (houses and apartments) on the subject lands, along with a childcare facility, gym, café, and retail unit. Specifically, it is proposed to construct 199 no. houses and 268 no. apartments (including 52 no. duplexes).

In addition, it is proposed to provide a landscaped public park (2.068 ha)4, public open space (1.933Ha)5, 2 no. vehicular access points off the Maynooth Road, 719 no. car parking spaces (including 154 basement car park spaces), 574 cycle spaces, internal roads, footpaths, cycle paths, landscaping and all associated site works.

Apartments The proposed apartments blocks (A, B, C & D) are located to the east of the site where they will form a strong urban edge to the Maynooth Road, the key access route to the town from the north. The building height ranges from 5 – 6 storeys. Apartment Block A at the north end will mark the gateway entry point into Celbridge when approaching from the M4, serving as a landmark building and aiding legibility. Communal open space for the apartments is located at the rear (west) side. Parking for the apartments is provided at basement level.

Dwellings

There are 23 no. 3 storey, terrace dwellings arranged in a row of 3 no. blocks located to the west (rear) of the apartments providing a dual frontage onto public open space and communal open space within the scheme. Parking is provided on the east side at ground level.

4 The proposed public park (2.068Ha) extends beyond the ‘F’ zoned lands (1.935Ha). 5 Within the New Residential zoned lands.

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Further west, the proposed dwellings are arranged in perimeter blocks in order to ensure that all areas of the public realm within the scheme are overlooked, including the areas of public open space to the south, west and north of the scheme. The dwellings range from 2 – 3 storeys in height. Car parking is primarily provided within the curtilage of the dwellings, with some on-street car parking.

Ancillary Development In the southern apartment block (block D) it is proposed to provide the following ancillary land uses at ground floor level:

Table No.1 Commercial uses within ground floor of Block D. Use Gross Floor Area (sq.m) Childcare Facility (89 children) 776 Gym (for private use by residents only) 320 Café 123 Retail unit 119

Public Open Space The ‘F’ zoned lands to the north of the site (1.935Ha) will be a landscaped public park, including multi-use games area, kickabout areas and biodiversity areas. The spatial extent of proposed park will extend beyond the ‘F’ zoned lands into the ‘New Residential’ zoned lands (0.1332Ha) with the total area of the park measuring 2.068Ha.

Separately, a total of 1.933Ha of public open space will be provided within the ‘New Residential’ Zoned lands (17.99%). This consists of: • a centrally located village green which is connected to the open space to the east and west of the housing. • A generous area of quality open space between the row of 3 storey dwellings and the houses further west to allow a connection between the stream at the south and the park to the north.

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• an area of public open space at the southern and western perimeters of the site, as well as the most southern part of the eastern boundary.

All these spaces exceed the 10m minimum depth for public open space. The perimeter spaces were largely dictated by the need to protect the established trees around the perimeter of the site. It is submitted that the open space around the perimeter will provide an attractive route for walkers, joggers and dog walkers alike.

Car and Cycle Parking

A total of 709 car park spaces are provided as follows: apartments (216), duplexes (52), houses (398), visitors (33) and commercial (10). 154 no. car park spaces are provided at basement level.

A total of 574 cycle parking spaces are provided at basement level, along with 23 no. spaces at surface level adjacent to Block D to facilitate the commercial element of the scheme.

Works on Lands Owned by Kildare County Council It is proposed to provide 2 no. vehicular entrances, including road widening, Footpath and cycle track to be re-constructed/re-aligned, public lighting displaced to be re-instated; existing Toucan Crossing to be relocated, 'Kassel' kerbing to be re-aligned, Priority junction to be constructed and associated road markings and signage.

Kilwoghan Stream It should be noted that no works are proposed to the stream at the south of the site; it is to be retained in its natural state to minimize the impact on the local biodiversity. The only intervention near the stream relates to the overgrown trees and scrubland to the north side which will be thinned out and made more visually attractive.

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Overhead Lines The intention is to underground all overhead lines. This underground has been the subject of discussions with ESB. The ESB have confirmed in writing that they are happy in principle with the proposed strategy to relocate the overhead cable under a permanent roadway within the site - see letter enclosed with the application from OCSC Consulting Engineers. The undergrounding will occur in phase 1 of the construction phase.

4.2 EIAR Screening

The proposed development does not meet the mandatory EIAR threshold for residential schemes involving 500 dwellings or more dwellings under Schedule 5, Part 2, Section 10 (b) (i).

Kildare County Council have advised however that the proposed development does meet the threshold under Schedule 5, Part 10 (Infrastructure projects), subsection (b) (iv):-

“Urban development which would involve an area greater than 2 hectares in the case of a business district, 10 hectares in the case of other parts of a built-up area and 20 hectares elsewhere”.

Under Part One, Article 3 (interpretation) of the Planning and Development Regulations, 2001 (as amended) a “built-up area” means a city or town (where “city” and “town” have the meanings assigned to them by the Local Government Act, 2001) or an adjoining developed area;

On the basis of the above Kildare County Council have advised that a mandatory EIAR should be submitted with the application. We would question whether a greenfield site forms part of a built-up area or adjoining developed area and whether an EIAR is therefore mandatory in this instance. We consider

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an EIAR is not mandatory. Nonetheless, given the strong advice from the Council an EIAR accompanies the application.

4.5 Appropriate Assessment Screening

A review of all Natura 2000 sites within 15km of the site has been undertaken. This has revealed the presence of only one such site, namely the Rye Water Valley/Carton SAC, Site Code 001398 at a distance of approximately 3.4km from the site.

The Rye Water Valley/Carton SAC is located between Leixlip and Maynooth extending along the River Rye Water, a tributary of the River Liffey. The river was arterially drained in the early 1950s, but remains the only significant salmon spawning and nursery stream discharging into the River Liffey downstream of Leixlip dam. The Rye Water Valley/Carton SAC is designated for the protection of two molluscs listed on Annex II of the EU Habitats Directive. In addition, the marsh, mineral spring and seepage area found at Louisa Bridge, which supports the presence of these molluscs is considered to be rare in Europe and is a habitat listed on Annex I of the EU Habitats Directive (source: Draft Celbridge LAP AA Screening Report prepared by ARUP Consulting Engineers in December 2016.

It is important to note that the Rye Water Valley/Carton SAC flows into the River Liffey downstream from the location where the Kilwoghan Stream flows into the River Liffey. It is not possible therefore for any potential pollution of the Kilwoghan Stream to impact on the Rye Water Valley/Carton SAC. There is no ecological link.

Mr Roger Goodwillie, ecologist, was engaged to prepare a Stage 1 Appropriate Assessment Screening Report and his report has determined that there is no material risk to any Natura 2000 habitat and therefore no requirement for a Stage II Appropriate Assessment.

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Rye River

Site

River Liffey

Fig No.20 Location of subject site relative to the River Rye (source: EPA.ie). Note flow direction of each river which shows that there is no direct pathway from the subject site to the River Rye.

Rye River/Carton SAC

Site

Fig No.21 Natura 2000 sites within 15km radius of the subject site (Source: MyPlan.ie - OSI Licence No.EN 0080915).

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5.0 CONSISTENCY WITH MINISTERIAL PLANNING GUIDELINES & OTHER RELEVANT STRATEGIC PLANNING POLICY

5.1 Rebuilding Ireland - Action Plan for Housing & Homelessness 2016

This Action Plan is a response to the housing crisis which has seen a significant shortfall in housing particularly in the greater Dublin area. The Action Plan sets targets 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.

There are 5 pillars to the Action Plan. Pillar 3 – Build More Homes – seeks to increase the output of private housing to meet demand at affordable prices.

The delivery of 467 dwellings would represent a significant contribution to the housing shortfall in the Metropolitan Area of North East Kildare.

5.2 National Planning Framework 2040 (‘NPF’)

The NPF is based on a projection of a 5.7 million people population by 2040 which is used as a benchmark against which the strategy is placed. This benchmark provides for one million additional people, 660,000 additional jobs and 550,000 new homes by 2040 (or 25,000 houses to be built each year).

Under the NPF 50% of the national population growth should happen in the Eastern and Midlands (EMRA) Region and 50% of this population growth should happen within the City of Dublin and its suburbs. This represents significant housing growth in the EMRA Region up to 2040 which includes Co. Kildare.

The proposed development is considered to be consistent with the following national policy objectives:

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National Policy Objective 11 – In meeting urban development requirements, there will be a presumption in favour of development that can encourage more people and generate more jobs and activity within existing cities, towns and villages, subject to development meeting appropriate planning standards and achieving targeted growth.

National Policy Objective 32 – To target the delivery of 550,000 additional households to 2040.

