Harolds Cross Residential

.3

2020

Residential Development at 153-155 Haroldâ€&#x;s Cross Road, Dublin 6W. Town Planning Report Planning Report to accompany planning application lodged on behalf of the MG Motors Ltd with Dublin City Council. This application seeks permission for a residential development on a site at 153-155 Haroldâ€&#x;s Cross Road, Dublin 6W.

Manahan Planners 38 Dawson Street, Dublin 2 31/01/2020

Introduction This planning report has been prepared in connection with a planning application to Dublin City Council by MG Motors Ltd for a 43 unit residential development at 153155 Harold‟s Cross Road, Dublin 6W.

Figure 1: Site Location Map, subject site hightlighted in red.

In summary the proposal provides a 43 apartment residential development. It consists of a six-storey setback residential development with a naturally ventilated basement, communal areas (rooftop terrace), landscaped green roof and bicycle parking stores, car parking and refuse storage facilities at basement level.

This report seeks to explain the proposed development and then assess the proposal against the relevant planning criteria.

Site Context The site is to the east of Harold‟s Cross Road and north of Leinster Road and has a stated area of 0.0747ha.

To the front of the site traverses Harold‟s Cross Road, a road used by cars, cycling and buses in both directions with bus stops located close to the site. Harold‟s Cross Park is located on the other side of the road.

To the rear of the site lies Harold‟s Cross Greyhound Stadium with an entrance directly adjacent to the right of the site. To the east of the site lies a row with a mix of residential two-and tree-storey buildings and a crèche, Leinster Park Montessori. To the west of the site lies a two and three storey building hosting a public house and off-licenses Peggy Kelly‟s with an out-door seating area. The row of houses further Harold's Cross January 2020

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east comprises two and three storey residential houses. The site is located in a densely built up area with a large mix of uses including residential, commercial, recreational, educational and employment.

The site has an area of approximately 0.747 ha, the existing building on the site proposed to be demolished comprise a total gross area of 835.86 sq.m.

Figure 2: Map Aerial image of the subject site, hightlighted in red.

Figure 3: Street view of existing structure and surrounding area fronting the subject site.

The site is partly located within a zone of Archaeological Interest according to Map H of the current Development Plan, which comprise the part fronting the Harold's Cross Park.

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Planning History (Reg. Ref. 0230/99) An outline planning application was refused comprising the construct new second floor offices to front of premises and construct new first floor workshop over existing workshop at rear in February 1999. The Council refused outline permission citing reasons that the proposed use as motor repair/showroom is neither permissible nor open for consideration under the zoning (A1), and that the proposed workshop extension by reason of its scale, height, design and bulk would be incongruous with the established pattern of development in the general area.

(Reg. Ref. 1584/92) Permission was granted subject to conditions by Dublin City Council for the demolition of a portion of the existing garage premises including residential first floor portion rebuilding and extending garage premises including new car showroom.

The Proposal The Statutory Notices lodged with the application states the proposal involves the following.

“The proposed development will involve the demolition of the existing building previously in use as a garage and car showroom and the construction of a residential development consisting of six floors over basement (seven floors in total) with a set-back at top floor at 153-155 Harold‟s Cross Road, Dublin 6W. The new building (with a total floor area of 3,970.64 sq. m) will include a total of 43 units (8 studio apartments, 12 one-bed apartments and 23 twobed apartments). There will be communal landscaped rooftop terrace, green roof. A total of 11 No. car parking and 88 No. bicycle spaces will be provided at basement level. The proposed development will also comprise of refuse storage, excavation and all other ancillary works. The proposed development represents a densification of the area providing additional housing, comprising the following apartment mix;   

8 studio apartments; 12 one-bed apartments; and, 23 two-bed apartments.

In addition, the proposed development will include;  

Communal amenity (roof terrace) = 259 sq.m; Landscaped green roof = 167 sq.m;

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   

88 bicycle spaces; 11 car parking spaces; External storage; and, Refuse storage.

Zoning The subject site is zoned Z1: Sustainable Residential Neighbourhoods in the Dublin City Development Plan 2016-2022, which seeks to “protect, provide and improve residential amenities”.

