CHILDCARE ASSESSMENT FOR A PROPOSED SHD RESIDENTIAL DEVELOPMENT ON LANDS LOCATED AT BELMAYNE P4, DUBLIN 13 ON BEHALF OF BALGRIFFIN PARK LIMITED BY ...

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CHILDCARE ASSESSMENT FOR A PROPOSED SHD RESIDENTIAL DEVELOPMENT ON LANDS LOCATED AT BELMAYNE P4, DUBLIN 13 ON BEHALF OF BALGRIFFIN PARK LIMITED BY ...
CHILDCARE ASSESSMENT

FOR A PROPOSED SHD RESIDENTIAL DEVELOPMENT

                             ON LANDS LOCATED AT

                           BELMAYNE P4, DUBLIN 13

                                    ON BEHALF OF

                       BALGRIFFIN PARK LIMITED

                                              BY

              April 2021
CHILDCARE ASSESSMENT FOR A PROPOSED SHD RESIDENTIAL DEVELOPMENT ON LANDS LOCATED AT BELMAYNE P4, DUBLIN 13 ON BEHALF OF BALGRIFFIN PARK LIMITED BY ...
CONTENTS
Introduction ............................................................................................................................................ 3
Proposal .................................................................................................................................................. 3
Planning Policy Context .......................................................................................................................... 4
   Childcare Facilities Guidelines for Planning Authorities, 2001 ........................................................... 4
   Sustainable Urban Housing: Design Standards for New Apartments, 2018 ....................................... 5
   Dublin City Development Plan, 2016–2022 ........................................................................................ 5
Site Context ............................................................................................................................................. 7
Area Demographic and Catchement Area .............................................................................................. 7
   Quarterly National Household Survey ................................................................................................ 8
Childcare Facilites ................................................................................................................................. 10
Demand for Childcare Places Likely Generated by the Proposed Development .................................. 13
Nearby Developments .......................................................................................................................... 14
Conclusion ............................................................................................................................................. 14
Appendix 1: Letter from DCCC October 2020 ....................................................................................... 15
Appendix 2: Letter from DCCC April 2021............................................................................................. 16

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CHILDCARE ASSESSMENT FOR A PROPOSED SHD RESIDENTIAL DEVELOPMENT ON LANDS LOCATED AT BELMAYNE P4, DUBLIN 13 ON BEHALF OF BALGRIFFIN PARK LIMITED BY ...
INTRODUCTION
McGill Planning Limited, 45 Herbert Lane, Dublin 2, is instructed by our client Balgriffin Park Limited,
to prepare this Childcare Assessment regarding the development of lands at Belmayne P4, at the
corner of Churchwell Road and Churchwell Crescent, Dublin 13. The proposal for 260 no. residential
units on a site area of c.1.31 consisting of 108 no. of 1 bed, 135 no. 2-beds, and 17 no. of 3 beds.

This Childcare Assessment has been prepared to assess childcare capacity in the Belmayne area. The
report will assess the childcare demand and the likely demand for childcare places resulting from the
proposed development at Belmayne. It will then determine whether there is sufficient supply within
the existing creche’s to cater for the demand of the existing and proposed developments in the area.

The following report has had regard to the Dublin City County Development Plan 2016–2022 and the
Childcare Facilities Guidelines for Planning Authorities (2001). The Design Standards for New
Apartments Guidelines 2018 are also noted. These state that the childcare guidelines are to be revised
with a view to ensuring that childcare facilities are of sufficient size and scale to be commercially
viable.

The report assesses the vacancy rates within local childcare facilities and determines if the demand
for places generated by the proposed development can be accommodated within the existing
childcare facility provisions.

PROPOSAL
Balgriffin Park Limited intend to apply to An Bord Pleanála for permission for a strategic housing
development at this site at Belmayne P4, adjacent Churchwell Road and Churchwell Crescent,
Belmayne, Dublin 13.

The development will consist of 260 no. apartment units within an urban block (with 6 cores)
ranging in height up to 7 storeys. The unit mix will comprise of 108 no. 1-beds, 135 no. 2-beds, and
17 no. 3-beds (10 no. duplexes and 7 no. apartments), all with associated private balconies/terraces
to the north/south/east/west elevations. The development will also include c.314 sqm of residential
amenity facilities, c.2,945sqm of communal open space at podium level, 199 no. car parking spaces
(180 no. at undercroft level and 19 no. at surface level), and 400 no. cycle parking spaces (384 no.
at undercroft level and 16 no. at surface level). Vehicular access to the undercroft parking area will
be provided from Churchwell Crescent. All other site services and works to enable the development
of the site will also be provided including bins, ESB substation and switchroom, plant areas,
boundary treatments and landscaping.