National Policy Objective 33 – Prioritise the provision of new homes at locations that can support sustainable development and at an appropriate scale of provision relative to location.

National Policy Objective 34 – Support the provision of lifetime adaptable homes that can accommodate the changing needs of a household over time.

5.3 Sustainable Residential Development in Urban Areas, 2009 (‘SRDUA’)

The subject lands are considered to fall under the category of Outer Suburban / ‘Greenfield’ sites under the SRDUA Guidelines - defined as “open lands on the periphery of cities or larger towns whose development will require the provision of new infrastructure, roads, sewers and ancillary social and commercial facilities, schools, shops, employment and community facilities. Studies have indicated that whilst the land take of the ancillary facilities remains relatively constant, the greatest efficiency in land usage on such lands will be achieved by providing net residential densities in the general range of 35-50 dwellings per hectare and such densities (involving a variety of housing types where possible) should be encouraged generally. Development at net densities less than 30 dwellings per hectare should generally be discouraged in the interests of land efficiency, particularly on sites in excess of 0.5 hectares. (s.5.11 – emphasis added).

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The net residential density for the proposed development is 43.46 units per hectare (net of 1.933ha public open space to the north) and accords with the density range specified in the guidelines and the guidance received from An Bord Pleanala in the tripartite consultation meeting on 29th May 2019

The SRDUA Guidelines also place a strong emphasis on creating Sustainable Neighbourhoods where social and community infrastructure along with amenities are all within close proximity. The subject site is situated adjacent to 2 no. large post primary schools and within close proximity to 2 no. national school and a neighbourhood centre. It is also within walking and cycling distance of the town centre. Please refer to the Social Infrastructure Assessment attached with the application for a more in-depth analysis.

Specific reference is made in the Guidelines to promoting sustainable travel patterns in respect of schools, which is exactly what would be achieved by providing the proposed development adjacent to a post primary school. “Spatial planning has a fundamental role in promoting more sustainable travel patterns and helping to reverse recent trends which have seen a decreasing share of people travelling to work by bus or bicycle or on foot. According to the results of Census 2006, the majority (55%) of primary school children were driven to school by car, compared with 28% in 1991. Apart from the energy and climate change implications of the increasing use of the car for journeys to work and school, cycling and walking have a role in achieving healthier lifestyles” – emphasis added.

School Demand The Guidelines advise that planning applications for 200+ dwelling units should be accompanied by a report identifying the demand for school places likely to be generated by the proposal and the capacity of existing schools in the vicinity to cater for such demand.

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Please refer to the School Capacity Analysis prepared by David Mulcahy Planning Consultants Ltd enclosed with the application which concludes that there is sufficient capacity to meet the demand for school places that will be generated.

5.4 Sustainable Urban Housing: Design Standards for New Apartments; Guidelines for Planning Authorities (2018).

The Guidelines note that apartments are a significant part of the solution to avoid continued urban sprawl “Given the gap between Irish and European averages in numbers of households living in apartments and the importance of addressing the challenges of meeting the housing needs of a growing population in our key cities and towns and by building inwards and upwards rather than outwards, apartments need to become more and more the norm for urban housing solutions” - emphasis added.

Under Section 28 (1C) of the Planning and Development Act 2000 (as amended), Planning Authorities and An Bord Pleanála will be required to have regard to the guidelines and apply any specific planning policy requirements (SPPR’s) of the guidelines in carrying out their function.

5.4.1 Specific Planning Policy Requirements (SPPR’s)

SPPR1 states that apartment developments may include up to 50% one bedroom or studio type units (with no more than 20-25% of the total proposed development as studios), and there shall be no minimum requirement for apartments with three or more bedrooms.

Response: The scheme is comprised of 216 apartments and 52 no. duplexes. The apartments are contained in 4 blocks and consist of 184 no. two bed apartments

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(85%) and 32 three beds (15%). The duplexes consist of 18 no.1 beds, 26 no. 2 beds and 8 no. 3 beds.

SPPR2 relates to building refurbishment schemes

Response: Not relevant in this instance.

SPPR3 Sets out minimum floor areas for apartments.

Response: All apartments in the proposed development meet the minimum floor area requirements set out the Guidelines. A majority of all apartments also exceed the minimum floor area standard by a minimum of 10% (given the unit numbers are in excess of 100). Please refer to the schedule of accommodation provide by Scott Tallon Walker Architects.

Table 2 Minimum overall Minimum Proposed Duplexes apartment floor Floor Area (apts) areas One Bed 45sq.m N/A Two bedrooms 63 sq.m 78sq.m (3 person) Three 90sq.m 102 sq.m bedrooms

SPPR4 The minimum number of dual aspect apartments shall be 33% in central urban locations; otherwise there shall be a minimum of 50% dual aspect apartments in a scheme.

Response: Scott Tallon Walker Architects have confirmed that 82 (38%) of apartments are dual aspect with 134 (62%) being single aspect. The orientation of single facing apartments are either east or west facing as noted the Accommodation Schedule prepared by Scott Tallon Walker Architects.

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SPPR5 Ground level apartment floor to ceiling heights shall generally be a minimum of 2.7m.

Response: Scott Tallon Walker have confirmed that the 2.7m minimum floor to ceiling height requirement is complied with for ground floor units.

SPPR6 A maximum of 12 apartments per floor per lift core may be provided in apartment schemes in urban locations.

Response: Scott Tallon Walker have confirmed that the maximum apartment ratio per lift core is complied with.

Car Parking The Guidelines recommend that for “Intermediate Urban Locations - suburban/urban locations served by public transport or close to town centres or employment areas and particularly for housing schemes with more than 45 dwellings per hectare net (18 per acre), planning authorities must consider a reduced overall car parking” (s.4.21).

The subject site is located in a suburban area of Celbridge, well served by public transport and situated close to the town centre. The proposed density is below the 45/h net density but only marginally so. It is therefore submitted that parking requirements for intermediate urban locations should apply.

It is noted that there is no specified car parking requirement for intermediate urban locations in the guidelines but given the more onerous recommendation for peripheral sites in the guidelines is one space + 25% visitor spaces, it is obviously lower than this baseline. The aim therefore is to provide 1 space + approximately 10% visitor car parking for the apartments (including duplexes) which NRB Consulting Engineers have advised to be a reasonable approach and consistent with the guidelines.

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Please refer to the Car Parking Schedule prepared by Scott Tallon Walker Architects enclosed in Architect’s Design Statement which gives a breakdown of the proposed car parking for apartments (216), duplexes (52) and visitors (33).

Apartments: 216 spaces (154 basement car park spaces and 62 on-street spaces) with 22 on-street visitor spaces. This equates to one space + 10% visitor parking.

Duplexes: 52 spaces (30 off-street and 22 on street) with 11 visitor spaces. This equates to one space + 21% visitor parking.

This car parking provision for apartments (including duplexes) is considered to be consistent with the guidelines.

Bedroom and living/dining/kitchen sizes

Response: The minimum space standards and dimensions are achieved for the apartments as set out in Scott Tallon Walker’s Schedule of Accommodation.

Internal storage The minimum internal storage standards to be achieved for apartments are set out in the Appendix to the Guidelines. No individual storage room within an apartment should exceed 3.5sq. metres.

Response All apartments in the proposed development will meet the storage requirements set out the Appendix of the Guidelines. Refer to Schedule of Accommodation prepared by Scott Tallon Walker Architects.

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Table 3 Minimum Storage Areas

2018 Guidelines Apartments Duplexes One Bed 3sq.m N/A 3.2 sq.m Two Bed (3 5sq.m N/A 6.5sq.m person) Two bedrooms 6sq m 6.1sq.m 7sq.m (4 person) Three bedrooms 9sq.m 9.2sq.m 9sq.m

Private amenity space It is a specific policy that private amenity space shall be provided in the form of gardens or patios/terraces for ground floor apartments and balconies at upper levels. Where provided at ground level, private amenity space level shall incorporate boundary treatment appropriate to ensure privacy and security. A minimum depth of 1.5 metres is required for balconies.

Response The private amenity space provided in each apartment are highlighted in the Architects Design Statement prepared by Scott Tallon Walker Architects. The depth of all balconies are at least 1.5m. A schedule of areas is contained in the Schedule of Accommodation prepared by Scott Tallon Walker Architects. Ground floor level apartments all have a screened private amenity space.

Table 4 Minimum Floor Areas for Private Amenity Space

2018 Guidelines Apartments Duplexes One Bed 5sq.m N/A 48sq.m Two bedrooms 7sq.m 10.3 sq.m 14sq.m (4 person) Three bedrooms 9sq.m 16.1sq.m 10sq.m

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Communal facilities in apartments Communal amenity The minimum communal amenity space standards to be achieved for apartments are set out in the Appendix to the Guidelines.

