Housing Development at Trusky East, Bearna, Co. Galway

Housing Development at Trusky East, Bearna, Co. Galway

Housing Development at Trusky East, Bearna, Co. Galway Statement of Consistency

Housing Development at Trusky East, Bearna, Co. Galway

180226 - Housing Development Trusky East, Bearna Statement of Consistency DOCUMENT DETAILS Client: Burkeway Homes Limited Project title: Housing Development at Trusky East, Bearna Co. Galway Project Number: 180226 Document Title: Housing Development Trusky East, Bearna Statement of Consistency Doc. File Name: SHDSOC F1-2018.02.20-180226 Prepared By: McCarthy Keville O’Sullivan Ltd. Planning & Environmental Consultants Block 1, G.F.S.C. Moneenageisha Road, Galway Document Issue: Rev Status Issue Date Document File Name Author(s) Approved By: 01 Draft 20.03.2018 SHDSOC D1-2018.03.20-180226 CH CR/GMcC 01 Final 30.07.2018 SHDSOC F1-2018.07.11-180226 CH GMcC

Housing Development at Trusky East, Bearna, Co. Galway

180226 - Housing Development Trusky East, Bearna Statement of Consistency Table of Contents 1 Introduction ___ 1
1.1 Preamble ___ 1
1.2 PrePlanning Consultations ___ 1
1.2.1 Galway County Council ___ 1
1.2.2 Other preplanning consultations ___ 2
1.2.3 Consultation with An Bord Pleanala and Galway County Council ___ 2
1.3 Site Location and Context ___ 3
1.4 Proposed Development ___ 4
1.5 Planning History ___ 5
1.5.1 Overview of previous application submitted under Planning Reference ABP- 300009-17 ___ 5
1.5.2 Other Relevant Planning History ___ 6
1.6 Designations, Flooding and Heritage ___ 8
1.6.1 Natura 2000 sites ___ 8
1.6.2 Flooding ___ 8
1.6.3 Historic Environment and Built Heritage ___ 9
2 Planning Policy Context ___ 10
2.1 National Planning Framework ___ 10
2.2 Regional Planning Guidelines for the West Region 2010-2022 ___ 10
2.3 Sustainable Residential Development in Urban Areas Guidelines (Cities, Towns & Villages), 2009 ___ 10
2.4 Galway County Development Plan 2015-2021 ___ 11
2.5 Variation No.2(a) to the Galway County Development Plan 2015-2021 (Bearna Plan) 11 2.6 Galway Transportation and Planning Study ___ 12
2.7 Gaeltacht Local Area Plan 2008-2018 ___ 12
2.8 Galway County Council Development Contribution Scheme 2016 ___ 12
3 Planning Compliance ASsessment ___ 13
3.1 Principle of the Proposed Development ___ 13
3.1.1 Variation No.2(a) to the Galway County Development Plan 2015-2021 ___ 13
3.1.1.1 Residential Development Phasing ___ 17
3.2 Compliance with Core Strategy ___ 17
3.2.1 Assessment of current Phase 1 allocated lands in Bearna ___ 18
3.2.2 Assessment of current Phase 1 allocated lands in Oranmore ___ 21
3.3 Design Approach ___ 23
3.3.1 House Types ___ 25
3.3.2 Private and Communal Open Space ___ 26
3.3.2.1 Communal Open Space ___ 26
3.3.2.2 Private Open Space .

