Environmental Impact Assessment Screening Report - St. Teresa's ...

 
Environmental Impact Assessment Screening Report - St. Teresa's ...
Environmental Impact
Assessment Screening
Report

Proposed SHD

Lands at ‘St. Teresa’s’
Temple Hill, Monkstown,
Blackrock, Co. Dublin

On behalf of
Oval Target Limited

February 2019

                          Planning & Development Consultants
                          63 York Road
                          Dun Laoghaire
                          Co. Dublin

                          www.brockmcclure.ie
Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

1     INTRODUCTION .............................................................................................................................. 2
1.1        Purpose of this Report ...................................................................................................................................2
1.2        EIAR Study Team and Guarantee of Competency and Independence ..................................2
2     METHODOLOGY .............................................................................................................................. 3
2.1        Environmental Directives and Guidance Documents....................................................................3
2.2        Legislative Context ..........................................................................................................................................3
2.3        Proposed Development is Sub-Threshold...........................................................................................3
2.4        Schedule 7 ............................................................................................................................................................4
2.5        The Criteria..........................................................................................................................................................4
3     SCREENING ASSESSMENT................................................................................................................ 7
3.1 Characteristics of Proposed Development..........................................................................................7
  3.1.1 The Size and Design of the Proposed Development .................................................................7
  3.1.2 Cumulation With Other Existing and or Approved Projects ................................................8
  3.1.3 Use Of Natural Resources .................................................................................................................. 12
  3.1.4 Production Of Waste............................................................................................................................ 12
  3.1.5 Pollution and Nuisances .................................................................................................................... 13
  3.1.6 Risk of Accidents .................................................................................................................................... 15
3.2 Location of The Proposed Development ...........................................................................................16
3.3 Type and Characteristics of Potential Impact ................................................................................19
4     ASSESSMENT FINDINGS ................................................................................................................ 27
5     APPENDIX 1 - LIST OF COMPETENT PERSONS ................................................................................ 28

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

1           INTRODUCTION
            This Environmental Impact Assessment Screening Report is prepared as part of a planning
            application submission to An Bord Pleanala for a residential development of 294 residential units, a
            crèche facility and residential club house for lands at St. Teresa’s, Temple Hill, Monkstown,
            Blackrock, Co. Dublin. This report is prepared and lodged on behalf of Oval Target Limited, 1st Floor,
            55 Percy Place, Dublin 4, (D04 CX38).

1.1         Purpose of this Report
            The purpose of this Environmental Impact Assessment Screening Report is to consider whether
            there is any requirement for the preparation of an Environmental Impact Assessment Report (EIAR)
            for the proposed development, the subject of this planning application to An Bord Pleanala.

1.2         EIAR Study Team and Guarantee of Competency and Independence
            This Environmental Impact Assessment Screening Report was completed by a project team led by
            Brock McClure, Planning and Development Consultants, who also prepared the Statement of
            Consistency and Planning Report enclosed with this application.
            The report has been prepared with direct input from the following design team:
                    •    Brock McClure - Planning Consultants
                    •    O’Mahony Pike Architects - Design Architects
                    •    JJ Campbells & Associates - Civil & Structural Engineers
                    •    NRB - Consulting Engineers
                    •    Mitchell & Associates - Landscape Architects
                    •    ARC - Architectural Consultants
                    •    AWN Consulting Ltd - Waste Management
                    •    Scott Cawley - Ecologists
                    •    OCSC - Mechanical & Electrical Engineers
                    •    Searsons - Acoustic Consultants
                    •    The Tree File - Consulting Arborists
                    •    Cathal O’Neill Architects - Conservation
                    •    Frank Myles - Consulting Archaeologists
            In accordance with EIA Directive 2014/52/EU, we confirm that the experts involved in the preparation
                                                                                                           1
            of this EIAR Screening are fully qualified and competent in their relevant areas of expertise. This
            ensures that the information provided to the Board is of a high quality and reliable.

            1
                The qualifications of the design team have been referenced in Appendix 1 attached.

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

2           METHODOLOGY
2.1         Environmental Directives and Guidance Documents
            The screening report is prepared having regard to the requirements of:
                 •    ‘Directive 2011/92/EU’
                 •    ‘Directive EIA 2014/52/EU’
                 •    ‘European Union (Planning and Development) (Environmental Impact Assessment)
                      Regulations 2018’ (“the 2018 Regulations”)
                 •    ‘Guidelines for Planning Authorities and An Bord Pleanala on carrying out Environmental
                      Impact Assessment’ (August 2018) - Department of Housing, Planning and Local
                      Government) (“The Guidance”)
                 •    ‘Government Circular PL05/2018
            Directive EIA 2014/52/EU amends Directive 2011/92/EU. The 2014 directive was required to be
            transposed to EU member states by 16 May 2017, necessitating changes in laws, regulation and
            administrative provisions across a number of legislative codes. This is being done to strengthen the
            EIA procedure and align procedure with principles of smart regulation and enhance coherence and
            synergies with other EU legislation. Consideration must now be given to the new Guidance on the
            new EIAR procedure and requirements.
            This Environmental Impact Assessment Screening Report takes into account relevant changes with
            regard to the screening procedure as detailed within the EIA Directive, as implemented under the
            2018 EIA Regulations.

2.2         Legislative Context
            The legislative context for screening remains as set out in the Planning and Development Act 2000
            (as amended) and the Planning and Development Regulations (2001-2018).
            Schedule 5, Parts 1 and 2 of the Planning and Development Regulations, 2001-2018 set out the types of
            projects and thresholds that require an Environmental Impact Assessment (EIA), now known as an
            Environmental Impact Assessment Report (EIAR) to be undertaken.
            The competent authority in this instance is An Bord Pleanala who can also require an EIAR where a
            project is below the specified threshold2 and where there is a likelihood of significant effects on the
            environment by reference to the nature and location of the proposed project. The criteria for
            determining whether a development is likely to have significant effects on the environment are set
            out in Schedule 7 of the Regulations and in Annex IIA of the 2014 EIA Directive (EIA 2014/52/EU). These
            are assessed in detail in Section 3 below.

