STATEMENT OF RESPONSE TO AN BORD PLEANÁLA'S CONSULTATION OPINION - Newtownpark Avenue ...
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STATEMENT OF RESPONSE TO
AN BORD PLEANÁLA’S CONSULTATION OPINION
PREPARED FOR
PREPARED BY
39 Fitzwilliam Place, Dublin 2
Telephone: (01) 662 5803
E-mail info@johnspainassociates.com
IN RESPECT OF A
PROPOSED RESIDENTIAL DEVELOPMENT AT
LANDS AT NEWTOWNPARK AVENUE, BLACKROCK,
CO. DUBLIN
DECEMBER 2020
December 2020 Statement of Response to An Bord Pleanála Opinion
DOCUMENT CONTROL SHEET
TABLE OF CONTENTS
Client: Glenveagh Homes Ltd
1.0 INTRODUCTION ........................................................................................................................1
2.0 STATEMENT OF RESPONSE TO SPECIFIC INFORMATION REQUIRED ...............................2 Project Title: Cluain Mhuire SHD
2.1 ITEM NO. 1 – DESIGN AND HEIGHT ........................................................................................2 Document Title: Statement of Response to An Bord Pleanàla’s Consultation Opinion
2.2 ITEM NO. 2 LEGIBILITY AND PERMEABILITY.........................................................................4
Document No: 19147ABPOR
2.3 ITEMS NO. 3 AND 4 LANDSCAPE MASTERPLAN AND DETAIL ............................................5
2.4 ITEM NO. 5 – TRANSPORTATION ............................................................................................9
Rev. Status Author(s) Reviewed By Approved By Issue Date
2.5 ITEM NO. 6 – DRAINAGE AND SURFACE WATER..................................................................9
2.6 ITEM NO. 7 – TAKING IN CHARGE...........................................................................................9
DV1 DV1 NR MN RK 01-10-2020
2.7 ITEM NO. 8 – CHILDCARE FACILITY .......................................................................................9
2.8 ITEM NO. 9 – BUILDING LIFE CYCLE .................................................................................... 10 F01 F01 MN JS MN 16-12-2020
2.9 ITEM NO. 10 – HOUSING QUALITY ASSESSMENT ............................................................... 10
3.0 CONCLUSIONS ....................................................................................................................... 10
LIST OF FIGURES
Figure 2.1 – Site Layout showing relationship to adjoining properties .............................................2
Figure 2.3 – CGIS View of Blocks C and D within the site ..................................................................3
Figure 2.4 –Aerial view of the site looking north .................................................................................3
Figure 2.5 – View of the entrance of the site from Newtownpark Avenue .........................................4
Figure 2.6 – View towards the site from (and including) St Catherine’s............................................4
Figure 2.6 – Proposed connections to the boundary of the subject site ...........................................5
Figure 2.7 – Tree Location Plan showing trees to be retained and planted ......................................6
Figure 2.3 – Landscape Masterplan .....................................................................................................8
Figure 2.9 – Proposed Pedestrian Crossing as shown below ............................................................9
Figure 2.10 – Extract from P1050 - Taking in Charge Plan .................................................................9
John Spain Associates Planning & Development Consultants
i
December 2020 Statement of Response to An Bord Pleanála’ Opinion
1.0 INTRODUCTION • “Additional transportation details for the site having regard to the requirements of the
Transportation Planning Division as indicated in their report, dated 07th May 2020, contained in
1.1 The pre-application consultation opinion from An Bord Pleanála in relation to the proposed Appendix B of the Planning Authorities Opinion.”
strategic housing development at lands to the rear of Cluain Mhuire, Newtownpark Avenue,
Blackrock, Co. Dublin was received on the 14th July 2020 (case reference no. ABP-307088-20). • “Additional drainage details for the site having regard to the requirements of the Drainage Division
as indicated in their report contained in Appendix B of the Planning Authorities Opinion.”