Figure 4: Extract of zoning map from Dublin City Development Plan 2016-2022 identifying the Z1 zoning of the subject site (outlined in red).

Sites under this zoning designation are subject to the following Vision: “The vision for residential development in the city is one where a wide range of accommodation is available within sustainable communities where residents are within easy reach of services, open space and facilities such as shops, education, leisure, community facilities and amenities, on foot and by

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public transport and where adequate public transport provides good access to employment, the city centre and the key district centres.”

Residential is a Permitted in Principle land use under the Z1 zoning.

The subject site is located within a Conservation Area. The Development Plan seeks to ensure that new development proposals within a Conservation Area “complement the character of the area, including the setting of protected structures, and comply with development standards”.

National Policy The National Planning Framework 2040 was adopted on the 29th May 2018 and seeks compact urban growth, with the associated objective that at least half of the future housing growth of the main cities will be delivered within their existing builtup areas through infill and brownfield development and 40% in other key towns. The National Planning Framework has a number of policy objectives that articulate delivering on a compact urban growth programme. These include: “NPO 2(a) relating to growth in our cities; NPO 3(a)/(b)/(c) relating to brownfield redevelopment targets; NPO 4 relating to attractive, well-designed liveable neighbourhoods; NPO 5 relating to sufficient scale and quality of urban development; and NPO 6 relating to increased residential population and employment in urban areas; NPO13 relating to a move away from blanket standards for building height and car parking etc. and instead basing it on performance criteria.”

In March 2018 the Department of the Environment Heritage and Local Government published “Sustainable Urban Housing: Design Standards for New Apartments – Guidelines for Planning Authorities”. These Guidelines build on the content of the 2015 Apartment Guidelines but it notes that there is balance in setting out planning guidance to achieve both high quality apartment development and a significant increased level of apartment output. The key policies which have relevance in this scheme are:   

50% can be one bed or studio (no more than 20-25% can be studio) with no min requirement on three bed units, A max of 12 units per core from previous 8 units.

Studio type 1 person units at 37sq.m, 1 bed (2 person) 45sq.m, 2 bed (3 person) 63sq.m, 2 bed (4 person) 73sq.m, 3 bed (5 person) at 90sq.m.

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

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The requirement for more than half of the apartments in relevant schemes to generate additional floor space that would exceed the minimum floor area standard by at least 10% may be applied differently to schemes of 10 to 99 units, in such schemes it is acceptable to distribute the minimum 10% additional floor space throughout the scheme.

Dual aspect – 33% -in central and accessible locations – restricted sites, but in larger schemes on Greenfield or standalone „brownfield‟ sites where requirements like street frontage are less onerous, it should be a min of 50%.

They note north facing units are units that face predominately north with a 45 degree which includes north east and North West.

The Urban Development and Building Height Guidelines 2018 (Now adopted) Circular FPS 08-2018 was issued on the 7th December 2018 advising of new Guidelines for Planning Authorities on Urban Development and Building Heights 2018 under Section 28 of the Planning and Development Act 2000 (as amended).

The new height guidelines set a clear direction for developing our cities and towns upwards, rather than ever outwards. In particular, Section 2 of the height guidelines sets out advice and information requirements for planning applications.

Section 3 of the guidelines sets out development management assessment criteria to consider when assessing height. Relevant excerpts are set out below.

Section 3.2 “In the event of making a planning application, the applicant shall demonstrate to the satisfaction of the Planning Authority/ An Bord Pleanála, that the proposed development satisfies the following criteria: At the scale of the relevant city/town  



The site is well served by public transport with high capacity, frequent service and good links to other modes of public transport.

Development proposals incorporating increased building height, including proposals within architecturally sensitive areas, should successfully integrate into/ enhance the character and public realm of the area, having regard to topography, its cultural context, setting of key landmarks, protection of key views.3 Such development proposals shall undertake a landscape and visual assessment, by a suitably qualified practitioner such as a chartered landscape architect.

