CHILDCARE CAPACITY ASSESSMENT - PROPOSED RESIDENTIAL DEVELOPMENT AT A SITE AT BALSCADDEN ROAD & THE FORMER BAILY COURT HOTEL, MAIN ST., HOWTH ...

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CHILDCARE CAPACITY ASSESSMENT - PROPOSED RESIDENTIAL DEVELOPMENT AT A SITE AT BALSCADDEN ROAD & THE FORMER BAILY COURT HOTEL, MAIN ST., HOWTH ...
CHILDCARE CAPACITY ASSESSMENT
PROPOSED RESIDENTIAL DEVELOPMENT AT A SITE AT BALSCADDEN
ROAD & THE FORMER BAILY COURT HOTEL, MAIN ST., HOWTH,
COUNTY DUBLIN.

                                               May 2018
CHILDCARE CAPACITY ASSESSMENT - PROPOSED RESIDENTIAL DEVELOPMENT AT A SITE AT BALSCADDEN ROAD & THE FORMER BAILY COURT HOTEL, MAIN ST., HOWTH ...
Contents
Introduction ............................................................................................................................................ 2
Policy Context: Fingal County Development Plan 2017-2023 ................................................................ 3
Policy Context: Childcare Facilities Guidelines for Planning Authorities (2001) ..................................... 4
Policy Context: Sustainable Urban Housing: Design Standards for New Apartments Guidelines for
Planning Authorities 2018....................................................................................................................... 5
Demand for Childcare Places likely to be Generated by Proposed Scheme........................................... 6
Subject Study Area & Existing Service Provision ..................................................................................... 7
General Demand and Service Provision Details provided by Giraffe.................................................... 13
Viable and Sustainable Childcare Facilities ........................................................................................... 14
Future Provision .................................................................................................................................... 15
Conclusion ............................................................................................................................................. 15

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CHILDCARE CAPACITY ASSESSMENT - PROPOSED RESIDENTIAL DEVELOPMENT AT A SITE AT BALSCADDEN ROAD & THE FORMER BAILY COURT HOTEL, MAIN ST., HOWTH ...
Introduction
This report has been prepared in response to the Opinion of the Board under Case Reference: ABP-
300879-18 in relation to a proposed Strategic Housing Development application at a site at the Former
Baily Court Hotel, Main Street and lands located south of the Martello Tower on Balscadden Road,
Howth, Co. Dublin.

The opinion did not specifically request a childcare demand analysis and the likely demand for
childcare places resulting from the proposed development. However, as a childcare facility is no longer
proposed as had previously been the case during pre-application consultation, a childcare demand
assessment report is submitted to provide a rationale for non-provision.

This report has been prepared with regard to the Fingal County Council Development Plan 2017 – 2023
(hereinafter Development Plan) and The Childcare Facilities Guidelines for Planning Authorities (2001).
The Report examines the existing level of childcare provision and options within proximity to a
proposed development of 164 no. units at a c.1.55 hectare site.

The report assesses the vacancy rates within local childcare facilities and to determine if the demand
for places generated by the proposed development can be accommodated within the existing
childcare facility provision. This Report also examines proposed childcare facilities likely to be
delivered in the short to medium term with consideration to the need to avoid over provision of
services within the catchment area.

The Updated Apartment Guidelines 2018 are also noted. These note 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. Commercial viability thresholds are at 80-100 children.

                                                                                                     2
Policy Context: Fingal County Development Plan 2017-2023
The Fingal County Development Plan 2017 – 2023 (hereinafter Development Plan) states that:

        “The provision of childcare facilities is an important factor for economic and social wellbeing.
        The National Anti-Poverty Strategy 2007-2016 states that the provision of childcare is essential
        to enable parents to participate in the workforce and to obtain an income that provides an
        acceptable standard of living for both them and their children. Quality childcare can also make
        a significant contribution to child development in the early years of a child’s life. Currently
        Fingal County Childcare Committee supports a childcare infrastructure of 364 early childhood
        facilities that collectively employ in excess of 3,000 staff.