1.2 The opinion states that An Bord Pleanála “has considered the issues raised in the pre-application
consultation process and, having regard to the consultation meeting and the submission of the • “A site layout plan showing which, if any, areas are to be taken in charge by the planning authority.”
planning authority, is of the opinion that the documents submitted with the request to enter into
consultations constitute a reasonable basis for an application for strategic housing development.” • “Further justification for non-provision of childcare facility, including childcare demand analysis
and likely demand for childcare places resulting from the proposed development.”
1.3 Article 285(5)(b) of the Planning and Development (Strategic Housing Development) Regulations
2017 states: • “A Building Life Cycle Report in respect of the proposed apartments as per section 6.13 of
Sustainable Urban Housing: Design Standards for New Apartments- Guidelines for Planning
‘(5) At the conclusion of a pre-application consultation, the Board may do either or both of the Authorities (2018)
following: (b) notify the prospective applicant that specified information should be submitted with
any application for permission for the proposed development, including photographs, plans, maps, • “A housing quality assessment which provides specific information regarding the proposed
drawings or other material or particulars and, where the Board considers it appropriate, either or apartments and which demonstrates compliance with the various requirements of the 2018
both—’. Guidelines on Design Standards for New Apartments, including its specific planning policy
requirements. This should also include a schedule of floor areas for all proposed units, clearly
1.4 The pre-application consultation opinion from An Bord Pleanála states pursuant to Article setting out the aspect (single, dual, triple) of each unit.”
285(5)(b) that the following specific information should be submitted with any application for
permission: 1.5 A detailed response to each of the points raised above has been provided within this response
report and has been included as part of the planning application documentation.
• “Further consideration and/or justification of the documents as they relate to the height and design
strategy. In this regard, the prospective applicant should satisfy themselves that the design 1.6 The Opinion from the Board also notes that:
strategy for the site as it relates to height provides the optimal architectural solution for this site
and should submit a rationale/justification for the heights/setbacks proposed. CGIs, visualisations “Pursuant to article 285(5)(a) of the Planning and Development (Strategic Housing Development)
and cross sections, as necessary, should be submitted which clearly show the relationship Regulations 2017, the prospective applicant is informed that the following authorities should be
between the proposed development and existing development in the immediate and wider area notified in the event of the making of an application arising from this notification in accordance
and which illustrates the topography of the area. Details should also include interactions with with section 8(1)(b) of the Planning and Development (Housing) and Residential Tenancies Act
nearby Protected Structures, Cluain Mhuire and St. Catherine’s, and their associated lands; 2016:”
boundary treatments and public realm. 1. Irish Water;
2. Department of Culture, Heritage and the Gaeltacht;
The proposed development shall have regard to inter alia, national policy including the National 3. Transport Infrastructure Ireland;
Planning Framework and Sustainable Urban Housing: Design Standards for New Apartments 4. National Transport Authority;
(March 2018) and local planning policy, the site’s context and locational attributes. 5. An Taisce-the National Trust for Ireland;
6. Heritage Council;
Furthermore, the applicant is advised that an appropriate statement in relation to section 8(1)(iv) 7. Failte Ireland;;
of the Planning and Development (Housing) and Residential Tenancies Act 2016, that outlines 8. An Comhairle Ealaionn
consistency with the relevant development plan and that specifically addresses any matter that 9. Dun Laoghaire Rathdown County Childcare Committee.
maybe considered to materially contravene the said plan, if applicable, should be submitted.”
1.7 With reference to the above, the above Authorities have been sent a copy of the SHD application.
• “Further consideration of cycle and pedestrian connections including legibility and permeability
through the development site to lands at Dunardagh and other surrounding areas. A layout plan
highlighting such connections should be provided.”
• “Landscaping proposals including an overall landscaping masterplan for the development site and
a site layout plan indicating the full extent of tree retention and removal.”
• “Details pertaining to the quantity, type and location of all proposed hard and soft landscaping
including details of play equipment, street furniture including public lighting and boundary
treatments.”