Response The communal open space proposed provides a large amenity space in excess of the minimum requirements. Refer to Schedule of Accommodation prepared by Scott Tallon Walker Architects.

Table 5 Minimum floor areas for communal amenity space in apartments Two bedrooms (4 person) 7 sq.m x 184 = 1,288sq.m Three bedroom 9sq.m x 32 = 288sq.m 1,576sq.m required.

A total of 2,945sq.m of communal open space is provided which is significantly above the minimum requirement and reflects the high quality nature of the scheme in terms of residential amenity.

The duplexes all have the benefit of public open space in the same manner as the dwellings.

Bicycle storage The Guidelines note that “a general minimum standard of 1 cycle storage space per bedroom shall be applied … visitor cycle parking shall also be provided at a standard of 1 space per 2 residential units. Any deviation from these standards shall be at the discretion of the planning authority and shall be justified with respect to factors such as location, quality of facilities proposed, flexibility for future enhancement/enlargement, etc” (s.4.17).

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Response A total of 216 apartments are provided involving total of 463 bedrooms. This equates to 463 cycle spaces with an additional 108 spaces (216/2) for visitors - a total of 571 spaces.

A total of 574 cycle spaces are provided at basement level for the apartments - an overprovision of 3 no. spaces.

Bicycle storage for the duplexes is available in the rear gardens via garden sheds in the same manner as any house.

5.5 Urban Development and Building Heights Guidelines for Planning Authorities Consultation, 2018

The Urban Development and Building Height Guidelines were published on the 7th of December 2018 under Section 28 of the Planning and Development Act 2000, as amended. The Guidelines are intended to 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.

Section 3.1 notes that “In relation to the assessment of individual planning applications and appeals, it is Government policy that building heights must be generally increased in appropriate urban locations. There is therefore a presumption in favour of buildings of increased height in our town/city cores and in other urban locations with good public transport accessibility” - emphasis added.

SPPR3 states: ‘It is a specific planning policy requirement that where: (A) 1. an applicant for planning permission sets out how a development proposal complies with the criteria above; and

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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 or local area plan may indicate otherwise’.

5.5.1 Assessment under SPPR3:

In the event of making a planning application, the applicant shall demonstrate to the satisfaction of the Planning Authority/ An Bord Pleanála, that the proposed development satisfies the following development management criteria:

The focus is on the 4 no. apartment blocks along the eastern edge of the proposed development as they are the element of the scheme that is relevant in terms of building height with heights ranging from 5 - 6 storeys (top storey is setback)

At the scale of the relevant city/town: • The site is well served by public transport with high capacity, frequent service and good links to other modes of public transport.

The proximity of the site to public transport in the form of bus and rail has been addressed in detail in section 2.6 above. Please also refer to the Traffic Assessment prepared by NRB Consulting Engineers.

Development proposals incorporating increased building height, including proposals within architecturally sensitive areas, should successfully integrate into/enhance the character and public realm of the area, having regard to topography, its cultural context, setting of key landmarks, protection of key views. Such development proposals shall undertake a landscape and visual assessment, by a suitably qualified practitioner such as a chartered landscape architect.

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The proposed development is not located in an architecturally sensitive area. It is outside the corridor of the views associated with Castletown House to the south-east which are to be preserved in the Celbridge Local Area Plan 2017-23 (see Fig No.29 below).

The land uses in the vicinity are predominantly residential (south and east), educational (north-west) and employment (north). They are generally low scale buildings, but importantly are also all a significant distance from the proposed development. The one exception is the building east of the north end of the site (in the M4 business Park) which is 3 storey.

A landscape and visual assessment, by a suitably qualified practitioner such as a chartered landscape architect accompanies the application.

On larger urban redevelopment sites, proposed developments should make a positive contribution to place-making, incorporating new streets and public spaces, using massing and height to achieve the required densities but with sufficient variety in scale and form to respond to the scale of adjoining developments and create visual interest in the streetscape.

The subject site measures 12.93 hectares (including the 0.25Ha of lands owned by Kildare County Council) and in our opinion would constitute a large urban redevelopment site. We highlight that the proposed apartment blocks make a positive contribution to place making, using appropriate building height to create a gateway feature to Celbridge when approached from Junction 6 on the M4 motorway and creating a sense of enclosure along the Maynooth Road. The apartment blocks, in conjunction with the proposed 3 storey dwellings further west within the scheme, enclose a large area of communal open space which makes a significant contribution to place-making - refer to Architect’s Design Statement prepared by Scott Tallon Walker for details.

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At the scale of district/ neighbourhood/ street • The proposal responds to its overall natural and built environment and makes a positive contribution to the urban neighbourhood and streetscape.

The proposed apartment blocks have been designed sensitively to respond to the surrounding context and the natural and built environment. The site benefits from the fact that it does not adjoin any established development, particularly residential development, and there is a significant separation distance from any existing and proposed residential development in the vicinity. All residential development in the vicinity (east and south) is on the opposite side of a public road. In terms of the natural environment the proposed development will provide passive surveillance of the stream and surrounding open space to the south edge and the proposed public park to the northern edge. The existing row of trees to the eastern edge (south end) have been retained in situ other than to allow for pedestrian access.

The proposal is not monolithic and avoids long, uninterrupted walls of building in the form of slab blocks with materials / building fabric well considered.

The apartments are divided into 4 no. blocks to avoid a monolithic appearance. Furthermore they are animated in a manner that further ensures against a monolithic appearance - refer to Scott Tallon Walker’s Architectural Design statement in the Architect’s Design Statement.

The proposal enhances the urban design context for public spaces and key thoroughfares and inland waterway/ marine frontage, thereby enabling additional height in development form to be favourably considered in terms of enhancing a sense of scale and enclosure while being in line with the requirements of “The Planning System and Flood Risk Management – Guidelines for Planning Authorities” (2009).

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As noted above, the apartments have been designed to provide passive surveillance of the stream to the south and proposed public park to the north. They will also provide passive surveillance of the communal open space to the west side along with enclosing this space in conjunction with the proposed 3 storey dwellings further west.

The proposal makes a positive contribution to the improvement of legibility through the site or wider urban area within which the development is situated and integrates in a cohesive manner.

It is submitted that apartment block A is located at a prominent junction at the roundabout junction entering Celbridge from Maynooth and the M4. It has been designed in a manner that it will act as a landmark feature at this node (by virtue of its 6 storey height and attractive, north-facing, animated façade). The remainder of the apartment blocks will form a distinct urban edge leading into Celbridge town.

The proposal positively contributes to the mix of uses and/ or building/ dwelling typologies available in the neighbourhood.

There is a notable lack of apartments in Celbridge (only 10.3% according to the Celbridge LAP 2017-23) and the proposed apartment will therefore make a positive contribution to the housing mix in the town offering more choice for homeowners and/or tenants.

Block D contains a gym, café, childcare facility and retail unit which will add to the mix of uses in the area.

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At the scale of the site/building • The form, massing and height of proposed developments should be carefully modulated so as to maximise access to natural daylight, ventilation and views and minimise overshadowing and loss of light.

It is submitted that the design of the proposed development allows sufficient natural daylight access, ventilation and views with minimal overshadowing and loss of light on neighbouring properties or the development itself. Please refer to the Daylight and Sunlight assessment prepared by OCSC Consulting Engineers.

• Appropriate and reasonable regard should be taken of quantitative performance approaches to daylight provision outlined in guides like the Building Research Establishment’s ‘Site Layout Planning for Daylight and Sunlight’ (2nd Edition) or BS 8206-2: 2008 – ‘Lighting for Buildings – Part 2: Code of Practice for Daylighting’.

The accompanying Daylight and Sunlight assessment by OCSC Consulting Engineers assesses the apartment units within the development and concludes that for all habitable rooms the daylight levels are acceptable.

• Where a proposal may not be able to fully meet all the requirements of the daylight provisions above, this must be clearly identified and a rationale for any alternative, compensatory design solutions must be set out, in respect of which the planning authority or An Bord Pleanála should apply their discretion, having regard to local factors including specific site constraints and the balancing of that assessment against the desirability of achieving wider planning objectives. Such objectives might include securing comprehensive urban regeneration and or an effective urban design and streetscape solution.

Not applicable in this instance.

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Conclusion In conclusion the above assessment under SPPR3 finds that proposed development meets each of the relevant criteria for building height at this location and we invite the Board as the relevant planning authority to agree with same.