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CHILDCARE ASSESSMENT FOR A PROPOSED SHD RESIDENTIAL DEVELOPMENT ON LANDS LOCATED AT BELMAYNE P4, DUBLIN 13 ON BEHALF OF BALGRIFFIN PARK LIMITED BY ...
PLANNING POLICY CONTEXT
Childcare Facilities Guidelines for Planning Authorities, 2001

                                    The Childcare Facilities Guidelines for Planning Authorities (2001)
                                    generally recommend that 1 no. childcare facility is required per 75
                                    no. dwellings. However, it is acknowledged that this is not always
                                    appropriate, and the omission of a childcare facility may be
                                    allowable “where there are significant reasons to the contrary for
                                    example, development consisting of single bed apartments or
                                    where there are adequate childcare facilities in adjoining
                                    developments”. In short, the provision of a childcare facility for new
                                    schemes of 75 no. dwellings is a guideline and not an absolute
                                    requirement.

                                    In considering this issue, it is further stated that “in relation to new
                                    housing areas, a standard of one childcare facility providing for a
                                    minimum 20 childcare places per approximately 75 dwellings may
                                    be appropriate. This is a guideline standard and will depend on the
                                    particular circumstances of each individual site [own emphasis
added]”, (Childcare Facilities Guidelines for Planning Authorities, 2001, p.9).

 Following on from the advice set out above, we have carried out an assessment, identifying the
 existing facilities, their capacity, and demand in the area as well as an assessment of the demand
 that will be generated by the proposed applications. The total number of units proposed is 260
 units.

 Applying the 2001 guidelines standard of 20 no. childcare spaces per 75 no. dwellings would suggest
 that c. 69 private childcare places (260 units / 75 *20) would be needed. However, as this
 development is predominantly one and two bed apartments it is highly unlikely that the
 development will generate anywhere near this level of demand for childcare.

 Applying this crude measure for calculating demand for creche facilities is likely to lead to an
 overprovision of permitted/built/vacant creche facilities. Furthermore, if there is an over provision
 in any area, then other creche facilities may not be commercially viable and will not be able to
 survive. Equally there are examples of creches throughout Ireland which have been built as part of
 residential schemes and which have either remained unoccupied or a change of use planning
 application has been submitted for an alternative use.

 As noted in the Design Standards for New Apartments Guidelines 2018, the childcare guidelines are
 to be revised in the future with a view to ensuring that childcare facilities are sufficient in terms of
 number, location and size to be commercially viable and to provide for sustainable communities. In
 the interim, until the new childcare guidelines are produced, the New Apartment Guidelines 2018,
 advise that creche requirement should be carefully considered with regard to local demographics
 and socio-economic trends, and with regard to the number of children who currently attend pre-
 school and the existing provision and capacity in the area.

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CHILDCARE ASSESSMENT FOR A PROPOSED SHD RESIDENTIAL DEVELOPMENT ON LANDS LOCATED AT BELMAYNE P4, DUBLIN 13 ON BEHALF OF BALGRIFFIN PARK LIMITED BY ...
Sustainable Urban Housing: Design Standards for New Apartments, 2020
                                  The Sustainable Urban Housing: Design Standards for New
                                  Apartments Guidelines for Planning Authorities 2020 include
                                  specific guidance on childcare provision. This gives an indication of
                                  revised approach currently evolving in relation to childcare facilities
                                  particularly in the context of the current guidelines which were
                                  published nearly 20 years ago.

                                  Section 4.7 of the Guidelines states as follows:

                                  “Notwithstanding the Planning Guidelines for Childcare Facilities
                                  (2001), in respect of which a review is to be progressed, and which
                                  recommend the provision of one child-care facility (equivalent to a
                                  minimum of 20 child places) for every 75 dwelling units, the
                                  threshold for provision of any such facilities in apartment schemes
                                  should be established having regard to the scale and unit mix of
the proposed development and the existing geographical distribution of childcare facilities and the
emerging demographic profile of the area. One-bedroom or studio type units should not generally
be considered to contribute to a requirement for any childcare provision and subject to location, this
may also apply in part or whole, to units with two or more bedrooms.”