2.3         Proposed Development is Sub-Threshold
            The development site is located at ‘St. Teresa’s’, Temple Hill, Blackrock, Co. Dublin. The proposal
            envisaged for the site provides for 294 residential units, a crèche facility and a residential club house
            and is considered sub-threshold having regard to the following Class of development as set out in the
            Regulations under Schedule 5, Part 2:
            10. Infrastructure Projects
                     “ (b)     (i) Construction of more than 500 dwellings”

            2
             ‘sub-threshold development’ means development of a type set out in Schedule 5 which does not exceed a
            quantity, area or other limit specified in that Schedule in respect of the relevant class of development.

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

                                 (iv) Urban development which would involve an area greater than 2 hectares in the case
                                 of a business district, 10 hectares in the case of other parts of a built up area and 20
                                 hectares elsewhere
                        (In this paragraph, business district means a district within a city or town in which the
                        predominant use is retail or commercial use)”
            It is evident from the above that the proposal (294 dwellings, a crèche facility and residential club
            house on a site of 4.56 ha is sub - threshold development for the preparation of an EIAR both in terms
            of the number of units and the area threshold.
            Having regard to the discretionary power of An Bord Pleanala as regards sub-threshold development,
            the Applicant is required to prepare an Environmental Impact Assessment Screening Report to
            provide the information necessary to assist An Bord Pleanala in making a determination on whether
            a sub-threshold development would or would not be likely to have significant effects on the
            environment.
            This criteria for determination of this matter will be outlined in Section 3 below.

2.4         Schedule 7
            Schedule 7 of the Planning and Development Regulations 2001 (as amended) sets out the relevant
            criteria to be applied in the screening process.
            The 2014 Directive (EIA 2014/52/EU) requires the applicant to provide certain information, to allow An
            Bord Pleanala carry out proper screening to determine if an EIAR report is required. This information
            is listed in Annex IIA of the Directive. This requirement is implemented under the Planning and
            Development Regulations, 2001 (“the 2001 Regulations”), as amended, most recently by the European
            Union (Planning and Development) (Environmental Impact Assessment) Regulations 2018 (“the 2018
            Regulations”). The criteria for determining whether development listed in Part 2 of Schedule 5 should
            be subject to an EIA are set out under Schedule 7 of the 2001 Regulations. The purpose of this
            screening exercise is to establish whether there is a need to prepare a sub-threshold EIAR in
            accordance with para. 15 (Schedule 5 Part 2) of the Regulations.
            The information to be provided by the applicant or developer for the purposes of screening sub-
            threshold development for environmental impact assessment is separately set out under Schedule 7A
            of the Planning and Development Regulations, 2001, as amended by the 2018 Regulations.
            However, Paragraph 4 of Schedule 7A requires that: ‘The compilation of the information at paragraphs
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            1 to 3 shall take into account, where relevant, the criteria set out in Schedule 7.’
            In this report, therefore, the information has been set out under the more detailed headings provided
            for under Schedule 7. In effect, this ensures that all of the information required under Schedule 7A
            has been furnished. It also presents the information in a manner that facilitates the competent
            authority in addressing the appropriate criteria in its screening assessment.
            Competent/consent authorities must have regard to these criteria in forming an opinion as to whether
            or not a sub-threshold development is likely to have significant effects on the environment by virtue,
            inter alia, of their nature, size or location should be subject to EIA.

2.5         The Criteria
            Schedule 7 of the Planning and Development Regulations 2001 (as amended) sets out the criteria for
            determining whether a development would or would not be likely to have significant effects on the
            environment as follows:
                   1.    Characteristics of Proposed Development
                   2.    Location of Proposed Development

            3
                Emphasis added

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

                 3.   Types and Characteristics of Potential Impacts
            Each of these categories contains a set of sub-criteria for consideration as follows:

            1.   Characteristics of Proposed Development
            The characteristics of proposed development, in particular:
                 -    the size of the proposed development,
                 -    the cumulation with other proposed development,
                 -    the use of natural resources,
                 -    the production of waste,
                 -    pollution and nuisances,
                 -    the risk of accidents, having regard to substances or technologies used.

            2.   Location of Proposed Development
            The environmental sensitivity of geographical areas likely to be affected by proposed development,
            having regard in particular to:
                 -    the existing land use,
                 -    the relative abundance, quality and regenerative capacity of natural resources in the area,
                 -    the absorption capacity of the natural environment, paying particular attention to the
                      following areas:
                 -    wetlands,
                 -    coastal zones,
                 -    mountain and forest areas,
                 -    nature reserves and parks,
                 -    areas classified or protected under legislation, including special protection areas designated
                      pursuant to Directives 79/409/EEC and 92/43/EEC,
                 -    areas in which the environmental quality standards laid down in legislation of the EU have
                      already been exceeded,
                 -    densely populated areas,
                 -    landscapes of historical, cultural or archaeological significance.

            3.   Types and Characteristics of Potential Impacts
            “The likely significant effects on the environment of proposed development in relation to criteria set
            out under paragraphs 1 and 2, with regard to the impact of the project on the factors specified in
            paragraph (b)(i)(I) to (V) of the definition of ‘environmental impact assessment report’ in section 171A
            of the Act, taking into account—
            (a) the magnitude and spatial extent of the impact (for example, geographical area and size of the
            population likely to be affected),
            (b) the nature of the impact,
            (c) the transboundary nature of the impact,
            (d) the intensity and complexity of the impact,
            (e) the probability of the impact,

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

            (f) the expected onset, duration, frequency and reversibility of the impact,
            (g) the cumulation of the impact with the impact of other existing and/or development the subject of
            a consent for proposed development for the purposes of section 172(1A)(b) of the Act and/or
            development the subject of any development consent for the purposes of the Environmental Impact
            Assessment Directive by or under any other enactment, and
            (h) the possibility of effectively reducing the impact.”