Section 3.4 of the Guidelines deals with ‘Building height in suburban/edge locations (City and Town)’ and notes that “newer housing developments outside city and town centres and inner suburbs, i.e. the suburban edges of towns and cities, typically now include town-houses (2-3 storeys), duplexes (3-4 storeys) and apartments (4 storeys upwards). Such developments deliver medium densities, in the range of 35-50 dwellings per hectare net. Such developments also address the need for more 1 and 2 bedroom units in line with wider demographic and household formation trends, while at the same time providing for the larger 3, 4 or more bedroom homes across a variety of building typology and tenure options, enabling households to meet changing accommodation requirements over longer periods of time without necessitating relocation” – emphasis added.

Section 3.6 therefore, goes on to state that “Development should include an effective mix of 2, 3 and 4-storey development which integrates well into existing and historical neighbourhoods and 4 storeys or more can be accommodated alongside existing larger buildings, trees and parkland, river/sea frontage or along wider streets” – emphasis added.

It is submitted that the proposed development meets this mix requirement - 2, 3, 5 and 6 storey (with setback) development with a range of different house types provided.

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5.6 National Transport Authority: Transport Strategy for the Greater Dublin Area 2016- 2035

The Transport Strategy places a strong emphasis on the need to promote sustainable travel patterns in relation to schools:

The zoning and development of land needs to be carried out in a manner which promotes walking, cycling and public transport for all trips and reduces the need for commuting by private car, particularly zoning for schools and large workplaces (s.3.6 – emphasis added.).

The proposed development will be in close proximity to primary and post primary schools and will encourage walking and cycling to schools. There is also a high frequency of public transport in the vicinity which would facilitate to schools at a further distance within the town.

The Transport Strategy also notes that a DART service will be provided to Hazelhatch in Celbridge and Maynooth, via Leixlip, as part of the DART Expansion Programme. Therefore, residents will have the option of cycling to enhanced train services in Leixlip or availing of the shuttle bus service to Hazelhatch.

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Site

Fig No.22 National Transport 2035 Overall Metropolitan Heavy and Light Rail Network adapted to show location of subject lands (white star symbol).

5.7 Childcare Facilities Guidelines for Planning Authorities June, 2001

Section 2.4 of the Guidelines deals with ‘Appropriate Locations for Childcare Facilities’ and note that for New communities/Larger new housing developments, planning authorities should require the provision of at least one childcare facility for new housing areas unless there are significant reasons to the contrary for example, development consisting of single bed apartments or where there are adequate childcare facilities in adjoining developments. For new housing areas, an average of one childcare facility for each 75 dwellings would be appropriate. This section goes on to state that authorities could consider requiring the provision of “larger units catering for up to 30/40 children in areas of major residential development on the basis that such a large facility might be able to offer a variety of services – sessional/drop in/after-school, etc.”.

Section 3.3.1 notes that in relation to new housing areas, a standard of one childcare facility providing for a minimum 20 childcare places per approximately

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75 dwellings may be appropriate depending on established childcare facilities and the number of one-bed units being proposed.

It is submitted to the Board that there are a large number of established childcare facilities within convenient walking distance of the subject site – see diagram below. It is also important to note that the Celbridge LAP 2017-23 recommends childcare provision at a rate of 1 facility per 150 dwellings on account of the healthy provision of existing childcare facilities in the area (this is addressed in more detail in section 6.2.5 below).

The proposed development contains a total of 467 dwelling units. Using the national average household size of 2.75 it is estimated that the proposed development will yield a population of approximately 1,285 persons. The pre- school cohort (aged 0-4) represents 7% of the overall population recorded in the 2016 Census. 7% of 1,285 (estimated population based on average household size of 2.75 persons) equates to 89.89 (90) children of pre-school age. This requirement is met by the proposed childcare facility which caters for 89 children.

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Site

Fig No.23 Location of established childcare facilities within walking distance of the subject site (source: Pobal Childcare Services Mapping).

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5.8 Eastern & Midland Regional Assembly Regional Spatial & Economic Strategy, 2019 - 2031 (RSES)

The Regional Spatial and Economic Strategy (RSES) for the Eastern and Midland Region was adopted on the 3rd May 2019 and came into effect on the 28th June 2019.

Celbridge is located in the Eastern Strategic Planning Area under the RSES and is identified as being within the Dublin Metropolitan Area. Under the RSES a Dublin Metropolitan Area Strategic Plan (DMASP) has been prepared to manage the sustainable and compact growth of Dublin. During the lifetime of the RSES the population of the DMASP area is projected to increase by 16%, or 250,000 people. The following policy under the DMASP is considered relevant:

RPO 5.4: 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’ - emphasis added.

Celbridge is identified as a Self-Sustaining Town - towns that require contained growth, focusing on driving investment in services, employment growth and infrastructure whilst balancing housing delivery.

It is submitted that the proposed development is consistent with the RSES by reason of the fact that will provide a high-density development of notable qualitative standard in Celbridge and is consistent with the relevant national planning guidelines.

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6.0 CONSISTENCY WITH DEVELOPMENT PLAN & LOCAL AREA PLAN

6.1 Kildare County Development Plan 2017-23 (‘KCDP’)

The subject lands are located within the administrative area of Kildare County Council and are therefore subject to the Kildare County Development Plan 2017- 23 (‘KCDP 2017-23’).

The KCDP 2017-23 notes that “in the 5 years between Census 2006 and Census 2011, Kildare experienced the 6th highest rate of population growth with an increase of 13% (23,977 persons) on the 2006 population (186,335 persons)” (s.1.3 – emphasis added). A continued strong growth rate has occurred in County Kildare between the Census 2011 and Census 2016 with a 5.6% population rate.

Section 4.1 notes that Kildare has “larger than average household size” (emphasis added) and section 4.6 notes that the average household size is 2.94 persons6.

The KCDP 2017-23 identified one of the key challenges facing Kildare for the Plan period to be “that of directing population growth to the main urban centres with maximum growth focused on the Metropolitan towns of Maynooth, Celbridge, Leixlip and Kilcock” (s.1.3 – emphasis added)

It is further stated that “Development within the Metropolitan Area which includes the north east Kildare towns of Maynooth, Leixlip, Celbridge and Kilcock, will be consolidated to achieve a more compact urban form, allowing for the accommodation of a greater population than at present” (s.1.4.2).

6 Average household size for the country in 2016 Census is 2.75 persons, up from 2.73 in 2011 Census.

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In relation to Public Transport Corridors the Plan seeks “to maximise the return on transport investment” noting that “it is important that land use planning underpins the efficiency of public transport services by sustainable settlement patterns – including appropriate densities – on lands within existing or planned transport corridors”. In this regard “Walking distances from public transport nodes (e.g. stations /bus stops) shall be used in defining such corridors within local area plans. Higher densities shall be determined on a site by site basis for sites within 500 metres walking distance of a bus stop” (s. 5.8 – emphasis added)

The Plan notes that 16% of commuters walk or cycle to work, school or college. This latter figure is well below the regional average of 22%. The Plan therefore specifically encourages walking and cycling to school and seeks to reduce traffic congestion associated with school traffic in the preparation of LAPs.

Apartments The KCDP 2017-23 notes that the “provision of apartment schemes shall only be considered in appropriate locations, at a suitable scale and extent. Primarily this will be in town centre locations and proximate to public transport” (s.17.4.6 – emphasis added). The location of the subject site adjacent to a public transport corridor (buses) accords with this requirement.

6.1.2 Residential Density

The proposed net density of 43.46 units per hectare accords with Table 4.2 in the County Development Plan which provides for a density range of 35-50 units per hectare on ‘Outer Suburban / Greenfield’ sites in Large Towns.

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6.1.3 Statement of Housing Mix

As the scheme exceeds 50 units a Statement of Housing Mix is required under Policy HSO 8. Policy HSO 8 seeks to ensure that an appropriate mix of housing types and sizes is provided in each residential development.

The following represents the Statement of Housing Mix:

The proposed development provides for a total of 467 dwellings ranging from 1 bed dwellings to 5 bed dwellings.

Unit mix percentage breakdown: Table 6 Proposed Housing Mix Unit Type Number Proposed Percentage Mix 1 bed units 18 (3.85%) 2 bed units 210 (44.97%) 3 bed units 127 (27.19%) 4 bed units 92 (19.70%) 5 bed units 20 (4.28%)

This mix equates to a breakdown of 48.82% smaller units (1 and 2 beds) with 51.18% (3+ beds).

It is submitted that the large number of small units (228 units) will represent a significant addition to Celbridge which is dominated by 3 and 4 bed housing units, and will increase the choice for younger persons looking for starter homes or to rent, and for persons looking to down-size in their local community.

