Statement of Consistency with National and County Development Plan Planning Policy - In respect of Proposed Residential Development at Site at ...
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Statement of Consistency
with National and County Development Plan
Planning Policy
In respect of
Proposed Residential Development at Site at Balscadden Road & Former
Baily Court Hotel, Main St., Howth, County Dublin
Crekav Trading GP Limited
May 2018
STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
Table of Contents
1. Introduction ............................................................................................................................................. 5
2. National and Regional Planning Policy ..................................................................................................... 6
National Spatial Strategy (2002) ......................................................................................................................... 7
National Planning Framework – Ireland 2040 .................................................................................................... 8
Rebuilding Ireland; Action Plan for Housing and Homelessness (2016) ............................................................. 9
Schools .............................................................................................................................................................. 11
Density .............................................................................................................................................................. 12
Urban Design Manual – A Best Practice Guide (2009)...................................................................................... 14
Delivering Homes, Sustaining Communities (2008).......................................................................................... 20
Design Manual for Urban Roads and Streets (DMURS) (2013) ......................................................................... 22
Guidelines for Planning Authorities on Childcare Facilities (2001) ................................................................... 23
Smarter Travel – A Sustainable Transport Future: A New Transport Policy for Ireland 2009-2020 ................. 24
Guidelines for Planning Authorities on ‘The Planning System and Flood Risk Management (November 2009)’
.......................................................................................................................................................................... 25
Birds and Habitats Directive – Appropriate Assessment .................................................................................. 25
Appropriate Assessment of Plans and Projects in Ireland Guidance for Planning Authorities (2009) ............. 26
Draft Guidelines for Planning Authorities and An Bord Pleanála on carrying out Environmental Impact
Assessment (2012). ........................................................................................................................................... 26
Regional Planning Guidelines for the Greater Dublin Area (2010 – 2022) ....................................................... 26
Transport Strategy for the Greater Dublin Area 2016 - 2035 ........................................................................... 28
3. Local Planning Policy .............................................................................................................................. 29
Fingal County Development Plan 2017 – 2023 ................................................................................................. 29
Core Strategy & Settlement Strategy ............................................................................................................... 29
Development Strategy for Howth – Objectives for Howth ............................................................................... 32
Development Plan Zoning and Site Specific Local Objectives ........................................................................... 33
Compliance with Residential Development Policies of the Fingal County Development Plan ......................... 34
Energy Efficiency and Climate Change .............................................................................................................. 34
Design Principles ............................................................................................................................................... 34
Mixed Use and Vitality of Sustainable Communities ........................................................................................ 35
Housing Mix ...................................................................................................................................................... 36
Part V – Social Housing ..................................................................................................................................... 37
Residential Densities ......................................................................................................................................... 37
Apartment Development .................................................................................................................................. 37
Open Space ....................................................................................................................................................... 38
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CREKAV TRADING GP LIMITED MAY 2018
STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
Childcare Facilities ............................................................................................................................................ 39
Flood Risk .......................................................................................................................................................... 40
4. Development Management Standards (Chapter 12 of Fingal Development Plan) .................................. 41
Objective ....................................................................................................................................................... 42
AA Screening ................................................................................................................................................. 42
Detailed Design Statement ........................................................................................................................... 42
Public Art ...................................................................................................................................................... 42
Shopfronts/Signage ...................................................................................................................................... 42
Green Roofs For SUDS and Green Corridors ................................................................................................. 42
Utility Providers/ESB Substations ................................................................................................................. 43
Dual Aspect ................................................................................................................................................... 43
Floor to Ceiling Heights ................................................................................................................................. 43
Units per Core ............................................................................................................................................... 43
Minimum Gross Floor Areas ......................................................................................................................... 43
Floor Area Standards .................................................................................................................................... 43
Floor Plans indicating furniture .................................................................................................................... 43
Separation Distances/Overlooking/Overshadowing .................................................................................... 44
Daylight/Sunlight .......................................................................................................................................... 44
Sound Transmission ...................................................................................................................................... 44
Management Companies.............................................................................................................................. 44
Communal Facilities ...................................................................................................................................... 45
Communal Laundry/Storage ......................................................................................................................... 45
Bin Storage/Refuse ....................................................................................................................................... 45
Naming and Numbering................................................................................................................................ 45
Height and Massing ...................................................................................................................................... 45
Visual Harmony/Design ................................................................................................................................ 46
Residential Character .................................................................................................................................... 46
Open Space – Permeability ........................................................................................................................... 46
Open Space Quantity .................................................................................................................................... 46
Open Space – 10% of Site/Financial Contribution in lieu of shortfall ........................................................... 47
Access to Public Parks ................................................................................................................................... 47
Taking in Charge of Open Spaces .................................................................................................................. 47
Open Spaces within Management Companies ............................................................................................. 47
Playground Facilities ..................................................................................................................................... 48
Tree Policy/Planting Plan .............................................................................................................................. 48
Private Open Space – Apartments and Duplex ............................................................................................. 49
Private Open Space ....................................................................................................................................... 49
Roads - Design in accordance with DMURS and Traffic Impact Assessment ................................................ 49
Objective DMS128 & DMS130 ...................................................................................................................... 49
Car Parking Standards ................................................................................................................................... 50
Bicycle Parking Standards ............................................................................................................................. 50
Waste Management ..................................................................................................................................... 51
Lighting Plan ................................................................................................................................................. 51
Site Assessment ............................................................................................................................................ 51
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CREKAV TRADING GP LIMITED MAY 2018
STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
Archaeology .................................................................................................................................................. 52
Protected Structures..................................................................................................................................... 52
Architectural Heritage .................................................................................................................................. 52
Architectural Conservation Areas ................................................................................................................. 52
Signage in Architectural Conservation Area ................................................................................................. 52
Biodiversity ................................................................................................................................................... 53
Coastal Erosion ............................................................................................................................................. 53
Flooding ........................................................................................................................................................ 54
5. Conclusions ............................................................................................................................................ 55
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CREKAV TRADING GP LIMITED MAY 2018
STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
1. Introduction
1.1 On behalf of the prospective applicant, Crekav Trading GP Limited, this Statement of
Consistency with Planning Policy has been prepared to accompany a proposed
planning application in relation to a proposed strategic housing development at a c.