On larger urban redevelopment sites, proposed developments should make a positive contribution to place-making, incorporating new streets and public spaces, using massing and height to achieve the required densities but with

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sufficient variety in scale and form to respond to the scale of adjoining developments and create visual interest in the Streetscape.

At the scale of district/ neighbourhood/ street  



The proposal responds to its overall natural and built environment and makes a positive contribution to the urban neighbourhood and streetscape The proposal is not monolithic and avoids long, uninterrupted walls of building in the form of slab blocks with materials / building fabric well considered.

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

Risk Management – Guidelines for Planning Authorities” (2009). 



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

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

At the scale of the site/building 



The form, massing and height of proposed developments should be carefully modulated so as to maximise access to natural daylight, ventilation and views and minimise overshadowing and loss of light.

Appropriate and reasonable regard should be taken of quantitative performance approaches to daylight provision outlined in guides like the Building Research Establishment‟s „Site Layout Planning for Daylight and Sunlight‟ (2nd edition) or BS 8206-2: 2008 – „Lighting for Buildings – Part 2:

Code of Practice for Daylighting 

Where a proposal may not be able to fully meet all the requirements of the daylight provisions above, this must be clearly identified and a rationale for any alternative, compensatory design solutions must be set out, in respect of which the planning authority or An Bord Pleanála should apply their discretion, having regard to local factors including specific site constraints and the balancing of that assessment against the desirability of achieving

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wider planning objectives. Such objectives might include securing comprehensive urban regeneration and or an effective urban design and streetscape solution.

Where the relevant planning authority or An Bord PleanĂĄla considers that such criteria are appropriately incorporated into development proposals, the relevant authority shall apply the following Strategic Planning Policy Requirement under Section 28 (1C) of the Planning and Development Act 2000 (as amended).

SPRR3 It is a specific planning policy requirement that where; 1. An applicant for planning permission sets out how a development proposal complies with the criteria above; and 2. the assessment of the planning authority concurs, taking account of the wider strategic and national policy parameters set out in the National Planning Framework and these guidelines; Then the planning authority may approve such development, even where specific objectives of the relevant development plan or local area plan may indicate otherwise.

(B) In the case of an adopted planning scheme the Development Agency in conjunction with the relevant planning authority (where different) shall, upon the coming into force of these guidelines, undertake a review of the planning scheme, utilising the relevant mechanisms as set out in the Planning and Development Act 2000 (as amended) to ensure that the criteria above are fully reflected in the planning scheme. In particular the Government policy that building heights be generally increased in appropriate urban locations shall be articulated in any amendment(s) to the planning scheme.

In addition to the Departmentâ€&#x;s Guidelines on apartments and height, the Guidelines for Sustainable Residential Development in Urban Areas and the policies and targets in the Regional Planning Guidelines 2010–2022 are also relevant and have been considered in this assessment. Within centrally located sites, densities of 30-40+ dwellings per hectare for mainly residential schemes may be appropriate.

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Local (Development Plan) Policy The following policies of the Dublin City Development Plan 2016-2022, amongst others apply: QH1”To have regard to the DoEHLG Guidelines on „Quality Housing for Sustainable Communities – Best Practice Guidelines for Delivering Homes Sustaining Communities‟ (2007); „Delivering Homes Sustaining Communities – Statement on Housing Policy‟ (2007), „Sustainable Urban Housing: Design Standards for New Apartments‟ (2007) and „Sustainable Residential Development in Urban Areas‟ and the accompanying Urban Design Manual: A Best Practice Guide (2009)” QH3“(i) To secure the implementation of the Dublin City Council Housing Strategy` in accordance with the provision of national legislation. In this regard, 10% of the land zoned for residential uses, or for a mixture of residential and other uses, shall be reserved for the provision of social and/or affordable housing in order to promote tenure diversity and a socially inclusive city…”

QH5“To promote residential development addressing any shortfall in housing provision through active land management and a co-ordinated planned approach to developing appropriately zoned lands at key locations including regeneration areas, vacant sites and under-utilised sites.”

QH6“To encourage and foster the creation of attractive mixed-use sustainable neighbourhoods which contain a variety of housing types and tenures with supporting community facilities, public realm and residential amenities, and which are socially mixed in order to achieve a socially inclusive city.”