Housing Development at Trusky East, Bearna, Co. Galway

180226 - Housing Development Trusky East, Bearna Statement of Consistency 3.3.3 Demolition of Existing Derelict Shed ___ 27
3.3.4 Community Room ___ 27
3.3.5 Crèche ___ 27
3.4 Traffic and Transport ___ 28
3.4.1 Compliance with Design Manual for Urban Roads and Streets ___ 28
3.4.2 Car Parking ___ 29
3.4.3 Roads and Footpaths ___ 29
3.5 Landscape Character and Views ___ 30
3.6 Impact on the Gaeltacht ___ 30
3.7 Part V Requirements ___ 31
3.8 Water Services ___ 32
3.9 Flood Risk ___ 32
3.10 Ecology and Natura 2000 Sites ___ 32
3.11 Landscaping ___ 32
3.12 Community Gain ___ 33
3.13 Development Contributions ___ 33
4 Conclusion ___ 35
1 Assessment of Potential Environmental Impacts ___ 37
1.1 Legislative Context ___ 37
1.2 Screening for Mandatory EIA ___ 37
1.3 Information Required by Annex II (A) of 2014/52/EU ___ 38
1.3.1 Physical Characteristics of the Project ___ 38
1.3.2 Location of the Project, with regard to the Environmental Sensitivities of Geographical Areas Likely to be Affected ___ 39
1.3.3 Description of Aspects of the Environment likely to be Significantly affected by the Project ___ 40
1.4 Screening Statement with Reference to Annex III EU Directive 2014/52/EU ___ 43
1.5 Screening for Sub-threshold EIA and Conclusion ___ 49
Appendices Appendix 1 Assessment of Potential Environmental Impacts Appendix 2 Statement of Consistency

Housing Development at Trusky East, Bearna, Co. Galway

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 1 1 INTRODUCTION 1.1 Preamble This Statement of Consistency, which has been prepared by McCarthy Keville O’Sullivan (MKO), supports an application to An Bord Pleanala (ABP) under the Planning and Development Act 2000 (As amended by the Residential Tenancies Act 2016). This application is made pursuant to a Notice of PreApplication Consultation Opinion Issued by the Board on 25 May 2018 (Ref. ABP-301346-18). The proposed residential development has been prepared in accordance with the Ministerial Guidelines, the requirements of Galway County Development Plan 2015- 2021, and the Variation No.2(a) to the Galway County Development Plan 2015-2021.

This Statement of Consistency also includes details in respect of the proposed development in relation to the site location and context, the development description and the relevant planning history and compliance with the development plan policies. This report provides a comprehensive assessment of the proposed development’s consistency with the relevant planning policy documents at national, regional and local levels. The following policy documents are considered in both the main body of the report and the appendices;  Project Ireland 2040 National Planning Framework;  Action Plan for Housing and Homeless, Rebuilding Ireland, July 2016;  Sustainable Residential Development in Urban Areas Guidelines 2009 and the associated Urban Design Manual;  Sustainable Urban Housing – Design Standards for New Apartments (2015);  Childcare Facilities Guidelines for Planning Authorities (2001)  Smarter Travel – A New Transport Policy for Ireland (2009-2020);  Appropriate Assessment of Plans and Projects in Ireland – Guidance for Planning Authorities (2009);  Design Manual for Urban Roads and Streets (2013);  Regional Planning Guidelines for the West Region 2010-2022;  Galway County Development Plan 2015-2021; and 1.2 PrePlanning Consultations 1.2.1 Galway County Council Prior to the submission of this request to enter into pre-planning consultation with ABP, the applicant team, on 15th March 2018, undertook formal pre-planning consultations with Galway County Council.

The pre-planning meeting primarily focused upon the following:  Overview of An Bord Pleanála Decision Ref. 300009-17;  Site Layout;  Development Mix;  Density;  Open Space;  Site Access and Services;  Pedestrian Connectivity and discussion of the implementation of Option 5

Housing Development at Trusky East, Bearna, Co. Galway

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 2 as outlined in the previous application (Pl. Ref. 300009-17);  Part V. A note of the pre-planning discussion, prepared by McCarthy Keville O’Sullivan accompanies this request. 1.2.2 Other preplanning consultations In advance of the submission of this Section 5 request to enter into preplanning consultations, discussions were held with the following stakeholders Table 1.2: Consultees/ Stakeholders Description of development  Galway County Council (Roads)  Galway County Council (Housing)  Irish Water  Inland Fisheries Ireland 1.2.3 Consultation with An Bord Pleanala and Galway County Council: Following consultations with Galway County Council, a request to enter into preplanning consultations with ABP was submitted on 29th March 2018 and a preplanning consultation meeting was held on 4th May 2018.

