STATEMENT OF CONSISTENCY PROPOSED SHD RESIDENTIAL DEVELOPMENT AT GLENHERON, GREYSTONES, COUNTY WICKLOW - CAIRN HOMES PROPERTIES LIMITED - FOR A ...
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STATEMENT OF CONSISTENCY
FOR A
PROPOSED SHD RESIDENTIAL DEVELOPMENT AT
GLENHERON, GREYSTONES, COUNTY WICKLOW
PREPARED BY
ON BEHALF OF
CAIRN HOMES PROPERTIES LIMITED
OCTOBER 2019
1
CONTENTS
1. INTRODUCTION ......................................................................................................... 3
2. NATIONAL PLANNING POLICY .................................................................................... 4
3. REGIONAL PLANNING POLICY................................................................................... 19
4. LOCAL PLANNING POLICY ......................................................................................... 22
5. CONCLUDING REMARKS .......................................................................................... 34
2
1. INTRODUCTION
On behalf of the applicant, Cairn Homes Properties Limited, Third floor, Block 7, Grand Canal Street
Lower, Dublin 2, this Statement of Consistency with Planning Policy accompanies this planning
application to An Bord Pleanála in relation to a proposed Strategic Housing Development at a site on
the Lands at Glenheron Site C, Charlesland, Greystones, Co. Wicklow, in accordance with Section 5 of
the Planning and Development (Housing) and Residential Tenancies Act 2016.
The development will consist of a mixed use, residential and employment proposal comprising the
following:
a) A residential development of 354 no. units including:
a. 124 no. 2-storey houses (comprising 13 no. 2-bed; 93 no. 3-bed and 18 no. 4 bed);
b. 2 no. apartment blocks (5-6 storeys in height) comprising 170 no. units (36 no. 1 bed,
123 no. 2 bed and 11 no. 3 bed). The apartment development will include a concierge,
security room, and communal amenity room.
c. 60 no. duplex apartments (30 no. 2-bed and 30 no. 3-bed).
d. All residential units provided with private garden/balcony/terrace space to standard
and facing north/south/east/west.
e. Provision of public and communal open spaces, car parking (456 no. spaces) and cycle
parking (388 no. spaces).
b) An employment development comprising a 2-storey Community Enterprise building (1,356
sq.m) and a 2 storey office building (1,376sqm), 91 no. parking spaces and 108 no. bicycle
spaces;
c) The relocation of the existing temporary bus parking facility to the western side of the
unnamed local road leading to Shoreline Sports Park;
d) Accesses to the development from the unnamed local road and via Seabourne apartment
development to the north;
e) Provision of pedestrian connections including across R774/L1221 to Charlesland
Neighbourhood Centre;
f) All associated site development works, drainage and infrastructural works, servicing (including
2 no. substations, bin stores), landscaping, open spaces, and boundary treatment works.
Please note that the main road running along the northern boundary of the site has two names, the
L1221 and the R774. For consistency R774 is used throughout this report. However, it is worth noting
for other reports that the L1221 and the R774 refer to the same road and can be used interchangeably.
This Statement of Consistency demonstrates that the proposal is in accordance with the relevant
national planning policy, guidelines issued under Section 28 of the Planning and Development Act
2000 (as amended), and with local planning policy. It should be read in conjunction with the
accompanying detailed documentation prepared by Darmody Architects, AECOM Engineers, IAC
Archaeology, Kevin Fitzpatrick Landscape Architects, Cunnane Stratton Reynolds Land Planning and
Design, Waterman Moylan Engineering Consultants, Chris Shackelton Consulting, Openfield Ecological
Services, O’Herlihy Access Consultants (OHAC), Integrated Environmental Solutions (IES).
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2. NATIONAL PLANNING POLICY
The key national and regional policies and guidelines (including Section 28 Guidelines) relevant to the
proposed development are as follows:
• Ireland 2040 Our Plan - National Planning Framework (2018);
• Guidelines for Planning Authorities on Urban Development and Building Heights (2018);
• Guidelines for Planning Authorities on Sustainable Urban Housing: Design Standards for New
Apartments (2018);
• Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas
(2009), and the accompanying Urban Design Manual;
• Quality Housing for Sustainable Communities (2007);
• Design Manual for Urban Roads and Streets (2013);
• Guidelines for Planning Authorities on Childcare Facilities (2001);
• Smarter Travel – A New Transport Policy for Ireland (2009-2020);
• The Planning System and Flood Risk Management (2009);
• Rebuilding Ireland – Action Plan for Housing and Homelessness 2016;
• Climate Action Plan 2019
Ireland 2040 Our Plan – National Planning Framework (2018)
The National Planning Framework (NPF) is the Government’s plan for shaping
the future growth and development of the country and to cater for the extra
one million people that is anticipated to be living in Ireland. The Eastern and
Midland Region (including Wicklow) will, by 2040, be a Region of around 2.85
million people, at least half a million more than today. The NPF includes National
Strategic Outcomes and National Policy Objectives to guide development and
policy making at regional and local levels, providing an overall framework for
the entire country.
The NPF Strategy includes the following aims:
• Target a greater proportion (40%) of future housing development to be within and close to
the existing ‘footprint’ of built up areas.
• One of the principal elements of the NPF’s overall strategy for spatial planning (NPF Section
2.2) is compact growth
• Balance the provision of good quality housing that meets the needs of a diverse population,
in a way that makes our cities, towns, villages and rural areas good places to live now and in
the future.