 The unit mix for the proposed Belmayne P4 development is 108 no. 1-bed, 135 no. 2 bed, and 17
 no. 3-bed. If the 1 and 2 beds are excluded, as suggested by the Guidelines, then the demand
 created for childcare would be minimal. Following on from this advice the Applicant gave due
 consideration to the provision of a childcare facility during the design phase of the subject scheme.
 It was found, following consultation with Dublin City Childcare Committee and childcare operators
 that there was a present lack of demand for another childcare facility within the catchment area.
 As planning has moved into an ‘‘evidence-based’’ era, the current evidence does not present the
 demand for a viable childcare facility.

Dublin City Development Plan, 2016–2022
                              Appendix 13 of the Development Plan (2016-2022) seeks to provide 1
                              childcare facility per 75 dwellings. This is a guideline standard, and it is
                              noted childcare provisions will depend on the circumstances of each
                              individual site and will take into account the existing geographical
                              distribution of childcare facilities and the emerging demographic profile
                              of area and the housing mix of the proposed development.

                              Policy SN17 of the Plan aims “to facilitate the provision in suitable
                              locations of sustainable, fit-for-purpose childcare facilities in residential,
                              employment, and educational settings, taking into account the existing
                              provision of childcare facilities and emerging demographic trends in an
                              area.”

Appendix 13 of the Development Plan identifies that regard shall be given to the existing geographical
distribution of childcare facilities and the emerging demographic profile of areas.

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CHILDCARE ASSESSMENT FOR A PROPOSED SHD RESIDENTIAL DEVELOPMENT ON LANDS LOCATED AT BELMAYNE P4, DUBLIN 13 ON BEHALF OF BALGRIFFIN PARK LIMITED BY ...
Any modification to the indicative standard of one childcare facility per seventy-five dwellings should
have regard to:

    •   The make-up of the proposed residential area, i.e. an estimate of the mix of community that
        the housing area seeks to accommodate (if an assumption is made that 50 per cent
        approximately of the housing area will require childcare, then in a new housing area of seventy
        five dwellings, approximately thirty-five will need childcare. One facility providing a minimum
        of twenty childcare places is, therefore, considered to be a reasonable starting point on this
        assumption. Other assumptions may lead to an increase or decrease in this requirement.)

    •   The results of any childcare needs analysis carried out as part of the city childcare strategy or
        carried out as part of a local or area action plan or as part of the development plan in
        consultation with the city childcare committees, which will have identified areas already well
        served or alternatively, gap areas where there is under provision, will also contribute to
        refining the base figure.

    •   This is a guideline standard and will depend on the particular circumstances of each individual
        site. Consideration of childcare facilities provision should be raised as early as possible in
        preplanning discussions for larger housing developments.

 In considering the above bullet points, the approach of the childcare assessment is in accordance
 with these requirements. Due consideration has been given to the existing the immediate area and
 has been completed in conjunction with the Dublin City Childcare Committee. Given the number of
 facilities within the area, it is appropriate to conduct a childcare assessment at the current time to
 appropriately determine whether there is a present under or over-supply of childcare facilities for
 the area.

The findings of the childcare assessment are discussed in detail in sections below with the findings in
accordance with the requirements of Appendix 13 of the Development Plan, ‘Guidelines for Childcare
Facilities’.

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CHILDCARE ASSESSMENT FOR A PROPOSED SHD RESIDENTIAL DEVELOPMENT ON LANDS LOCATED AT BELMAYNE P4, DUBLIN 13 ON BEHALF OF BALGRIFFIN PARK LIMITED BY ...
SITE CONTEXT
The site is currently vacant and is located north of the proposed Main Street and to the south of
existing Belmayne estates. The application site measures c. 1.31 hectares gross and is broadly
rectangular in shape. It is a mainly flat site running in an east-west direction. Within the wider area,
to the north and east are predominantly residential land uses.

It is located c.8.5km north east of Dublin City Centre, less than 500m north east of Clare Hall Shopping
Centre and within walking distance of the Clongriffin Train Station. A number of Dublin Bus services
pass within the immediate vicinity of the site.