The large units (3 beds+) will cater for the strong demand in Celbridge for family sized homes. As noted in the KCDP 2017-23, County Kildare has larger than average household size and the average household size is 2.94 persons.

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It is submitted that the mix of dwelling units proposed will cater for a wide range of household types.

6.1.4 Social Infrastructure Assessment

Policy CO 2 seeks a Social Infrastructure Assessment (SIA) for all residential schemes on zoned land. Please refer to the SIA prepared by David Mulcahy Planning Consultants Ltd submitted with the application.

6.1.5 Part V

Policy HSO 2 seeks to apply a 10% social housing requirement, pursuant to Part V of the Planning and Development Act 2000 (as amended) to all sites that are zoned solely for residential use, or for a mixture of residential and other uses.

Discussions have taken place with Kildare County Council Housing Section and an agreement has been reached to transfer 10% completed units to the Council. A letter from Kildare County Council Housing Section is included with the application. Please refer to the site layout plan prepared by Scott Tallon Walker Architects which outlines the location of the Part V units in a pepper-potted fashion throughout the scheme. House types for each of the Part V units are also provided, along with costings.

6.1.6 Design Statement

Policy HCO 4 seeks to require the submission of a design statement with planning applications that incorporate 10 or more residential units.

A detailed Architects Design Statement prepared by Scott Tallon Walker Architects is enclosed with the application. Note, this design statement also includes the Architects Report addressing facia treatments, materials and finishes as requested by An Bord Pleanála in the tripartite meeting.

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6.1.7 Removal of Hedgerows

Policy NH 1 of the CDP seeks to “facilitate, maintain and enhance as far as is practicable the natural heritage and amenity of the county by seeking to encourage the preservation and retention of woodlands, hedgerows, stonewalls, rivers, streams and wetlands. Where the removal of such features is unavoidable, appropriate measures to replace like with like should be considered, subject to safety considerations” - emphasis added.

The hedgerows along the western, and eastern7 boundaries will be retained as part of the proposed development, along with the thicket to the south8; only the central hedgerow boundaries will be removed.

The Arboricultural Impact Assessment prepared by The Tree File Ltd concluded that the hedgerows with the centre of the site (i.e. those dividing the fields) are of poor quality and can be removed. It notes that replacement planting within the proposed landscape plan will compensate for same.

In addition, the EIAR Biodiversity assessment carried out by Mr. Roger Goodwillie found that the “The lands in question do not have significant [natural] heritage interest; they contain common and expected species of wildlife for an agricultural area … The southern drainage ditch and western hedge support most of the biodiversity owing to their more complex physical structure (trees etc)” – emphasis added. The report notes that “The growth of gardens within the estate and the landscaping of open spaces will do something to maintain some bird and insect populations though not in their current diversity” however, “The more interesting areas for biodiversity on the site will be maintained”.

7 Southern portion of eastern boundary. 8 To be improved as per landscape proposals.

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Replacement planting will be provided in the form of new native deciduous tree planting throughout the scheme. Refer to the landscape plan and drawings prepared by Kevin Fitzpatrick Landscape Architects for details.

6.1.8 Biodiversity

The following KCDP Policies are deemed relevant:

GI 19 Require the submission of an Ecological Impact Assessment where deemed necessary by the planning authority (and where necessary an Appropriate Assessment in relation to Natura 2000 sites) including bat and otter surveys for developments along river, stream and canal corridors.

Please refer to the Biodiversity chapter of the EIAR which assesses the impact of the proposed development.

GI 23 Contribute towards the protection of rivers, streams and other water courses and, wherever possible, maintain them in an open state capable of providing suitable habitats for fauna and flora while discouraging culverting or realignment.

The approach adopted is to leave the Kilwoghan Stream in its current natural state. No works are proposed to the stream.

GI 24 Consult, as appropriate, with Inland Fisheries Ireland in relation to any development that could potentially impact on the aquatic ecosystems and associated riparian habitats.

A copy of this application has been submitted to Inland Fisheries Ireland.

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GI 20 Maintain a biodiversity zone of not less than 10 metres from the top of the bank of all watercourses in the county, with the full extent of the protection zone to be determined on a case by case basis by the Council, based on site specific

characteristics and sensitivities.

A biodiversity zone of 10m has been provided for north of the stream. Please refer to drawing no.101 prepared by Kevin Fitzpatrick Landscape Architects which shows the extent of this 10m zone. The only works within this zone are a pedestrian/cycle route. Some landscaping is proposed within this zone however this only consists of retaining and enhancing existing vegetation, along with riparian planting.

WC 8 Contribute towards the protection of waterbodies and watercourses,

including rivers, streams, associated undeveloped riparian strips, wetlands and

natural floodplains, from inappropriate development. This will include buffers free

of development in riverine and wetland areas, as appropriate.

See response above.

6.1.9 Childcare

Section 17.5 deals with Childcare Facilities. It notes that all childcare facilities shall be provided in accordance with the Childcare Facilities: Guidelines for Planning Authorities (DEHLG). In particular the following should be noted:

“One childcare facility is generally required to cater for 20 places in developments of 75 houses, including local authority and social housing schemes, in accordance with DEHLG Guidelines”. It is further noted that:-

“This standard may be varied depending on local circumstances. The Council will consult with the Kildare County Childcare Committee in this regard”. – emphasis added

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6.1.10 Development Management Standards

The relevant development management standards which apply to new residential development are addressed below.

Site coverage

The site coverage of the proposed development at 19.3% is below the 50% maximum for residential development specified in the CDP (s.17.2.2) and reflects the generous public and private open space provision within the scheme.

Plot Ratio

The plot ratio of 0.43 (based on site area of 12.68Ha which excludes the proposed works on Kildare County Council lands) is below the 0.5 limit for outer suburban sites in close proximity to public transport (s.17.2.3).

Public Open Space

The CDP requires a minimum of 15% public open space for residential development on greenfield lands (s.17.4.7). A total of 1.933Ha of public open space is provided within the residential zoned lands. This figure equates to 17.99% of the site (residential zoned lands only) and therefore comfortably exceeds the minimum.

When taken in conjunction with the additional 1.935 hectares of public open space at the north end of the site, the amount of public open space that will be available to residents will be considerable by any reasonable measurement.

From a qualitative perspective all the open space is conveniently located to the proposed dwellings and is overlooked. A combination of passive and recreational spaces is provided.

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House Size & Storage (including Duplexes)

The minimum house size and storage area are all met – see tables below and Schedule of Accommodation prepared by Scott Tallon Walker Architects.

Table No.7 Minimum House Floor Area House Type KCDP Size Min. Requirement (sq.m) Min. Provided (sq.m) 3 bed 100 106 4 bed 110 149.5 5 bed 110 163

Table No.8 Minimum Storage Area House Type KCDP Min. Storage (sq.m) Min. Provided (sq.m) 3 bed 9 9 4 bed 10 10.1 5 bed 10 10

Private Open Space (Including Duplexes)

The minimum private open space requirement for all house types is met – see tables below along with Architects Design Statement and Accommodation Schedule prepared by Scott Tallon Walker Architects.

Table No.9 Minimum Private Open Space Provision House Type KCDP Requirement (sq.m) Min. Provided (sq.m) 1 bed 48 48 2 bed 55 55 3 bed 60 60 4 bed 75 75 5 bed 75 75 *Note the majority of private open space provision is well in excess of the minimum – refer to site layout prepared by Scott Tallon Walker Architects.

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Car Parking

Table 17.9 of the KCDP 2017-23 requires a minimum of 2 no. spaces per unit for houses and 1.5 spaces per unit + 1 visitor space per 4 apartments for apartments.

Please refer to the Car Parking Schedule prepared by Scott Tallon Walker Architects enclosed with Architects Design Statement.

Table No.10 Compliance with KDCP Minimum Residential Parking Standards Houses Duplexes Apartments Total No. of units Proposed 199 52 216 467 KDCP Requirement 398 91 378 867 Proposed car parking 398 63* 238** 699 Shortfall 0 28 140 168 *52 + 11 visitor **216 + 22 visitor

This shortfall on KCDP minimum requirements is considered to be acceptable having regard to the fact that the car parking for the apartments and duplexes is consistent with the Sustainable Urban Housing: Design Standards for New Apartments Guidelines for Planning Authorities, 2018 – as addressed in section 5.4 above.

10 no. car park spaces have been provided to serve the commercial element of the scheme in Block D i.e. the childcare facility, shop, gym and café. As noted in table No.11 below this is a shortfall based on KCDP requirements.