• Section 3.2 identifies that in locations such as “Wicklow, proximate to the Capital, has resulted
in significant development in a region characterised by the dominance of Dublin. … Managing
the challenges of future growth is critical to this regional area. A more balanced and
sustainable pattern of development, with a greater focus on addressing employment creation,
local infrastructure needs and addressing the legacy of rapid growth, must be prioritised. This
means that housing development should be primarily based on employment growth,
accessibility by sustainable transport modes and quality of life, rather than unsustainable
commuting patterns”
4
• Section 6.6 of the NPF sets out national core principles for housing delivery. These principles
include: ‘Prioritise the location of new housing provision in existing settlements to maximising
a better quality of life for people through accessing services, ensuring a more efficient use of
land and allowing for greater integration with existing infrastructure.’
This major new policy emphasis on renewing and developing existing settlements aims to prevent the
continual expansion and sprawl of our cities. This aim for compact growth notes that achieving
effective density and consolidation, rather than more sprawl of urban development, is a top priority.
The NPF projects that 550,000 additional homes will be required by 2040 to meet future demand.
These new homes should be located in places that can support sustainable development and in cities
and larger towns where large scale housing exists. To achieve this housing target, we will need to build
inwards and upwards and apartments will need to become a more prevalent form of housing. The NPF
also states that that “to avoid urban sprawl and the pressure that it puts on both the environment and
infrastructure demands, increased residential densities are required in our urban areas”.
Key National Policy Objectives which relate to this site are set out below:
National Policy Objective 2a
A target of half (50%) of future population and employment growth will be focused in the
existing five Cities and their suburbs.
National Policy Objective 3a
Deliver at least 40% of all new homes nationally, within the built-up footprint of existing
settlements.
National Policy Objective 4
Ensure 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.
National Policy Objective 5
Develop cities and towns of sufficient scale and quality to compete internationally and to
be drivers of national and regional growth, investment and prosperity.
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 13
In urban areas, planning and related standards, including in particular building height and
car parking will be based on performance criteria that seek to achieve well-designed high-
quality outcomes in order to achieve targeted growth. These standards will be subject to
a range of tolerance that enables alternative solutions to be proposed to achieve stated
outcomes, provided public safety is not compromised and the environment is suitably
protected.
National Policy Objective 27
5
Ensure the integration of safe and convenient alternatives to the car into the design of
our communities, by prioritising walking and cycling accessibility to both existing and
proposed developments and integrating physical activity facilities for all ages.
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 35
Increase residential density in settlements, through a range of measures including
reductions in vacancy, reuse of existing buildings, infill development schemes, area or
site-based regeneration and increased building heights.
Evaluation of Consistency
The subject site is located within the settlement boundary of Greystones, Co. Wicklow and the
proposed development, and the provision of medium density development will increase the overall
residential density of the area in accordance with NPO 35.
In accordance with the NPF’s objectives for areas such as Wicklow, this development provides for
both residential development and employment. A community enterprise centre of c. 1356sqm and
an office building of c. 1,376sqm is being provided. These will serve the existing and future
community by providing more jobs in the locality. This will help achieve NPO 11 by providing new
employment within the settlement area of Greystones A masterplan for the remainder of the
employment site is also submitted with this application.
The development will integrate with and improve the social and physical infrastructure along the
R774 and within Charlesland and the wider Greystones area.
The site is in a highly sustainable location with good access to existing public transport, services and
facilities, which will promote the use of sustainable transport modes. Bus routes from Kilcoole Road
and the R774 connect the subject site with Greystones and Bray town centres and Dublin airport.
There are also existing cycle lanes and pedestrian routes in the area and additional routes are
included as part of the proposed development.
Pedestrian permeability was a major design outcome for the proposed development. By providing
attractive, safe and direct routes for pedestrians it is hoped that
The proposed layout and design of the development ensures a high-quality residential scheme. The
choice of high-quality materials and finishes enhances the quality of the development creating an
attractive, liveable and high-quality urban area for the future residents of the proposed
development.
Overall, the development of these lands is fully in accordance with the recommendations of the
NPF.
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Guidelines for Planning Authorities on Urban Development and Building Heights (2018)
The Guidelines set out national planning policy guidelines on building heights
in urban areas in response to specific policy objectives set out in the National
Planning Framework and Project Ireland 2040. There is a presumption in favour
of tall buildings at public transport nodes and state that it is Government policy
to promote increased building height in urban locations with good public
transport services.
Under Section 28 (1C) of the Planning and Development Act 2000 (as amended),
Planning Authorities and An Bord Pleanála are required to have regard to the
guidelines and apply any specific planning policy requirements (SPPR’s) of the
guidelines in carrying out their function. SPPRs as stated in the Guidelines, take precedence over any
conflicting, policies and objectives of development plans, local areas plans and strategic development
zone planning schemes.
The Guidelines emphasise the policies of the NPF to increase levels of residential development in
urban centres and increase building heights and overall density by both facilitating and encouraging
the development of increased heights and densities by Local Authorities and An Bord Pleanála.
They place significant emphasis on promoting development in existing urban areas and utilising the
existing sustainable mobility corridors and networks. “In order to optimise the effectiveness of this
investment in terms of improved and more sustainable mobility choices and enhanced opportunities
and choices in access to housing, jobs, community and social infrastructure, development plans must
actively plan for and bring about increased density and height of development within the footprint
of our developing sustainable mobility corridors”. It goes on to highlight that “the preparation of
development plans, local areas plans, and Strategic Development Zone Planning Schemes and their
implementation in the city, metropolitan and wider urban areas must therefore become more
proactive and more flexible in securing compact urban growth through a combination of both
facilitating increased densities and building heights”.