1.55 hectare (c.3.8 acres) site comprising a site located south of the Martello Tower
on Balscadden Road & the former Baily Court Hotel, Howth, County Dublin.
The development will consist of:
• The demolition of existing structures on site including the disused sports
building (c. 604 sq m) on the Balscadden Rd. Site and the Former Baily Court
Hotel Buildings on Main St (c. 2051 sq m) and a reduction in ground levels.
• Construction of 164 no. residential units in 3 no. separate apartment blocks
and 1 mews building, comprising 158 no. apartments and 6 duplexes which
includes 40 no. 1 bed units, 97 no. 2 bed units and 27 no. 3 bed units.
• Provision 397 no. bicycle parking spaces and a total of 120 no. car parking
spaces, which comprises 112 no. spaces in an underground basement in Block
C and 8 no. on-street parking spaces.
• Provision of commercial/retail space (c. 757 sqm), which includes a
community room (c. 161sqm), 2 no. retail units (c. 429sqm and c. 96sqm) and
a café (c. 71sq m).
• The main vehicular entrance to the scheme will be from Main Street to serve
the underground car park in Block C
• The scheme provides for a new linear plaza which will create a new
pedestrian link between Main St and Balscadden Rd to include the creation of
an additional 2 no. new public plazas and also maintains and upgrades the
pedestrian link from Abbey Street to Balscadden Road below the Martello
Tower. The public footpath on the opposite side of Balscadden Road will be
widened for the length of the site as part of the development.
• All other ancillary site development works, site services, a sub-station, public
lighting, plant, bin stores, bike stores, boundary treatments and landscaping;
• Commercial and retail signage (c. 75 sqm)
1.2 The final design has evolved through a lengthy collaborative process involving the
planning and various local authority departments and the Marlet Design Team,
including architecture, conservation as well as roads and drainage. The feedback from
An Bord Pleanala following our pre-planning meeting has necessitated design changes
to the development which been included in our final application.
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CREKAV TRADING GP LIMITED MAY 2018
STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
1.3 The scheme provides for a new town centre quarter, at an appropriate and efficient
residential density, a safe vehicular access arrangement, creation of new connections
between the village core and Balscadden Road through the provision of new
accessible streets and plazas which are accessible to all.
1.4 This statement of consistency with planning policy has been prepared to specifically
address the requirements of the strategic housing development guidance document
issued by An Bord Pleanala. This planning application is also accompanied by a
Planning Report which includes further details in respect of the proposed
development in relation to the site location and context, the development description
and the relevant planning history. The planning policy section is included below.
1.5 This standalone planning policy consistency statement, prepared by Marlet Property
Group Ltd., 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), and with local planning policy. It should be read in conjunction
with the accompanying detailed documentation prepared by CCK Architects, Murray
& Associates Landscape Architects and OCSC Consulting Engineers as well as specialist
input from conservation and archaeology.
1.6 For further details of consistency with the quantitative standards for residential units
as set down in the Apartment Guidelines 2015, the Quality Housing for Sustainable
Communities and the 2016-2022 Development Plan please refer to the Housing
Quality Assessment document prepared by CCK Architects.