            The applicability of the Schedule 7 criteria to the proposed development is considered below.

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

3           SCREENING ASSESSMENT
            In order to assist An Bord Pleanala in deciding if significant effects on the environment are likely to
            arise in the case of development proposed in this case, the project is described in the following
            sections under each of the three aforementioned headings in Section 2 above.

3.1         Characteristics of Proposed Development
            The first set of criteria under Schedule 7 relates to the “Characteristics of proposed development” -
            The characteristics of proposed development, in particular:
                 -    the size of the proposed development,
                 -    the cumulation with other proposed development,
                 -    the use of natural resources,
                 -    the production of waste,
                 -    pollution and nuisances,
                 -    the risk of accidents, having regard to substances or technologies used.
            We note the following in this regard:

3.1.1       The Size and Design of the Proposed Development
            The development will consist of a new residential scheme of 294 residential units (ranging from 1 - 8
            storeys overall in height) in a combination of new apartment buildings; the subdivision, conversion
            and re-use of ‘St. Teresa’s House’; and the dismantling and relocation of ‘St. Teresa’s Lodge’ within the
            site development area. The demolition (total c. 2,787 sq m GFA) of all later ancillary buildings and
            extensions (buildings vary from 1-3 storeys) associated with ‘St. Teresa’s House’ and ‘St. Teresa’s
            Lodge’ is also proposed. This includes a single storey return on lands at The Alzheimer’s Society of
            Ireland adjoining ‘Building 1’on the subject site.
            A total of 14 new residential blocks (Blocks A1 - E5) comprising 287 new apartment units are proposed
            as follows:
                 •    Block A1 (4 storeys) comprising 29 no. apartments (26 no. 1 bed units and 3 no. 2 bed units).
                 •    Block B1 (7/8 storeys), Block B2 (5/6 storeys), Block B3 (5/6 storeys) and Block B4 (5 storeys)
                      comprising 127 no. apartments (82 no. 1 bed units, 27 no. 2 bed units and 18 no. 3 bed units).
                 •    Blocks C1 - C3 (3 storeys) comprising 14 no. apartments (11 no. 2 bed units and 3 no. 3 bed
                      units).
                 •    Block D1 (5 storeys) comprising 50 no. apartments (15 no. 1 bed units, 23 no. 2 bed units and
                      12 no. 3 bed units).
                 •    Blocks E1 - E3 (2 - 5 storeys) and Blocks E4-E5 (4 storeys) comprising 61 no. apartments (45 no.
                      2 bed units, 16 no. 3 bed units) and 6 no. 3 bed duplex units.
            Each residential unit has associated private open space in the form of a terrace / balcony.
            The development also provides for the subdivision and conversion of ‘St. Teresa’s House’ (3 storeys)
            into 6 no. apartments (5 no. 2 bed units and 1 no. 3 bed unit) including the demolition of non-original
            additions and partitions, removal and relocation of existing doors, re-instatement of blocked up
            windows, replacement of windows, repair and refurbishment of joinery throughout and the upgrade
            of roof finishes and rainwater goods where appropriate. It is also proposed to dismantle and relocate
            ‘St. Teresa’s Lodge’ (1 storey) from its current location to a new location, 66m south within the
            development. St. Teresa’s Lodge will be deconstructed in its original location and reconstructed in a
            new location using original roof timbers, decorative elements and rubble stonework, with original

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

            brickwork cleaned and re-used where appropriate. A non - original extension will be removed and it
            will be converted into 1 no. 1 bed residential unit (c. 39 sq m GFA).
            Public open space is proposed in the form of a woodland park (incorporating an existing folly), play
            areas, courtyards and gardens (c. 14,887 sq m overall). Provision is also made for new pedestrian
            connections to Rockfield Park on the southern site boundary and Temple Hill along the northern site
            boundary.
            The development also provides for a Crèche Facility of c. 286 sq m GFA (and associated outdoor play
            area of c. 225 sq m) located in Block C2 and a Resident’s Clubhouse of c. 136 sq m GFA located within
            Block C3.
            Basement areas are proposed below Blocks A1, B1 to B3 and D1 (c. 6,522 sq m GFA). A total of 272 car
            parking spaces (163 at basement level and 109 at surface level); 666 bicycle spaces (486 at basement
            level and 180 at surface level); and 20 motorcycle spaces at basement level are proposed. The proposal
            also provides for Bin Storage areas and ESB substations.
            The development also comprises works to the existing entrance to St. Teresa’s, Carmond and St
            Vincent’s Park from Temple Hill (N31/R113) including the realignment and upgrade of the existing
            signalised junction and associated footpaths to provide for improved and safer vehicular access/egress
            to the site and improved and safer access/egress for vehicular traffic to/from St Vincent’s Park.
            Emergency vehicular access and pedestrian/cyclist access is also proposed via a secondary long
            established existing access point along Temple Hill.
            Site Development Works are also proposed within the curtilage of existing gates to the north of the
            site (Protected Structure). No works are proposed to these gates as part of this proposal.
            The associated site and infrastructural works include provision for water services; foul and surface
            water drainage and connections; attenuation proposals; permeable paving; all landscaping works;
            green roofs; boundary treatment; internal roads and footpaths; and electrical services including solar
            panels at roof level above Blocks A1, B1 - B4, C1-C3, D1, E1-E5.
            An architectural and masterplanning design statement has been prepared by O’Mahony Pike
            Architects and is included herewith for further detail on the design of the scheme.