Criteria Evaluation of Consistency
SPR1 Support increased The subject site is well served by public transport
building height and services. Dublin Bus Routes 84 (Blackrock-
density in locations with Newcastle) and 84x (Hawkins Street –
good public transport Newcastle/Kilcoole) service the bus stops within a
accessibility 10 minute walk of the subject site.
At the scale of the Site is well served by The temporary Aircoach bus stop along the
town public transport with unnamed road will be formalised as part of the
high capacity, frequent proposed development. This stop is the terminus
service and good links to stop for Aircoach route 702 to Dublin Airport, which
other modes of operates every hour and stops in 23 places along
transport the route to Dublin Airport including stops in Bray,
Shankill, Foxrock, Blackrock, Ballsbridge and Grand
Canal.
Three new bus routes along the R774 are proposed
under the BusConnects – Dublin Outer South. These
7
will provide services every 20 minutes to Kilcoole,
Newcastle, Delgany, Greystones and Bray.
In addition, the subject site is within cycling and
walking distance of Greystones DART station, which
provides services to Dublin City.
Successfully integrates The proposed development includes a variety of
into/enhances the buildings types and uses that will make a positive
character and public contribution to the character of the area and public
realm of the area, having realm.
regard to topography, its
cultural context, setting The public open spaces will provide an amenity for
of key landmarks, the existing and future residents of the area.
protection of key views.
The 6 storey apartment buildings are located to act
Make a positive as a continuation of the Seabourne apartments
contribution to place- while also being set back into the site.
making
At the scale of the Responds to its overall The proposed development maintains existing tree
neighbourhood natural and built and hedgerows as much as possible as part of the
environment and makes development works. The duplexes along the R774
a positive contribution will provide a strong urban edge to the road making
to the urban a positive contribution to the streetscape.
neighbourhood and
streetscape.
The proposal is not The residential area of the proposed development
monolithic and avoids consists of a mix of duplexes, houses and
long, uninterrupted apartments which are laid out to create distinct
walls of building. character areas and avoid long uninterrupted walls
of buildings.
The apartment blocks are angled to continue the
curve of the Seabourne View apartments and avoid
a monolithic style.
Enhances the urban The proposed development will provide a strong
design context for public urban edge along the R774, which improve the
spaces and key existing urban context and help the development
thoroughfares integrate into the area. The key routes through the
site will be landscaped and a woodland walk will be
provided through the development overall
enhancing the urban public realm.
Makes a positive The proposed development prioritises pedestrians
contribution to the and cyclists by providing multiple access points and
improvement of into the site and providing attractive pathways
legibility through the throughout the site.
site or wider urban area
within which the
8
development is situated The three different public open spaces in the
and integrates in a residential area act as focal points in the
cohesive manner. development to guide people through. The large
public open space in front of the apartment blocks
acts as the main focal point and creates a
destination within the development for existing
and future residents for the area.
Positively contributes to The mix of building sizes and typologies will add to
the mix of uses and/or the existing housing mix in the area and provide for
building typologies a variety of household types and sizes. The
available in the residential area of the proposed development will
neighbourhood. cater for individuals, couples and families.
At the scale of the Form, massing and The layout has been designed to ensure that every
site/building height should be residential unit receives adequate daylight and
modulated to maximise sunlight. The chosen layout has minimised
access to natural overshadowing issues.
daylight, ventilation and
views and minimise In addition, the block of houses, duplexes and
overshadowing and loss apartments have been located to provide glimpse
of light view through the development to the open spaces
and to the adjacent golf course.
Regard should be taken A Daylight Sunlight Assessment carried out by IES is
of quantitative submitted with this application which found that
performance the proposed development will have a minimal
approaches to daylight adverse effect on the adjacent properties.
provision
Specific Specific impact Not considered necessary in this instance given the
Assessment assessment of micro- relative low scale and orientation of buildings
climatic effects which is unlikely to result in micro-climate issues in
terms of wind, etc.
Evaluation of Consistency
It is considered that the subject site is an appropriate site for building height of 6 storeys as
proposed in this application. The proposal responds to its overall natural and built environment
surrounding the site, while providing a strong urban edge to the R774. The five storeys plus a
setback sixth floor apartments are located beside Seabourne Apartments which are 5 storeys in
height. As a result, the apartments read as a continuation of this height in this area. It makes a
positive contribution to the existing neighbourhood and the streetscape.
The proposed development is set out in distinct areas of development. The mix of residential unit
types provides different character areas, which a public open space as the focal point for each area.
The community enterprise building and office building provide a different area of development in
contrast to the residential area.
9
The proposed development has had regard to the planning policy framework as set out in the
building height guidelines and National Planning Framework. The provision of residential
development at this location between 2 no. and 6 no. storeys is supported by the height guidelines
which encourages increased density and building heights in such urban locations as Glenheron. The
proposed development complies with such objectives therefore is considered to be in accordance
with the provisions of national policy guidelines.
Guidelines for Planning Authorities on Sustainable Urban Housing: Design Standards for
New Apartments (2018)
The Apartment Guidelines 2018 promote sustainable housing, by ensuring that
the design and layout of new apartments provide satisfactory accommodation
for a variety of household types and sizes, including families with children over
the medium to long term. The guidelines provide for updated guidance on
apartment developments in response to the National Planning Framework and
Rebuilding Ireland.
