STATEMENT OF CONSISTENCY - FOR A - MCCAUGHEY HOMES LTD - Old Golf Links Road

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STATEMENT OF CONSISTENCY - FOR A - MCCAUGHEY HOMES LTD - Old Golf Links Road
STATEMENT OF CONSISTENCY

                               FOR A

    RESIDENTIAL DEVELOPMENT AT
OLD GOLF LINKS ROAD, BLACKROCK,
            DUNDALK, CO. LOUTH

                         PREPARED BY

                        ON BEHALF OF

         MCCAUGHEY HOMES LTD

        December 2018
STATEMENT OF CONSISTENCY - FOR A - MCCAUGHEY HOMES LTD - Old Golf Links Road
CONTENTS

1    INTRODUCTION & RATIONALE                 3

2.   DEMOGRAPHIC & SOCIO-ECONOMIC CONTEXT      5

3.   SITE & NEIGHBOURHOOD CONTEXT             14

4.   STATEMENT OF CONSISTENCY WITH NATIONAL

     & REGIONAL PLANNING POLICY               18

5.   STATEMENT OF CONSISTENCY WITH LOCAL
     PLANNING POLICY                          41

6.   CONCLUSION                               45

APPENDIX A                                    46

REFERENCES                                  48

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STATEMENT OF CONSISTENCY - FOR A - MCCAUGHEY HOMES LTD - Old Golf Links Road
1.     INTRODUCTION & RATIONALE

On behalf of the applicant, McCaughey Homes Ltd., this report accompanies this
planning application to An Bord Pleanála in relation to a proposed Strategic Housing
Development at Old Golf Links Road, Blackrock, Dundalk, Co. Louth, in accordance
with the Planning and Development (Housing) and Residential Tenancies Act 2016.

The proposed residential development will consist of 166 no. residential units
comprising 67 no. 1-3 bed apartments/duplexes within 12 no. 2-3 storey blocks, and
99 no. 2-storey, 2-4 bed, semi-detached/detached/terraced houses. Provision of a
crèche (c.250 sq.m), bike and bin stores. 294 no. car parking spaces. Provision of
open spaces and completion of street network and link roads. Main access to Old
Golf Links Road via existing estate road shared with the adjoining Cois Farraige
estate. Separate access off Old Golf Links Road to serve 4 of the proposed houses.
Pedestrian/cyclist access via Tuite’s Lane and extension of public footpath along Old
Golf Links Road (on land in ownership of applicant). All associated site development
works, landscaping, boundary treatments and services provision.

This report provides a Statement of Consistency which demonstrates that the
proposal is consistent with the relevant national planning policy, guidelines issued
under Section 28 of the Planning and Development Act 2000 (as amended).

The report also demonstrates consistency with the key policies and development
management standards outlined in the Dundalk & Environs Development Plan 2009-
2015 (as extended).

It is acknowledged that this proposed strategic housing development application on a
residentially zoned site may require a Material Contravention of the Dundalk &
Environs Development Plan.

As per Variation Number 1 (Core Strategy) of the Development Plan the subject
lands are located within Core Strategy Phase 2, and not Phase 1. Under Policy CS2
the Core Strategy requires the development of at least 75% of Phase 1 lands before
development within Phase 2 can be considered. That level of development within
Phase 1 has not occurred over the life of the Development Plan and the continued
implementation of Policy CS2 is restricting the sustainable development of the other
development areas within the Dundalk Environs including the well-established suburb
of Blackrock where the application site is located.

Under Section 5(6), the Planning and Development (Housing) and Residential
Tenancies Act, 2016, the Board may grant planning permission for the proposed
strategic housing development notwithstanding the material contravention.

This application includes a Statement on Material Contravention Statement outlining
how and why the Board should grant permission in accordance with Section 37(2)(b)
of the Planning and Development Act 2000 (as amended).

There is also broad support from the planning authority for the development of this
site for a mixed residential scheme, as evidenced in the report submitted to the
Board at pre-application stage.
STATEMENT OF CONSISTENCY - FOR A - MCCAUGHEY HOMES LTD - Old Golf Links Road
This strategic housing development can provide for the housing needs of a broad
range of household types including professionals working nearby in the main
employment centres along the Inner Relief Road (e.g. PayPal), students at Dundalk
Institute of Technology, young families looking for starter homes, and empty nesters
interested in downsizing to more manageable accommodation which in turn will
create an additional supply of larger family houses in the area.

As such it is requested that An Bord Pleanála have regard to the justification set out
within this Statement and the Material Contravention Statement which demonstrate
the following:

   (1) The proposed development is consistent with national planning policy and
       guidelines, regional planning policy and local planning policy;
   (2) In accordance with Section 37(2)(b) of the Planning & Development Act,
       despite the material contravention of the Development Plan, permission can
       be granted given that the proposed development is of strategic importance
       and accords with current national and regional planning policy.

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STATEMENT OF CONSISTENCY - FOR A - MCCAUGHEY HOMES LTD - Old Golf Links Road
2.     DEMOGRAPHIC & SOCIO-ECONOMIC CONTEXT

The following section provides an analysis of demographic and socio-economic
trends in the Dundalk and Blackrock areas since the adoption of the Core Strategy in
2011, in order to understand the reasons for the current housing needs crisis in the
town and how the current proposal for strategic housing development can help
address same.

Overview of Dundalk

Dundalk is strategically located along the Eastern Economic Corridor mid-way
between Dublin and Belfast. Dundalk benefits from high quality road and rail
infrastructure linking the area to Dublin, Belfast and the rest of Ireland. The M1
motorway links Dundalk to Dublin, George Best and Belfast airports within
approximately an hour drive. This motorway also links the town to 3 deep seaports.

Dundalk is one of the largest towns in Ireland with a population in excess of 39,000.
It has an abundance of skilled labour and a highly educated workforce supplied by
Dundalk Institute of Technology (DkIT). The area is supplied by high speed
broadband.

All of this makes Dundalk extremely attractive to multinational corporations (MNC)
for foreign direct investment (FDI). The Industrial Development Agency (IDA) has
promoted investment in the Dundalk area and has secured a number of MNC to
locate in Dundalk. This has led to the continued growth in population within
Dundalk and surrounding areas.