An Bord Pleanala issued a Notice of PreApplication Consultation Opinion on 25th May 2018, which identified three items to be addressed, in order for the application to constitute the reasonable basis for a Strategic Housing Application. These Items were as follows: Three items were identified to addressed and were as follows:  Item 1: Layout - Dwelling unit distribution;  Item 2: Movement through the site;  Item 3: Connections to Bearna Village Centre; The Board also requested, pursuant to article 285(5)(b) of the Planning and Development Act 2000 (As amended by the Residential Tenancies Act 2016), the provision of the following specific information; 1.

A site layout plan outlining those units located within the residential zoned lands and within the Environmental Management Zone in the context of zoning provisions within the current Bearna Local Area Plan; 2. Full and complete drawings, including levels and cross sections showing the relationship between the proposed development and existing Heather Hill (Cnoc Fraoigh) housing estate to the west; 3. Relevant photomontage images that show the proposed development from a variety of viewpoint locations around Bearna Village should be provided; 4. Childcare demand analysis and the likely demand for childcare places resulting from the proposed development.

In the event that a creche facility is not proposed a detailed assessment of the existing and likely future provision of childcare facilities in the area and how these would meet demand; 5. Detailed analysis that shows the achievement of an acceptable residential density, in terms of gross and net residential density per hectare. The inclusion, or otherwise, of open space within these calculations should be clearly justified at application stage;

Housing Development at Trusky East, Bearna, Co. Galway

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 3 6. A schedule of accommodation and a long-term management and maintenance structures plan, in accordance with section 6 of the Sustainable Urban Housing: Design Standards for New Apartments Guidelines for Planning Authorities 2018; 7. A Construction and Demolition Waste Management Plan; 8. Detailed phasing plan, that demonstrates the provision of suitable and appropriate levels of public open space and mix of house types in each phase; 9. Sufficiently detailed drawings that show the proposed pedestrian and vehicular bridges over the Trusky stream; 10.

Details, including photographic samples, of the materials, colours and textures of all the external finishes to the proposed buildings, having regard to the need for low maintenance/high quality finishes that take account of the climatic characteristics of the area.

A Statement of Response has been prepared by MKO, detailing how each of the items outlined in the pre-application consultation opinion from An Bord Pleanála (APB) have been addressed in full by the applicant and design team prior to lodgement of this application to ABP. 1.3 Site Location and Context The subject site is located in Bearna, a coastal village, approximately 6 kilometres to the west of Galway City. The site is accessed via an existing residential development at Trusky East, called Cnoc Fraoigh. The subject lands measure 7.2 hectares in area, are generally arranged in a rough inverted L shape and is at a broadly similar level to the adjacent residential development.

The site is currently formed of scrubland and rough agricultural grazing and the lands are generally bounded to the north, east and south by existing stone walls. The western boundary is generally defined by a 2-metre-high block wall to the rear of the existing dwellings at Cnoc Fraoigh and to the north west by native stone walls. The site is traversed in a north-south direction by the Trusky East stream. The location of the proposed site in the context of the available aerial photography is shown in Figure 1.1 below.

Figure 1.1 – Site Location Plan (Site Boundary Indicative Only)

Housing Development at Trusky East, Bearna, Co. Galway

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd.

4 1.4 Proposed Development The development will consist of the demolition of existing outbuildings and the construction of 197 No. new dwellings comprising  2 no. 4 bed detached dwelling houses (Type 2);  1 no. 4 bed detached dwelling houses (Type 2A);  5 no. 4 bed detached dwelling houses (Type 4);  3 no. 4 bed detached dwelling houses (Type 4A);  12 no. 4 bed semi-detached dwelling houses (Type 5);  3 no. 4 bed semi-detached dwelling houses (Type 5A);  1 no. 4 bed semi-detached dwelling houses (Type 5C);  1 no. 4 bed semi-detached dwelling houses (Type 5D);  1 no. 4 bed semi-detached dwelling houses (Type 5E);  31 no.