QH7“To promote residential development at sustainable urban densities throughout the city in accordance with the core strategy, having regard to the need for high standards of urban design and architecture and to successfully integrate with the character of the surrounding area.”

QH13“To ensure that all new housing is designed in a way that is adaptable and flexible to the changing needs of the homeowner as set out in The Residential Quality Standards and with regard to the Lifetime Homes guidance contained in Section 5.2 of the Department of Environment, Heritage and Harold's Cross January 2020

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Local Government „Quality Housing for Sustainable Communities – Best Practice Guidelines for Delivering Homes Sustaining Communities‟ (2007).”

QH18“To promote the provision of high-quality apartments within sustainable neighbourhoods by achieving suitable levels of amenity within individual apartments, and within each apartment development, and ensuring that suitable social infrastructure and other support facilities are available in the neighbourhood, in accordance with the standards for residential accommodation.”

QH19“To promote the optimum quality and supply of apartments for a range of needs and aspirations, including households with children, in attractive, sustainable mixed-income, mixed-use neighbourhoods supported by appropriate social and other infrastructure.”

SC13“To promote sustainable densities, particularly in public transport corridors, which will enhance the urban form and spatial structure of the city, which are appropriate to their context, and which are supported by a full range of community infrastructure such as schools, shops and recreational areas, having regard to the safeguarding criteria set out in Chapter 16 (development standards), including the criteria and standards for good neighbourhoods, quality urban design and excellence in architecture. These sustainable densities will include due consideration for the protection of surrounding residents, households and communities.”

GI 27“To minimise the environmental impact of external lighting at sensitive locations to achieve a sustainable balance between the needs of an area, the safety of walking and cycling routes and the protection of light sensitive species such as bats.”

Development Standards Chapter 16 of the Dublin City Development Plan 2016-2022 sets out development management standards and guidance in addition to the “Sustainable Urban Housing: Design Standards for New Apartments – Guidelines for Planning Authorities”. This includes an indicative plot ratio of 0.5-2.0 and an indicative site coverage of 45-60%. Other relevant guidance in Chapter 16 is set out below.

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16.4 Density “Dublin City Council will promote sustainable residential densities in accordance with the standards and guidance set out in the DEHLG Guidelines on Sustainable Residential Development in Urban Areas and having regard to the policies and targets in the Regional Planning Guidelines 2010–2022 or any Regional Spatial and Economic Strategy that replaces the regional planning guidelines. …...Sustainable densities promoting the highest quality of urban design and open space will be sought by the City Council in all new developments. The density of a proposal should respect the existing character, context and urban form of an area and seek to protect existing and future residential amenity. Public transport capacity will also be used to determine the appropriate density allowable….. All proposals for higher densities must demonstrate how the proposal contributes to place making and the identity of an area, as well as the provision of community facilities and/or social infrastructure to facilitate the creation of sustainable neighbourhoods.”

Figure 5: Current building‟s site coverage. (Source: Survey Demolitions drawing No. 1806 S02 prepared by Andrew Lohan Architects)

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The current building on the site, a car showroom, occupies the full footprint of the site.

The proposed development will be slightly set back from the boundary while still maximising the potential of the site. It is proposed that the site coverage will be c.

98% with a plot ratio of 4.46:1. It is noted that the Development Plan sets out a plot ratio of 0.5-2.0 and site coverage of 45-60% but these are indicative numbers only.

Given this infill site‟s prime location along excellent public transport, it‟s close proximity to District Centres and amenities and the need to deliver higher densities in these areas we submit that the scale of this proposal is in keeping with Planning Guidelines and policies.

16.7.2 Height The subject site is located along Harold‟s Cross Road and is identified as a „Low Rise Area‟ – Outer City- which has a maximum height of 16 metres from both commercial and residential development.

The proposed development is 20.8 metres at ridge level. The “Urban Development and Building Heights Guidelines for Planning Authorities” published in December 2018 supersede the blanket height guidelines set out in Development Plans. The building is designed to minimise the appearance of its height by setting back the top floor and the plant located at roof level.