John Spain Associates 1 Planning & Development Consultants
December 2020 Statement of Response to An Bord Pleanála’ Opinion
2.0 STATEMENT OF RESPONSE TO SPECIFIC INFORMATION REQUIRED Figure 2.1 – Site Layout showing relationship to adjoining properties
2.1 The following sets out how the applicant has addressed the Board’s request for additional
information in respect of the proposed development.
2.1 Item no. 1 – Design and Height
2.2 Item 1 of the An Bord Pleanála opinion relates to the design and height regarding the relationship
between the proposed development and the existing developments, protected structures and
topography.
2.3 Item no. 1 states:
“Further consideration and/or justification of the documents as they relate to the height and design
strategy. In this regard, the prospective applicant should satisfy themselves that the design
strategy for the site as it relates to height provides the optimal architectural solution for this site
and should submit a rationale/justification for the heights/setbacks proposed.”
“CGIs, visualisations and cross sections, as necessary, should be submitted which clearly show
the relationship between the proposed development and existing development in the immediate
and wider area and which illustrates the topography of the area. Details should also include
interactions with nearby Protected Structures, Cluain and St. Catherine’s, and their associated
lands; boundary treatments and public realm.”
“The proposed development shall have regard to inter alia, national policy including the National
Planning Framework and Sustainable Urban Housing: Design Standards for New Apartments
(March 2018) and local planning policy, the site context and locational attributes. Furthermore, the
applicant is advised that an appropriate statement in relation to section 8(1)(iv) of the Planning
and Development (Housing) and Residential Tenancies Act 2016, that outlines consistency with
the relevant development plan and that specifically addresses any matter that maybe considered
to materially contravene the said plan, if applicable, should be submitted.”
2.1.1 Height and Design
2.4 In response to this item, a detailed Architectural Design Report has been prepared by Henry J
Lyons and accompanies this application. The report includes justification and details of the design
rationale and layout for the proposed development. Sections are also provided showing the
relationship with adjoining development.
2.5 The subject site is an infill site located adjacent to Cluain Mhuire Family Centre and St Catherine’s
both of which are protected structures. The site also adjoins the Guardian Angels National School
to the south and existing residential dwellings to the east and north. The infill nature of the site
and the sensitivity of the adjoining land uses required careful consideration in this regard. The
proposed scheme as submitted has been designed to include appropriate setbacks from the
existing residences and protected structures as illustrated below;
John Spain Associates 2 Planning & Development Consultants
December 2020 Statement of Response to An Bord Pleanála’ Opinion
2.6 The proposed building heights have been designed to directly correspond with the topography of ‘In conclusion, the assessment found that the development would have no negative landscape
the site. The fall from north to south across the site is approximately 3.6m. This is based on the or visual effects and it can be considered an appropriate intervention in the evolving landscape
existing site levels with the highest point being to the north east of Block D (+24.400). The lowest of Blackrock.’
point is to the south west of Block B (+20.800). Accordingly, the proposed building heights across
the site step from 5 storeys at Block B (the lowest point), 4- 5 storeys at Block C and down to 2-3 Figure 2.2 – CGIS View of Blocks C and D within the site
storeys at Block E. The transition from 3 storeys to 4 storeys (Block E to Block D at the north of
the site) is considered a suitable design response considering the massing of the buildings in the
context of the protected structures. Block E contains duplex units stepping from 2 to 3 storeys in
height directly responding to the adjoining single and 2 storey residences located to the east.
2.7 Block C and D reach 4 to 5 and 5 storeys respectively at the centre of the site. The buildings have
been carefully placed to allow for the retention of as many as possible of the existing trees onsite,
including an additional Category A tree when compared to the extant permission on the site and
the proposal as submitted to an Bord Pleanála for pre-application consultation (see Figure 2.3
below). We note the redesign of the basement and road layout within the site to accommodate
additional tree retention onsite when compared to the proposal submitted at pre-application stage.
2.8 As illustrated in the Architectural Design Report increased building massing and/or height, over
and above which is now proposed, was not considered suitable at this location given the need to
protect views to and from the adjoining protected structures at the centre of the site. It is
considered that the proposed design is the optimal solution for the subject lands, having regard to
the site’s characteristics and the proximity of adjoining structures.