3 bed semi-detached dwelling houses (Type 6);  7 no. 3 bed semi-detached dwelling houses (Type 6A);  4 no. 2 bed two storey terraced houses (Type 7);  2 no. 3 bed two storey terraced houses (Type 7A);  16 no. 3 bed two storey terraced houses (Type 9);  6 no. 3 bed two storey terraced houses (Type 9 A);  12 no. 3 bed two storey terraced houses (Type 9 B); A total of 10 no. apartment blocks are also proposed, ranging between three and four storeys in height, and which contain a total of 9 no. 1 bed apartments, 51 no. 2 bed apartments and 6 no. 3 bed apartments. The apartment blocks also contain 24 no.

3 bed duplex / own door apartment units.

The proposed development also includes the construction 1 no single storey multipurpose community room, 3 no. vehicular and 4 no. pedestrian link bridges, provision of visitor parking areas, associated bicycle and bin storage areas, public realm landscaping including shared public open space and public lighting, decommissioning an existing wastewater treatment plant, provision of all associated surface water and foul drainage services and connections, ancillary to the residential development, pedestrian and vehicular access from the L-1321 via the Cnoc Froaigh development located immediately west of the proposed site as well as all associated site development works and services.

It should also be noted that a communal sewage treatment plant which serves the existing 21 dwellings within the Cnoc Fraoigh estate adjacent to the application site will be decommissioned and fully removed from the site. Wastewater from all the existing and new dwellings will connect to the existing village pipe network which is connected to the main Galway City Sewage Treatment Plant. A preconnection enquiry letter from Irish Water confirms that there is sufficient capacity within the existing network to accommodate the proposed development.

Housing Development at Trusky East, Bearna, Co. Galway

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd.

5 1.5 Planning History 1.5.1 Overview of previous application submitted under Planning Reference ABP-300009-17 Following consultations with Galway County Council, a request to enter into preplanning consultations with An Bord Pleanala (The Board) was submitted on 27 August 2017 and a subsequent preplanning consultation meeting was held on 4 September 2017. The Board issued a Notice of PreApplication Consultation Opinion on 21 September 2017, which stated that the Board ‘is of the opinion that the documents submitted with the request to enter into consultations require further consideration and amendment to constitute a reasonable basis for an application for strategic housing development’.

Four items were identified to addressed and were as follows:  Density;  Connections to Bearna Village Centre;  Public Open Space;  Flooding. An application was submitted to An Bord Pleanala on the 23rd October 2017, following which comments were received from three prescribed bodies being;  Minister for Culture, Heritage and the Gaeltacht (Development Applications Unit);  Údarás na Gaeltachta;  Irish Water No objections were raised to the proposed development from any prescribed bodies. A number of third party submissions were received, primarily from persons with an address in the Cnoc Fraoigh residential development and related to the following:  Principle of development  Access and Transportation  Drainage/Flooding  Amenity On 6th February 2018, planning permission was refused for a 113-unit Strategic Housing Development.

In their direction, the Board considered that the “density of the proposed development was contrary to the provisions of the Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas (2009), which was not considered to be developed at a sufficiently high density to provide for an acceptable efficiency in serviceable land usage given the proximity of the site to the built-up area of Beama and Galway City”. Furthermore, it was considered that the “development as proposed did not have an adequate mix of dwelling types, being predominantly semi-detached and detached housing”.

The current application has been designed to specifically address the concerns of An Bord Pleanala.