The guidelines outline 9 Special Planning Policy Requirements (SPPRs) that take
precedence over any conflicting policies and objectives of development plans,
local area plans and strategic development zone planning schemes.
Guidance Evaluation of Consistency
The apartment guidelines (SPPR1) note The proposed development provides for 36 no. 1 bed
that apartment may include up to 50% units (21% of the apartments, 10.2% of entire residential
one bedroom or studio type units and development), 166 no. 2 beds, 134 no. 3 bed units and
that there shall be no minimum 18 no. 4 bed units and is therefore compliant with the
requirement for 3 or more bed units. stated housing mix in the Guidelines.
The apartment guidelines (SPPR3) set The Housing Quality Assessment illustrates in tabular
out the minimum floor areas for format how each apartment within the blocks meet or
apartment units along with a exceed the relevant standards in respect to apartment
requirement that the majority of units size.
within a scheme shall exceed the
minimum floor areas by 10%.
While SPPR4 requires more than 50% The proposed layout ensures that the scheme has 50%
dual aspect apartments. dual aspect apartments which meets the apartment
guidelines and none of the single aspect units are north
facing. A Design Statement prepared by Darmody
Architects is submitted as part of this planning
application which demonstrates compliance with the
applicable standards.
The apartment guidelines states that all Each of the proposed units will contain private open
apartments should include private and space in excess of the requirements. The quantum of
communal open space. private open space is set out in the Housing Quality
Assessment. There is also over 13% public open space
within the residential development in this scheme.
10All ground floor apartments are required All the ground floor apartments have 2.7m floor to
to have 2.7m high floor to ceiling heights ceiling heights in line with SPPR5
(SPPR5).
SPPR6 limits the number of units per The proposal is also in line with SPPR6 regarding the
core to 12 units. number of units per core.
Section 4.16 identifies that cycling In line with this ambition 496 no. secure, readily
“provides a flexible, efficient and accessible residential bicycle parking spaces and visitor
attractive transport option for urban bicycle parking spaces have been provided and designed
living and these guidelines require that into this scheme. 276 no. of these bicycle parking spaces
this transport mode is fully integrated are provided for the proposed apartments.
into the design and operation of all new
apartment development schemes.”
Section 4.19 identifies that in Accessible This scheme has reduced the car parking in the
Urban Locations such as this one, in apartment element of the development significantly in
“larger scale and higher density line with this policy to provide 1.2 no. spaces for 1 no.
developments, comprising wholly of and 2 no. bed units, and 2 no. spaces per 3 no. bed unit.
apartments in more central locations 4 no. car club sharing spaces are proposed for the
that are well served by public transport, apartment blocks ensuring that future residents have
the default policy is for car parking access to cars should the need arise but ensuring they
provision to be minimised, substantially do not have to buy one or that valuable land is taken up
reduced or wholly eliminated in certain through car storage. The accessibility of this site due to
circumstances.” the confluence of public transport systems including the
bus and Dart located in proximity, along with the new
and improved cycle routes within and around the site
enables this scheme to have this reduced parking level.
The subject development in accordance with the
guidelines is suitable for substantially reduced car
parking provision in locations served by public transport.
It is respectfully submitted that the proposed car
parking rate is therefore compliant with the overall
objectives to increase the utilisation of sustainable
modes of transport and reduce the overall car parking
reliance for residential developments. There are
sufficient number of drop off, service, visitor parking
and parking for the mobility impaired in line with section
4.23. Furthermore, section 4.24 recommends the use of
car sharing clubs for sites such as this one. A Traffic
Impact Assessment has submitted as part of this
application to demonstrate the justification for the
proposed car parking provision on the site.
Appropriate Density The proposed density on the subject site is c.49.24 no.
units per hectare. It is considered that the proposed
density is appropriate given the National Policy
objective to increase residential density in existing
urban infill location. This planning application is
accompanied by a Housing Quality Assessment
document prepared by Darmody which demonstrates
11the compliance of the proposed development with the
relevant quantitative standards required under the
2018 Apartment Guidelines.
Appropriate Location The proposed apartment buildings and units are
considered to be suitability located on the subject site,
integrated within the protected structures and
landscape and well connected to adjacent facilities
including public transport, and will provide a high-
quality development on the subject site
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.
This has been fully addressed in the Response to An Bord Pleanála’s Opinion also submitted with
this SHD application.
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.
These have been addressed in the Response to An Bord Pleanála’s Opinion also
submitted with this SHD application.
12Quality Housing for Sustainable Communities (2007)
The Department’s policy statement Delivering Homes, Sustaining Communities,
Guidance provides the overarching policy framework for an integrated approach
to housing and planning. Sustainable neighbourhoods are areas where an
efficient use of land, high quality design, and effective integration in the provision
of physical and social infrastructure combine to create places people want to live
in. The policy statement is accompanied by Best Practice Guidelines that
promotes quality sustainable residential development in urban areas having
regard to the following:
• promote high standards in the design and construction and in the provision of residential
amenity and services in new housing schemes;
• encourage best use of building land and optimal of services and infrastructure in the provision
of new housing;
• point the way to cost effective options for housing design that go beyond minimum codes and
standards;
• promote higher standards of environmental performance and durability in housing
construction;
• seek to ensure that residents of new housing schemes enjoy the benefits of first-rate living
conditions in a healthy, accessible and visually attractive environment; and
• provide homes and communities that may be easily managed and maintained.