16.10 Standards for Residential Accommodation “The provision and protection of residential amenities is a primary concern of Dublin City Council. This will be achieved through the relevant objectives of the Dublin City Development Plan. As outlined in the „Quality Housing‟ chapter, it is an aim of Dublin City Council to encourage and foster living at sustainable urban densities through the creation of attractive mixed-use sustainable neighbourhoods.”

The proposed apartments in this development are well above the minimum standards. 

The minimum allowable size of a 1-bed apartment is 45 sq. m. Apartment sizes in this development range between 50 – 50.4 sq. m.



The minimum allowable size of a 2-bed apartment is 73 sq. m. Apartment sizes in this development range between 76.6 – 90.8 sq. m.

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16.10.3 Public Open Space “In new residential developments, 10% of the site area shall be reserved as public open space……All public open spaces shall be of a high quality in terms of design and layout, be located in such a manner as to ensure informal supervision by residents and be visually and functionally accessible to the maximum number of dwellings... A landscaping plan will be required for all developments identifying all public, communal (semi-private) and private open space. The design and quality of public open space is particularly important in higher density areas…”

A rooftop terraced area of 259 sq. m will be provided for the residents of this development.

16.10.10 Infill Housing Having regard to policy on infill sites and to make the most sustainable use of land and existing urban infrastructure, the planning authority will allow for the development of infill housing on appropriate sites. In general, infill housing should comply with all relevant development plan standards for residential development; however, in certain limited circumstances, the planning authority may relax the normal planning standards in the interest of ensuring that vacant, derelict and under-utilised land in the inner and outer city is developed.

Infill housing should: 

 

Have regard to the existing character of the street by paying attention to the established building line, proportion, heights, parapet levels and materials of surrounding buildings Comply with the appropriate minimum habitable room sizes Have a safe means of access to and egress from the site which does not result in the creation of a traffic hazard.

Planning Assessment Land Use As outlined above, the proposed development is located within an area with a zoning designation where residential is a Permitted in Principle land use as per the current Development Plan.

The surrounding area is characterised by medium to high-density buildings, with a mix of residential land-uses, community and recreational facilities located in the Dublin 6W area. The site has easy reach of services, open space, shops, education, Harold's Cross January 2020

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leisure, community facilities and amenities. There is adequate public transportation available in the area providing good access to employment, education, the city centre.

Building Height The now adopted new height guidelines, The Urban Development and Building Height Guidelines 2018 set a clear direction for developing our cities and towns upwards, rather than ever outwards.

In addition to these Guidelines, Section 16.7.2 of the current Development Plan includes an assessment criterion for higher buildings. All proposals for mid-rise and taller buildings must have regard to this assessment as set out below: 

Relationship to context, including topography, built form, and skyline having regard to the need to protect important views, landmarks, prospects and vistas

The buildings in the area are generally one to three storeys in height, with the exception of the Russian Orthodox Church located on the other side of Harold's Cross Park. The development is proposing a 6 storey building with a set-back roof which will blend in with the existing environment. The proposed development is 20.8 metres at ridge level.

The site is not in close proximity to important views, landmarks, prospects or vistas. The proposed design and height of the building has been considered in order to effects in regard to heights of surrounding buildings and skyline.

Figure 6: Drawing of proposed development.

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

Effect on the historic environment at a city-wide and local level

The architectural response provides a modern style building in an area comprising a mix historic heritage in the area. The building proposed has been carefully designed to utilise the full size of the plot and providing an appropriate number of units and an architectural response which will have a positive effect on the existing environment. A red brick finish which is typical to this area of Dublin will be installed, which must be agreed upon by the Local Authority prior to commencement. 

Relationship to transport infrastructure, particularly public transport provision

Public transportation including cycling infrastructure is in reach of the subject site providing good access to the city centre and key district centres in the city.

The site is also located on one of the proposed main routes within the Busconnects Plan. 

Contribution to public spaces and facilities, including the mix of uses

The current building on site has not been in use over a number of years and its structure detracts from the attractive building in its vicinity. The proposed development will accommodate new residents which will boost the local retail offerings in the area.