        Current issues in general childcare provision include lack of affordable, accessible community
        based childcare services and before and after school childcare services in urban and rural areas
        of Fingal, particularly in the vicinity of Swords. These services are vital in assisting people to
        return to work and to facilitate training for persons in long term unemployment. There is also
        increased demand for school age childcare and wrap around provision such as breakfast clubs,
        homework clubs and summer camps as parents are returning to the workforce. While
        the Council is not directly involved in the provision of childcare services, the Development Plan
        seeks to ensure that sufficient facilities are provided particularly in newly developing areas.”

The Development Plan Objectives in this section are as follows:

                                                                                                           3
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”. 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 [emphasis added]”, (Childcare Facilities Guidelines for Planning Authorities, 2001, p.9).

We would therefore caution against utilising an approach which requires a crèche facility for
effectively every apartment scheme in the county. We note the decision of An Bord Pleanala to grant
permission for a change of use of a permitted crèche to office space at a site in Sandyford Industrial
Estate (Reg. Ref. D15A/0032; ABP Ref. PL06D.224737 refers). This crèche had been lying vacant since
its construction. The Inspector notes that ‘the very act of providing space for such use does not
guarantee that it will be used for such’. We would argue therefore that it is not the intention of the
Childcare Guidelines to provide small scale inefficient crèches within every building or development
regardless of the need and provision elsewhere.

This point is emphasised by The Building Resource Manual Project Management Guidelines for the
Construction, Refurbishment or Extension of Childcare Facilities (page 5) states that:

        “It is essential to be clear about the extent of the need for childcare in the area, both at present
        and in the future. Gathering accurate and real information about the area, will provide clear
        direction when the building project moves to more advanced stages. It will enable the
        management committee to ensure the facility built matches clearly with the current and future
        needs of the community”.

There are a number of a reasons by which it may not be appropriate or necessary to provide a childcare
facility within a new residential scheme of over 75 no. dwellings and it is respectfully submitted that
there is a clear justification for the omission of a childcare facility in this case.

                                                                                                          4
Policy Context: Sustainable Urban Housing: Design Standards for New
Apartments Guidelines for Planning Authorities 2018
The recently published Sustainable Urban Housing: Design Standards for New Apartments Guidelines
for Planning Authorities 2018 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 approaching 20 years since publication. Section 4.7 of the Draft Guidelines state
as follows:

        ‘4.7 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.’ (Emphasis added).

The majority of units proposed are 1 and 2 bedrooms (84%) and therefore this emerging policy stance
should be considered by An Bord Pleanala.

It should be noted that 40 of the 164 apartment units are 1beds (24.4%) with a further 97 or 59.1% of
the total being 2 beds.

The potential for children to be living in the scheme is therefore limited to 124no. units in accordance
with new Guidelines.

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 childcare operators and local letting
agents that there was a lack of demand for the type of childcare facility which could reasonably be
accommodated on the subject site. As planning has moved into an ‘‘evidence-based’’ era, the evidence
to date does not present the demand for a viable childcare facility.

                                                                                                       5
Demand for Childcare Places likely to be Generated by Proposed
Scheme
The proposed development at the Howth/Cluxton/Baily Court site provides for 164 no. dwelling units.

A summary schedule is shown below. As outlined above, 1bed units are excluded from the assessment
as per the updated apartment guidelines 2018.

                              2 Bed Units           97           78.22%
                              3 Bed Units           27           19.77%
                                  Total            124            100%
The assessment has assumed an occupancy rate of 2.1 persons per apartment as per the results of
Census 2016 resulting in a development population of 261 persons.

In 2016, approximately 7% of the national population was of pre-school age (0 – 4). The application of
this rate to the projected population of 261 no. persons gives a likely childcare demand of 19no. places

It is important to note that Census 2016 demonstrates that there has been a fall of 24,814 persons in
the 0-4 age group primarily due to a fall in births since 2009 and as such, it is submitted that the
demand for 19no. spaces is likely to be an over estimate.

In order to provide a viable and efficient business, childcare operators providing full day care services
generally require a minimum of 80 childcare places. As such, it is clear that a standalone facility located
within the subject site would not present a viability business opportunity and is unlikely to be pursued
by an operator. Therefore, it is necessary to examine if sufficient childcare services are available in the
local area in order to accommodate the demand generated by the proposed scheme.