            The Nature of any Associated Demolition Works
            The proposed development involves the demolition of (total c. 2,787 sq m GFA) of all ancillary
            buildings and extensions associated with the ‘St. Teresa’s House’ and ‘St. Teresa’s Lodge’ is also
            proposed.
            We note at this time that the Construction Management Plan prepared by JJ Campbell & Associates
            provides a robust strategy for the storing, handling, collection and transport of the wastes
            generated on site during construction and applies appropriate mitigation measures. It is considered
            that there will not be any significant effects on the environment arising from the demolition works
            or disposal of demolition waste.

3.1.2       Cumulation With Other Existing and or Approved Projects
            The Site
            There is no significant or relevant planning history for the subject site.
            The current application is a new proposal for a site that is currently occupied by St. Teresa’s House
            and St. Teresa’s Lodge (referred also to as ‘The Gate Lodge’). The majority of the site is greenfield in
            nature.
            The Surrounding Area
            The following represents the relevant planning history surrounding the subject site:

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

                                                   Figure 1 - Planning History Map

 Map       Planning         Applicant              Description               Decision       Final        Conditions/       An Bord
 Ref.        Ref.                                                                           Grant         Reasons          Pleanala
                                                                                            Date                           Decision
   A       D03A/1047       Alzeheimers      New day car and respite          Granted       02/02/04            -              -
                            Society of      centre and headquarters
                              Ireland        within the walls of the
                                                protected walled
                                             garden. This is a single
                                              storey development,
                                               which includes the
                                                demolition of the
                                            existing greenhouse and
                                                      shed.
   B        05/8208        Alzeheimers          Fire Certificate in          Granted        11/11/05           -              -
                            Society of       relation to D03A/1047
                              Ireland
   C      D05A/0301       Daughters of           Replacement of              Granted       10/06/05            -              -
                          Charity of St.      windows, alterations
                           Vincent De         and renovations to a
                              Paul             protected structure
                                            including disable access,
                                             new fire enclosures and
                                                  new final exit.
   D      D05A/1596        Alzeheimers       Revisions to D03A/1047          Granted       16/03/06            -              -
                            Society of        comprising of: 5sqm
                              Ireland         more space, internal
                                             revisions, removal of 2
                                             car parking spaces and
                                               new retaining walls
   E      D07A/1389       Daughters of       Paving and lighting of a        Granted       14/02/08            -              -
                          Charity of St.     550 sqm area and new
                           Vincent De          manually operated
                              Paul          entrance barrier to form
                                              an overflow car park.

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

   F      D10A/0446        Alzeheimers        New 1.8m high metal            Granted         05/11/10          -             -
                            Society of        railing with vehicular
                              Ireland        entrance adjoining 3.4
                                            metre high granite stone
                                                 wall (protected
                                                    structure).
   G      D18A/0954        Oval Target      A new entrance gateway           Refused         30/11/18       Injure           -
                              Ltd.             comprising of 22.1m                                       amenity to
                                             granite clad piers and a                                   the Rockfield
                                             pair of 1.8m high steel                                      park area.
                                                pedestrian gates.
                                           Table 1 - Planning History for Surrounding Area

            The National Planning Framework
            The National Planning Framework, Project Ireland 2040 and its target for the delivery of new housing
            within existing built up areas and on infill and/or brownfield sites is also considered at this point. The
            Statement of Consistency enclosed herewith clearly sets out the compliance of the development
            with the objectives of this Framework.
            Notably, the following objectives are considered relevant:
            National Policy Objective 1 -
            Planning for a population in the Eastern and Midland Region of 490,000 - 540,000 additional people
            i.e. a population of around 2.85 million;

            National Policy Objective 3a -
            Deliver at least 40% of all new homes nationally, within the built-up footprint of existing settlements.
            National Policy Objective 3b -
            Deliver at least half (50%) of all new homes that are targeted in the five Cities and suburbs of Dublin,
            Cork, Limerick, Galway and Waterford, within their existing built-up footprints.
            National Policy Objective 31 -
            Prioritise the alignment of targeted and planned population and employment growth with
            investment in the provision of childcare facilities and new and refurbished schools on well located
            sites within or close to existing built up areas that meet the diverse needs of local populations.
            National Policy Objective 32 -
            To target the delivery of 550,000 additional households to 2040.
            National Policy Objective 33 -
            Prioritise the provision of new homes at locations that can support sustainable development and at
            an appropriate scale of provision relative to location.
            National Policy Objective 35 -
            Increase residential density in settlements, through a range of measures including reductions in
            vacancy, re-use of existing buildings, infill development schemes, area or site-based regeneration
            and increased building heights.

            It is submitted that the current proposal for c.294 new residential units, a crèche facility and
            residential amenity facility will deliver on the above objectives of the NPF. We note specifically that
            the addition of 294 new residential units will be a modest and proportionate increase to population
            within the Blackrock area. The site is also zoned for residential development and is considered
            appropriately serviced with appropriate infrastructure to deliver on a sustainable residential
            development in close proximity to the main town centre area and public transport nodes.

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

            We submit to An Bord Pleanala that the current proposal is supportive of the objectives of the
            National Planning Framework for 2040.