2.9 Block B to the south west of the site reaches 5 storeys in height. A similar exercise was conducted
in this regard following the Board’s opinion and the design team concluded that given the proximity
to the existing school additional height was not considered suitable at this location. The proposal
as presented meets all required BRE guidance in terms of solar access, overshadowing and
daylight access. Additional building massing would not be considered suitable in light of the
Figure 2.3 –Aerial view of the site looking north
sensitive location of adjoining protected structures, the need to retain Category A trees on the site
and to respect and ensure the privacy of the existing dwellings on Newtownpark Avenue.
2.10 We also refer the Board to the extant permission (Reg. Ref. D15A/0036,ABP PL06D.245945) on
the site for 48 units which includes a density of 36 units per ha and maximum building height of 3
storeys. The subject scheme has been carefully considered given the location of the site c. 1km
from Seapoint DART station and national policy guidance, including the National Planning
Framework and Sustainable Urban Housing: Design Standards for New Apartments (March
2018), Urban Development and Building Heights Guidelines for Planning Authorities December
2018 and local planning policy. Accordingly, the design team and the applicant respectfully submit
that the scheme as proposed and the increase in density, compared to the extant permission, is
entirely appropriate in terms of height, scale and massing in the sensitive context of the subject
site.
2.11 To conclude, given the sensitive nature of the surrounding protected structures, the need to retain
protected views and vegetation on the site and the constrained nature of the site in terms of the
interface with adjoining lower density residential development, the proposed density, design and
building heights as proposed on site are considered suitable for the site context and location and
that the architectural design solution, has had regard to the context as well as national strategic
guidance in promoting sustainable densities, in proximity to public transport.
2.1.2 CGIs and Visualisation
2.12 We also refer to the CGIs and visualisations prepared by Modelworks which accompany the
subject application. Verified Views have also been prepared and are addressed within the
Landscape and Visual Impact Statement prepared by Modelworks which concludes;
John Spain Associates 3 Planning & Development Consultants
December 2020 Statement of Response to An Bord Pleanála’ Opinion
Figure 2.4 – View of the entrance of the site from Newtownpark Avenue 2.1.3 Material Contravention Statement
2.13 In addition, we refer the Board to the Statement of Material Contravention prepared by John Spain
Associates. The statement includes a suitable justification (in accordance with the provisions
under Section 37(2)(b) of the Planning and Development Act 2000) for the proposed height of the
scheme which exceeds the maximum 4 storey height as set out in the Blackrock Local Area Plan
2015-2021 (as extended).
2.14 The statement includes a detailed assessment of the proposal in relation to the requirements of
the Urban Development and Building Height Guidelines (2018) (the guidelines) and the National
Planning Framework. Specifically, we note the guidelines state;
“to meet the needs of a growing population without growing out urban areas outwards requires
more focus in planning policy and implementation term on reusing previously developed
“brownfield” land, building up urban infill sites (which may not have been built on before)
and either reusing or redeveloping existing sites and buildings that may not be in the optimal usage
or format taking into account contemporary and future requirements”.
2.15 The subject application meets this requirement. The statement also specifically addresses the
criteria under SPPR 3 of the guidelines and conclude;
“the proposed building heights are considered appropriate for the subject site and meet the
requirements of the development management criteria in the Guidelines.”
2.16 The statement concludes;
“As set out in Section 37(2)(b) and Section 28(1)(C) of the Planning and Development Act 2018
Figure 2.5 – View towards the site from (and including) St Catherine’s (as amended), An Bord Pleanála may materially contravene a development plan where national
planning policy objectives take precedence. In particular, under Section 9(3)(b) of the 2016 Act,
as amended, provides that to the extent that they differ from the provisions of the Development
Plan or Local Area Plans, the provisions of SPPRs must be applied instead. In the present context
the most relevant of these requirements SPPR 3A of the Building Height Guidelines which applies
to the assessment of this application to the Board. It is submitted that the performance criteria
under Section 3.1 and 3.2 have been satisfied in this regard by the development as proposed.