                                                                                                         6
Subject Study Area & Existing Service Provision
A catchment area has been proposed to include the subject Howth Electoral District (ED). The ED
examined and the childcare facilities located here are shown in Fig. 1 listed below:

                                                                       Subject Development Site

          Figure 1: Catchment Area of Howth ED and subject site. Childcare facilities contacted are indicated.

Childcare Facilities listed in the Howth ED on the Pobal mapping system are as follows:

    1.   Sutton Playgroup
    2.   Little Rainbows (Sutton)
    3.   The Cottage Montessori
    4.   Deerpark Montessori
    5.   Howth Pre-school Playgroup
    6.   Bracken Hill Nursery School
    7.   Bumblebee Montessori and Childcare – Sutton Park

A further childcare facility located just outside the Howth ED within the Sutton ED was also contacted:

    8. Rainbow Sutton Montessori

                                                                                                                 7
Subject Development Site

   Figure 2: Map of the existing childcare service provision in the Howth ED according to the Pobal mapping database.

There are 7 no. childcare facilities operating within the catchment area as shown above in Fig. 2. One
additional facility was also contacted located just outside the catchment in the Sutton ED.

The Fingal Childcare Committee were also contacted to ascertain the information they hold in relation
to childcare numbers and capacity in the catchment.

Fingal Childcare Committee

Prior to contacting individual premises, the applicant contacted the Fingal County Childcare
Committee (DLRCC) to ascertain capacity and vacancy rates in the catchment area. The response was
as follows:

        ‘‘I have gathered some information regarding Early Years Services and the Howth area, ED
        4024.

        At present there are 4 session services providing care within that area. Sessional care is up to
        3hrs 30mins and all of these services are participating in ECCE and 3 are also participating in
        CCSP DCYA funded programmes. I have attached the Tusla Preschool service list for the Dublin
        region were you will be able to see where these services are located.

        We would not have information on capacity – future or current, current availability or
        estimated capacity for September 2018 in 2019. We rely on Pobal to gather this information
        based on Service profile information that they gather from individual services. The latest Pobal
        ‘Early Years Sector Profile 2016/2017’ details the following stats for Fingal:

              •   Number and percentage of ECCE places in Fingal = 9,372 (95% private/5% community)
                  – Fingal is the 3rd largest registration of children nationally behind Cork and Dublin City

                                                                                                                        8
•   Number and percentage of registrations CCS for Fingal = 171 (63%) CCSP places for
                 Fingal = 99 (37%)
             •   Number and percentage of TEC registrations for Fingal = 552 (8%) of 7,344 national
                 registrations. Fingal have the highest amount of TEC registrations nationally
             •   According to the DCYA Early Years Sector Profile 2016/2017, the number of vacant
                 places as a percentage of children enrolled in Fingal are as follows:

                 10,564 enrolled, 637 vacant places (6% availability, one of the lowest figures
                 nationally)

        If you wish you can view the full Early Years Sector Profile by following this link -
        https://www.pobal.ie/Publications/Documents/Early%20Years%20Sector%20Profile%20Rep
        ort%202016-2017.pdf

        Also, we find the CSO statistics very useful, you may be able to source some information
        regarding family structure and type of childcare that parents access’’.

The information received from the Fingal County Childcare Committee indicated a low rate of vacant
childcare places in Fingal County. Specific information in relation to facilities located in the Howth ED
was not provided, however.

Following this, the Applicant undertook email consultations with local operators in April and May 2018
in order to understand local demand and capacity.

It is important to note that many operators organise their capacity numbers and staffing prior to the
commencement of the school year in order to ensure that the optimum use is made from their facility
according to demand i.e. additional demand for baby places would require increased staffing due to
smaller staff-child ratios.

The below list of questions were put to local operators:

        ‘I am writing in relation to a proposed residential development at a site at the Former Baily
        Court Hotel, Main Street and lands located south of the Martello Tower on Balscadden Road,
        Howth, Co. Dublin.