            Traffic Generation
            An Bord Pleanala will note from a review of the Traffic Assessment submitted by NRB Consulting
            Engineers that traffic generated by the proposed development will be relatively low and is not
            expected to result in a significant impact. We note specifically the following summary from Section
            6.6. of the Transport Assessment:
                    “This report demonstrates that the proposed development will have a negligible impact upon
                    the established local traffic conditions and can easily be accommodated on the road network
                    without any capacity concerns arising. The assessment also confirms that the proposed junction
                    is of sufficient size, and is of more than adequate capacity to accommodate the worst case traffic
                    associated with the proposed development of the St Catherines LAP lands to the south.”
                    (p.18 para 6)

            Ecology Matters
            We refer An Bord Pleanala to the 2 reports prepared by Scott Cawley, which include the following
            concluding comments:
            Natura Impact Statement:
                    “Following an examination, analysis and evaluation of the relevant information including, in
                    particular, the nature of the proposed development and the relationship between the proposed
                    development site and the relevant European sites and, applying the precautionary principle, it is
                    the professional opinion of the authors of this report that there will be no adverse impact on the
                    integrity of any European sites”
                    (p.41, para 2)
                    “A range of precautionary measures have been incorporated into the project design, and other
                    mitigation measures have been developed and proposed, with the purpose of avoiding or
                    minimising impacts on the qualifying interests and conservation objectives of the relevant
                    European sites. The efficacy of these measures was also considered and no issues in respect of
                    their effective implementation were identified.”
                    (p.41, para 5)
            Ecological Impact Assessment:
                    “It can be concluded that the overall ecological implications of the project are limited to local
                    level impacts. Potential significant effects have been identified in the case of habitats, invasive
                    species, bats, badgers and birds. Measures have been provided to reduce the potential impacts
                    on KERs, and to ensure compliance with wildlife law. Nonetheless significant impacts remain
                    likely, albeit at a local scale, in the case of habitats, bats and badgers.”
                    (p. 42, para 3)
            In summary, it is our opinion that having regard to the nature of the proposed development and
            other developments in the general area, that there is not likely to be any significant cumulative
            impacts on the receiving environment.
            Cumulative or in-combination effects will be considered further below.

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

3.1.3       Use Of Natural Resources
            Soil
            As set out by JJ Campbell & Associates, excavated soil will be carefully stored in segregated piles
            on the site and subsequently removed from site for direct beneficial use elsewhere.

            Foul Water and Water Supply
            We can also confirm that there is confirmation of feasibility for the proposed development to
            connect to public water mains and sewers. We refer specifically to the Irish Water Confirmation of
            Feasibility attached to the input from JJ Campbells, which sets out that subject to a valid connection
            agreement being put in place, the proposed connection to Irish Water can be facilitated.

            Gas
            During operational stage, the only potential natural resources utilised will potentially be natural gas
            and water in quantities applicable to the daily operation of the new dwellings, crèche facility and
            residential club house.
            Land, soil and biodiversity are not considered to feature as natural resources used at operational
            stage.

            Energy & Sustainability
            As set out by O’Connor Sutton Cronin, the report entitled ‘Energy and Sustainability Report’ outlines
            how the proposal complies with European Performance of Buildings Directive (EPBD) and Irish
            Regulations (specifically TGD Part L) at operational stage. The conclusions drawn in this report set
            out the following:
                    “The St. Teresa’s residential development will meet or exceed the requirements of the Part L
                    (2018) NZEB standard, which stipulates requirements on minimum renewable contributions,
                    minimum fabric and air permeability requirements, and also the maximum energy use and
                    carbon dioxide emissions allowable.
                    This report confirms that if the strategy is adopted as suggested and properly implemented,
                    then all apartments and dwellings in the St. Teresa’s development will comply with Part L
                    (Conservation of Fuel and Energy) of the Technical Guidance Documents and will also achieve a
                    targeted BER rating of A2/A3 throughout.”
                    (p. 16 paras 5 & 6)
            It is concluded that the proposed development will not involve any significant use of natural
            resources during operational phase having regard to its nature (i.e. a residential development).

3.1.4       Production Of Waste
            The principal objective of sustainable resource and waste management is to use material resources
            more efficiently and to reduce the amount of waste requiring final disposal. However, where residual
            waste is generated, it should be dealt with in a way that follows the national waste hierarchy and
            actively contributes to the economic, social and environmental goals of sustainable development.
            During the construction stage, quantities of construction and demolition related waste will arise. This
            quantum of waste is expected to be minimal. Any waste arising will be re-used, recycled or sent to a
            licensed waste facility.
            The proposed development has been designed to comply with local, regional, and national waste
            legislation along with best practice. All waste generated from the operational phase of this
            development will be sent for reuse, recycling and/or disposal at appropriately licensed waste
            facilities.

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

            We confirm for An Bord Pleanala that this pre-application request is accompanied by the following
            waste documents:
                 •    Construction Management Plan (including a Construction and Demolition Waste
                      Management Plan) prepared by JJ Campbell & Associates.
                 •    Operational Waste Management Plan prepared by AWN Consulting.
            These documents clearly set out how waste will be managed and relevant mitigation measures during
            the construction and operational stages of the project.
            It is considered that there are not likely to be any significant effects on the environment arising from
            the production or disposal of waste.

3.1.5       Pollution and Nuisances
            The only potential sources of pollution from the proposed development will be emissions to air,
            water, and noise pollution.
            The following is proposed in terms of services:

            Water
            A 110mm MDPE pipe (type PE 80 and SDR 11) will be provided, looped around the development to
            serve each unit. Fire hydrants will be provided to ensure that no unit is more than 46m away from an
            accessible hydrant.

            Surface Water Drainage
            It is proposed to separate the storm runoff from the existing and proposed buildings and to use SuDS
            techniques, as per the Greater Dublin Strategic Drainage Study (GDSDS), to control stormwater
            discharge from the site. The proposals are discussed in more detail below. A storm water carrier pipe
            is to be provided around the site to intercept runoff and, where located within filter drains, will be
            perforated pipe.
            Because of the sloping topography of the site it is proposed to make two surface water connections:
            The zones are each approximately 50% of the site area. Surface Water Connection No 1 is for Zone 1
            and connects to the existing public sewer 9002 on the North East side of the site.
            Surface Water Connection No 2 is for Zone 2, 50% of the propose development and connects to the
            existing public sewer manhole on the North corner of the site.

            SUDS
            SUDS measures include:
                 •    Green Roofs
                 •    Permeable Paving
                 •    Attenuation Proposals

            Foul Water Drainage
            The foul drain will connect to the existing 300Ø combined sewer located within the site boundary on
            Temple Hill Road, it then discharges to an existing manhole on the public 1200Ø public combined
            public sewer.