2. National and Regional Planning Policy
2.1 The key provisions of national (including relevant Section 28 guidelines) and regional
planning policy as it relates to the proposed development is set out in the following
sections. The key policy and guidance documents of relevance to the proposed
development are as follows:
➢ National Spatial Strategy (2002);
➢ National Planning Framework 2040 (2018)
➢ Rebuilding Ireland; Action Plan for Housing and Homelessness (2016)
➢ Guidelines for Planning Authorities on Sustainable Residential Development in
Urban Areas (2009), and the accompanying Urban Design Manual;
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CREKAV TRADING GP LIMITED MAY 2018
STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
➢ Delivering Homes, Sustaining Communities (2008) and the accompanying Best
Practice Guidelines- Quality Housing for Sustainable Communities;
➢ Design Standards for New Apartments - Guidelines for Planning Authorities (March
2018)
➢ 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);
➢ Birds and Habitats Directive – Appropriate Assessment
➢ Guidance on Appropriate Assessment for Planning Authorities (2009)
➢ Draft Guidelines for Planning Authorities and An Bord Pleanála on carrying out
Environmental Impact Assessment (2012).
➢ Regional Planning Guidelines for the Greater Dublin Area (2010 – 2022);
➢ Greater Dublin Area Transport Strategy 2016-2035
National Spatial Strategy (2002)
2.2 The National Spatial Strategy (NSS) provides a broad planning framework for the
location of development in Ireland. The key objective of the National Spatial Strategy
is to provide an overarching planning framework for the Country and to result in the
achievement of more balanced regional development.
2.3 The NSS provides for increasing urbanisation of the population and achievement of
critical mass in large urban areas. The National Spatial Strategy (NSS) is a twenty-year
planning framework designed to achieve a better balance of social, economic, physical
development and population growth between regions.
2.4 One of the core objectives of the NSS is the consolidation of the Greater Dublin Area
(GDA) in a manner which protects local character and amenity through the
achievement of higher development densities at sustainable locations proximate to
public transport and services. The subject lands are located adjacent to the Bus Stop
for Dublin Bus into the City and c. 800m from Howth DART Station (10 minute walk).
The NSS supports the consolidation of the GDA in order to limit the spread of the GDA
into surrounding counties and to ensure the efficient operation of the public transport
system.
2.5 The proposed development seeks to deliver a new quarter for Howth Village, which is
designed to take account of the village grain and scale and will open up new streets
and plazas for the community. It provides for appropriate new residential
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CREKAV TRADING GP LIMITED MAY 2018STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
development which will help to promote local services & schools along quality
transport routes. As such the development of these lands is considered to be fully in
accordance with the recommendations of the National Spatial Strategy.
National Planning Framework – Ireland 2040
2.6 The Department of Housing Planning and Local Government, on behalf of the
Government, has recently published the National Planning Framework called Ireland
2040 Our Plan. The high-level objectives of the plan are as follows:
1. In addressing future change, Ireland will continue on a path of economic,
environmental and social progress that will improve our prosperity, sustainability and
well-being.
2. Ensuring that Ireland’s many unique assets can be built upon, with an emphasis on
improving economic output and stability as well as quality of life, environmental
performance and the liveability of Dublin, our cities, towns and rural areas.
3. Setting out likely future change in Ireland and the spatial pattern required for
effective and co-ordinated investment in a range of sectors to best accommodate and
support that change.
4. Putting in place a strategy for the sustainable development of places in Ireland and
how that can be achieved, through planning, investment and implementation.
In particular, the redevelopment of this zoned Town Centre/Residential site in Howth
Village would contribute to compact growth. The proposed development, would
ensure the much needed provision of residential units in an area and site that have
has not seen housing development for a substantial period.
It is submitted that the proposed development is consistent with the objectives of the
NPF in seeking to consolidate and densify an urban area proximate to primary
transport routes.
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CREKAV TRADING GP LIMITED MAY 2018STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
Rebuilding Ireland; Action Plan for Housing and Homelessness (2016)
2.7 In 2016, the
Government
launched Rebuilding
Ireland which
targeted solutions to
the ongoing supply
issues in the
residential sector in
the country. The
overarching aim of
this Action Plan is to
ramp up delivery of
housing from its
current under-supply
across all tenures to Figure 1: Five Pillars of the Rebuilding Ireland Action Plan
help individuals and
families meet their housing needs, and to help those who are currently housed to
remain in their homes or be provided with appropriate options of alternative
accommodation, especially those families in emergency accommodation.
This Plan sets ambitious targets to double the annual level of residential construction
to 25,000 homes and deliver 47,000 units of social housing in the period to 2021, while
at the same time making the best use of the existing housing stock and laying the
foundations for a more vibrant and responsive private rented sector. The five pillars
of the action plan are as follows:
The development proposed will directly contribute to Pillar 2 seeking to ‘Accelerate
Social Housing’, and Pillar 3 which seeks to ‘Build More Homes’.
159 no. residential dwellings are proposed in a wide mix of unit types and sizes to fit
a broad tenure demand. 10% of the units are proposed for transfer as social housing.
The scheme will therefore indirectly assist in Pillars 1 and 4 which seek to ‘Address
Homelessness’ and ‘Improve the Rental Sector’, respectively.