         Prior to submitting a planning application for this development we have been requested by
        An Bord Pleanala to examine the childcare services and capacity available in the Howth and
        surrounding areas.

         I was wondering would you have any information in relation to this? If available would I be
        able to get an indication of the below:

         1. Max childcare number capacity possible within the facility.

                                                                                                       9
2. Current number/capacity take up within the facility

        3. Type of childcare services provided and age ranges provided for.

        4. Times of different childcare services provided daily.

        5. Capacity within different services/age groups and whether any current availability.

        6. Estimated capacity situation in September 2018 and September 2019?

        7. Would you be interested in seeing another childcare facility in the area?’

The below table demonstrates that there is expected to be capacity within existing services to cater
for the demand generated by the proposed development. It is noted that the September 2018 date
should be considered as a general indicator of availability as children are usually booked into a
childcare facility one year in advance of beginning attendance and hence cannot be ascertained for
the design year of the proposed development.

8 operators were contacted via email and phone. 3 of which issued responses containing enrolment
numbers broadly in line with the questions asked. Table 1 below presents the results of this survey.
The Pobal /Census figure of 6% vacancy in Fingal County was used to estimate available capacity in
the remaining facilities.

Giraffe, a large childcare company with interests in the area were previously contacted by the
applicant provide more general information in relation to childcare supply and demand. Their
response is also detailed below.

Considering that the proposed development will result in a demand for a maximum of just 19 no.
places, it is respectfully submitted that the provision of a purpose built facility is unwarranted and may
result in an untenantable building.

The below table demonstrates that there is expected to be capacity within existing services to cater
for the demand generated by the proposed development.

It is submitted that there is ample capacity to facilitate the estimated demand of 19 no. places within
existing services.

                                                                                                       10
5. Capacity within
                                1.Max childcare       2. Current                 3. Type of childcare            4. Times of
                                                                                                                                    different                            6. Estimated
                                number capacity       unoccupied rate            services provided and           different                                                                       7. Would you be interested in seeing another
        Question Asked                                                                                                              services/age groups                  capacity situation in
                                possible within       /available                 age ranges provided             childcare services                                                              childcare facility in the area?
                                                                                                                                    and whether any                      2018/2019.
                                the facility.         numbers                    for.                            provided daily.
                                                                                                                                    current availability.
                                                                                 Childcare 9 months to 5
                                                         15 full day care
                                                                                 years,                                                    Availability only for                                 Open to the development of a commercially viable
                                                              places                                                                                                     Full from September
     Little Rainbows (Sutton)           50                                       ECCE class 3-5 years,           7.45am to 6pm             part time ECCE places                                 facility that would be built in accordance with
                                                       7 part time places                                                                                                2018 onwards.
                                                                                 After-School 5 years to                                   and some after-school                                 current childcare regulations and community needs.
                                                      2 after-school places
 1                                                                               8 years.
                                                                                                                                                          As before.
                                                                                                                 Morning Class 9am
                                                                               Sessional Montessori                                6 places in the        September 2019:
       Rainbow Montessori                                  45 (2 children                                        – 12 and Afternoon                                                              Full time childcare needed for new residential
                                        44                                     Pre School/2years – 6                               afternoon class for    Unknown as numbers
               Sutton                                    sharing 1 place).                                       Class 12.30-3.30pm                                                              development.
                                                                               years                                               September 2018         fluctuate from year to
                                                                                                                 Monday – Friday
 2                                                                                                                                                        year.
                                                                                                           Half Day:                                      Full for 2018.
        Bracken Hill Nursery
                                                                               Aged 2 yrs. and 9mths       5 days a week from                             No fixed numbers yet
               School
 3                                      55                       53            up to 5                     8:50 to 12:10           N/A                    for 2019.                              No
No response was received from the below facilities. The total capacity figures, times and age group figure were generally taken from the respective facilities websites.
The response figures have been assumed at the Fingal county wide rate of 6% vacancy (*)
In the case of The Cottage Montessori the size of the facility has been estimated as per the average size of facility in the catchment (X)
                                                                                                                 9.00 am to 12.30
                                                                                                                 four days a week-
      Deerpark Montessori               22                     20*               2.1/2 years to 5 years.         Monday to
                                                                                                                                           N/A                           N/A                     N/A
 4                                                                                                               Thursday