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

            Air & Noise
            There are no envisaged air or noise emissions arising from the residential proposal at this site other
            than noises arising from traffic associated with the development. The crèche facility is a main area of
            focus for noise and appropriate measures are being implemented through the landscaping plan to
            counteract any likely effects.

            Construction Stage
            Conclusion on Pollution and Nuisances: The potential impacts arising during the construction phase can
            be avoided or minimised by adopting the mitigation measures set out in the Construction
            Management Plan (including a Construction and Demolition Waste Management Plan) prepared by
            JJ Campbell & Associates.

            Operational Stage
            Microclimate
            It is considered that there are not likely to be any significant effects on the environment arising from
            pollution or nuisances during the construction or operational phase of the development. This is said
            given there are clear proposals outlined in the Operational Waste Management Plan prepared by
            AWN Consulting.
            With regard to Microclimate specifically, we note the input enclosed from B-Fluid, which concludes
            by noting the following:
            •    “The wind profile was built using the annual average of meteorology data collected at Dublin Airport
                 Weather Station. In particular, the local wind climate was determined from historical meteorological
                 data recorded 10 m above ground level at Dublin Airport.
            •    The site is well surrounded by landscaping. This has a beneficial effect in mitigating the impact of the
                 incoming wind. The prevailing wind directions for the site are identified in the West, West South-
                 West and South-East with magnitude of approximately 6m/s. In all of these directions the
                 development presents a good shielding through landscaping. The trees are beneficial in calming the
                 incoming wind and deviating it.
            •    The site does not include any tall building (such as there are no buildings exceeding 30m of height).
                 The buildings of the development are in line with the surroundings therefore no down-drafts or
                 down-wash effect are expected under these conditions.
            •    The buildings of the development also are all designed to have a larger base in relation to the top roof
                 area. This type of design is well capable of mitigating potential funnelling effect.
            •    Given the position of the development, the major wind directions and the landscaping implemented,
                 issues on the Temple Hill existing footpath (on the North East side of the development) are not
                 expected.”
            With regard to Noise, we note the following summary of notes from Searson & Associates (Non
            Technical Summary):
                    “The existing Noise-scape was assessed via automated and attended noise monitoring with
                    specialist Brüel & Kjær instrumentation.
                    Overall data and specific individual passes of representative vehicles – particularly the heavier
                    goods vehicles, buses and Motor-Cycles - were individually assessed and the type and character
                    of the noise associated with same was carefully explored and analysed.
                    Measurement locations close to the edge of the proposed development and a suitable distance
                    back were taken. Additionally synchronized measurements at this close location and at a notable
                    distance back were taken to enable the screening effect of the retained and preserved building
                    to be taken into account and to be applied to the proposed apartments within the development,
                    close to the amenity areas and designated parkland to be measured.

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

                    Specific attention has been paid to measures which will permit in-bedroom noise levels (when
                    completed) to remain at or below the strictest current guidelines of reputable bodies including
                    the World Health Organization (WHO), the current British Standard Guidelines, Dun Laoghaire
                    and Rathdown County Council’s Guidelines and indeed the TII’s recommendations (which are
                    somewhat less onerous than the WHO’s current guidelines).
                    It is intended - when this development is completed - to have apartments with enhanced
                    quietude from external noise sources, particularly against that emanating from traffic on
                    Temple Hill and indeed traffic movements from within the development. The external noise-
                    scape will be appropriate for outdoor amenity areas.
                    The Construction Noise criteria and hours of work are modelled on those levels deemed
                    appropriate by Transport Infrastructure Ireland (TII) with additional recommendations for
                    particular noisy phases which may occur.
                    It is envisaged that Control and Management measures will enable this project to proceed in a
                    reasoned and reasonable fashion taking into account the amenity of established residents and
                    also enabling best and efficient construction practices to be deployed and adhered to. This will
                    result in minimizing the disruption and disturbance generated. Furthermore the
                    recommendation that noise monitoring at two suitable stations for the duration of the works –
                    the results being made available to nearby residents - demonstrates a commitment to ensuring
                    that best practicable means are demonstrably used to execute this development in a responsible
                    and professional fashion, balancing the amenity of the proximate residents with the exigencies
                    of professional and responsible Engineering construction methods and practices.”

3.1.6       Risk of Accidents
            There is a new requirement under the 2014 EIA Directive and under Schedule 7 of the 2001 Regulations
            to consider the risk of major accidents and/or disasters which are relevant to the project concerned,
            including those caused by climate change, in accordance with scientific knowledge. In addition, the
            risks to human health (for example due to water contamination or air pollution) should be
            considered.
            The technologies involved for the proposed development are low risk and common in all residential
            developments. The end use of the crèche facility will have various health and safety and operational
            protocols to ensure that the risk of accidents is minimised.
            In terms of Flood Risk, we note that there is a detailed and site - specific assessment prepared by JBA,
            which is submitted herewith for reference.
            The concluding points from the Flood Risk Assessment set out the following:
                    “Review of the Eastern CFRAM and DLR SFRA flood maps indicates that the northern boundary of
                    the site is within Flood Zone A (defended)/B. However, based on the site visit and provided
                    calculations, it is confirmed that the development is not at risk from the 0.1% AEP flood event.
                    Flood defences are located along the Carysfort-Maretimo and provides protection from a 1% AEP
                    standard. The 0.1% AEP event will result in inundation of the access road, but floodwaters will be
                    prevented from entering the site.
                    A single apartment block intersects the Flood Zone A/B outline. Residential apartments are
                    restricted to the 1st floor level at 16.48mOD. The proposed basement / ground floor car park
                    entrance is located in Flood Zone C, with a freeboard of 600mm above the estimated 1% AEP flood
                    level. All residential properties onsite are located in Flood Zone C.
                    To mitigate against the identified flood risks, it is necessary to provide a barrier to the ingress of
                    floodwater to the basement car park. This can be achieved by raising the proposed carpark
                    entrance to provide a 400mm freeboard of over the expected 0.1% AEP flood level. The kerbs along
                    the car park entrance should be set to a level of 12.95mOD. All openings to the basement in this
                    area should be raised to a minimum of 400mm over the existing ground level.
                    A stormwater system has been designed to manage surface water runoff from the site. An
                    attenuation tank is included as part of the design and has a storage capacity of 1,650m3/s to retain