It is respectfully submitted that should An Bord Pleanála consider the proposed development is a
material contravention of the Dun Laoghaire Rathdown County development Plan 2016-2022 and
the Blackrock Local Area Plan 2015-2021, an appropriate justification is set out within this
statement demonstrating that the proposed development should be considered for increased
building heights and density due to the location of the subject site, the overall context of the wider
development, adjacent to high-quality public transport corridors, and the policies and objectives
set out within the Urban Development and Building Heights Guidelines 2018.”
2.2 Item no. 2 – Legibility and Permeability
2.17 Item no. 2 seeks:
“Further consideration of cycle and pedestrian connections including legibility and permeability
through the development site to lands at Dunardagh and other surrounding areas. A layout plan
highlighting such connections should be provided.”
2.18 Cycle and pedestrian connections are provided within the site in accordance the Blackrock Local
Area Plan 2015 – 2021 (as extended). A future potential pedestrian, cycle and vehicle connection
is provided to the boundary of the subject site at the south-west of the site, which will allow for
Source: Modelworks
connectivity through to the adjoining boundary of St Catherine’s (Dunardagh) when it is developed.
John Spain Associates 4 Planning & Development Consultants
December 2020 Statement of Response to An Bord Pleanála’ Opinion
The connection is proposed to the boundary wall and to be implemented upon redevelopment of Figure 2.6 – Proposed connections to the boundary of the subject site
St Catherine’s, as envisaged by the Blackrock LAP 2015-2021. We note that the Traffic and
Transport Assessment by DBFL Consulting Engineers includes a Sensitivity Analysis including
the future potential traffic movements through the site as a result of this connection and future
potential development at Dunardagh. The proposed road has been designed accordingly and the
analysis found that:
‘The results of the sensitivity analysis therefore indicate that with the addition of the development
traffic arising from the potential future development of the lands to the west of Cluain Mhuire, the
proposed priority controlled access junction onto Newtownpark Avenue continues to operate
within capacity with minimal delays.’
2.19 A second future pedestrian and cycle connection will also be provided to the north of the site which
can connect through to St Catherine’s (Dunardagh), when it is developed (as indicated in the
Blackrock LAP). It is provided to the site boundary as part of the subject proposal. In addition, a
vehicle access point for staff is provided through to Cluain Mhuire, adjacent to the main entrance
to the subject site from Newtownpark Avenue. This access point will be used by staff only and will
be maintained throughout the construction phase of the development. This access arrangement
was provided for in the extant permission and was agreed with the HSE and the applicant as part
of the sale of the lands.
2.3 Item nos. 3 and 4 – Landscape Masterplan and Detail
2.20 Items no. 3 and 4 and seek:
• “Landscaping proposals including an overall landscaping masterplan for the development site and
a site layout plan indicating the full extent of tree retention and removal.”
• “Details of proposed tree protection measures during construction. Details pertaining to the
quantity, type and location of all proposed hard and soft landscaping including details of play
equipment, street furniture including public lighting and boundary treatments should be
submitted.”
2.21 In response to the above we refer the Board to The Landscape Design Statement and
accompanying drawings prepared by NMP Landscape Architects. We also refer the Board to the
Arboricultural Assessment prepared by Charles McCorkell which includes a tree removal (Drawing
No. 190911-P-11) and protection plan (Drawing No. 190911-P-12) and details on tree protection
measures to be implemented during construction.
John Spain Associates 5 Planning & Development Consultants
December 2020 Statement of Response to An Bord Pleanála’ Opinion
2.22 Hard and soft landscape treatment proposals are included at Drawing nos. 901 – 903 of the Figure 2.7 – Tree Location Plan showing trees to be retained and planted
landscape drawings pack. The landscape strategy aims to integrate the new development with
the existing landscape context through a significant planting scheme on the site. Replacement of
existing trees on the site which must be removed due to the presence of Japanese knotweed is
required. A survey carried out by Enviroguide Consulting (see accompanying Ecological Impact
Assessment Report (EcIA)) has identified the continued presence of the invasive species at the
site.