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Table No.11 KCDP Commercial use car parking requirements Use GFA (sq.m) KCDP Req. Spaces Req. Childcare Facility 776 0.5 per staff + 1 23 + 5 staff spaces (89 children) per 4 children (28) Gym (private) 320 1:15sq.m 0* Café 123 1:10sq.m 12 Retail unit 119 1:20sq.m 6 Total 46 *The proposed gym is private to residents of the proposed development who can all walk or cycle and therefore will not generate any car parking demand.

We would strongly argue that 10 no. car park spaces is sufficient having regard to the fact that the proposed commercial uses are within convenient walking and cycling distance from all dwelling units in the proposed development who are expected to be the primary users of the proposed commercial uses (note the gym is for private use of the residents only and will not attract any visitors). The proposed car parking is primarily needed to serve staff and visitors to the development. However, in this regard, it is reasonable to expect that staff are likely to be residents of the scheme and staff car parking demand is likely to be very low. Visitors are also expected to be low as there are ample local shops and cafes elsewhere in Celbridge, including ‘Applegreen’ in the M4 business park close by. Where travel is necessary for visitors and/or staff they can avail of high-quality public transport and cycle access to the site.

We note that the car parking arrangement for these 10 no. spaces is provided in the form of a dedicated drop-off loop to facilitate parents dropping off or collecting children in order to facilitate efficient traffic circulation. Again, most parents are likely to live in the scheme and will walk or cycle to the childcare facility so demand is expected to be low.

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Cycle Parking

Table 17.10 of the CDP deals with Cycle Parking Standards and notes that Apartments require 1 space per unit + 1 visitor space per 2 units. A total of 216 apartments are provided which gives rise to a need for 216 + 108 visitor spaces - a total of 324 cycle spaces. A total of 574 cycle spaces are provided at basement level for the apartments. There is no KCDP requirement for houses. In relation to the commercial uses in Block D Table 17.10 requires a total of 23 cycle spaces. It is proposed to provide a total of 23 cycle spaces.

Table No.12 KCDP Commercial use cycle parking requirements Use GFA (sq.m) KCDP Req. Space Req. Childcare Facility (89 776 1 per 5 staff 10 children) 1 per 10 children Gym 320 1:50sq.m 6 Café 123 1:30sq.m 4 Retail unit 119 1:40sq.m 3 Total 23

6.2 Proposed Variation (No.1) to the Kildare County Development Plan 2017-23

On the 9th January 2020 Kildare County Council issued a public notice that it proposes to make a variation to the Kildare County Development Plan 2017– 2023. The stated purpose of the respond to the recent changes in national and regional policy, namely the publication of Project Ireland 2040: National Planning Framework (NPF), The Implementation Roadmap for the National Planning Framework and the Eastern and Midland Regional Assembly (EMRA) Regional Spatial and Economic Strategy (RSES).

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The proposed variation comprises of the following:

• The integration of the changes in national and regional policy into the Kildare County Development Plan 2017-2023; • Integration of the Transitional Population Projections contained in the NPF Implementation Roadmap and; • Revisions to the overall county Settlement Hierarchy;

Celbridge is identified as a Tier 3 Self-Sustaining Town as per the RSES.

The key element of the proposed variation to the current Kildare County Development Plan from a housing perspective is the reduction in the population target projection for Kildare to the end of the Plan period from 253,600 under the current plan to 238,993, and the knock-on implications for housing allocation from 32,497 units by 2023 to 6,023 unit. The housing target for Celbridge by 2023 is 603 units (table 3.3). It is noted however that table 3.3 also states that the NPF 2026 housing target units for Celbridge is 1,406 and it is considered that the proposed development is acceptable in this context - as was confirmed Ms. Louise Murphy of Kildare County Council in the pre-planning meeting on 11th February 2020.

We note that 73 submissions have been made in respect of this variation so there are likely to be material amendments and it will not be adopted until summer time this year.

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6.3 Celbridge Local Area Plan 2017-23 (‘CLAP’)

6.3.1 Zoning Objectives

The subject lands are primarily zoned ‘C’ (New Residential) with 1.935Ha of lands to the north of the site zoned ‘F’ (Open Space /Amenity).

The zoning objective for ‘C’ zoned lands is ‘To provide for new residential development’. The proposed development involves 467 residential dwellings, childcare facility, gym, café and local shop along with associated open space, roads, paths, cycle lanes etc within the ‘C’ zoned lands. Dwellings and childcare facility are permitted in principle under the New Residential zoning objective. Shop and gym are open for consideration uses. A café is not referenced in the land use zoning matrix but a restaurant, which is the most comparable use, is open for consideration.

The zoning objective for ‘F’ zoned lands is ‘To protect and provide for open space, amenity and recreation’. A park is a permissible use under the zoning objective.

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Employment

School

Site

Neighbourhood Centre

Fig No.24 Extract from Celbridge LAP 2017-23 showing subject lands to be zoned ‘C’ (New Residential) and ‘F’ (Open Space/Amenity).

6.3.2 Key Development Area

The subject lands are identified as part of one of the 5 Key Development Areas in Celbridge - KDA4 – 21.9 hectares. KDA4 is comprised of the subject lands on the west side of the Maynooth Road and the New Residential zoned lands on the east side of the Maynooth Road.

Policy CSO1.2 seeks To support new residential development in Key Development Areas (KDAs) in tandem with the delivery of supporting physical and social infrastructure.

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See section 6.2.7 below for further details.

6.3.3 Residential Density

Table 4.1 of the LAP shows the estimated density for KDA4 lands to be 600 units based on 30 units per hectare within 21.9 hectares.

Section 12.2.4 states that lands in KDA4 will accommodate medium to low- density residential development in the order of 25 units per hectare. However, where the quality of the design and layout is particularly high, a maximum density of 30 units per hectare may be achievable.

The net residential density for the proposed development is 43.46 units per hectare. The density exceeds the density limit stipulated in the CLAP 2017-23, although we highlight that the CLAP 2017-23 itself states that where conflict exists between the CLAP and the KCDP, the KCDP will take precedence.

“This LAP outlines specific policies and objectives of the Council with regard to developing Celbridge. The overarching policies and objectives of the Kildare County Development Plan also apply, specifically the Development Management Standards set out in Chapter 17. Where conflict exists between the LAP and the CDP, the CDP will take precedence.” - s.13.2 emphasis added.

The proposed residential density is consistent with the KCDP and therefore we do not consider that a material contravention occurs. Nonetheless, in the event that the Board disagree, we have provided a Material Contravention Statement below.

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Material Contravention Statement

The proposed residential density of 43.46 units per hectare is not consistent with the ‘maximum’ density of 30 units per hectare for the subject lands under Section 12.2.4 of the CLAP.

Under Section 5(6), the Planning and Development (Housing) and Residential Tenancies Act, 2016, the Board may grant planning permission for a proposed development that is considered to materially contravene the Development Plan, other than in relation to zoning, having regard to the requirements of Section 37(2)(b) of the Planning and Development Act, 2000, as amended. The requirements of section 37(2)(b) of the Act of 2000 are as follows;

(i) the proposed development is of strategic or national importance, (ii) there are conflicting objectives in the development plan, or the objectives are not clearly stated, insofar as the proposed development is concerned, or (iii) permission for the proposed development should be granted having regard to regional spatial and economic strategy for the area, guidelines under section 28, policy directives under section 29, the statutory obligations of any local authority in the area, and any relevant policy of the Government, the Minister or any Minister of the Government, or (iv) permission for the proposed development should be granted having regard to the pattern of development, and permissions granted, in the area since the making of the development plan.

We submit that Board can grant permission as follows: Subjection (i) The proposed development comes within the definition for ‘Strategic Housing Development’ under the Acts on the basis that the proposed development exceeds 100 no. units and is located on zoned residential land. Furthermore, the proposed development of 467 no. units in the Metropolitan Town of Celbridge is of strategic importance in terms of securing appropriately

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designed compact residential development on zoned and serviced lands, being located immediately adjacent to a bus route (number 67 Dublin Bus) and helping to avoid further urban sprawl.

Subsection (ii) as there are conflicting objectives in the development plan and the Celbridge LAP.

6.3.4 Demographics

The LAP notes that “Households in Celbridge have an occupancy rate of two to four persons predominantly, reflecting the high proportion of young families and is typical of the county average in 2016” (Pg.24) and “Residential development in Celbridge predominantly comprises medium detached houses” (pg.25).

The proposed development provides for 1-5 bed dwelling units and therefore will cater for a wide range of household sizes. The predominant house type is 2 bed dwellings (44.97%), with 3 bed dwellings (27.19%) and 4 bed dwellings (19.70%) being the other dominant house types. It is submitted that this mix will cater for the 2- 4 bed demand for housing in Celbridge.