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

                     a 100 year rainfall event, including a 20% allowance for climate change. Stormwater discharge will
                     be limited to the site's greenfield equivalent of 12.4l/s. In addition, green roofs have been provided
                     in the apartment blocks cover a minimum of 60% of the roof area, which will not be connected to
                     the stormwater system. Permeable paving has also been provided.
                     Residual risks have been identified as potential increase in stream flow & frequency of flooding
                     resulting from climate change and failure of the Carysfort-Maretimo flood defences. The proposed
                     mitigation measures above are sufficient to protect the site from the identified residual risks.
                     As a result of the analysis, design and mitigation measures the proposed development is
                     considered to be in line with the core principles of the Planning Guidelines and objectives outlined
                     in the DLR Development Plan 2016-2022.”
            It is our considered view that there will be no risks to Human Health as a result of the proposed
            development nor are there any risks of major accidents or disasters as a result of climate change.

3.2         Location of The Proposed Development
            The second set of criteria under Schedule 7 relates to environmental sensitivity of geographical areas
            likely to be affected by the proposed development.
            The following section therefore reviews the sensitivity of the receiving environment, under prescribed
            criteria under Schedule 7 of the Planning and Development Regulations 2001-2018, namely:
            The environmental sensitivity of geographical areas likely to be affected by proposed development,
            having regard in particular to:
                 -    the existing land use,
                 -    the relative abundance, quality and regenerative capacity of natural resources in the area,
                 -    the absorption capacity of the natural environment, paying particular attention to the following
                      areas:
                      a) wetlands,
                      b) coastal zones,
                      c)   mountain and forest areas,
                      d) nature reserves and parks,
                      e) areas classified or protected under legislation, including special protection areas designated
                         pursuant to Directives 79/409/EEC and 92/43/EEC,
                      f)   areas in which the environmental quality standards laid down in legislation of the EU have
                           already been exceeded,
                      g) densely populated areas,
                      h) landscapes of historical, cultural or archaeological significance.

            Existing Land Use
            The proposed development will be located on a mostly greenfield site at St. Teresa’s, Temple Hill,
            Blackrock, Co. Dublin. The site is bounded to the north by Temple Hill Road, with mature residential
            development to the East and the Alzheimer’s Society of Ireland to the West. The site is within 1km of
            Blackrock Village and has high accessibility to public transport. The N31 (Temple Hill Road) is
            designated as a proposed QBC and both Blackrock and Seapoint DART stations are within easy walking
            distance.
            The surrounding area can be characterised as a mostly suburban environment.
            The site is identified by the relevant statutory context as being capable of accommodating residential
            development of the form and quantum currently proposed, by way of the residential zoning governing

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

            the site. We are of the opinion that the proposal will not have any significant effect on the surrounding
            uses and that the proposed development has been well designed internally to ensure that residential
            amenities within the development are protected.

            The Relative Abundance, Quality and Regenerative Capacity of Natural Resources in the Area
            Having regard to the character of the receiving environment and the surrounding area, the proposed
            development it is considered that the proposed development, individually or cumulatively, will not
            have any impact on the relative abundance, quality and regenerative capacity of natural resources in
            the area.
            We refer An Bord Pleanala to the detailed landscape strategy prepared by Mitchell & Associates, which
            clearly outlines that an exceptional landscaping design has been prepared for this site.
            We note also that there are no Natura 2000 sites immediately adjacent to the subject site. We confirm
            that this planning application is accompanied by a Natura Impact Statement prepared by Scott Cawley,
            which addresses the matter of Natura 2000 sites in detail.
            In terms of land and soil, the site is greenfield in nature. The Natura Impact Statement submitted
            herewith addresses considerations in terms of potential impacts on European sites arising from the
            proposed development. An Ecological Impact Assessment Report has also been prepared by Scott
            Cawley and addresses considerations in terms of Biodiversity.
            We refer An Bord Pleanala to the 2 reports prepared by Scott Cawley, which include the following
            concluding comments:
            Natura Impact Statement:
                    “Following an examination, analysis and evaluation of the relevant information including, in
                    particular, the nature of the proposed development and the relationship between the proposed
                    development site and the relevant European sites and, applying the precautionary principle, it is
                    the professional opinion of the authors of this report that there will be no adverse impact on the
                    integrity of any European sites”
                    (p.41, para 2)
                    “A range of precautionary measures have been incorporated into the project design, and other
                    mitigation measures have been developed and proposed, with the purpose of avoiding or
                    minimising impacts on the qualifying interests and conservation objectives of the relevant
                    European sites. The efficacy of these measures was also considered and no issues in respect of
                    their effective implementation were identified.”
                    (p.41, para 5)
            Ecological Impact Assessment:
                    “It can be concluded that the overall ecological implications of the project are limited to local
                    level impacts. Potential significant effects have been identified in the case of habitats, invasive
                    species, bats, badgers and birds. Measures have been provided to reduce the potential impacts
                    on KERs, and to ensure compliance with wildlife law. Nonetheless significant impacts remain
                    likely, albeit at a local scale, in the case of habitats, bats and badgers.”
                    (p. 42, para 3)
            The buildings on site consist of St Teresa’s (A Protected Structure), which is a 3 storey Victorian House
            with associated Gate Lodge and Entrance (also a Protected Structure) at the main entrance to the site
            off Temple Hill Road. There are a number of ancillary buildings linked to St Teresa’s, which are later
            additions of no particular architectural character or merit in this case.
            Matters of Conservation are addressed under separate cover by Cathal O’Neill Conservation Advisers
            as part of this submission. The Conservation Advisers have set out that “There is unlikely to be any
            significant impact on the Environment arising out of works to Protected Structures, subject to the
            implementation of the measures described in the Construction Management Plan.”