The Blackrock area is part of the greater Dundalk area. It is a village located to the
south east of Dundalk. It has a population of c. 7,000 people. Blackrock is c. 3km
away from DkIT and c. 5km away from Dundalk town centre.

Population & Socio-Economic Trends

The following sections assess demographic changes which have occurred since the
Core Strategy was adopted, with specific reference to the results of the 2011 and
2016 Census.

Dundalk overall and the Haggardstown Electoral Division (ED) (which is the ED
within which Blackrock is located) are examined.

CSO results show that Dundalk’s population in 2016 was 39,004 a 3% increase from
2011 as shown on the table below.

Blackrock experienced a greater increase in population of 8.5% to 6,932 people in
2016.

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STATEMENT OF CONSISTENCY - FOR A - MCCAUGHEY HOMES LTD - Old Golf Links Road
The Louth County Development Plan 2015-2021 expects Dundalk to continue to
grow. They have predicted that the population of Dundalk will be 46,622 by 2021.

Blackrock has also seen an increase in the percentage of the population in the age
cohorts 0-18 and 65+.

Dundalk overall has also seen an increase in the percent of the population between
0-18.

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STATEMENT OF CONSISTENCY - FOR A - MCCAUGHEY HOMES LTD - Old Golf Links Road
Census results show that smaller households (1-4 person) are by far the largest
proportion of households at town and local level.

                                                                              7
STATEMENT OF CONSISTENCY - FOR A - MCCAUGHEY HOMES LTD - Old Golf Links Road
In relation to house types the census result show that in both Blackrock and
Dundalk the vast majority are own door houses or bungalows. Only 4% of the units
in Blackrock and 7% in Dundalk are flats or apartments.

In Blackrock 79% of all households are owner occupied compared to 61% in Dundalk
overall. Only 19% of the houses in Blackrock are rented compared to 35% in
Dundalk.

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STATEMENT OF CONSISTENCY - FOR A - MCCAUGHEY HOMES LTD - Old Golf Links Road
In terms of socio-economic trends, Blackrock has 54% of its population at work, 11%
students and only 5% unemployed compared to Dundalk which has 47% of its
population at work, 13% students and 11% unemployed.

                                                                                  9
STATEMENT OF CONSISTENCY - FOR A - MCCAUGHEY HOMES LTD - Old Golf Links Road
For the current analysis the Socio-economic groups within Blackrock and Dundalk
have been grouped as follows, A-C: employers and managers, higher professionals,
and lower professionals, D-G: non-manual, manual skilled, semi-skilled, and unskilled
and H-Z: own account workers, farmers, agricultural workers, and all gainfully
occupied and unknown.

Blackrock has seen a steady increase in groups A-C and D-G. Group H-Z only had a
slight increase. 48% of the population were in group A-C and 36% were in group D-
G.

Dundalk saw a slight increase across all Socio-economic groups. In Dundalk 28% of
the population are in group A-C, 46% in group D-G and 26% in group H-Z.

Blackrock has a highly educated population with 38% of the people with an ordinary
Bachelor Degree or higher compared to Dundalk with 23% and Ireland with 29%.

                                                                                   10
Economic Growth

At the same time as the population of Dundalk has grown and diversified, the town
has emerged out of the economic recession and remains the main hub of economic
activity in the North-east of Ireland.

The town is home to a number of large international companies which provide
financial services, engineering, pharmaceutical and technology. Dundalk also has
many Irish companies including Irish Life, Digiweb, Boyle Sports, Glen Dimplex,
Kerry Group and Ovelle.

The following employment developments are noted:

      In 2012 PayPal opened a European Operations Centre in Dundalk and
       currently employs over 1,000 staff.
      National Pen, a leading global provider of personalised marketing
       merchandise is understood to employ c.1,000 staff.
      Prometric, a provider of market-leading test development and delivery
       solutions, established its Test Development headquarters in Dundalk in 2011
       and currently employs circa 100 people.
      Graebel Companies Inc. created 125 new jobs in an EMEA Financial Shared
       Services and Operations Centre in Dundalk in 2017.
      The pharmaceutical company Wasdell Group announced in 2017 that it plans
       to establish a Packaging & Distribution Facility creating 300 jobs over five
       years.
      Dundalk will also see continued growth from existing companies such as
       Coca-Cola, Becton Dickinson, Xerox, Actavis, International Fund Services
       (IFS) and Cargotec.

In 2012 it was confirmed that Dundalk had secured 1,326 jobs generated by the IDA.
This was out of 6,570 which were secured by the IDA for the state. Apart from the
major firms such as PayPal the IDA also secures FDI from smaller companies such as
the pet-product company Radio Systems with 56 jobs and Diaceutics which is a
medical software company with 20 jobs.

                                                                                 11
IDA Ireland states that it will continue to roll out its building programme across
Dundalk over the coming years. At the year ending 2017 there were 11,469 FDI jobs
created by the IDA in the Border Region which was a 4% increase from 2016.

The IDA also has a site at Mullagharlin, south of Inner Relief Road which is to be
developed as a Science & Technology Park for Bio-Pharmaceuticals. Planning
Permission has been obtained for two Bio Pharmaceutical facilities. Up to an
additional 1,000 jobs can be achieved once investment is secured.

Planning Implications

The population of Dundalk is growing and diversifying.

A main driver has been the growth of employment opportunities in Dundalk which
in turn is creating significant and currently unfulfilled housing demand from workers
moving to the town.

In a 2017 article published on the MyHome.ie website titled “Lack of rental property
affecting foreign direct investment in Ireland” Louise Phelan (Vice President of western,
central and eastern Europe, Ireland, the Middle East and Africa at PayPal) stated that
“the lack of available housing means that staff at PayPal (in Dundalk) are being asked to
offer rooms to new employees who cannot find accommodation.”

Ms Phelan says that this problem is now at crisis point and that further Foreign
Direct Investment will be lost if it is not addressed. If accommodation is not available
for employees then companies will take their business elsewhere.

In an interview with the Dundalk Leader in 2017 Kevin Adams (Training Co-
ordinator at National Pen) stated that “workers are actually turning down jobs in the
company due to the lack of suitable houses to rent around town”. Other workers are
being forced to live in areas such as Newry and Portadown and commuting to
Dundalk each day with this having a negative impact on the local economy.