The following criteria indicate the 7 no. essential requirements new residential developments should
have regard to when carrying out development:
Evaluation of Consistency
Socially & Environmentally Appropriate The scheme will provide an appropriate mix of 1,
“The type of accommodation, support services 2 and 3-bedroom apartments and 2, 3 and 4-
and amenities provided should be appropriate bedroom houses. The proposal seeks to
to the needs of the people to be accommodated. integrate usable open spaces distributed
The mix of dwelling type, size and tenure should throughout several character areas and all
support sound social, environmental and interconnected. All open spaces will be
economic sustainability policy objectives for the overlooked by adjoining housing.
area and promote the development of
appropriately integrated play and recreation A part V proposal is submitted with this scheme
spaces.” to address the requirements for social and
affordable housing.
Architecturally Appropriate The design and layout of the scheme creates a
“The scheme should provide a pleasant living liveable and visually pleasing residential
environment, which is aesthetically pleasing and environment.
human in scale. The scheme design solution
should understand and respond appropriately to The design is appropriate and mindful of the
its context so that the development will enhance urban edge context, the site constraints, and
the neighbourhood and respect its cultural architectural character of the adjoining
heritage.” residential areas.
Accessible & Adaptable The layout of the proposed development allows
“There should be ease of access and circulation for ease of access for all residents, with vehicle
for all residents, including people with impaired
mobility, enabling them to move as freely as
13possible within and through the development, entrances located on both the northern and
to gain access to buildings and to use the southern boundaries.
services and amenities provided. Dwellings
should be capable of adaptation to meet All the houses will be adaptable and can be
changing needs of residents during the course of changed to meet the needs of the residents into
their lifetime.” the future.
Safe, Secure & Healthy The scheme provides good segregation of
“The scheme should be a safe and healthy place vehicle and pedestrians/cyclists.
in which to live. It should be possible for
pedestrians and cyclists to move within and A very safe walking and cycling environment will
through the area with reasonable ease and in be provided for residents and those travelling
safety. Provision for vehicular circulation, through the scheme from other development to
including access for service vehicles, should not get to the DART and buses or cycle paths.
compromise these objectives.”
The interconnectivity of the scheme will ensure
access for all while creating a walkable
environment for inhabitants of the scheme. The
continuity of path networks will assist natural
way-finding in the scheme. Public open space
shall be overlooked as far as practicable to
achieve maximum passive surveillance.
Affordable The scheme will have high quality materials and
“The scheme should be capable of being built, landscaping throughout, ensuring that it has
managed and maintained at reasonable cost, longevity in terms of appearance and ease of
having regard to the nature of the maintenance.
development.”
Durable The scheme endeavours to use the best
“The best available construction techniques available materials and construction techniques
should be used, and key elements of in order to minimise the level of refurbishment
construction should have a service life in the over the lifetime of the scheme.
order of sixty years without the need for
abnormal repair or replacement works.
Resource Efficient The scheme is considered to accord with the
“Efficient use should be made of land, sustainable development principles.
infrastructure and energy. The location should
be convenient to transport, services and
amenities. Design and orientation of dwellings
should take account of site topography so as to
control negative wind effects and minimise the
benefits of sunlight, daylight and solar gain;
optimum use should be made of renewable
sources of energy, the use of scarce natural
resources in the construction, maintenance and
management of the dwellings should be
minimised.”
14Design Manual for Urban Roads and Streets (2019)
The Design Manual for Urban Roads and Streets (DMURS) was first published in
2013 with an updated version released in May 2019. It sets out design guidance
and standards for constructing new and reconfiguring existing urban roads and
streets in Ireland. It also outlines practical design measures to encourage more
sustainable travel patterns in urban areas.
These Guidelines have been assessed in the Response to An Bord Pleanála’s
Opinion also submitted with this SHD application.
Guidelines for Planning Authorities on Childcare Facilities (2001)
These guidelines state that Development Plans should facilitate the provision of
childcare facilities in larger new housing estates with the standard minimum
provision of one childcare facility with 20 places for each 75 dwellings.
Section 4.7 of the Sustainable Urban Housing Design Guidelines for New Apartments,
2018 states the following:
“Notwithstanding the Planning Guidelines for Childcare Facilities (2001), in respect of
which a review is to be progressed, and which recommend the provision of one child-
care facility (equivalent to a minimum of 20 child places) for every 75 dwelling units, the
threshold for provision of any such facilities in apartment schemes should be established
having regard to the scale and unit mix of the proposed development and the existing
geographical distribution of childcare facilities and the emerging demographic profile of the
area. One-bedroom or studio type units should not generally be considered to contribute to
a requirement for any childcare provision and subject to location, this may also apply in part
or whole, to units with two or more bedrooms.”
Evaluation of Consistency
An assessment was undertaken by McGill Planning Ltd into the demand for a crèche on the site.
Following an assessment of existing and proposed facilities in the local area, it is clear that the
increased demand can be accommodated by the existing and proposed facilities. Therefore, there
is no need for an additional childcare facility in the area and the provision of such a facility may
adversely affect the vitality and viability of existing childcare facilities in the area. Please refer to
the submitted Crèche Audit included within Chapter 4 of the Environmental Impact Assessment
Report for further details.