Figure 1 Site Location Map

AREA DEMOGRAPHIC AND CATCHEMENT AREA
Approximately 9,696 no. people were living within the Grange A Electoral Division (where the subject
lands are located) at the time of the 2016 Census. There was an c. 8.3% increase in population between
the 2011 and 2016 Census. The analysis of CSO data showed that the population was aging with a
45.5% increase in population over the age of 65, an increase of 9.5% in population of older adults (35-
64 years old) and a decrease of 6.5% for young adults (19-34 years old).

Of the total population, 8.6%, or 837 people, were of pre-school age, and this age cohort had only
increased by 2.38% since 2011 which is a very small growth rate compared to other age groups.
Nevertheless, it is still higher that the national average of 7%.

 2011 Population               2016              Population Change 2011-     Percentage Change 2011-
                             Population                   2016                        2016
        8,948                  9,696                       748                        8.3%
Table 1 CSO Data of the Grange A Electoral Division

            Age                           2011                2016         Change   Percentage Change

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CHILDCARE ASSESSMENT FOR A PROPOSED SHD RESIDENTIAL DEVELOPMENT ON LANDS LOCATED AT BELMAYNE P4, DUBLIN 13 ON BEHALF OF BALGRIFFIN PARK LIMITED BY ...
0-4 Pre-school                        817                       837               +20           +2.38
  5-18 School Children                    1,987                     2,198             +211            +9.6
      19-34 Adults                        2,436                     2,286             -150            -6.5
      35-64 Adults                        3,327                     3,676             +349            +9.5
       65+ Adults                          381                       699              +318           +45.5
Table 2 Age Groups CSO Data of the Grange A Electoral Division

Quarterly National Household Survey
The Quarterly National Household Survey (QNHS) carried out by the Central Statistics Office includes
a Special Module on Childcare. The most recent report on this module was published for Quarter 4
2016. What the figures indicate is that crèche/Montessori attendance for pre-school age children
nationally is 19%, with the Dublin region unsurprisingly with the highest rate (25%) (Source: CSO.ie).
At the same time 78% of childcare is carried out unpaid by a parent/partner or relative/friend in the
Dublin area.

Figure 2 Extract from Quarterly National Household Survey, 2016 Special Module on Childcare

Figure 3 Site Location within Catchment Area for Population Analysis – Grange A Electoral Division

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CHILDCARE ASSESSMENT FOR A PROPOSED SHD RESIDENTIAL DEVELOPMENT ON LANDS LOCATED AT BELMAYNE P4, DUBLIN 13 ON BEHALF OF BALGRIFFIN PARK LIMITED BY ...
Population Change
                                      Electoral Division - Grange A
                   4000
                   3500
                   3000
   No. of People

                   2500
                   2000
                   1500
                   1000
                    500
                      0
                             0 to 4      5 to 18           19 to 34            35 to 64                  65+
                                                     Age Demographic

                                                    2016     2011

Figure 4 Changing Population Grange A ED 2011-2016

                          Age Profile: Electoral Division - Grange A
                                             2016

                                                                                              0 to 4
                                                                                              5 to 18
                                              7% 9%
                                                                                              19 to 34

                                                           23%                                35 to 64

                                       38%                                                    65+

                                                     23%

Figure 5 Population breakdown for Electoral Division – Grange A for the 2016 census period.

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CHILDCARE ASSESSMENT FOR A PROPOSED SHD RESIDENTIAL DEVELOPMENT ON LANDS LOCATED AT BELMAYNE P4, DUBLIN 13 ON BEHALF OF BALGRIFFIN PARK LIMITED BY ...
CHILDCARE FACILITES
Pobal, the government agency, maintains an up-to-date map of registered childcare facilities within
Ireland, enabling more objective analysis of gaps in provision and the targeting of areas where facilities
may be needed in the future. We have undertaken an analysis of existing facilities in the local area as
detailed in Figure 6 (below) using this data from Pobal, as well as from Google Maps and the applicable
creche websites. This analysis identified 33 no. childcare facilities within 2km of the subject site, 11 of
which are within 1km of the site.

We have liaised with Dublin City Childcare Committee (DCCC) who completed two surveys of the
existing facilities within the area. The first survey took place in October 2020 and the second in late
March 2021. The results of these surveys are shown in the table below.