At the same time Dundalk Institute of Technology (which has c.5,000 students and
500 members of staff) is being impacted by a “chronic shortage of houses for students to
rent” in Dundalk. With students competing with employees from PayPal and other
firms for accommodation DKIT has effectively become “a commuter college” with
students travelling long distances to get to and from college every day.

The failure of housing supply to meet increased demand is further reflected in the
increase in property prices and rents in recent years. The latest 2018 Q1 House
Price Report provided by Daft.ie indicates that the average price of a house in
County Louth is now €210,074 which represents a year on year increase of 7.1% and
a 64.7% increase from the third quarter of 2013 when nationally the average asking
price reached its lowest point.

The above analysis demonstrates that household numbers are growing, household
sizes are decreasing and household types are diversifying. However the number and
range of housing types available in Dundalk do not meet these existing growing
demands.

                                                                                       12
For instance, despite 1 and 2 person households representing the vast majority of
household sizes in Dundalk, apartments represent only a fraction of the existing
housing stock.

Empirical and anecdotal evidence suggests a significant and growing housing crisis in
Dundalk which needs to be addressed by increased and diversified residential output
particularly in sustainable locations which are both convenient to the resident in
terms of getting to work or education and are well served by existing social
infrastructure.

As the below map demonstrates, the subject site, is strategically located close to the
majority of the main employment providers noted above which are principally
located along the Inner Relief Road within 5 minutes’ drive of the site. DKIT is also
located in close proximity.

Development of this site for mixed residential types can help address the
considerable housing demand crisis which the town is currently experiencing.

The current proposal provides a sustainable residential mix. 41% of the units are 1-
2-bed apartments. 50% are 3-bed houses. These will appeal to a broad number of
household types including first time buyers, young professionals/couples looking to
buy or rent, students and older people/empty nesters /specific needs
accommodation. Lifetime family homes comprising larger 3 and 4 bed houses are
also provided.

This view is also confirmed by estate agents who have identified a broad range of
buyers making up the current demand, reflecting the household trends identified in
the census results. A letter from Lavelle’s to the applicant in this regard is attached
as Appendix A to this report.

                                                                                     13
3.     SITE & NEIGHBOURHOOD CONTEXT

The following section summarises the positive attributes of the site as a sustainable
location for a strategic housing development as proposed.

This site is located along the Old Golf Links Road, on a site area of c.4.8 ha. It is
located within the well-established suburb of Blackrock c.4km from the centre of
Dundalk.

Golf Links Road is currently a low density residential area. Tuite’s Lane and Old
Golf Links Road to the north-west and west comprise mainly detached dwellings on
large plots, as also occurs to the north-east and east at The Hamiltons and along
Rock Road.

To the south and south-east the range of housing typologies broadens somewhat
with semi-detached and terraced housing at the more recently developed Gort na
Glaise and Cois Farraige residential developments, the latter of which was developed
by the applicant.

The existing residential areas are all below 30 units per ha while along the local
roads are typically detached dwellings on large plots with densities well below 10
units per ha.

Furthermore the immediate area has seen little recent residential development. Due
to the Core Strategy restriction residential zoned greenfield sites have not been
brought forward for planning.

Aside from the granting of extensions of durations to older permissions for
residential development west of the Dublin Road in the Haggardstown area (where
works had previously commenced), the only new residential permissions of note in
the area has been at the Fairways centre located near the junction of the Old Golf
Links Road and the Dublin Road. Due to the mixed use nature permission can be
granted on those under the current Core Strategy.

                                                                                    14
In this regard we note permission LCC Reg. Ref.: 17440 which comprises an
 extension of the Fairways Hotel and the construction of 40 no. houses and 8 no.
 apartments.

 Despite the low density and quantum of residential development this established
 suburb is very well provided for in terms of social infrastructure. We note the
 following:

 Education:

        The subject site is a 3-minute walk to St. Francis National School.
        The subject site is a 9-minute walk to Blackrock National School.
        The subject site is a 4-minute drive to Scoil Fhursa (National School).
        The subject site is a 4-minute drive to Dundalk Institute of Technology.
        The subject site is a 6-minute drive to Ó Fiaich Institute of Further Education.

Local Retail and Services:

        Fairways Retail Centre is a 10-minute walk from the subject site. This centre
         has a SuperValu, Costa Coffee and Hotel. Beside this there is a Gym and a
         Topaz garage.
        The subject site is a 12-minute walk from Blackrock main street which has a
         range of shops and services including Centra, Londis, Post Office, Pharmacy,
         Medical Centre, Pubs, Cafes and Restaurants.

 Recreation & Amenity:

        Blackrock Park, Community Centre and Rock Celtic Football Club is
         approximately an 8-minute walk from the subject site.
        The subject site is a 12-minute walk from Blackrock Beach.
        There is a church and graveyard to the south boundary of the site.

 The proposed development will be located at the heart of this neighbourhood and
 within walking/cycling distance of a wide range of services and facilities for future
 residents. There is a good footpath network throughout the area (with the
 exception of a short stretch along the boundary with the historic graveyard) which
 the proposed development will connect directly to via the entrance shared with the
 adjoining Cois Farraige scheme.

 A stream divides the subject site crossing east to west which will be developed into a
 new open space. This is an important provision as it will provide cyclists and
 pedestrian with a more direct route to the Fairways neighbourhood centre to the
 north-east via Tuite’s Lane and the Old Golf Links Road.

 The proposed development will also provide a mix of residential types which will
 create a sustainable new community that will support the existing services and
 provide demand for additional services.
4.       STATEMENT OF CONSISTENCY WITH NATIONAL &
         REGIONAL PLANNING POLICY

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

        Project Ireland 2040 - National Planning Framework (2018);
        Draft Regional Spatial and Economic Strategy for the Eastern and Midland Region
         (RSES);
        Guidelines for Planning Authorities on Sustainable Residential Development in Urban
         Areas (2009), and the accompanying Urban Design Manual;
        Delivering Homes, Sustaining Communities (2008) and the accompanying Best
         Practice Guidelines- Quality Housing for Sustainable Communities;
        Quality Housing for Sustainable Communities (2007);
        Design Standards for New Apartments (2015);
        Design Manual for Urban Roads and Streets (2013);
        Guidelines for Planning Authorities on Childcare Facilities (2001);
        Smarter Travel – A New Transport Policy for Ireland (2009-2020);
        The Planning System and Flood Risk Management (2009).