In light of this, the proposed development will be in the form of a 6-storey building.

It is submitted that the density, scale and height of proposal accords with the current Development Plan and recent policy on building height, in particular Section 3.2 of The Urban Development and Building Height Guidelines 2018.

Design Standards The Design Standards for New Apartments - Guidelines for Planning Authorities (Dec. 2015) document establishes a number of criteria under which applications for new apartments will be assessed. The principle ones are as follows and assessed below:     

Apartment Floor Area; Dual Aspect Ratios; Lift and Stair Cores; Internal Storage; and Private Amenity Space.

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All apartments accord with the development standards.

In terms of apartment mix, the Development Plan requires a maximum of 25-30% one-bedroom units. The proposed development meets this requirement by providing approximately 28% one-bedroom units.

With respect to apartment orientation, national standards state: "in urban locations, it is a specific planning policy requirement that the minimum number of dual aspect apartments that may be provided in any single apartment scheme shall be 50%.�

52% of the proposed units are dual aspect.

With regard to stair/life cores, the national guidance states that: "subject to compliance with the dual aspect ratios specified in these guidelines and building regulations particularly in relation to fire safety, it is a specific planning policy requirement that up to 12 apartments per floor per individual stair/lift core may be provided in apartment schemes".

The development proposes a variation of 5 to 8 units per each floor and therefore meets the recommended maximum 12 units per floor. The stairs/lift core are located in the centre of the building. All units are served with lift and stair cores at each floor.

Internal Storage and Private Open Space All the apartments exceed the standards with respect to apartment storage space and private open space. See the Housing Quality Assessment Schedule submitted as part of this application.

Communal Amenity Space The communal roof terrace area provides 259 sq. m of amenity space for the residents. The development also includes a green roof. This space is landscaped with low level planting. The area within the site boundary seeks to reinforce a green setting that incorporates some planting.

The Development Plan requires a minimum area of communal open space for the residents of 253 sq. m. As indicated above, the proposed area of communal open space is in excess of this.

The site is located directly opposite Haroldâ€&#x;s Cross Park as well as close to other city parks which are within walking distance.

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Parking and Access The site is located within a Zone 3 as designation by the current Development Plan in Map J. The policies of the Development Plan seek 1.5 car parking spaces and one bicycle parking space per residential unit is required in this location.

Vehicular access to the site is via Harold's Cross Road. The entrance laneway and footpath extends inside the northern boundary of the site to provide access to both blocks for residents and visitors, waste collection and emergency services.

There is a basement linking the entire development providing 88 secure bicycle spaces for residents. Also there 11 car parking spaces which includes one disabled car parking spaces.

It is considered that this is an appropriate supply of car parking spaces given the central location of the site in the intersection of two QBC‟s and the close proximity of bus stops from where residents can avail of easy access to the city centre.

The Mobility Management Plan prepared by NRB which is submitted as part of this application states that access and parking for this proposed development “can be accommodated without any noticeable or adverse traffic impact arising.”

Public Realm The proposed development includes a pedestrian entrance to the front of the proposed building on Harold‟s Cross Road.

The proposal has incorporated a slightly recessed ground floor into the design to allow for wider footpaths. This will provide a more generous footpath along the street and create a more comfortable public realm.

The presence of windows and balconies at upper levels also provides passive surveillance of the public realm thus increasing the sense of security to pedestrians below.

Visual Impact The proposal is a context-appropriate architectural response to the site‟s conditions with the aim to support and enhance its surroundings. Harold‟s Cross has experienced much change in the years and decades gone by. The buildings have differing materials and colours with varying heights exhibiting different architectural typologies and styles. It is submitted that the emerging character of the area is extremely varied and inconsistent.

The proposed scheme presents as a 6-storey building with setback top floor. The overall proposed ridge height of the block is 20.8 meters.

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By setting the upper storey back, the uppermost level is visually recessed and subservient to the main body of the building below. Further, the uppermost level is predominantly only visible to passers-by from oblique angles.

The proposed facade is highly articulated with recessed balconies light coloured brick with a series of dark and light grey cement panelling with dark grey framed windows.