2.23 Following extensive analysis, excavation of the knotweed is recommended by Enviroguide. This
approach will provide for the removal of the species and the future well-being of new planting on
the site.
2.24 An Invasive Species Management Plan for the removal of the species is included in the EcIA. The
assessment notes that herbicides are not considered a suitable method of treatment in this
instance as construction will commence immediately on the grant of planning permission.
Herbicide removal takes a minimum of three to four years to successfully complete. We also note
that the country is experiencing a housing shortage and it is not feasible to delay commencement
of construction (by 3 to 4 years to allow for the herbicide treatment method) and therefore
excavation of the Japanese Knotweed from the site is required. The proposed excavation
methodology is the more efficient method of removal.
2.25 The presence of the knotweed on the site has influenced the landscape proposal for the scheme.
In order to ensure the success of new planting, the Japanese knotweed must be totally removed.
Extensive new planting is proposed throughout the site.
2.26 This is further incorporated into the documentation prepared by NMP which illustrates tree
retention and a proposed planting scheme for the site (as illustrated at Figure 2.7 below). We also
refer to the public lighting plan prepared by Waterman Moylan Engineering Consultants. Full
details are included on above items as required.
John Spain Associates 6 Planning & Development Consultants
December 2020 Statement of Response to An Bord Pleanála’ Opinion Figure 8 – Extract - Tree Protection Plan including proposed site services John Spain Associates 7 Planning & Development Consultants
December 2020 Statement of Response to An Bord Pleanála’ Opinion Figure 2.9 – Comparison drawing showing the pre-application proposal and amendments made to address the ABP Opinion John Spain Associates 8 Planning & Development Consultants
December 2020 Statement of Response to An Bord Pleanála’ Opinion
2.4 Item no. 5 – Transportation 2.6 Item no. 7 – Taking in Charge
2.27 Item no. 5 of the An Bord Pleanála opinion states: 2.31 Item no. 7 seeks:
“Additional transportation details for the site having regard to the requirements of the “A site layout plan showing which, if any, areas are to be taken in charge by the planning authority.”
Transportation Planning Division as indicated in their report, dated 07th May 2020, contained in
Appendix B of the Planning Authorities Opinion.” 2.32 In response to this item we refer the Board to the enclosed Taking in Charge Plan (Drawing No.
P1050) by Henry J Lyons Architects (showing the areas to be taken in charge in turquoise) with
2.28 A detailed response to this item is included within Section 4.4 of the accompanying Traffic and an extract shown below;
Transport Assessment prepared by DBFL Consulting Engineers. A Mobility Management Plan
has also been prepared by DBFL and accompanies the application. We also note the provision of Figure 2.11 – Extract from P1050 - Taking in Charge Plan
a Toucan crossing on Newtownpark Avenue as requested by the Council Transportation Division
as shown below;
Figure 2.10 – Proposed Pedestrian Crossing as shown below
Proposed Toucan Crossing as
required by DLR COCO
Source: HJL
Source: DBFL 2.7 Item no. 8 – Childcare Facility
2.5 Item no. 6 – Drainage and Surface Water 2.33 Item no. 8 is seeking:
2.29 Item no. 6 (i) of the An Bord Pleanála opinion states: “Further justification for non-provision of childcare facility, including childcare demand analysis
and likely demand for childcare places resulting from the proposed development.”