4.1 PROJECT IRELAND 2040 - NATIONAL PLANNING FRAMEWORK
    (2018)

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

Strategic Policies

The NPF Strategy includes the following aims and objectives relevant to the current
proposal:

        Developing a new region-focused strategy for managing growth in order to
         build stronger regions and accessible centres of scale.
        Making better use of under-utilised land and providing higher housing
         densities, better serviced by existing facilities and public transport.
        Increasing the proportion of more compact forms of growth in the
         development of settlements to bring new life and footfall, contribute to the
         viability of services, shops, and public transport, increase housing supply, and
         enable more people to be closer to employment and recreational
         opportunities, as well as to walk or cycle more and use the car less.
        Consolidating developments which grew rapidly in the past decade.
        Promoting self-sustaining economic and employment based developments
         met with adequate housing. This will be achieved through the continuation of
         balanced population and employment growth.
        Deliver at least 40% of all new homes nationally, within the built-up footprint
         of existing settlements. Within the Eastern and Midland Region 30% of all
new housing to be delivered within the existing urban footprints outside
       Dublin.

   The NPF highlights the unique role that Dundalk will play in the future
   development of Ireland and the need for significant investment, residential
   development and population growth in this key growth centre.

          Dundalk is supported for development within the context of the Dublin-
           Belfast economic corridor and the significant cross border interactions
           with Newry as a driver for regional development.
          The NPF highlight both Dundalk and Drogheda as “key centres on the
           Drogheda-Dundalk-Newry cross-border network and in the context of
           the Dublin-Belfast economic corridor” and indeed their importance for
           regional development.
          National Policy Objective (NPO) 2b identifies the regional role of
           Dundalk and which is to be supported in the Regional Spatial and
           Economic Strategy for the Eastern and Midland Region.
          NPO 44 seeks to further support and develop the economic potential of
           the Dublin-Belfast Corridor and in particular the core Drogheda-
           Dundalk-Newry network and to promote and enhance its international
           visibility.
          Section 8.3 supports the planning and development of large centres of
           population and employment including Dundalk along the main economic
           corridor.
          Figure 8.2 identifies the need for Dundalk to develop critical mass to
           compete with other larger cities.
          Section 3.2 promotes a focused approach to the compact, sequential and
           sustainable development of Dundalk.
          Section 3.2 states that it will be necessary to prepare co-ordinated
           strategies for Dundalk (and Drogheda) at both regional and town level to
           ensure it had the capacity to grow sustainably and secure investment as a
           key centre on the Drogheda-Dundalk-Newry cross-border network.

Sustainable Residential Development

Chapters 4 & 6 of the National Planning Framework also outlines a number of
National Policy Objectives to provide for “People, Homes and Communities” and
“Stronger Urban Places”:

      NPO4 promotes the creation of attractive, liveable, well designed, high
       quality urban places that are home to diverse and integrated communities
       that enjoy a high quality of life and well-being. The proposed development
       achieves this objective in providing a mixed residential scheme of houses,
       apartments and duplexes within an attractive layout provided with open
       spaces and access to a range of existing social infrastructure within walking
       distance including schools, shops, sports clubs, etc. The development will
       attract a diverse range of household types including single owners, couples,
       small and large families, and empty nesters.

                                                                                  19
   NPO6 promotes new developments with “enhanced levels of amenity and
       design quality, in order to sustainably influence and support their surrounding area.”
       The proposed development is designed around a number of key amenities
       including a new central open space and with views to the adjoining historic
       graveyard. A creche is also centrally located within the development.
       Permeability through the site is provided for pedestrians and cyclists.

      NPO 28 promotes a more diverse and socially inclusive society that targets
       equality of opportunity and a better quality of life for all citizens, through
       improved integration and greater accessibility in the delivery of sustainable
       communities and the provision of associated services. The mixed residential
       housing typology proposed will facilitate a diverse new community of various
       household types and sizes.

      NPO 30 seeks to meet the needs and opportunities of an ageing population.
       Again the provision of a broad range of housing typologies provides a unique
       opportunity in the Blackrock area for older residents currently within large,
       empty family homes to downsize to an apartment or smaller house within the
       proposed development, and still remain living within their community.

      NPO 33 prioritises the provision of new homes at locations that can support
       sustainable development and at an appropriate scale of provision relative to
       location. As outlined in this Statement of Consistency and in the Design
       Report prepared by DWD Architects, the proposed location within an
       established and well serviced residential community is wholly sustainable.
       Furthermore the quantum and mix of residential development is progressive
       and suitable for the area.

      NPO 34 supports the provision of lifetime adaptable homes that can
       accommodate the changing needs of a household over time. The proposed
       development includes a range of house types which have the potential to be
       adaptable to developing households, with the potential for attic conversion
       and rear extensions to the smaller houses to facilitate an expanding family.
       Equally with the smaller houses there is the potential to convert an area
       downstairs to an additional bedroom to facilitate mobility impaired residents
       in later life.

      NPO 35 promotes increased residential density in settlements, through a
       range of measures including infill development schemes. The proposed site is
       located within an established residential area surrounded by housing. It is
       proposed to be developed at a density of over 36 units per ha and with a
       range of housing types including 40% apartments.            The proposed
       development represents a significant progression in density and mixed
       housing for the area which is currently characterised by low density,
       predominantly detached housing along the Old Golf Links Road.

Overall the proposed development seeks to deliver an appropriate form and scale of
residential development on a zoned and serviced site located within the suburban
settlement of Blackrock in the Dundalk Environs and which is proximate to
employment opportunities, existing services and facilities. The proposed

                                                                                           20
development will help create critical mass to support local shops, schools, retail
services and public transport in the Blackrock area.

This development involves more efficient use of zoned and serviced land with
increased density and mix of housing types. This development is located within
walking and cycling distance of major employment areas, social infrastructure and
Blackrock Village which will reduce car dependency. The development will promote
further consolidation in the area and will supply extra housing to support economic
growth.