6.3.5 Residential Density, Mix and Design

The LAP notes that “The housing allocation for Celbridge is based on an average density of 30 (approx.) units per hectare … The need for smaller housing units and apartments should be considered within each of the Key Development Areas to contribute to the achievement of an appropriate housing mix and to address an emerging demand for smaller units” (s.6.2.2).

A significant number of smaller units are proposed within the scheme (18 no. one beds (3.85%) and 210 two beds (44.97%).

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Policy RD 2 ‐ Residential Density, Mix and Design The LAP also notes that “It is the policy of the Council to require that all new residential development provides for a sustainable mix of house types, sizes and tenures and that new development complements the existing residential mix”.

The varied mix of units provided has been addressed above (see section s.6.1.3).

It is an objective of the Council: RDO2.1: To require all new residential developments meet the (relevant national) standards and guidance. RDO2.2: To ensure that a good mix of housing types and sizes is provided in each Key Development Area to meet the future needs of the population of Celbridge. RDO2.3: To require the submission of a Design Statement and Housing Mix Statement with applications for residential development in accordance with the provisions of the County Development Plan. RDO2.4: To apply a 10% social housing requirement, pursuant to Part V of the Planning and Development Act 2000 (as amended) to all sites that are zoned solely for residential use or for a mixture of residential and other uses (save where the development is exempt from the provisions of Part V).

All these objectives have been met as demonstrated above in this report. Early Childcare and Education (s.6.3.2) The CLAP 2017-23 states that “ a rate of 20 childcare spaces per 150 dwellings represents an adequate level of provision in conjunction with new housing development and “Planning applications for housing within Key Development Areas (KDA’s) will be required to outline proposals to meet childcare requirements on a pro‐rata basis in accordance with the phasing strategy set out in Chapter 13 of the LAP. To ensure the optimal outcome it is considered that the pro‐rata provision be provided at an onsite or off‐site location that is proximate to the site” - emphasis added.

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COMO1.2 To require the provision of childcare spaces in the Key Development Areas, in accordance with the phasing requirements set out in Chapter 13.

20 childcare spaces per 150 dwellings equates to a total demand for 62.26 childcare spaces. It is proposed to provide a childcare facility accommodating 89 no. children which meets this demand. The issue of phasing in respect of childcare spaces is addressed below.

6.3.6 Community & Recreational Facilities

COMO2.2: To ensure that adequate and safe amenity and recreational open spaces are available for all groups of the population at a convenient distance from their homes and places of work.

It is submitted that the future residents will have the benefit of generous public open space provision within the residential zoned lands (1.933Ha), along with the 1.935 hectare park to the north which forms part of the overall site. The site is also within convenient walking distance of the entrance to the demesne lands in Castletown House, which are open to the public.

6.3.7 Council Design Brief

Design briefs have been prepared to guide development in Key Development Areas 2, 3, 4 and 5 (the subject lands are identified as KDA 4). These design briefs set out broad parameters for the future development of these areas. The briefs are based on an appraisal of each area in relation to its urban and landscape setting. While principal access points and connections, key building frontages and public spaces should generally be regarded as fixed requirements, a degree of flexibility can apply. For example, access points from the main road network and key connections within the KDA will be required but the actual position of each connection could be altered subject to appropriate traffic safety considerations. Key building frontages may be varied where it is

David Mulcahy Planning Consultants Ltd demonstrated that there is a strong urban design rationale and that passive supervision of public spaces is not compromised – emphasis added.

Fig No.25 Design Concept for KDA 4 Crodaun.

The Design Concept show provision for: • New vehicular entrance from public road to east • Centrally located public open space • Open space to the south and eastern perimeter • North-South pedestrian/cycle links • East-West pedestrian/cycle link along the south of the residential zoned lands • A new link road from roundabout • Use of perimeter blocks • Fronting housing onto public road to east

Full details of compliance with KDA4 are provided below.

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The Celbridge LAP identifies the subject lands as part of Key Development Area No. 4 Crodaun. The stated ‘Vision’ is “a residential area and public park that consolidates development to the north of the town and presents a landscaped edge to the Maynooth Road”.

The proposed development will deliver a housing development and a public park. A landscaped edge is provided to the east of the proposed apartment blocks.

Connectivity/ Movement The primary means of vehicular access to this KDA will be off the Maynooth Road. New streets and spaces should provide for a cycle and pedestrian friendly environment with connections to the Maynooth Road and Kilwogan Lane. A permeable and integrated street network shall be a key requirement of development proposals.

There are two vehicular entrances proposed, both from the Maynooth Road to the east of the site, which accords with DMURS in terms of increasing permeability. This represents a deviation from the Celbridge LAP which shows one vehicular entrance of the Maynooth Road and one off the new link road from the roundabout junction. However, the Council have confirmed that the link road to the north, off the roundabout junction, no longer forms part of the Celbridge LAP 2017-23.

The proposed layout is based on the perimeter block layout and involves a permeable network of streets and spaces as required.

Provision has been made to potentially extend two of the internal roads to facilitate future development to the west of the site at a future date. These areas will be taken in charge by the Council as part of the open space area and can be used to facilitate a potential connection to these lands at a future date. It is highlighted that these areas extend fully to the western boundary of the site. It is

David Mulcahy Planning Consultants Ltd submitted that this approach is more appropriate than extending the roads to the edge of the site as they would disrupt the open space and the pedestrian route it contains. The lands to the west are not zoned for any development at present and it could be some time before any development occurs on these lands. In the meantime, the residents of the proposed development will have the benefit of open space. Any purchaser of a dwelling in the scheme will be aware from the planning drawings that provision has been made to facilitate 2 no. potential connections to the adjoining lands to the west.

A cycle and pedestrian network are provided linking the park at the north end of the scheme to the stream at the southern end of the site. There is also east- west pedestrian permeability.

It is not possible to provide pedestrian/cycleway connections to the Kilwogan Lane on the south side of the stream as the applicant’s ownership only extends as far as the stream. There is a relatively narrow strip of lands between the stream and Kilwogan Lane in third party ownership.

Any such, pedestrian connections would require the provision of a new bridge but this is outside the applicant’s control. The applicant has shown a location where pedestrian bridge could be provided over the stream to facilitate access to a future footpath on Kilwogan lane if this were to be delivered by others in the future.

It is highlighted however that there is a proposed east-west pedestrian/cycle route along the southern boundary of the proposed development which will connect with the existing footpath at the south east corner of the site. It is submitted that this meets the objective to provide a pedestrian/cycle route to the south of the site. It also preserves the dense thicket of planting to the south side of the stream and the hedgerow which is considered a positive in terms of maintaining the biodiversity in this area.

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There is an existing raised table ramp pedestrian crossing at this point across Kilwogan Lane to the footpath on the south side of Kilwogan Lane. This will facilitate pedestrian connectivity back into the town. There are also existing pedestrian crossings to the east of the site and to the north-east providing safe access to the footpath/cycle network on the opposite side of the Maynooth Road.

Built Form The development of this KDA should reflect the established pattern of development in the area and should protect the amenity of adjoining residential estates. A mix of housing types that range from two to three storeys in height is encouraged. Landmark / feature buildings should be provided along prominent routes and at key junctions to provide for variety and legibility in the urban environment and to reinforce a hierarchy of streets and spaces. This site will accommodate medium to low-density residential development in the order of 25 units per hectare. However, where the quality of the design and layout is particularly high, a maximum density of 30 units per hectare may be achievable.

The established pattern of development in the area is relatively low density suburban dwellings based on cul-de-sac layouts and is considered to be unsustainable. The proposed housing element of the proposed layout is based on the perimeter block layout and seeks to depart from the cul-de-sac layouts that exist in the area as promoted under DMURS.

The Kilwogan Lane and narrow strip of land north of same separates the subject lands from the established residential development to the south. There will be a significant distance from the proposed apartments and the two-storey apartments to the south and thus the potential for impact on residential amenity is avoided. The very fact that the established residential development is south of the proposed development means that shadow impact will not be a material issue.

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A mix of dwelling types are provided including different types of houses and apartments. The houses include terrace, semi-detached and detached units.

A hierarchy of streets and open spaces is provided for – refer to the Architects Design Statement for details.

The proposed apartments to the northeast and south-east corner of the development will form landmark/feature buildings at these prominent locations.

The issue of density has been addressed in detail above. The higher density proposed for the site is considered to be a more sustainable form of development and in line with national planning guidelines.

Landscape and Spaces New residential areas at Crodaun should comprise a hierarchy of open spaces. Larger open spaces should provide a focus for the developments on both sides of the road with smaller areas of open space being utilised to provide a landscape buffer to the Maynooth Road and incidental open spaces within the site. There is a hierarchy of open space provided.