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CREKAV TRADING GP LIMITED MAY 2018STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas
(2009)
2.8 The role of the Guidelines for Planning Authorities on Sustainable Residential
Development in Urban Areas is to ensure the sustainable delivery of new development
throughout the country. The Guidelines focus on the provision of sustainable
residential development, including the promotion of layouts that:
➢ Prioritise walking, cycling and public transport, and minimise the need to use cars;
➢ Are easy to access for all users and to find one’s way around;
➢ Promote the efficient use of land and of energy, and minimise greenhouse gas
emissions;
➢ Provide a mix of land uses to minimise transport demand.
2.9 The Guidelines also provide guidance on the core principles of urban design when
creating places of high quality and distinct identity. The Guidelines recommend that
planning authorities should promote high quality design in their policy documents and
in their development management process. 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.
2.10 These Guidelines support a plan-led approach to development as provided for in the
Planning and Development Act 2000. Section 2.1 of the Guidelines note that ‘the scale,
location and nature of major new residential development will be determined by the
development plan, including both the settlement strategy and the housing strategy’.
2.11 The Guidelines reinforce the need to adopt a sequential approach to the development
of land and note in Section 2.3 and ‘the sequential approach as set out in the
Departments Development Plan Guidelines (DoEHLG, 2007) specifies that zoning shall
extend outwards from the centre of an urban area, with undeveloped lands closest to
the core and public transport routes being given preference, encouraging infill
opportunities…’.
2.12 Having regard to the above the subject site has been zoned to provide for residential
development having a Town Centre zoning on the former Baily Court Hotel site and a
Residential zoning on the Balscadden Road sites.
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CREKAV TRADING GP LIMITED MAY 2018STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
2.13 Sustainable neighbourhoods require a range of community facilities, and each
district/neighbourhood will need to be considered within its own wider locality, as
some facilities may be available in the wider area while others will need to be provided
locally.
Schools
2.14 Section 4.4 of the Guidelines relates to the provision of school spaces with large scale
residential development. It is respectfully submitted that there is a very good
provision of school places in this area of the County. The following 9 no. schools and
8 no. crèches are located within the Howth/Sutton/Dublin 13 area (within 5km from
the site):
Crèche/Montessori
1. Deerpark Montessori School
2. Bracken Hill Nursery School
3. Little Rainbows, Sutton
4. Rainbow Montessori, Sutton
5. Sutton Playgroup
6. The Cottage Montessori
7. Howth pre-school playgroup
8. Bumblebee Montessori & Childcare
Primary Schools
1. Howth primary school, Scoil Mhuire
2. Sutton Park School
3. St. Fintans National School
4. The Burrow, National School, Sutton
5. North Bay Educate Together
Secondary Schools
6. Santa Sabina Dominican College
7. St. Fintan’s High School
8. Pobalscoil Neasain
9. Saint Marys for Girls, Baldoyle
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CREKAV TRADING GP LIMITED MAY 2018STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
Density
2.15 The subject lands would be considered to be lands adjacent to ‘Public Transport
Corridors’ in the context of the densities required under the Guidelines for Planning
Authorities on Sustainable Residential Development in Urban Areas (2009), as the
lands are located within c. 1km of DART Station and the No. 31/A bus serves the site
hourly with a bus stop situated directly outside the development site.
2.16 Section 5.8 of the Guidelines recommends that ‘in general, minimum net densities of
50 dwellings per hectare, subject to appropriate design and amenity standards, should
be applied within public transport corridors, with the highest densities being located
at rail stations / bus stops, and decreasing with distance away from such nodes’.
2.17 The proposals for the lands is to provide for a net density of c. 106 units per hectare.
Thus, the proposed development of the subject lands would be consistent with the
guidelines in respect to residential density and regard to Government Guidelines and
the Development Plan policies, with a mix of apartments and commercial &
community space.
2.18 In addition to recommending appropriate densities, the Guidelines focus on the
provision of sustainable residential development, including the promotion of layouts
that:
➢ prioritise walking, cycling and public transport, and minimise car use;
➢ are easy to access for all users and to find one’s way around;
➢ promote the efficient use of land and of energy, and minimise greenhouse gas
emissions; and
➢ provide a mix of land uses to minimise transport demand.
➢ reduce traffic speeds in housing developments
2.19 The proposed development incorporates design principles such to reduce traffic
speeds with a no-through access road to eliminate the possibility of a rat-run. The
layout is highly accessible for all users, with a permeable layout both internally and
externally as new linkages are provided to surrounding land uses, with a new linear
plaza being opened up which will bring pedestrians directly from Howth Village to
Balscadden Road and the Howth SAAO lands. The layout is considered to be legible,
with a clear distinction in design, character and treatment.
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CREKAV TRADING GP LIMITED MAY 2018STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
2.20 The Guidelines also provide guidance on the core principles of urban design when
creating places of high quality and distinct identity. The Guidelines are accompanied
by a Design Manual 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.