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

4.2 DRAFT REGIONAL SPATIAL AND ECONOMIC STRATEGY FOR
    THE EASTERN & MIDLAND REGION 2019-31

The Eastern and Midland Region covers the counties of Longford, Westmeath,
Offaly, Laois, Louth, Meath, Kildare, Wicklow, and Dublin.

The draft Regional Spatial and Economic Strategy (RSES) is a strategic plan and
investment framework to shape the future development of the eastern region to
2031 and beyond. Its vision is to create a sustainable and competitive region that
supports the health and wellbeing of all people and places with access to quality
housing, travel and employment opportunities for all.

The draft RSES supports the implementation of the NPF, National Development Plan
(NDP) and the economic policies and objectives of the Government and provides a
long term strategic planning and economic framework for the development of the
region.

In accordance with the NPF the RSES promotes the development of Dundalk as both
a Regional Growth Centre and key urban centre along the Dunlin-Belfast Economic
Corridor. Dundalk is identified as a self-sustaining regional driver to deliver targeted
and sustained development in order to grow to city scale and achieve a population of
c.50,000 by 2031.

The subject development seeks to provide for residential development on a key site
within the established suburb of Blackrock, to increase densities and urban
consolidation close to existing services and facilities including schools, shops, leisure
and open spaces. The proposed development therefore is compliant with the policies
and objectives of the RSES in this regard.

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

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

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

   Prioritise walking, cycling and public The application site will create new
   transport, and minimise the need to use linkages        with       the      wider
   cars;                                     pedestrian/cycle network connecting
                                             to local services with schools, retail
                                             and recreational facilities within 5-10
                                             minutes’ walk.
   Deliver a quality of life which residents The scheme has been designed to the
   and visitors are entitled to expect, in highest residential standard. We note
   terms of amenity, safety and that all units have dual aspect with
   convenience;                              access to private garden space
                                             meeting and exceeding minimum
                                             standards. In terms of safety, open
                                             space will be passively surveilled and
                                             pedestrian priority given to these
                                             public areas.

   Provide a good range of community and      The development will consist of
   support facilities, where and when they    residential units with a crèche facility.
   are needed and that are easily             The development is well located in
   accessible;                                relation to existing educational,
                                              sports and retail services in the
                                              neighbourhood.         The      scheme
                                              therefore does not warrant additional
                                              services on site.

   Present an attractive, well-maintained     The layout of development has been
   appearance, with a distinct sense of       designed around a number of new
   place and a quality public realm that is   public open spaces and principally the
   easily maintained;                         main open space along the open
                                              stream running through the site.

                                              Additional open space is provided as
                                              a buffer to the historic graveyard and
                                              the street layout proposed allows for
                                              new views of the graveyard from
                                              within the scheme. The landscape
                                              strategy also allows for an additional
                                              future access via the historic
                                              graveyard (currently in separate
                                              private ownership).

                                                                                          22
A series of distinct residential
                                         character areas are provided, defined
                                         by typology, layout, and elevational
                                         treatments.

Are easy to access for all and to find The road/footpath network extends
one’s way around;                      from the main access connecting to
                                       the Old Golf Links Road via the
                                       adjoining Cois Farraige scheme. A
                                       variety of character areas are
                                       proposed as noted above.

                                         The layout is logical and wayfinding
                                         uncomplicated. The main open space
                                         presents      a     new      east-west
                                         pedestrian/cyclist route through the
                                         site and a new public connection
                                         between Tuite’s Lane and Old Golf
                                         Links Road.
Promote the efficient use of land and of The proposal seeks to import best
energy, and minimise greenhouse gas practice           construction/engineering
emissions;                               techniques and use of energy efficient
                                         materials to maximise energy capacity
                                         and minimise impacts of climate
                                         change in accordance with current
                                         buildings regulations.
Provide a mix of land uses to minimise The site is zoned primarily for
transport demand;                        residential    development     as    is
                                         proposed.

                                       The scheme is located close to the
                                       existing    and    planned     services
                                       including local retail, schools, sports
                                       clubs, and leisure all within 5-10
                                       minutes’ walk.
Promote social integration and provide A range of unit sizes is proposed for
accommodation for a diverse range of the scheme, ranging from 2/3/4-
household types and age groups;        bedroom apartments and houses.

                                     A variety of household types will be
                                     catered     for    including    young
                                     professionals working in the main
                                     employment centres along the Inner
                                     Relief Road, students at Dundalk
                                     Institute of Technology, young
                                     families looking for starter homes,
                                     and empty nesters interested in
                                     downsizing to more manageable
                                     accommodation.
Enhance and protect the green The proposed design protects the
infrastructure and biodiversity; and existing stream through the site and
                                     provides a public open space along its
                                                                                   23
banks.

                                     The mature planting around the
                                     historic graveyard will also be
                                     protected.
   Enhance and protect the built and The     site  of   the    proposed
   natural heritage.                 development is located adjacent to
                                     Recorded Monument LH012-014001
                                     (Church)     and     LH012-014002
                                     (Graveyard). Recorded Monuments
                                     LH012-063 and LH012-011 (Local
                                     tradition of a souterrain) also lie
                                     within the area of the proposed
                                     development.

                                             An      archaeological       assessment
                                             (geophysical survey and test trenching
                                             under licence) was carried out on the
                                             site at design stage in order to
                                             identify any potential archaeological
                                             constraints within the site.

                                             As a result of the archaeological
                                             assessment it is recommended that as
                                             a condition of any planning
                                             permission that all archaeological
                                             features and deposits identified be
                                             fully excavated and recorded prior to
                                             commencement of development. In
                                             addition, it is also recommended that
                                             all topsoil stripping associated with
                                             the proposed development be
                                             archaeologically monitored in order
                                             to determine the presence/absence of
                                             any additional archaeological features
                                             or deposits, most notably one or
                                             more souterrains.

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

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

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

In this regard, the Guidelines are accompanied by a Design Manual (discussed below)
which demonstrates how design principles can be applied in the design and layout of
new residential developments, at a variety of scales of development and in various
settings.
                                                                                       24
To ensure sustainable communities the Guidelines stress that community facilities
are also to be provided for.