Housing Development at Trusky East, Bearna, Co. Galway

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 6 1.5.2 Other Relevant Planning History Table 1.2 below provides a list of the other relevant planning applications in the vicinity of the subject lands and has been compiled following a review of Galway County Council’s Planning Register in respect of the subject lands: Table 1.2: Subject and adjoining Lands - Planning History Planning Ref Applicant Description of development Decision 03/4315 C & T Development Ltd.

Application for the demolition of existing dwelling, construction of 22 no. 2 storey dwellings with treatment plant and associated site works Granted 04/3846 C & T Developments Ltd Application for replacing two storey semidetached dwellings with 5 no. detached two storey dwellings, revised boundaries/driveways to sites 9 to 16 and associated external works (gross floor space 5320sqm) Granted 04/4249 C & T Developments Ltd Application for construction of 15 no. two storey dwellings and associated external works at previously granted residential development (03/4315) Refused 06/903 C & T Developments Application to relocate a wastewater treatment system (originally granted under planning permission no's 03/4315 and 04/3846) Granted 09/1278 Liam O'Toole Application for the demolition of 3 No.

sheds/outbuildings, the construction of 94 No. dwellings comprising of; 54 No. two storey semidetached units, 20 No. two storey terrace units comprising of 5 No. terrace blocks, 16 No. two storey detached units, 4 No. bungalow units, 3 No. two and a half storey buildings comprising of 5 No. Granted by Galway County Council but refused by An Bord Pleanála (under reference no Pl. 07. 236240),

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 7 Planning Ref Applicant Description of development Decision commercial/retail units, 10 No.

apartments and a creche, the provision of parking and ancillary delivery areas, the construction of 3 No. link bridges, 4 No. ancillary storage area ABP- 300009- 17 Burkeway Homes Limited The demolition of existing outbuildings and the construction of 113 No. new dwelling houses comprising; 46 no. 2 storey detached units; 64 no. 2 storey semi-detached units, and 3 no. 2 storey terraced units. The proposed development also includes the construction of 2 no. vehicular and 6 no. pedestrian link bridges, provision of visitor parking areas, public realm landscaping including shared public open space and public lighting, decommissioning an existing wastewater treatment plant, provision of all associated surface water and foul drainage services and connections, ancillary to the residential development, pedestrian and vehicular access from the L-1321 via the Cnoc Froaigh development located immediately west of the proposed site as well as all associated site development works and services.

Refused by An Bord Pleanala on 6th February 2018 As can be seen from the above summary of planning history, there are a total of six separate relevant planning applications associated with the subject lands and the adjacent residential development. The existing Cnoc Fraoigh houses were developed under the terms of Pl. Ref. No’s. 03/4315 and 04/3846 and, in addition, the waste water treatment plant was permitted under Pl. Ref. No. 06/903. Permission was refused for 96 dwellings (incl. commercial/ retail development) on the subject lands under Pl. Ref. 09/1278 and An Bord Pleanála Ref. no: PL 07.236240.

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 8 this case, a recommendation to grant permission was made by Galway County Council subject to 31 no. conditions. This decision was then the subject of the 3rd party appeal and the sole reason for refusal related to sewerage capacity and reads as follows: ‘It is proposed to treat the effluent from the proposed development in an on-site wastewater treatment plant, prior to discharge of the effluent to Mutton Island Sewerage Treatment Plant via a pumping station in Bearna. Having regard to the limited capacity of the Mutton Island Sewerage Treatment Plant to accommodate the additional hydraulic loading the proposed development would generate, the proposed development would pose an unacceptable risk of water pollution and would be prejudicial to public health.

The proposed development, by itself and the undesirable precedent it would set for similar such piecemeal development, would be premature, pending the upgrading of the existing Mutton Island Sewerage Treatment Plant or the operation of an alternative public sewerage treatment plant for the Bearna area. The proposed development would, therefore, be contrary to the proper planning and sustainable development of the area.’ The current design team have however engaged in consultations with Irish Water who have confirmed that there is sufficient capacity to accommodate the proposed development and accordingly the reason for refusal, as outlined above has been overcome.