2.21 In respect to pre-application consultations with the Planning Authority and An Bord
Pleanala the design team had regard to the advice set down in the ‘In Practice’ section
of the Urban Design Manual (2009), which recommends the following approach
Development Brief: An analysis of the site was carried out which included reviewing
the local development plan & framework plan, precedent, planning history, visual
impact assessment, utilities and services etc.
Site Analysis: The characteristics of the subject lands and surrounding context were
established and potential linkages and vistas to adjoining lands were analysed.
Concept Proposals: An initial proposal responding to the parameters established by
the development brief and site analysis was prepared describing aspects of the
scheme such as land use and density range, boundary conditions and connections.
Pre-planning: Pre-planning consultation is designed to respond to initial designs to
encourage an interactive process, particularly for sites in excess of approx. 50 units.
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CREKAV TRADING GP LIMITED MAY 2018STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
Extensive pre-planning consultation was undertaken consisting of a series of
preapplication consultations with the Planning Authority under Section 247. In
addition, separate informal consultations were undertaken with relevant personnel in
the Planning Authority to ensure all relevant matters have been addressed as part of
the pre-application process. A pre-planning meeting was held with An Bord Pleanala
and this application has been informed by the opinion received.
2.22 The above approach is reflected in the structure of the Conroy Crowe Kelly
Architectural Design Statement.
2.23 The Design Manual sets out a series of 12 criteria which it recommends should be used
in the assessment of planning applications and appeals. The 12 criteria are discussed
in detail below.
2.24 This planning application is accompanied by a Design Statement, prepared by CCK
Architects, which demonstrates how the proposed development has regard to and has
been developed in accordance with best practice in respect to urban design. The
Design Statement should be read in conjunction with this Statement of Consistency
and the Planning Report and with the plans and particulars accompanying this
planning application.
Urban Design Manual – A Best Practice Guide (2009).
2.25 The Design Manual sets out a series of 12 criteria which it recommends should be used
in the assessment of planning applications and appeals. The 12 no. criteria are listed
below, with a response to each provided, which should be read in conjunction with
the Design Statement.
Fingal County Development Plan states ‘To achieve good urban design in
developments, the 12 Urban Design Principles set out in the Urban Design Manual –
A Best Practice Guide (2009) should be taken into account in designing schemes. These
principles are: Context, Connections, Inclusivity, Variety, Efficiency, Distinctiveness,
Layout, Public Realm, Adaptability, Privacy/Amenity, Parking and Detailed Design.
Every area of the County is different, therefore the rules of good design should, in so
far as possible, respond to the characteristics, history and culture of a place to which
they are applied’.
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CREKAV TRADING GP LIMITED MAY 2018STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
2.26 Context: How does the development respond to its surroundings?
Response: As part of the preparation for the design for this project careful analysis
was carried out to identify the important urban characteristics of the area. The
proposal aims to provide a scheme design that creates a sustainable, liveable
community within a quality landscaped environment that will also be an attractive
addition and useful to Howth Village and environs. The development will be finished
in materials of a high-quality design which integrates sympathetically with
surrounding residential areas. The scheme has been designed with the Martello
Tower, a protected structure, in mind. The scheme is lower than the level of the
Martello Tower and provides for views from the top to the mound towards the church
steeple on Main St. The entire scheme has been designed in a 3-D context to take
account of the views towards Howth Village/Howth Head, which includes a detailed
design on the roof plan which provides for well-designed roof gardens. This view
across the roof gives visitors to the Martello Tower an appropriately designed green
roof vista, which adds to the views from the Mound.
The urban design of the scheme looks to take clues from the immediate context and
the site layout is structured around forming a new street and making new connections
between Howth Village and Balscadden Bay. The development encourages pedestrian
and cyclist movements through enhanced permeability and will result in a high quality
new residential neighbourhood.
The subject site is located in Howth Village which makes it accessible to a wide range
of shops, services and bus/DART routes to the city centre. It is well connected in terms
of public transport links. The proposed development has been designed to respond
positively to the existing residential developments surrounding.
2.27 Connections: How well is the new neighbourhood / site connected?
Response: The proposal adds to existing context by;
➢ Creating pedestrian links between Howth Village and Balscadden Road and
beach through a new linear plaza
➢ Providing an access route that is DMURS compliant to provide access for all.
➢ Creating 2 no. new public open space plazas to serve the proposed and existing
community.
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CREKAV TRADING GP LIMITED MAY 2018STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
➢ Providing a wide range of unit size to allow for a diverse community.
The proposed development will provide for a main vehicular access point from Main
St. which will serve the underground carpark under Block C. Emergency vehicles will
be able to traverse along the linear plaza to access the apartments located at the rear
of the scheme in case of emergency.