        Sutton Playgroup                                                                                                                   N/A                           N/A                     N/A
 5                                      24                     22*               N/A                             Sessional
                                                                                                                 Sessional
     The Cottage Montessori                                                      ECCE                            9:15am – 12:45pm
 6                                      36x                    33*               2.6-5 year age range            Monday to Friday          N/A                           N/A                     N/A
                                                                                                                 9:00 > 12:00
        Howth pre-school                                                                                         Sessional
           playgroup                                                                                             (Morning)
 7                                      20                     18*               2.5 Yrs > 4.5 Yrs               Monday to Friday          N/A                           N/A                     N/A
                                                                                 6months up to
     Bumblebee Montessori                                                        Afterschool age (11
         & Childcare                                                             years)
 8                                      36x                    33*               ECCE                            7.45am-6.15pm             N/A                           N/A                     N/A

Total capacity/potentially available Childcare Numbers in respondent facilities                                                                                                                                                                   287
Total Available Childcare Numbers in respondent facilities                                                                                                                                                                                         29
Total Available Childcare Numbers as a % of Capacity                                                                                                                                                                                              10%

                                                                              Figure 3: May 2018 Capacity Survey. Note: The figures provided were in some cases were estimated.

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As no response was received from 5 of the 8 potential facilities, it was decided to use an estimate of
capacity in the remaining facilities in conjunction with the information provided by the Fingal Childcare
Committee and the Census.

The Fingal Childcare Committee stated a rate of 6% vacancy exists in childcare facilities in the County
as per the Pobal ‘Early Years Sector Profile 2016/2017’.

As only 3.6% of the population of Howth are of pre-school age (ages 0-4) which is considerably lower
than the national figure of 7% (Census 2016), it is submitted that the potential childcare demand
generated by the proposed development can be easily subsumed in the existing and planned serviced
provision in the area.

There are approximately 29no. spaces available in the area based on the information provided. This
represents 10% of the potential overall capacity in Howth ED.

The estimated 19 childcare space demand generated by the proposed development (i.e. 7% of the
estimated development population) can therefore be accommodated in the existing surrounding
facilities.

In addition, there are at least a further 3 childcare facilities planned or granted permission in the
Howth area as will be expanded upon below.

Considering that the proposed development will result in a demand for just 19 no. places, it is
respectfully submitted that the provision of a purpose built facility is unwarranted and may result in
an untenantable building.

Additional correspondence was previously received by Marlet/Crekav from Giraffe childcare which is
a major service provider in the Dublin area. The information provided childcare service provision
generally and is outlined below.

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General Demand and Service Provision Details provided by Giraffe
Marlet Property Group previously received correspondence from Giraffe Childcare correspondence
relation to childcare service provision generally.

It is important to note that a parent/guardian will not necessarily use the creche in the vicinity of their
home and will instead utilise facilities on their work commute route. Any potential demand from the
proposed development will therefore be comfortably subsumed into existing facilities in the Dublin
area. See Giraffe commentary below (emphasis added):

    ➢ Commuting parents will not always use the crèche nearest their home and their choice while
        be dictated by quite a number of factors will be heavily influenced by where they work and
        convenience of pick up by second parent, grand parent or guardian.
    ➢ The duration of a child’s stay in a care setting is largely predicated on the primary care parent’s
        employment and lifestyle choice. This is usually the mother. The factors influencing this can
        be the arrival of a second child and there being a preference by one of the parents to stay at
        home and be a full-time parent or to reduce their working hours with a knock-on effect on
        childcare requirements. This is also influenced during second pregnancies where the first child
        or older siblings are typically kept at home while on maternity leave. This can be a cost
        consideration or a life style choice. As Giraffe are often dealing with young parents at an early
        stage of establishing home or career there is a higher instance of families moving house or
        parents changing jobs.
    ➢ Given these circumstances the average length of stay for a child in crèche, attending full day
        care is circa 24 months.
    ➢ Therefore unlike a primary school, where a child joins and attends for eight years, a crèche
        will cater for a high churn rate of up to 65% with new families consisting of young children,
        joining and leaving on average every two years, and also a new intake of 3 year old children
        attending under the free ECCE preschool scheme each year from September to June.
    ➢ In looking at demand for childcare in any given area, it is important to carry out an analysis of
        the demographics and socio-economic profile of the residents of the greater catchment as
        their childcare requirements will vary.
    ➢ There can be a wide variation of factors influencing demand.
    ➢ Attendances in the summer typically fall to 60% of year-round main. This is because the
        current occupancies include children attending under the ECCE free preschool scheme, for 38
        weeks of the year. These children leave the crèche in June. Fee revenue from the free
        preschool scheme is considerably less than the normal full day care fees. Also there is an