It is noted that these features and colours are subject to approval. The brick facade incorporates individual windows in a linear arrangement between floors.

Transport Assessment/Mobility Management Plan A Mobility Management Plan has been prepared by NRB consulting engineers and is included with this application. It concluded that: “The Transportation Assessment Report confirms that there is an absolutely negligible traffic impact associated with the opening of the proposed subject development and that it can be accommodated without any noticeable or adverse traffic impact arising.

Based on our study, we believe that there are no traffic/transportation capacity, traffic safety or operational issues associated with the proposed development that would prevent a positive determination of the planning application by Dublin City Council.”

Part V – Social Housing It is recognised that since 1st September 2015 there is now a requirement to provide 10% social housing in developments with 10 or more residential units in them.

However, as the site is smaller than 0.1 ha this development is exempt from Part V obligations. A Social Housing Exemption Cert has been lodged for this application.

Screening for Appropriate Assessment Planning applications are required to undertake a “screening” as to whether the project proposed could have significant effects on a Natura site, such that a Natura Impact Study (NIS) is required to be lodged with the application. This section addresses this issue.

In relation to “Appropriate Assessment”, this procedure was introduced by the European Union Habitats Directive as a way of determining if a planned project is likely to have significant effect on any of the Natura 2000 sites designated as either Harold's Cross January 2020

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candidate SACâ€&#x;s and SPAs or any of their conservation objectives. It requires a broader overview of the project than an environmental impact statement would have as it necessitates an examination of the secondary effects at some distance from the project location.

Natura 2000 sites are areas of established environmental merit as described under the European Union Habitats Directive (Council Directive 92/43/EEC) and the Birds Directive (Council Directive 79/409/EEC).

There are four Natura 2000 sites that could potentially be affected by this development. These are the Dalkey Islands, the North Dublin Bay SAC, North Bull Island SPA or the South Dublin Bay and River Tolka Estuary SPA. However, the site of this application is in the Harold’s Cross area of Dublin. The site is not located within or directly adjacent to any Natura 2000 area (SAC or SPA). This part of Harold’s Cross is a built-up business and residential zone and is predominantly composed of surfaces that are sealed with tarmacadam and concrete.

Inert construction and demolition waste will be removed by a licenced contractor and disposed of in accordance with the Waste Management Act. Also, foul and surface drainage infrastructure will be separated up to the final point of entry to the municipal sewer. Combined effluent and storm water from the proposed development will be sent to the wastewater treatment plant at Ringsend in Dublin.

Therefore due to the distance involved and the modest nature of the development, the proposal of itself or taken together with other developments, is not likely to have any adverse impacts on a Natura site.

In relation to screening for this proposal therefore, the design, nature, limited scale as one house, the mitigating measures proposed and location of the development, will ensure that the proposal will not have any significant effects on a Natura site either individually or collectively.

Due to the unlikelihood of significant ecological effects on the qualifying interests of the Natura sites downstream, it is reasonable to conclude that the screening carried out shows that the further more detailed stages of the Appropriate Assessment procedure are not required.

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Conclusion In conclusion it is submitted that the proposal is consistent with the provisions of the Dublin City Development Plan, is an appropriate design response to such a well located site and it is consistent with the proper planning and sustainable development of the area. In the current circumstances of a shortage of housing supply in the Dublin region, it is requested that the Dublin City Council proceed to grant permission for this worthy and much needed development.

We look forward to a Decision in due course.

Manahan Planners 31st January 2020

Enclosures 1x Planning Application Form dated 31st January 2020.

6x copies of this Planning Report.

6x copies of Architectural Drawings and Design Statement prepared by Andrew Lohan Architects.

6x copies of Mobility Management Plan prepared by NRB Consulting Engineers.

6x copies of Civil Structural Report and Drawings prepared by Hanley Pepper Consulting Engineers 1x Social Housing Exemption Certificate and Statutory Declaration.

2x copies of the Site Notice dated 31st January 2020.

2x copies of the newspaper advert published 31st January 2020.

A cheque for payment of application of â‚Ź2,875.

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