A pedestrian access routes is also provided from Abbey St. along the bottom of the
mound of the Martello Tower. This is currently an informal pedestrian route which is
not well managed. This footpath will be brought into the development site and will
be improved for universal access. Footpaths will be provided within the scheme rather
than along the roadway. On suggestion by the Roads Dept., we have set back our
scheme by 600mm from the road verge, which provides sufficient room to upgrade
the size of the existing footpath on the opposite side of Balscadden Road. This would
enable a footpath of 1.8m. As part of the scheme, safe pedestrian access crossing
points are provided where the internal footpaths meet Balscadden Road. These
proposals were agreed in conjunction with the Roads Dept and will enable safe and
legible connectivity to Balscadden Bay and the Howth SAAO. A letter of consent has
been proved by Fingal County Council to apply for the footpath widening on
Balscadden Road.
2.28 Inclusivity: How easily can people use and access the development?
Response: The main access point into the site is via the new vehicular, pedestrian
access road off Main St. It is proposed to provide a community building and
retail/commercial on the new block at Main St. This commercial space will wrap
around the ground floor of the building and will meet the new proposed plaza. On the
far side of the public plaza is a proposed new community building. This will make a
great addition for local people and will be very easily accessible. The street will not
be heavily trafficked and will be used only for access to underground car park in Block
C for the residents of the scheme. A new linear plaza is proposed through the site. At
the end of the street where it meets Balscadden Road, a café is proposed which will
have outdoor seating looking out onto a 2nd new plaza. This will be a new public space
which will face Balscadden Bay and its fantastic views.
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CREKAV TRADING GP LIMITED MAY 2018STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
2.29 Variety: How does the development promote a good mix of activities?
Response: The proposed development gives variety to the greater context of the
Howth Village by providing a higher density in an existing area that is predominately
made up of family houses with rear gardens.
This development fills the gap by providing apartment units aimed at smaller
households for which there is a great demand due to the changes in the demographics
of the area. Variety is provided within the development in terms of architecture
through a mix of unit types. The mix of unit types and sizes apartment ranging in size
from c. 50 sqm to 100 sqm and caters for a variety of demographics. Architecture
unity is ensured through the use of similar materials and finishes on all units.
It is considered that the proposed development provides for the necessary ancillary
land uses required for this large scale residential development, whilst having regard
to the significant range of community, commercial and social infrastructure in the
immediately surrounding area.
This scheme proposes a community room, a large retail/cafe space on ground of Block
A, 2 no. retail units on the ground floor of maisonette building facing civic plaza, &
café on the corner of Block C facing Balscadden Bay.
2.30 Efficiency: How does the development make appropriate use of resources, including
land?
Response: The development aims to maximise the potential of the site by both
conserving the views from the important areas of the landscape (Martello Tower and
Balscadden Road) and by increasing the density in Howth Village, an area which is fully
serviced with roads, piped infrastructure, public transport networks, schools, shops,
services, restaurants etc. The proposed density is 106 units per hectare.
The layout is designed to maximise natural sunlight, views and air into the open space.
The proposed density makes efficient use of these valuable residential/town centre
zoned lands and includes an appropriate quantum of public open space which will link
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CREKAV TRADING GP LIMITED MAY 2018STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
to the wider green network of Howth. The layout and orientation of the scheme has
been designed by CCK to have regard to aspect and views and ensure both dwellings
and areas of open space achieve light throughout the day.
2.31 Distinctiveness: How do the proposals create a sense of place?
Response: The proposed development will provide for a new quarter to Howth Village.
It will connect the village with Balscadden Bay and the Martello Tower. It will be open
an accessible to the public with proposed new civic plazas which will create a sense of
place for Howth Village and for residents of the new scheme. The residents of the
scheme will have a private area of open space which Block C has been designed around.
This is also true of Block B. The residents will have access to semi-private roof gardens
also. Native planting from the Howth SAAO species list is proposed in the planting
scheme along Balscadden Road and this will provide a soft buffer boundary treatment
along the Balscadden Road which is the main route to the SAAO lands.
2.32 Layout: How does the proposal create people-friendly streets and spaces?
Response: The layout allows for new pedestrian connections onto public plaza areas,
to Balscadden Bay and the Howth SAAO and The Martello Tower promoting
connectivity and accessibility through safe, overlooked footpaths.
A community building is providing on the new plaza off Main St. and a café is proposed
on the second plaza on Balscadden Road with the aim of drawing people into the space
and providing a friendly new quarter for all to enjoy. Furthermore, a large retail/café
is proposed in Block A which faces onto Main St. and will provide for a large type
restaurant/retail store.
2.33 Public Realm: How safe, secure and enjoyable are the public areas?
Response: The layout and design of the proposed development has been heavily
influenced by the level of security and overlooking obtained by the future residents.
The design of the development has been carefully considered as to provide a high level
of passive surveillance on areas of open space and publicly accessible areas. The
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CREKAV TRADING GP LIMITED MAY 2018STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
design of the dwellings provides for direct frontage onto all public areas ensuring the
provision of a safe, secure and enjoyable residential development. There will be
beautiful views of the sea and the Martello Tower as you pass down the new
pedestrian linear plaza to Balscadden Road. There will be improved access to the
tower with an upgraded pedestrian footpath at the base of the mound. The new civic
plaza at the junction with Main St. will be a great new addition to Howth Village.