Smarter Travel – A New Transport Policy for Ireland (2009-2020)
The Irish Government published Smarter Travel – A New Transport Policy for
Ireland in 2009 in acknowledgment that the transport trends throughout the
country are unsustainable. This national policy document was designed to
demonstrate how unsustainable transport and travel patterns can be reversed
Key targets of this national sustainable transport policy include:
15• To support sustainable travel, future population and employment growth will have to
predominantly take place in sustainable compact urban areas or rural areas, which discourage
dispersed development and long commuting
• Work-related commuting by car will be reduced from a current modal share of 65% to 45%, which
will mean that between 500,000 and 600,000 commuters will be encouraged to take means of
transport other than car driver (of these 200,000 would be existing car drivers). Change in personal
behaviour will also be necessary for other travel purposes as most travel relates to non-
commuting.
• Car drivers will be accommodated on other modes such as walking, cycling, public transport and
car sharing (to the extent that commuting by these modes will rise to 55% by 2020) or through
other measures such as e-working.
• The total kilometres travelled by the car fleet in 2020 will not increase significantly from current
total car kilometres.
Evaluation of Consistency
The proposed development is in line with this overall vision for better integration between land-
use and transport. The proposed residential development is located within walking/cycling distance
of a local neighbourhood centre and Greystones town and is in a location with access to public
transport including the DART and the bus.
The proposal also includes the provision of a community enterprise building and an office building,
which will provide employment alongside the residential area, and also a masterplan for the
employment zoned land. As a result, this Action Plan Area is bringing forward residential and
employment uses in one location which is in line with the Smarter Travel policies.
In addition, the entire proposed development has been designed to provide pedestrian
permeability to make walking a more viable and attractive form of transport and encourage people
to leave their cars behind.
The Planning System and Flood Risk Management (2009)
These guidelines require the planning system to avoid development in areas at
risk of flooding, particularly floodplains, unless there are proven wider
sustainability grounds that justify appropriate development and where the
flood risk can be reduced or managed to an acceptable level without increasing
flood risk elsewhere.
The Guidelines adopt a sequential approach to flood risk management when
assessing the location for new development based on avoidance, reduction and
mitigation of flood risk; and incorporate flood risk assessment into the process
of making decisions on planning applications and planning appeals.
Evaluation of Consistency
The application has been the subject of a Strategic Flood Risk Assessment. The study indicates that
the development is not at risk from a 1 in 1000-year coastal event. This places the site in Flood Zone
C, which is an appropriate location for residential development.
16Rebuilding Ireland – Action Plan for Housing and Homelessness 2016
Rebuilding Ireland was launched in 2016 with the objective to double the annual level of residential
construction to 25,000 homes and deliver 47,000 units of social housing in the period to 2021. It was
based on 5 no. pillars. Pillar 3 – Build More Homes aims to increase the output of private housing to
meet demand at affordable prices.
Evaluation of Consistency
The proposed development is consistent with Pillar 3 to build more homes. The proposed
development provides for 124 no. houses, 170 no. residential apartments and 60 no. duplexes
which will add to the housing stock of the area, provide variety in the type of house provision and
will cater to the increasing demand for the settlement area.
Climate Action Plan 2019
The Department of Communications, Climate Action and Environment
published the Climate Action Plan 2019 aims to make Ireland a leader in
responding to climate disruption. This Action Plan acknowledges the impact of
climate change and that the window of opportunity to act is fast closing and
that decarbonisation is now a must if the world is to contain the damage and
build resilience in the face of such a profound challenge.
The Action Plan includes the following objectives:
• Increase reliance on renewables from 30% to 70% adding 12GW of renewable
energy capacity
• Increase attention to Energy and Carbon ratings in all aspects of managing
property assets.
• Make growth less transport intensive through better planning, remote and home-working and
modal shift to public transport.
• A target of 55% renewable power and at least 500,000 electric vehicles on the road by 2030.
• Reduced travel distances and greater proximity to employment and services, which will enable
a greater proportion of journeys by bike or on foot (zero emissions)
• Greater urban density, which when combined with the point above, will ensure more viable
public transport (less emissions per person than by individual vehicle)
• Greater sustainable mode share, which will enable cities and towns to densify, as
development will not be dependent on road capacity nor car parking requirements, and less
land will be required for the latter
• Closer proximity of multi-storey and terraced buildings, which will require less energy and
make renewables-based systems of energy distribution such as district heating, or area-wide
technology upgrades, more feasible
The Action Plan notes that the built environment accounted for 12.7% of Ireland’s greenhouse gas
emissions in 2017 and it is therefore important that we improve the energy efficiency of our buildings.
Ireland’s dispersed settlement pattern and low population density are identified as challenges specific
to Ireland that need to be addressed reduce transport emissions.
Actions to address spatial planning and urban form of development are required to aid the transition
to a low carbon and climate resilient society.
17Evaluation of Consistency
The proposed development will help to achieve the targets set by the Climate Action Plan 2019.
The proposed development provides a medium to high density residential development in close
proximity to existing community facilities and amenities. This proximity will help to support the
existing facilities and will reduce the need of future residents to travel long distances by car for basic
services and as a result will help reduce greenhouse car emissions.
In addition, the location is well-served by transport links, including the Dart station in Greystones c.
2.5km from the subject site and bus stops located along the R774. The provision of more housing
in this location will support the existing public transport serving the area and will make the provision
of further public transport options (such as increased frequency of services) viable and worthwhile
in the future. This will help the overall transition to more sustainable modes of transport and a
reduction in our greenhouse gas emissions.