      Childcare Facility                  Total No.          Vacancies        Services Offered
                                          Children
 1.   Giraffe Childcare Northern                           Less than 5 part   Full Day Care
                                             94
      Cross*                                                 time places
 2.   Bumblebees*                            55                   0           Full Day Care
 3.   Tigers Childcare Balgriffin*      FCC Remit             FCC Remit       Full Day Care
 4.   Lovable Me Montessori^                 44                   0           Sessional
 5.                                    44 in morning                          Sessional/After school
                                                                  0
      Pipalong Childcare*             44 in afternoon
 6.                                                         4 afterschool     Full Day Care
                                             34
     Children’s Choice*                                         places
 7. Coraline’s Playschool^                  16                     0          Sessional
 8. First Steps Academy*                 FCC Remit           FCC Remit        Full Day Care
 9. Ayrfield         Community                                                Sessional
                ^                            20                   7
     Playgroup
 10. Little Rainbows Belmayne^                                                Full Day Care, Part Time
                                             133                  0
                                                                              and School Age Childcare
 11. Little Rainbows                                                          Full Day Care, Part Time
                                             83                   0
     Donaghamede^                                                             and School Age Childcare
 12. Little Blossoms Creche^                32                   0            Full Day Care
 13. Learning Circle Childcare*          FCC Remit           FCC Remit        Full Day Care
 14. The Learning Circle*                   60                   4            Full Day Care
 15. Madeline’s Preschool*               FCC Remit           FCC Remit        Not Provided
 16. Fizzy Fingers*                         22                   0            Sessional
 17. Mead Day Care Centre^                  54                   0            Part Time
 18. Stepping Stones*                       44                  19            Sessional
 19. The Kids Den^                                                            Full Day Care , Part Time,
                                             44                  12           Sessional & School Age
                                                                              Childcare
 20. Learn and Play Preschool                                                 Part Time and Sessional
                                             33                  11
     and Afterschoool CLF^
 21. Darndale           Belcamp                                               Full Day Care
     Integrated        Childcare             140                  0
     Service^

                                                      10
22. Drumnigh Montessori                                                                    Independent Primary
     Primary School^                                  66                     12             School with Sessional
                                                                                            ECCE
 23. Naíonra Leanaí Óga*                              11                      4             Sessional
 24. Kilbarrack      Community                                                              Full Day Care, Part Time
                                                      23                      0
     Childcare Services^                                                                    and Sessional
 25. St. Benedicts Creche^                      Closed for              Closed for          Part Time
                                             holidays at time        holidays at time
                                                of survey               of survey
 26. One Step Ahead Preschool^                      40                      4               Part Time and Sessional
 27. Kidz First^                                Closed for              Closed for          Full Day Care
                                             holidays at time        holidays at time
                                                of survey               of survey
 28. Our World Montessori                       Closed for              Closed for          Sessional
     School^                                 holidays at time        holidays at time
                                                of survey               of survey
 29. An Cuan D’Or^                                                    4 ECCE places         Part time and Sessional
                                                      22
                                                                       for Sept 21
 30. Edenmore Early Education                                                               Full Day Care and
                                                      60                      0
     Centre^                                                                                Sessional
 31. Garden of Eden^                                  80                      0             Full Day Care
 32. Moatview Early Education                                                               Sessional
                                                      16                      8
     Centre^
 33. Dolphins Early Education &                                                             Full Day Care, Part Time,
     Childcare Centre, Doolin                         64                      2             Sessional and School Age
     House^
     Total                                          1334                     91
 (Note: Many of the Full Time Care also provide sessional/part time/afterschool care in conjunction with the Full Time Care.)
 ^results from March 2021 survey
 *results from October 2020 survey
Table 3 Results of DCCC Surveys

When contacted by DCCC many services remarked that, with Covid-19, their capacity has changed and
been reduced in order to safely accommodate both children and staff. It is therefore expected that
the capacity identified in the survey will likely increase when Covid restrictions are eased.

Four of the facilities within 2km of the site are within Fingal County Childcare Committee and three of
the services were closed at the time of the survey. These seven facilities would likely have further
vacancies and capacity for the area.

The Dolphins Early Education & Childcare Centre at Doolin House have lodged an application for a
first-floor extension which will allow them to cater for an additional 44 no. children (DCC Reg. Ref.:
2383/21). Dublin City Council is due to decide on this application in early May. If granted and
completed this extension will provide further childcare capacity in the area.

The location of the childcare facilities within 2km of the subject site are shown in the map below.