A hierarchy of open spaces is provided with the ‘F’ zoned lands to the north at the top of the hierarchy, followed by the central areas of open space and the generous open spaces around the perimeter of the site (all in excess of 10 metres) with the remaining incidental open space at the bottom of the hierarchy.

Existing landscape features such as tree lines should be integrated into open spaces. Open space networks that incorporate pedestrian and cycle routes, provide for passive and active recreation, promote ecology and integrate Sustainable Urban Drainage Systems are promoted.

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The key natural features of the subject lands are the existing trees/hedgerows along the perimeter and centre of the site and the stream to the south. All trees/hedgerows will be retained around the perimeter (apart from where new pedestrian routes are provided) and the open stream will also be retained. The central hedgerows will be cleared but significant replacement planting will be provided within the areas of public open space.

Pedestrian and cycle routes are provided through the areas of public open space.

6.3.8 Flood Risk

The flood risk assessment diagram in the CLAP 2017-23 does not show any flooding associated with the stream to the south of the site. The site is not located in an area where a site-specific flood risk assessment is required. However, for the sake of completeness and to avoid any doubt please refer to the site- specific Flood Risk Assessment prepared by GDCL Consulting Engineers. This report concludes that there is no material flood risk in respect of the proposed development or down-stream.

Site

Fig No.26 Extract from Celbridge LAP Strategic Flood Risk Assessment Map, Map No.9.1. No site-specific flood risk assessment is required.

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6.3.9 Transportation

Transport and Movement Map (Map 8.1) shows a New Pedestrian / Cycle Objective along Kilwogan Lane to the south of the site, beyond the stream and adjoining third party lands. The delivery of this pedestrian/cycle route is outside the control of the applicant as the lands to the south side of Kilwoghan Stream are owned by a third party. Notwithstanding that the delivery of this objective is outside the applicants control we highlight that a new east-west pedestrian/cycle route is proposed along the north of the stream within the site

Site

Fig No.27 Extract from Celbridge LAP Transportation and Movement Map, Map No.8.1 showing objective for new pedestrian/cycle route along Kilwogan Lane.

The LAP also notes that “All planning applications for development within KDA’s shall be accompanied by a detailed Traffic Impact Assessment”. A Transportation Assessment Report has been prepared by NRB Consulting Engineers which includes traffic impact assessment.

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6.3.10 Cultural Heritage

Subject Site A review of the Celbridge LAP confirms there are no known constraints associated with the subject lands in respect of: • Archaeology • Built Heritage • Natural Heritage

In the Vicinity Castletown House is identified in the Celbridge LAP as being “the most significant building in the area and is of national and European importance” (s.10.3). The house itself is a Protected Structure, along with many features in its expansive associated demesne – Ref. B11-13.

Castletown House is located approximately 1.22km from the site at its closest point (south-east corner). Between the site and Castletown House there is an established residential housing estate characterised by two storey dwellings (Crodaun Forest Park) and a notably large area of dense mature tree planting within the demense. Please refer to Landscape and Visual Impact Assessment of the EIAR prepared by Kevin Fitzpatrick Landscape Consultants which demonstrates that there is no view of the proposed development from the rear of Castletown House.

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Housing Estate

Tree Belt

Castletown House Site

Fig No.28 Aerial photograph showing the proximity of the subject site to Castletown Demense House (c.1.22km).

Section 10.3.2 of the Celbridge LAP deals with scenic routes and protected views and these are shown in Map No.10.1. ‘Views from within Castletown’, but none of these views pass through or are in the immediate vicinity of the subject lands.

We refer the Council to the Cultural Heritage chapter in the EIAR prepared by Dr. Charles Mount, archaeologist, which concludes that there are no items of cultural heritage, monuments or buildings of heritage interest known from the application area. There are no direct or indirect impacts on any known items of cultural heritage, archaeology or buildings of heritage interest in the application area or the vicinity.

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Site

Fig No.29 Extract from Map 10.1 (Natural & Archaeological Heritage Map) showing views to be preserved from Castletown (blue dotted lines).

6.3.10 Phasing

The LAP notes that “A statement of compliance with the phasing requirements of the LAP shall be required with planning applications for new housing development in the Key Development Areas and compliance will be governed by condition of planning consent”.

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The proposed development includes provision for a childcare facilityto the south- east of the development. The facility has a gross floor area of 776sq.m and will cater for 89 children.

The applicant undertakes to build this facility prior to the commencement of dwelling no. 151 as required and invites a condition of planning to this effect. The childcare facility is included in Phase 1 of the Phasing Strategy - see drawing No. 19080-SIT-PLAN-0009 prepared by Scott Tallon Walker Architects.

6.4 Summary of Planning Context

• The proposed development is considered to be wholly consistent with national and regional planning guidelines.

• There is a need to increase the output of new houses on appropriately zoned land under the National Framework Plan.

• National planning guidelines specifically identify outer suburban/greenfield to achieved residential densities between 35-50 units per hectare.

• The town has been identified in the Kildare County Development Plan 2017- 23 for a higher growth rate along with other towns in the north east of the county.

• The site forms part of a Key Development Area in the Celbridge LAP 2017-23.

• The proposed development accords with the zoning objectives for the subject lands in the Celbridge LAP.

• The residential density proposed (43.46 units per hectare) materially contravenes the density limit for the subject lands in the Celbridge LAP but,

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the LAP notes that the density standards in the Kildare County Development Plan 2017-23 take precedent and the scheme is compliant with same.

• The proposed development broadly follows the Design Brief in the Celbridge LAP 2017-23.

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7.0 CONCLUSION

This application is being made directly to An Bord Pleanála under Strategic Housing Development legislation as it involves over 100 dwelling units – 467 in total.

The site involves a large greenfield site on the northern periphery of Celbridge town. The site is situated in close proximity to schools, an employment zone, a neighbourhood centre and supermarkets. The site is very well served by public transport with a bus stop to the east of the site providing bus access to the town centre, Maynooth and to Dublin city. There is also an established shuttle bus service to Hazelhatch Train station at Salesians School. There is an established pedestrian and cycle network to the east of the site which provides access to Celbridge town centre and thetrain station and Intel facility in Leixlip.

The proposed development involves 467 dwelling units, café, retail unit, childcare facility and gym. It also involves the provision of a 2.068Ha landscaped public park at the northern end. The proposed dwellings and childcare facility are acceptable in principle under the New Residential zoning objective for the lands, with the local shop, café (restaurant) and gym being open for consideration.

The scheme has been designed to be consistent with ministerial planning guidelines. It also accords with the policies and objective in the Kildare County Development Plan 2017-23.

The proposed development departs from the density restriction in the Celbridge LAP. We consider however that the departure is consistent with national planning guidelines and represents a more sustainable use of lands which are close to high quality public transport links.

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The scheme has been designed largely in accordance with the Design Concept for KDA 4 in the Celbridge LAP 2017-23. Provision has been made for two vehicular entrance/exit points on the Maynooth Road instead of one as per the LAP in order to increase permeability and be consistent with DMURS. Additional public open space along the western boundary of the site has also been provided relative to that shown in the Design Concept, in order to protect the mature hedgerow and trees.

The Celbridge LAP reveals that there are no constraints associated with the subject lands. The Kilwoghan Stream to the south of the site will be left in its natural state apart from improvements to the existing planting on the north side.

The proposed development will have the following benefits:

• Tying the isolated school and employment area at the roundabout junction into the town. • Intensive and sustainable use of currently underutilised lands which are zoned for residential development. • Provision of significant new housing opportunities on a site close to high quality public transport links. • Provision of a wide variety of house types, including apartments which are scarce in Celbridge. • Provision of new landscaped public park for residents and wider community on lands which are currently in private use. • Provision of a new gateway entrance into Celbridge from Junction 6 on the M4. • Introduction of high-quality architecture into the north side of the town. • Provision of a significant amount of Part V units. • Provision of a new shop and café which will serve the proposed development and wider residential community in the area.

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• Provision of a childcare facility and gym which will serve the proposed development (and potentially the wider community in the case of the childcare facility). • Enhancement of the lands on the north side of Kilwoghan Stream. • Provision of a new walk route around the perimeter of the development which will serve both residents and the wider community (dog walking, running etc).

In conclusion, we consider that the proposed development is consistent with the National Planning Framework, the Regional Eastern & Midland Regional Assembly Regional Spatial & Economic Strategy, ministerial planning guidelines, the Kildare County Development Plan 2017-23 and the Celbridge LAP 2017-23 and fully accords with the proper planning and sustainable development of the area.

Signed:

David Mulcahy David Mulcahy Planning Consultants Ltd CHARTERED PLANNING CONSULTANTS