The development has been designed to give pedestrians and cyclists priority over cars which will
help to encourage cycling and walking as a mode of transport especially those attending the nearby
schools and working within the proposed office building. Movement away from the car as the main
mode of transport will be key to achieving our climate change aims and it is hoped that the
proposed development will encourage this change. The provision of car parking spaces throughout
the site is an acknowledgement of the fact that this change will not happen overnight, and people
in this location will likely still have their own cars. However, every car parking space throughout the
development can be equipped with an electrical charge point to ensure that the transition to an
electric car is a viable option for all residents. In addition, the 8 no. car club sharing spaces, 4 no.
spaces for the apartments and 4 no. spaces for the office and enterprise building, will be provided
within the development to provide an alternative travel option for residents.
The provision of solar panels within the development and the inclusion of green roofs on the
apartment blocks will help with decarbonisation and the reduction of greenhouse gas emissions.
183. REGIONAL PLANNING POLICY
This section will outline the consistency of the proposed development with the following regional
planning policies and guidelines:
• Transport Strategy for the Greater Dublin Area 2016-2035
• Regional Spatial and Economic Strategy 2019-2031
Transport Strategy for the Greater Dublin Area 2016-2035
The NTA Strategy promotes the consolidation of the Metropolitan Dublin area
allowing for the accommodation of a greater population than at present, with
much-enhanced public transport system, with the expansion of the built-up areas
providing for well-designed urban environments linked to high quality public
transport networks, enhancing the quality of life for residents and workers alike.
The strategy’s primary policy notes that Ireland is required to radically reduce
dependence on carbon-emitting fuels in the transport sector and that the strategy
must promote, within its legislative remit, transport options which provide for
unit reductions in carbon emissions. This can most effectively be done by
promoting public transport, walking and cycling, and by actively seeking to reduce car use in
circumstances where alternative options are available.
Section 7 states that “the implementation of the Strategy will facilitate a more efficient use of land
within the GDA. By focussing public transport investment, and investment in the cycling and pedestrian
network, into the city centre, major suburban centres and hinterland growth towns, the Strategy will
complement national, regional and local planning policy by promoting and enabling the consolidation
of development into higher order centres… In terms of the provision of housing, the Strategy will
directly enable the sustainable development of strategically important residential sites, particularly in
Metropolitan Dublin, where demand is highest.”
Evaluation of Consistency
The application site is located within “Corridor-F (Arklow – Wicklow – Greystones – Bray –
Cherrywood – Dundrum – Dun Laoghaire – Dublin City Centre)”. There are multiple upgrades in this
area to both the DART and through bus connects all of which aim to create a modal shift to other
modes of transport other than reliance on cars.
This proposed development is in line with the ambitions of this policy, providing residential
development in a strategic location that will support the proposed public transport improvements.
19Regional Spatial and Economic Strategy 2019-2031
Under the Local Government Reform Act 2014 the Regional Planning Framework
has been revised with the previous Regional Authorities/Assemblies (ten in total)
now replaced with three Regional Assemblies. The Regional Authorities for the
Greater Dublin Area – The Dublin Region and the Mid-East Region - have been
replaced by the Eastern and Midland Regional Assembly.
The Regional Spatial and Economic Strategy (RSES) is a strategic plan and
investment framework to shape the future development of the eastern regional
to 2031 and beyond which is a new concept in Irish Planning tying spatial
planning to economic factors. The region covers nine counties, Longford,
Westmeath, Offaly, Laois, Louth, Meath, Kildare, Wicklow, and Dublin.
The RSES will support the implementation of Project Ireland 2040 – the National Planning Framework
(NPF) and National Development Plan (NDP). It addresses employment, retail, housing, transport,
water services, energy and communications, waste management, education, health, sports and
community facilities, environment and heritage, landscape, sustainable development and climate
change. The vision for the RSES is to create a sustainable and competitive region that supports the
health and wellbeing of our people and places, from urban to rural, with access to quality housing,
travel and employment opportunities for all.
Section 3.2 identifies that the Dublin Metropolitan Area (DMA) ‘covers the continuous built up city
area and includes the highly urbanised settlements of Swords, Malahide, Maynooth, Leixlip, Celbridge,
Bray and Greystones’ (emphasis added).
The Growth enablers for the DMA include ‘to realise ambitious compact development targets of at
least 50% of all new homes to be built, to be within or contiguous to the existing built up area of Dublin
city and suburbs and a target of at least 30% for other metropolitan settlements’.
Section 5.3 sets the Guiding Principles for the growth of the Dublin Metropolitan Area. Some of these
principles include:
• Compact sustainable growth and accelerated housing delivery - Promote sustainable
consolidated growth of the Metropolitan Area, including brownfield and infill development,
to achieve a target of at least 50% of all new homes within or contiguous to the existing built
up area in Dublin and at least 30% in other settlements. Support a steady supply of sites and
to accelerate housing supply in order to achieve higher densities in urban built up areas,
supported by improved services and public transport.
• Integrated transport and land use – To focus growth along existing and proposed high quality
public transport corridors and nodes and to support the delivery and integration of key public
transport projects including ‘BusConnects’, DART expansion and Luas extension programmes
and the Metro Link, along with better integration between networks.
• Increased employment density in the right places – Plan for increased employment densities
and suburbs and at other sustainable locations near high quality public transport nodes, near
third level institutes and existing employment hubs and to relocate less intensive employment
uses outside the M50 ring and existing built-up areas.