2.34 Adaptability: How will the buildings cope with change?
Response: Each of the proposed dwellings meets or exceeds the minimum standards
for residential unit size. For schemes over 100 units, guidelines state that the majority
of apartments must exceed the minimum floor area by 10% . The size of the units are
proposed to be 1 bed x c.50-55sq m, 2 bed x 85 sq m, 3 bed 100 sq m, thus the
apartment sizes are compliant with the guidelines.
The development provides a mix of 1, 2 & 3 bedroom units that can be easily
reconfigured to adapt to the changing life cycles and personal needs of each resident.
2.35 Privacy / Amenity: How do the buildings provide a high quality amenity?
Response: Each dwelling is provided with an area of useable private open space which
meets or exceeds the Development Plan standards. All of the dwellings meet or
exceed the Section 28 Guidelines unit size requirements. The design of dwellings has
also had due regard to the siting and orientation of the development in order to
maximise the views of the sea, views onto open space, solar gain and natural light
aspect of each dwelling. The design of balconies maintains a high level of privacy and
amenity obtained by residents, and reduces the level of overlooking and
overshadowing.
Class 2 open space is provided through a number of well-designed public open space
and wide landscaped paths/plazas throughout the scheme (See Murray and Associates
drawings for detailed design of the open spaces). These spaces include the Main
Street Plaza and Balscadden Plaza, Linear Plaza, Martello Path and Plaza, Balscadden
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CREKAV TRADING GP LIMITED MAY 2018STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
Path South and Public Right of Way and Public Plaza. (See Murray & Associates
Drawing indicating this – Howth SHD_Open Space Areas). The layout is designed to
maximise natural sunlight, views and air into the open space.
2,686sqm of landscaped high amenity public open space is provided on site. 0.19 ha
Class 2 Open Space is required for the proposed development. There is a shortfall of
Class 1 Open Space. It is proposed to make a payment in lieu of Class 1 open space as
per Objective PM53 of the Development Plan.
2.36 Parking: How will the parking be secure and attractive?
Response: Parking is provided in an underground basement carpark under Block C. It
is designed to be secure and attractive.
2.37 Detailed Design: How well thought through is the building and landscape design?
Response: The proposed design of the development has been subject to a number of
pre-application consultations between the design team and the Planning Authority.
The design rationale from an urban design and architectural perspective is explained
in the Design Statement prepared by CCK. The landscape design rationale is set out in
the Landscape Design Statement prepared by Murray & Associates. We consider the
end result of this collaborative process is a well thought out design which addresses
the main concerns including relationship of the new scheme to the existing village’s
grain and scale, impact on views, impact on buffer of the Howth SAAO.
The proposed landscaping aims to enhance the amenity of the area by providing a
quality overall character and visual amenity in the development. Full details on the
rationale for the landscaping design can be found in the Landscape Design Report and
Landscape Plan prepared by Murrays.
Delivering Homes, Sustaining Communities (2008)
2.38 The Department’s policy statement Delivering Homes, Sustaining Communities,
Guidance provides the overarching policy framework for an integrated approach to
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CREKAV TRADING GP LIMITED MAY 2018STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
housing and planning. The statement notes that demographic factors will continue to
underpin strong demand for housing, which in turn will present considerable
challenges for the physical planning of new housing and the provision of associated
services. The quality of the housing environment is stated as being central to creating
a sustainable community.
2.39 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.
2.40 The Delivering Homes, Sustaining Communities policy statement is accompanied by
Best Practice Guidelines entitled ‘Quality Housing for Sustainable Communities’. The
purpose of these Guidelines is to promote high standards in the design and
construction and in the provision of residential and services in new housing schemes.
They encourage best use of building land and optimal utilisation 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 scheme 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.
2.41 This planning application is accompanied by a Housing Quality Assessment (HQA)
document prepared by CCK Architects which demonstrates the consistency of the
proposed development with the relevant standards in the Quality Housing for
Sustainable Communities document and the County Development Plan where
relevant.
Design Standards for New Apartments - Guidelines for Planning Authorities (March 2018)
2.42 The new Apartments Guidelines are also intended to promote sustainable housing, by
ensuring that the design and layout of new apartments provide satisfactory
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CREKAV TRADING GP LIMITED MAY 2018STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
accommodation for a variety of household types and sizes, including families with
children over the medium to long term.
2.43 This planning application is accompanied by a Housing Quality Assessment document,
prepared by CCK Architects which demonstrates the compliance of the proposed
development with the relevant quantitative standards required under the 2018
Apartment Guidelines. The HQA illustrates how each apartment meets or exceeds the
relevant standards for example in respect to apartment size, internal areas,
dimensions, private open space, dual aspect etc.