In relation to schools we note the following located in the immediate area:

      St. Francis National School, Blackrock
      Scoil Na Gcreachacha Dubha primary school, Blackrock.
      Scoil Fhursa, primary school, Haggarstown

A number of post primary schools are located in Dundalk including Dundalk
Grammar School, St. Vincent’s, Pobailcholáiste Chú Chulainn, Colaiste Rís and St.
Mary’s College.

In relation to childcare facilities, a crèche is included with the current scheme and
which is assessed in detail below.

In relation to community centres, healthcare facilities and neighbourhood centre
uses we note the proximity of the development to such services in the Blackrock
area.

In relation to density the subject lands are considered “Outer Suburban /
‘Greenfield’” being open lands on the periphery of a large town. The Guidelines
recommend minimum net densities of at least 35 units per ha should be achieved and
should involve a variety of housing types where possible.

The current proposal is at a net density of 36.5 units per ha which is well above the
existing densities in the area. The density is calculated based on a net site area
which excludes the main link road through the site which will provide the potential
for future connection to the adjoining undeveloped residential lands to the north-
east. This calculation of net site area is in accordance with Appendix A of the
Guidelines.

Furthermore, a sustainable mix of housing units are proposed including apartments, 2
and 3 bedroom houses.

The proposed development is considered in broad compliance with the objectives of
these national guidelines.

4.4 URBAN DESIGN MANUAL – A BEST PRACTICE GUIDE, 2009

The Urban Design Manual is the accompanying document to the Sustainable
Residential Development in Urban Areas document which provides policy guidance
for the creation of successful neighbourhoods having regard to the 12-point criteria.
The proposal complies with the following design criteria:

                                                                                   25
1. Context –How does the development respond to its surroundings?
The development seems to have evolved The proposed development responds
naturally as part of its surroundings. positively to the adjoining residential
                                       areas.       It utilises existing road
                                       connections       and     provide    new
                                       pedestrian/cyclist connections through
                                       the site and for future connection to
                                       residential lands to the north-east.

                                           The layout responds to and respects the
                                           natural characteristics of the site
                                           particularly the stream which will
                                           become part of a new linear open space,
                                           and the historic graveyard which will be
                                           framed with new vistas from the
                                           development.
Appropriate increases in density respect
the form of buildings and landscape        The proposed development significantly
around the site’s edges and the amenity    increases the density and mix of housing
enjoyed by neighbouring users.             typology compared to that existing in
Form, architecture, and landscaping have   the area whilst achieving a scheme that
been informed by the development’s         is attractive, contemporary and does not
place and time.                            impact the amenity of adjoining
                                           residential areas.

The development positively contributes The existing character of the area is of
to the character and identity of the predominantly low density own door
neighbourhood.                         housing with more recent developments
                                       providing a broader range of typologies
                                       including terraced housing.

                                           The current proposal improves again on
                                           the range of housing types providing for
                                           own door housing and apartments.

Appropriate responses are made to the Where        existing   natural     mature
nature of specific boundary conditions. boundaries exist with properties to the
                                        north-west and east these will be
                                        retained and enhanced so as to provide
                                        a natural buffer with existing rear
                                        gardens. The scheme will remain open
                                        to the south-east in order to integrate
                                        with the adjoining Cois Farraige scheme.
                                        The soft buffer with Haggardstown Old
                                        Graveyard will be retained and
                                        enhanced.

                                                                                      26
2. Connections – How well connected is the new development
There are attractive routes in and out for The principal access to the development
pedestrians and cyclists.                  will be via the existing road from Old
                                           Golf Links Road which also serves the
                                           Cois Farraige scheme.          This road
                                           provides access to the local national
                                           school Blackrock Park and Blackrock
                                           village all within 5-10 mins walk.

                                         Streets into the various character areas
                                         will branch off a main access road which
                                         will bridge the stream and central open
                                         space at one location only, and will run
                                         to the north-eastern boundary providing
                                         the opportunity for future access to
                                         adjoining residential lands.

                                         The central spine of open space will
                                         provide pedestrian/cyclist connectivity
                                         east-west through the site and with a
                                         connecting leading out to Tuite’s Lane to
                                         the north-west which in turn provides
                                         an additional connection to the Old Golf
                                         Links Road with the Fairways
                                         neighbourhood centre and gym.

The development is located in or close to As noted above the scheme is located
a mixed-use centre.                       equidistant      from    the  Fairways
                                          Neighbourhood Centre and Blackrock
                                          Village, both c.10 mins walk.
                                          .
The development’s layout makes it easy A bus service is not considered
for a bus to serve the scheme.            necessary given the size of the
                                          development.

                                          There are Bus Eireann services in the
                                          wider area – the 100 (Drogheda-
                                          Dundalk) and 168 (Dundalk-Annagassan)
                                          services operate along the Dublin Road
                                          10 mins walk to the south-west with a
                                          stop at Sexton’s Bar.
The layout links to existing movement Pedestrian         permeability     connects
routes and the places people will want to directly to the existing public footpath
get to.                                   network along Old Golf Links Road and
                                          Tuite’s lane.

                                         The scheme also includes for extension
                                         to the public footpath along Old Golf
                                         Links Road.
Appropriate density, dependent on The density of 36.5 units per ha (Uph)
location, helps support efficient public accords with national guidelines for an
transport.                               outer suburban location.
                                                                                      27
3. Inclusivity – How easily can people use and access the development?
New homes meet the aspirations of a The range of house types will facilitate
range of people and households.            a very broad range of homeowners
                                           including individuals, couples, small
                                           families, and empty nesters.
Design and layout enable easy access by The proposal has been designed for
all.                                       ease of access throughout the site in
                                           accordance with Part M of the building
                                           regulations.
There is a range of public, communal, The scheme will provide a number of
and/or private amenity spaces and public open spaces include a central
facilities for children of different ages, spine open space along the stream and
parents, and the elderly.                  a second open space adjacent the
                                           graveyard.
Areas defined as public open space that The open spaces will be publicly
have either been taken in charge or accessible. Crossings to these spaces
privately managed will be clearly defined, will be denoted by a change in the
accessible and open to all.                surface treatment.
New buildings present a positive aspect The layout is designed to maximise
to passers-by, avoiding unnecessary visual and physical fluidity throughout
physical and visual barriers.              the scheme and will not hinder
                                           movement.