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

            Furthermore, it has been set out that it is not likely that any archaeological remains will be found on
            the subject site. The Desktop Study prepared by Archaeology and Built Heritage enclosed herewith
            makes the following conclusion in this regard:
                    “The site inspection, cartographic analysis and historical background would all suggest that the
                    risk of encountering archaeological deposits or artefacts on the site is medium to low; however,
                    the lack of any modern ground works or construction disturbance over the area to the west and
                    southwest of St. Teresa’s House would serve to protect any sub-surface stratigraphy present.
                    On the basis of there being a) a Protected Structure on site and b) the size of the site being
                    developed, is recommended that a programme of licensed test trenching be undertaken to
                    identify and quantify any archaeological deposits which may have a sub- surface survival. Due to
                    the granite bedrock underlying the site, geophysical prospection is unlikely to produce any valid
                    responses.
                    It is recommended that the granite folly identified over the site inspection be protected over the
                    course of development works with heavy-duty plywood fitted with inspection holes, with an
                    inspection log maintained by an appointed individual. The structure should be cleared of
                    vegetation, consolidated and repointed as necessary and preserved in the public realm. In
                    addition, it is suggested that the surviving historic boundaries being retained be consolidated
                    where required, using a lime-based mortar.
                    Although there will be no ground disturbance per se, particular care should be taken when the
                    southern boundary wall is being reduced over the area of the cemetery marked on the Ordnance
                    Survey. This can be achieved by placing heavy plywood boards on the ground as the upper courses
                    of the wall are being dismantled.”
            The applicant is amenable to addressing the recommendations outlined in this report.
            It is therefore our considered view that there are no environmentally sensitive elements in the
            immediately adjoining geographical areas, that are likely to be affected in a significant manner by the
            proposed development.

            The absorption capacity of the natural environment, paying particular attention to the following
            areas:
                      i)   wetlands,
                      j)   coastal zones,
                      k) mountain and forest areas,
                      l)   nature reserves and parks,
                      m) areas classified or protected under legislation, including special protection areas designated
                         pursuant to Directives 79/409/EEC and 92/43/EEC,
                      n) areas in which the environmental quality standards laid down in legislation of the EU have
                         already been exceeded,
                      o) densely populated areas,
                      p) landscapes of historical, cultural or archaeological significance.
            The accompanying reports submitted herewith, have clearly set out that the natural environment can
            easily absorb the proposed development.
            Notably, the reports and documentation prepared by JJ Campbell & Associates (Services and
            Construction Management), Mitchell & Associates (Landscape), Cathal O’Neill Architects
            (Conservation), Scott Cawley (Ecology/Biodiversity), O’Connor Sutton Cronin (Energy &
            Sustainability), NRB Consulting Engineers (Traffic Matters), AWN (Operational Waste Management)
            and Frank Myles (Archaeology) confirm that the proposal can be easily accommodated.

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Environmental Impact Assessment Screening Report - Lands at ‘St. Teresa’s’ Temple Hill, Monkstown, Blackrock, Co. Dublin

            We refer An Bord Pleanala to these documents enclosed herewith for further consideration of this
            matter.

3.3         Type and Characteristics of Potential Impact
            The final set of criteria to be considered under Schedule 7 relates to the characteristics of the potential
            impact and the location of the proposed development having particular regard to the following
            matters:
                       “The likely significant effects on the environment of proposed development in relation to criteria
                       set out under paragraphs 1 and 2, with regard to the impact of the project on the factors specified
                       in paragraph (b)(i)(I) to (V) of the definition of ‘environmental impact assessment report’ in
                       section 171A of the Act, taking into account—
                       (a) the magnitude and spatial extent of the impact (for example, geographical area and size of the
                       population likely to be affected),
                       (b) the nature of the impact,
                       (c) the transboundary nature of the impact,
                       (d) the intensity and complexity of the impact,
                       (e) the probability of the impact,
                       (f) the expected onset, duration, frequency and reversibility of the impact,
                       (g) the cumulation of the impact with the impact of other existing and/or development the subject
                       of a consent for proposed development for the purposes of section 172(1A)(b) of the Act and/or
                       development the subject of any development consent for the purposes of the Environmental
                       Impact Assessment Directive by or under any other enactment, and
                       (h) the possibility of effectively reducing the impact.”
            We have already given consideration, under the above Sections, to the effects of the proposed
            development in the context of the criteria listed under paragraph 1 and paragraph 2 of Schedule 7 (i.e.
            characteristics of the proposed development and the location of the proposed development).
            Further detail is now provided, as required by the Schedule criteria, on the aspects of the environment
            referred to under section 171A of the 2000 Act.

            Section 171A of Planning and Development Act 2000, as amended
            The effects of the proposed development on the following factors needs to be evaluated in an
            “environmental impact assessment” as defined under Section 171A of the 2000 Act:
                 i.     “population and human health;
                ii.     biodiversity, with particular attention to species and habitats protected under the Habitats
                        Directive and the Birds Directive;
                iii.    land, soil, water, air and climate;
                iv.     material assets, cultural heritage and the landscape;
                v.      the interaction between the factors mentioned in clauses (I) to (IV)” (Section 171A of Planning
                                                               4
                        and Development Acts 2000 as amended ).
            The above topics are considered below.

            4
             As amended by Article 16 of the European Union (Planning and Development ) (Environmental Impact Assessment)
            Regulations 2018.

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