2.44 The proposed apartment buildings and units are considered to be suitability located
on the subject site, integrated within the landscape and well connected to adjacent
facilities including public transport, and will provide high quality residential
development on the subject site. In additional following pre-planning with An Bord
Pleanala, a decision was made to reduce the level of parking on the site in line with
National Guidance for sites located within a 10 minute walk of a DART Station. The
level of bicycle parking is in excess of Development Plan standards and complies with
the New Apartment Guidelines. A total of 397 no. bicycle parking spaces are provided
with the aim of promoting sustainable transport modes. In addition, it is proposed to
provide 3 no car sharing spaces in the underground basement for use by the residents.
Design Manual for Urban Roads and Streets (DMURS) (2013)
2.46 The Design Manual for Urban Roads and Streets (DMURS), 2013, 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. The Engineering Infrastructure Report, and
DMURS Statement of Compliance prepared by OCSC Consulting Engineers provides
further detail in respect of the compliance of the proposed development with DMURS.
2.47 DMURS aims to end the practice of designing streets as traffic corridors, and instead
focus on the needs of pedestrians, cyclists, and public transport users. The Manual
sets out design guidance and standards for constructing new and reconfiguring
existing urban roads and streets in Ireland. Incorporating good planning and design
practice and focus on the public realm, it also outlines practical design measures to
encourage more sustainable travel patterns in urban areas. The principle design
guidance of DMURS has been considered in the design of this development. The
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CREKAV TRADING GP LIMITED MAY 2018STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
proposed development seeks to prioritise pedestrian and cyclists throughout and
around the site in accordance with the policies set out in DMURS.
2.48 In line with DMURS and on the advice of An Bord Pleanala the linear plaza has been
created to replace a trafficked street. Surface car parking was also omitted. This has
created a wonderful pedestrian and cycle friendly urban environment within this new
proposed quarter of Howth Village.
2.49 Connectivity and permeability are encouraged throughout the development.
Pedestrian linkages in the form of a new linear plaza have also been proposed to
encourage and improve connectivity in the wider area.
2.50 DMURS also suggests that measures should be considered that reduce the dominance
of the vehicle in favour of pedestrian and cyclists having dominance within a street.
This is provided within the scheme, with local access provided and no through traffic
allowed which will encourage sustainable modes of transport.
2.51 The Design Manual for Urban Roads and Streets notes that drivers are more likely to
maintain lower speeds over shorter distances than over longer ones, therefore the
proposed road layout has been designed according to this principle.
Guidelines for Planning Authorities on Childcare Facilities (2001)
2.52 Guidelines for Planning Authorities on Childcare Facilities (2001) indicate that
Development Plans should facilitate the provision of childcare facilities in appropriate
locations. These include larger new housing estates where planning authorities
should require the provision of a minimum of one childcare facility with 20 places for
each 75 dwellings. The threshold for provision should be established having regard to
existing location of facilities and the emerging demography of the area where new
housing is proposed. Following a review of creches in the area and an assessment of
the requirement of the scheme, a childcare demand assessment was prepared which
concludes that a creche within the scheme would not be viable. It is proposed that
the community room could be used for a dual use, with mother and toddlers groups
being accommodation.
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CREKAV TRADING GP LIMITED MAY 2018STATEMENT OF CONSISTENCY SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH
Smarter Travel – A Sustainable Transport Future: A New Transport Policy for Ireland
2009-2020
2.53 The Government has committed in ‘Smarter Travel – A Sustainable Transport Future:
A New Transport Policy for Ireland 2009 – 2020’ to reducing the total share of car
commuting from 65% to 45%, a rise in non-car trips by 55% and that the total vehicle
miles travelled by the car fleet will not increase. The key targets are as follows:
Future population employment growths will predominantly take place in sustainable
compact forms which reduces the need to travel for employment and services;
➢ 500,000 more people will take alternative means to commute to work to the
extent that the total share of car commuting will drop from 65% to 45%;
➢ Alternatives such as walking, cycling and public transport will be supported and
provided to the extent that these will rise to 55% of total commuter journeys to
work;
➢ The total kilometres travelled by the car fleet in 2020 will not increase significantly
from current levels;
➢ A reduction will be achieved on the 2005 figure for Greenhouse gas emissions from
the transport sector.
2.54 Key to the achievement of these targets is better alignment between land-use and
transport to minimise travel demand. The subject site is located within a 10 minute
walk from Howth DART station and is also served by Dublin Bus services. There are
QBC’s located along the Howth Road and along the Clontarf Road from Raheny into
the City Centre. Thus, the principle of a residential development at a density in excess
of 35 units per hectare in this location would be in accordance with the principles set
down in Smarter Travel.
It is proposed to provide c. 0.7 spaces per residential unit based on the high level of
public transport available to the residents of the scheme. This is in keeping with the
principles of Smarter Travel. As mentioned previously, 397. No bicycle parking spaces
will be provided which is in excess of Development Plan Standards.
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