4. Variety – How does the development promote a good mix of activities?
Activities generated by the development The proposal will significantly improve
contribute to the quality of life in its the housing mix of the area and will
locality.                                   increase population creating additional
                                            demand for educational, sports and
                                            retail services all of which are provided
                                            close to the development.
Uses that attract the most people are in The crèche, playground and the variety
the most accessible places.                 of open spaces are strategically located
                                            within the scheme and will be easily
                                            accessible to residents.
Neighbouring uses and activities are The immediate area is characterised by
compatible with each other.                 residential uses; the proposed use is
                                            compatible with the surrounding area.
Housing types and tenure add to the A variety of houses and apartments are
choice available in the area.               provided which will further improve
                                            the range of unit types in the area
                                            available to various household types.
                                            Please refer to the accommodation
                                            schedule for more information.
Opportunities have been taken to The scheme is not of a size that would
provide shops, facilities and services that warrant a new local retail centre and
complement those already available in noting the proximity to the Fairways
the neighbourhood.                          and Blackrock village. The proposed
                                            layout encourages connection to these
                                            centres via sustainable means (walking
                                            and cycling).

                                                                                        28
5. Efficiency - How does the development make appropriate use of
resources, including land?
The proposal looks at the potential of The overall average density of 36.5
higher density, taking into account units/ha             is   considered     wholly
appropriate accessibility by public appropriate for this site given the
transport and the objectives of good outer suburban location, the existing
design.                                    character of the area and proximity to
                                           social infrastructure.
Landscaped areas are designed to Significant public open space will be
provide amenity and biodiversity, protect provided across the entire scheme
buildings and spaces from the elements incorporating           SuDS,     promoting
and incorporate sustainable urban biodiversity, and providing residential
drainage systems.                          amenity.
Buildings, gardens, and public spaces are All rear gardens will enjoy sufficient
laid out to exploit the best solar daylight and sunlight provisions
orientation.                               throughout the day. Whilst the public
                                           open spaces are all overlooked by
                                           adjoining residential streets there is
                                           sufficient set back to ensure that these
                                           spaces enjoy         optimum sunlight
                                           provision.
The scheme brings a redundant building n/a
or derelict site back into productive use.
Appropriate recycling facilities are Each unit will undertake its own
provided.                                  recycling with collection by municipal
                                           services. Communal bin stores for the
                                           apartment elements will be provided.

6. Distinctiveness - How do the proposals create a sense of place?
The place has recognisable features so The main characteristics that define
that people can describe where they live the site are the stream that runs
and form an emotional attachment to through the site and the location
the place.                               adjoining the graveyard.

                                         The proposed design incorporates
                                         these two features providing a scheme
                                         that encircles a new linear open space
                                         along the stream, while to the
                                         southwest a visual link to the graveyard
                                         along a new street is provided and a
                                         second open space providing an
                                         attractive buffer.
The scheme is a positive addition to the The site is currently vacant. The
identity of the locality.                proposal will provide an appropriate
                                         scale and quantum of residential
                                         development on a key site within the
                                         Haggradstown/Blackrock area.

                                                                                      29
The layout makes the most of the         The proposed layout adapts to the site
opportunities presented by existing      boundaries and its constraints, with the
buildings, landform, and ecological      scheme broken into a number of
features to create a memorable layout.   character areas with the layout
                                         responding to the stream, the
                                         graveyard, and adjoining properties.
The proposal successfully exploits views There are limited views into the site
into and out of the site.                due to the existing boundary planting
                                         and the graveyard along Old Golf Links
                                         Road. The site will be opened from
                                         the main access to the south and will
                                         address the access road and the public
                                         road. The scheme will also become
                                         more visible from Tuite’s lane to the
                                         north west with the opening up of a
                                         new pedestrian connection.

There is a discernible focal point to the The main linear open space along the
scheme, or the proposals reinforce the stream will be the main focal point that
role of an existing centre.               unifies the scheme.

7. Layout - How does the proposal create people friendly streets and
spaces?
Layout aligns routes with desire lines to Pedestrian permeability across the
create a permeable interconnected scheme and                  between      adjoining
series of routes that are easy and logical residential areas and open spaces is a
to navigate around.                        key design outcome with connection
                                           to the existing public footpath network
                                           along the public roads a key concern
                                           so as to ensure that local services are
                                           within short walking distance.
The layout focuses activity on the streets The scheme provides a series of
by creating frontages with front doors streets and avoids long, straight
directly serving the street.               stretches in order to reduce traffic
The streets are designed as places speeds in accordance with DMURS.
instead of roads for cars, helping to
create a hierarchy of space with less The streets will be co-shared with
busy routes having surfaces shared by cyclists and on the smaller streets
pedestrians, cyclists and drivers.         serving a small number of houses will
Traffic speeds are controlled by design operate much like shared surfaces with
and layout rather than by speed humps. residents using the streets to cross
                                           over to open spaces and other houses.
Block layout places some public spaces The open space strategy for the
in front of building lines as squares or scheme creates multiple open space
greens, and some semi-private space to areas of varying uses and sizes. The
the back as communal court.                apartment      and     elderly   housing
                                           elements      are     located     around
                                           communal open space courtyards.

                                                                                       30
8. Public Realm - How safe, secure, and enjoyable are the public areas?
All public open space is overlooked by All spaces are overlooked and
surrounding homes so that this amenity surveilled by surrounding residential
is owned by the residents and safe to streets.
use.
The public realm is considered as a Public realm is integrated into the
usable integrated element in the design design of the development and forms
of the development.                      part of the wider network of usable
                                         public spaces in the wider area.
Children’s play areas are sited where A children’s play area is provided and
they will be overlooked, safe and centrally located.
contribute to the amenities of the
neighbourhood.
There is a clear definition between Private open space is provided with
public, semi-private, and private space. private gardens for houses and
                                         balconies    for     the    apartments.
                                         Communal open spaces for the
                                         apartments are located in courtyard
                                         settings.   Public open spaces are
                                         provided throughout the scheme.

Roads and parking areas are considered Each unit will be provided with
as an integral landscaped element in the adequate parking. Roads and parking
design of the public realm.              areas are considered to be part of the
                                         public realm as such they are carefully
                                         soft landscaped and planted to reduce
                                         the harsh effects of hard landscaping.