• Co-ordination and active land management - Enhance co-ordination across Local Authorities
and relevant agencies to promote more active urban development and land management
policies that help develop underutilised, brownfield, vacant and public lands.
The RSES along with the NTA and Local Authorities have developed Guiding Principles for Integration
of Land Use and Transport in the region. These include:
20• For urban-generated development, the development of lands within or contiguous with
existing urban areas should be prioritised over development in less accessible locations.
Residential development should be carried out sequentially, whereby lands which are, or will
be, most accessible by walking, cycling and public transport – including infill and brownfield
sites – are prioritised.
• The management of space in town and village centres should deliver a high level of priority
and permeability for walking, cycling and public transport modes to create accessible,
attractive, vibrant and safe, places to work, live, shop and engage in community life.
Accessibility by car does need to be provided for, but in a manner, which complements the
alternative available modes. Local traffic management and the location / management of
destination car parking should be carefully provided.
• Planning at the local level should prioritise walking, cycling and public transport by maximising
the number of people living within walking and cycling distance of their neighbourhood or
district centres, public transport services, and other services at the local level such as schools.
• Support the ’10 minute’ settlement concept, whereby a range of community facilities and
services are accessible in short walking and cycling timeframes from homes or accessible by
high quality public transport to these services in larger settlements.
• Cycle parking should be appropriately designed into the urban realm and new developments
at an early stage to ensure that adequate cycle parking facilities are provided.
• Support investment in infrastructure and behavioural change interventions to encourage and
support a shift to sustainable modes of transport and support the use of design solutions and
innovative approaches to reduce car dependency.
Metropolitan Area Strategic Plan Housing and Regeneration policy objective RPO 5.4 states that
“Future development of strategic residential development areas within the Dublin Metropolitan area
shall provide for higher densities and qualitative standards as set out in the ‘Sustainable Residential
Development in Urban Areas’, ‘Sustainable Urban Housing; Design Standards for New Apartments’
Guidelines’, and ‘Urban Development and Building Heights Guidelines for Planning Authorities’.”
Greystones has been identified, in Table 5.2, as having significant employment growth opportunities
with ‘the IDA strategic site’ in Greystones which will offer ‘an opportunity to strengthen the
employment base and reduce commuting pressures in North Wicklow.’
Evaluation of Consistency
The subject development seeks to provide for a residential development on a key development site
within the Greystones Settlement. This proposal will increase the population for the south of
Greystones and provide more housing choice in the area.
The proposal also includes a community enterprise centre which will enable people to set up and
grow businesses in Greystones. There is also a masterplan setting out a proposal for the
development of the remainder of the employment site.
This proposal is in line with the principles of a compact development with the housing and
employment within the site and walking and cycling distance of the wider Greystones area.
The layout of the proposed development prioritises pedestrian and cyclist permeability with several
pedestrian and cyclist access points into the subject site. Vehicular access and permeability are
limited which will help to maintain the priority for pedestrians and cyclists.
Overall, it is respectfully submitted that the proposed development is in accordance with the vision
and objectives of the RSES.
214. LOCAL PLANNING POLICY
The key provisions of local planning policy relating to the proposed development are set out in the
following sections. Reference is made to the following documents:
• The Wicklow County Development Plan 2016-2022
• The Greystones-Delgany and Kilcoole Local Area Plan 2013-2019
• Charlesland Action Plan
• Draft Charlesland Action Plan
An evaluation of the proposed development in terms of the relevant policy or policies is included
within each section.
Wicklow County Development Plan 2016-2022
The site is located within the administrative area of Wicklow County Council
and is therefore subject to the land use policies and objectives of the Wicklow
County Development Plan 2016-2022 (WCDP).
The subject site is located within the settlement area of Greystones-Delgany,
which is designated as a Level 3 Large Growth Town II within the
Metropolitan Area. These towns are described as ‘smaller in scale but strong
active growth towns, economically vibrant with high quality transport links
to larger towns/city.’ Greystones forms part of the
Bray/Cherrywood/Greystones Core Economic Area and it is an objective to
improve the rail track south of Bray to facilitate additional rail services.
The WCDP notes that the town has not been successful in attracting employment facilities and as a
result the employment of the population of the town commutes to other locations for employment.
It states that the town should aim to attract a concentration of major employment generating
investment and to be economically self-sustaining.
The aim is to grow the population of Greystones-Delgany from c. 17,208 in 2011 to c. 24,000 in 2028
(+6,792) with the associated growth in the number of houses by 3,501 units or 11.21% during this
period (WCDP Table 2.2 and Table 2.7). Table 2.8 Wicklow LAP Settlements – Housing and Zoning
Requirements identifies a shortfall of 1,267 units, highlighting a current shortfall of zoned land.
Table 2.11 outlines the employment growth targets for each settlement in the county. Between 2011
and 2028, the aim is to increase the jobs in Greystones-Delgany by 7%, the equivalent of 1,492
additional jobs in the area.
Key Policy Objectives
Housing
Below are the relevant county plan development management policies for housing and an evaluation
of the proposed development in terms of each policy.
Policy Objective Evaluation of Consistency
Policy HD2 requires new development to The proposed development will provide attractive
enhance residential amenity, provide for open spaces and high-quality varied house types. The
high living standards for occupants and buildings are located in such a way as to prevent any
not harm residential amenity for existing detrimental impact on the neighbouring properties.
residents.
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