“Additional drainage details for the site having regard to the requirements of the Drainage Division
as indicated in their report contained in Appendix B of the Planning Authorities Opinion.” 2.34 We refer the Board to the enclosed Creche Needs Assessment prepared by John Spain
Associates. The report demonstrates that there is sufficient capacity in the area to accommodate
“Any surface water management proposals should be considered in tandem with any Flood Risk the minimal demand that will be generated by the subject proposal. The demand does not give
Assessment, which should in turn accord with the requirements of The Planning System and Flood rise to a commercially viable creche unit and it is considered that there is sufficient provision is the
Risk Management including associated technical Appendices.” locality in this regard. The assessment concludes;
2.30 A detailed response to this item is included at Section 3 of the Infrastructure Design Report “JSA contacted the DLR County Childcare Committee to seek information on creche provision in
prepared by DBFL Consulting Engineers. The response addresses each of the items raised in the the area. The DLRCCC indicated that they did not have information on capacity or
Council’s report. numbers. While they considered that from a policy perspective a creche may be required, the
creche demand assessment, has demonstrated that there are 17 no. creche operators in the
John Spain Associates 9 Planning & Development ConsultantsDecember 2020 Statement of Response to An Bord Pleanála’ Opinion
area. Seven of the operators did not provide information on childcare numbers, but the remaining 3.2 The document also addresses the specific information requested by An Bord Pleanála and
11 no. childcare providers indicated c. 610 childcare places and a vacancy of c. 24 places in the identifies the source or location of the response within the planning submission documentation.
environs of the subject site. Additional childcare capacity in the area would accrue from the 6 no.
childcare operators which did not provide information. In addition, the St. Teresa’s SHD included 3.3 The relevant prescribed authorities identified in the pre-application consultation opinion from An
c. 47 no. childcare places, which would further add to overall capacity in the area. Bord Pleanála have also been notified of the submission of the planning application in accordance
with Section 8(1)(b) of the Planning and Development (Housing) and Residential Tenancies Act
Having regard to the proposed nature of the mix of the proposed development, that even if all of 2016.
the 2 and 3 bedroom apartments required childcare places, (a 21 place requirement) they could
be accommodated within the existing spare capacity from the JSA survey (which equated to c. 3.4 The layout and design changes incorporated into the final scheme will result in improvements to
24 places). The proposal would comprise (assuming all 2 and 3 bed units in assessment) just the overall design and layout and will provide a sustainable approach to the development of these
3.3% of childcare places in the area (of 11 operators who gave information) and is likely to be lands. It is respectfully submitted that the proposed development is consistent with the proper
lower if remaining 6 no. operators provided detail on childcare numbers. Having regard to the planning and sustainable development of the area, and is consistent with all relevant national,
QNHS Survey, the actual demand is anticipated to be significantly below the 21 no. places and regional and local planning policies and guidelines and respectfully request that An Bord Pleanála
is considered to be as low as 3 no. places (c. 25% of pre-school children) of the overall population grants permission for the proposed development.
equivalent (216 population 80 x 2.7).”
2.35 Notwithstanding, should the Board feel that creche provision is required on the site, it is
respectfully requested that this may be addressed by way of condition. We note there is sufficient
area within the concierge/reception building to accommodate the same should this be necessary.
2.8 Item no. 9 – Building Life Cycle
2.36 Item no. 9 is seeking:
“A Building Life Cycle Report in respect of the proposed apartments as per section 6.13 of
Sustainable Urban Housing: Design Standards for New Apartments- Guidelines for Planning
Authorities (2018).”
2.37 A Building Life Cycle Report prepared by Henry J Lyons Architects in respect of the Sustainable
Urban Housing: Design Standards for New Apartments- Guidelines for Planning Authorities is
enclosed with this application.
2.9 Item no. 10 – Housing Quality Assessment
2.38 Item no. 10 is seeking:
“A housing quality assessment which provides specific information regarding the proposed
apartments and which demonstrates compliance with the various requirements of the 2018
Guidelines on Design Standards for New Apartments, including its specific planning policy
requirements. This should also include a schedule of floor areas for all proposed units, clearly
setting out the aspect (single, dual, triple) of each unit.”
2.39 In response to this item a Housing Quality Assessment (HQA) prepared by Henry J Lyons
Architects accompanies this application submission. The HQA demonstrates full compliance with
the Guidelines on Design Standards for New Apartments as required.
3.0 CONCLUSIONS
3.1 This document outlines how the items outlined in the pre-application consultation opinion from An
Bord Pleanála in relation to the proposed residential development at lands adjacent and to the
rear of Cluain Mhuire Family Centre have been addressed in full by the applicant and design team
prior to lodgement of the application to An Bord Pleanála.
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