                                                                                                        13
average of 25% to 35% of the overall crèche population moving to big school in any one year
        which is also a very large contributor to the churn rate.
    ➢ Giraffe were keen to state the creation of small individual development specific childcare
        facilities /creches to the required numbers in accordance with the current guidelines, as it
        will be unsustainable and ‘will only contribute to the fragmentation that already bedevils
        the sector’.
    ➢ The demand created by the proposed development will be easily catered for by existing
        providers through the wider catchment.

Viable and Sustainable Childcare Facilities
According to the representative of Giraffe childcare, any new Childcare Centres should be designed to
cater for a critical mass and not be built under 500 sq. meters as this leads to further unsustainable
supply and is a wasted resource.

A 500 sqm creche would accommodate approximately 80 children based on projects elsewhere. 19
childcare places have been calculated for the proposed development.

As noted, childcare facilities need to be +500 sqm in order to ensure a sustainable and viable service.
To provide a 500 sqm creche to cater for 19 children is simply not viable nor is it in accordance with
proper planning and sustainable development. It will also risk the fragmentation and reduce viability
of existing and future planned purpose-built facilities in the surrounding area. A development of
approximately 300 units (or 380 units including one beds) would generate a demand for a facility of
500 sqm / 80 children.

It should also be noted that as this is a suburban location, the large majority of end users will be
travelling to employment centres elsewhere and will thus use childcare facilities located proximate to
same as noted in the Giraffe childcare correspondence.

A small facility of 200sqm would need to be provided to cater for a potential maximum demand of 19
children. Such a facility would likely be unable to find an end user and will thus become unviable and
lie vacant. As noted above there are approximately 29 available places in the 8 respondent facilities
which can accommodate the relatively insubstantial demand.

It is therefore imperative that potential required childcare places are accommodated elsewhere in
existing or already planned future facilities.

                                                                                                    14
Future Provision
The Applicant has also had consideration to any other significant residential development proposed
in the locality and notes that larger residential schemes proposed for the provision of a childcare
facility which will also likely contribute to the overall quantum of childcare places available.

In addition, a number of planning applications for childcare that been recently granted including:

    ➢ Reg. Ref. F11A/0028/E1 = Techrete site. Crèche size of c.314 sq.m.
    ➢ Reg. Ref. F15A/0362 = Creche development at a site on the Howth Road, Howth.
    ➢ Reg. Ref. F17A/0615 = Development proposed by Parsis Limited for 96 no. dwelling units to
        include a crèche at lands that formerly formed part of Santa Sabina Dominican College &
        Convent Complex, Greenfield Road, Sutton, Dublin 13.

Conclusion
This report identifies that a demand of c.19 no. childcare places is likely to be generated by the
proposed development. Following an assessment of existing facilities in the local area, it is clear that
a significant vacancy rate of exists within full time, purpose built facilities which will easily cater for
the insubstantial demand potentially generated from the proposed development.

Therefore, there is no compelling case for an additional childcare facility on the site and the provision
of such a facility may adversely affect existing childcare facilities in the area.

Further to this, it should be noted that Giraffe childcare have previously stated that it cannot see the
merit of building a crèche to the required numbers in accordance to the planning guidelines, as it will
be unsustainable and will only contribute to the fragmentation that already bedevils the sector. The
demand created by the Howth/Balscadden development will be easily catered for by existing
providers through the wider catchment.

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