                                                             11
Figure 6 Location of Childcare Facilities (Source Pobal.ie)

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DEMAND FOR CHILDCARE PLACES LIKELY GENERATED BY THE PROPOSED DEVELOPMENT
The table below provides a breakdown of the proposed units.

             Unit Size                            Number of Unit                  Percentage %
              1 Bed                                   108                            41.5%
              2 Bed                                   135                            51.9%
              3 Bed                                   17                              6.5%
              Total                                   260                             100
Table 4 Unit Breakdown for Proposed Development

Based on an average household size of 2.7 then the estimated population of the proposed
development would be c.702 persons. Based on the 2016 Census figures for the area then the
population estimate for the 0-4 age cohort (pre-school at 8.6% of the population) would be c.60
children.

As noted above not all children in the 0-4 age cohort require private childcare. The 2016 QNHS
indicates that in the Dublin region on average 25% of pre-school age children attend private childcare.

Applying this figure to the total estimate of children in the proposed development indicates that only
c.15 private childcare spaces would be needed.

Of course, the 25% QNHS estimate for the Dublin Region is an average and one would expect the
percentage to be greater in areas where there are higher instances of both parents working, and
therefore needing private childcare.

Therefore, the tables below also include a “worst case” scenario where 50% of children may require
private childcare. This would be double the average for Dublin according to the QHNHS. In that
instance the total number of childcare spaces needed for the proposed development would be c. 30.

However, if one also factors in the potential exclusion of 1-bed and 2-bed units from the calculation
of childcare demand (as promoted in the 2018 national apartment guidelines) then the estimated
private childcare demand for proposed development reduces to just 2 places. Excluding just the one
bed units, suggests the development will generate a demand for c. 18 no. spaces.

                                                                        No. without 1
                                                                        beds and only   No. without 1
                                  Total No. of         No. without 1-   50% of 2 bed    and 2 beds (17
                                 Units (260 no.)       beds (152 no.)      (85no.)           no.)
      Total Population
       Estimate (@2.7                   702                 410             230              46
      Household Size)
 Total Population of 0 - 4
                                        60                  35               20                  4
   years (8.6% Census)
 Total 0-4 Years Requiring
 Private Childcare (QNHS                15                   9               5                   1
            25%)

                                                       13
Total 0-4 Years Requiring
 Private Childcare (Worst                30                   18             10                  2
         Case 50%)
Table 5 Projected Private Childcare Demand for Proposed Development

In summary, the above tables indicate that the likely childcare demand arising out of the proposed
development will be very low and that the total demand will be at worst 30 places if all units are
included. However, when the one and two bed units are excluded, as recommended in the 2018
apartment guidelines, the demand reduces to c. 2 no. childcare spaces. Assuming half of all 2 beds
generate a demand for a childcare space, the worst case scenario is 10 no. childcare spaces arising.

It is noted, according to the survey carried out, that within the existing creches in the wider area there
is an existing confirmed supply of c. 91 no. spaces within2km across the 33 existing facilities. Both the
number of existing facilities, and the existing availability is significant.

It is therefore considered that there will be more than sufficient childcare provision in the local area
to facilitate the (predominantly 1 and 2 bed) development, without the need for an additional on-site
creche.

NEARBY DEVELOPMENTS
The surrounding area has seen significant development, in particular the Parkside lands and the
Clongriffin lands. Both of these lands have undergone development in recent years and both have
received planning permission recently for further development.

The Clongriffin lands include four childcare facilities and the Parkside development includes one
childcare facility. These developments are therefore considered to be self-sufficient in terms of
childcare demand and have therefore not been assessed in detail in this report.

CONCLUSION
From the assessment set out above, it is clear there are c. 91 childcare existing vacant spaces near to
the development, which is significantly in excess of the 30 no. childcare facilities identified in the worst
case scenario. The proposed development, as it is predominantly 1 and 2 bedroom apartment scheme,
is unlikely to generate a significant demand for childcare spaces. It is considered that the development
may generate a need c. 18 no. childcare spaces (worst case scenario, when 1 beds are excluded). The
existing childcare provision in the immediate area will be sufficient to serve this level of demand
without the need for an additional creche facility.

                                                        14
APPENDIX 1: LETTER FROM DCCC OCTOBER 2020

                                     15
APPENDIX 2: LETTER FROM DCCC APRIL 2021

                                      16
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