9. Adaptability - How will the buildings cope with change?
Designs exploit good practice lessons,   Proposed house types in the scheme
such as the knowledge that certain       include attic space and rear garden
house types are proven to be ideal for   private areas that may be suitable for
adaptation.                              adaptation if required.

                                         Specific 2 storey units are designed
                                         with the ability to convert ground floor
                                         living accommodation into a bedroom
                                         and provide for an accessible
                                         bathroom at ground floor. All 2-story
                                         units are designed for future extension
                                         to the rear and into the attic.
The homes are energy-efficient and Yes, design practices and proposed
equipped for challenges anticipates from materials will militate against the
a changing climate.                      effects of climate change.
Homes can be extended without ruining Yes, as discussed above.
the character of the types, layout and
outdoor space.

                                                                                    31
The structure of the home and its loose Yes, as discussed above.
fit design allows for adaptation and
subdivision, such as the creation of an
annex or small office.
Space in the roof or garage can be easily This can be achieved in the attics of
converted into living accommodation.      most house designs proposed.

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

The homes are designed to provide All houses and apartments are
adequate storage including space within designed in accordance with national
the home for the sorting and storage of design standards on storage areas.
recyclables.

11. Parking – How will the parking be secure and attractive?
Appropriate car parking is on-street or Parking will be provided to the front
within easy reach of the home’s front and side of dwelling units.
door.
Parked cars are overlooked by houses, Yes, this will contribute to surveillance
pedestrians and traffic, or stored of the street.
securely, with a choice of parking
appropriate to the situation.
Parking is provided communally to This is provided for at the apartment
maximise efficiency and accommodate and elderly housing elements.
visitors without the need to provide
additional dedicated spaces.
Materials used for parking areas are of Yes, the highest quality materials will
similar quality to the rest of the be used throughout the scheme.
development.
Adequate secure facilities are provided Dedicated bicycle parking is provided
for bicycle storage.                    for the apartment blocks.      Bicycle
                                        parking will be accommodated in the
                                        rear hardens of own door houses.

                                                                                    32
12. Detailed Design – How well thought through is the building and
    landscape design?
    The materials and external design make A variety of materials and treatments
    a positive contribution to the locality. that complement the existing character
                                             of the area will be employed.
    The landscape design facilitates the use The public open spaces will be
    of the public spaces from the outset.    provided in tandem with the phasing of
                                             the overall scheme.
    Design of the buildings and public space This can be achieved and will be
    will facilitate easy and regular provided by the estate management
    maintenance.                             company.
    Open car parking areas are considered Communal parking areas will be
    as an integral element within the public designed and finished to the highest
    realm design and are treated standard.
    accordingly.
    Care has been taken over the siting of Bin stores for the houses will be
    flues, vents, and bin stores.            located in        the rear    gardens.
                                             Communal bin stores for the
                                             apartments will be carefully designed
                                             and will not form a negative visual
                                             element.

4.5 QUALITY HOUSING FOR SUSTAINABLE COMMUNITIES: BEST
PRACTICE GUIDELINES FOR SUSTAINABLE COMMUNITIES, 2007

The Department’s policy statement Delivering Homes, Sustaining Communities,
Guidance provides the overarching policy framework for an integrated approach to
housing and planning. Sustainable neighbourhoods are areas where an efficient use of
land, high quality design, and effective integration in the provision of physical and
social infrastructure combine to create places people want to live in. The policy
statement is accompanied by Best Practice Guidelines that promotes quality
sustainable residential development in urban areas having regard to the following:

     promote high standards in the design and construction and in the provision of
      residential amenity and services in new housing schemes;
     encourage best use of building land and optimal of services and infrastructure in the
      provision of new housing;
     point the way to cost effective options for housing design that go beyond minimum
      codes and standards;
     promote higher standards of environmental performance and durability in housing
      construction;
     seek to ensure that residents of new housing schemes enjoy the benefits of first-rate
      living conditions in a healthy, accessible and visually attractive environment; and
     provide homes and communities that may be easily managed and maintained.

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

                                                                                         33
Socially & Environmentally Appropriate          The scheme will provide an appropriate
“The type of accommodation, support             mix of 2/3/4 bed houses and apartments.
services and amenities provided should be       The proposal seeks to integrate usable
appropriate to the needs of the people to be    public     open    spaces    distributed
accommodated. The mix of dwelling type,         throughout a number of character areas
size and tenure should support sound social,    and all interconnected. All public open
environmental and economic sustainability       spaces will be overlooked by adjoining
policy objectives for the area and promote      housing.
the development of appropriately integrated
play and recreation spaces.”
Architecturally Appropriate                     The design and layout of the scheme
“The scheme should provide a pleasant           creates a liveable and visually pleasing
living environment, which is aesthetically      residential environment.
pleasing and human in scale. The scheme
design solution should understand and           The design is appropriate and mindful of
respond appropriately to its context so that    the urban edge context, the site
the development will enhance the                constraints, and architectural character of
neighbourhood and respect its cultural          the adjoining residential areas.
heritage.”

Accessible & Adaptable                          A single vehicular access will be provided.
“There should be ease of access and Several pedestrian/cyclist connections will
circulation for all residents, including people also be provided.
with impaired mobility, enabling them to
move as freely as possible within and
through the development, to gain access to
buildings and to use the services and
amenities provided. Dwellings should be
capable of adaptation to meet changing
needs of residents during the course of their
lifetime.”

Safe, Secure & Healthy                          The scheme provides an appropriate
“The scheme should be a safe and healthy        layout for pedestrians/cyclists with a
place in which to live. It should be possible   dedicated alternative access via Tuite’s
for pedestrians and cyclists to move within     Lane available.
and through the area with reasonable ease
and in safety. Provision for vehicular          A safe walking and cycling environment
circulation, including access for service       will be provided for residents and those
vehicles, should not compromise these           travelling through the scheme will be
objectives.”                                    provided.

Affordable                                      The interconnectivity of the scheme will
“The scheme should be capable of being          ensure access for all while creating a
built, managed and maintained at                walkable environment for inhabitants of
reasonable cost, having regard to the nature    the scheme. The continuity of path
of the development.”                            networks will assist natural way-finding in
                                                the scheme. Public open space shall be
                                                overlooked as far as practicable to
                                                achieve maximum passive surveillance.

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