1.6 Designations, Flooding and Heritage 1.6.1 Natura 2000 sites: The subject land is not located within the boundary of any Natura 2000 sites. There are however a number of designated areas located within the vicinity of application site, which include the following; Table 1.3: Designated Sites Site Name and Code Distance from the proposed development Galway Bay Complex SAC (000268) 1.2 km east Inner Galway Bay SPA (004031) 1.3 km east In this regard an Ecological Impact Assessment and an Appropriate Assessment Screening Report have been prepared to accompany this application and more detail is given in respect of this matter later in this report.

In addition, a Bat Survey was carried out by MKO, which concluded that the “development of this site for residential housing will have negligible effect on the local bat populations” and the existing outbuilding does not support any bat roosts.

1.6.2 Flooding: Portions of the site are identified as being located within Flood Zone A (1:100 year flood risk) and Flood Zone B (1:1000 year flood risk) respectively. A Floodrisk Assessment, prepared by O’Connor Sutton Cronin & Associates, accompanies this application. In relation to flooding it is also noted that as part of the previous application, a number of submissions highlighted flood risk and included photos that appeared to show flooding to the south-eastern corner of the subject site, adjacent to the existing Cnoc Fraoigh estate.

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd.

9 O’Connor Sutton Cronin (OCSC) have carried out a review (See Section 4.3 of the – Site Specific Flood risk Assessment) of the photos of apparent flooding at the site, and have confirmed that the source of the water was unrelated to the Trusky East Stream and was caused as a result of the topography of the site preventing rainwater from the Cnoc Fraoigh estate draining into the adjacent watercourse. Furthermore, OCSC have confirmed that this can and has been resolved as part of the surface water drainage design.

It should also be noted that as part of the previous SHD application (ABP-300009-17), both Galway County Council and the Board’s Inspector reviewed and discounted issues of potential flooding on the subject site, outside of the site specific identified flood zones. 1.6.3 Historic Environment and Built Heritage: A desktop review of the National Monuments survey mapping indicates that there are no archaeological records on the site. Furthermore, the site does not contain any structures included within the Record of Protected Structures (RPS) which accompanies the Galway County Development Plan.

As part of the most recent application on the subject site, the scheme was reviewed by the Development Applications Unit of the Department of Culture, Heritage and the Gaeltacht. In this regard, no objections were raised in relation to proposed development, in terms of impact on National Monuments.

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 10 2 PLANNING POLICY CONTEXT 2.1 National Planning Framework The Department of Housing, Planning, Community and Local Government recently published the National Planning Framework (NPF) entitled ‘Ireland 2040‘’ to succeed the NSS. The NPF comprises the Government’s proposed long-term strategic planning framework to guide national, regional and local planning and investment decisions over the next 25 years. The NPF is a high-level document which provides a framework for future development and investment in Ireland, providing a long-term and placebased aspect to public policy and investment, and aiming to coordinate sectoral areas such as housing, jobs, transport, education, health, environment, energy and communications, into an overall coherent strategy.

2.2 Regional Planning Guidelines for the West Region 2010-2022 The Regional Planning Guidelines (RPGs) for the West Region have given effect to national population targets assigned by the Department of the Environment, Community and Local Government, by designating a maximum target at County level, as outlined within the Galway County Development Plan. 2.3 Sustainable Residential Development in Urban Areas Guidelines (Cities, Towns & Villages), 2009 Bearna is located approximately 6km from Galway city, and is identified in the Galway County Development Plan (GCDP) as being located within Tier 1 - Galway Metropolitan Area (GMA), which is an identified gateway and vital economic driver for the entire West region.

The GCDP states that significant employers include large public service and industrial organisations that draw employees for the network of satellite towns surrounding the City.

Section 2.6.2 of the GCDP states in relation to the GMA, the future prosperity of towns and villages near the city and the quality of life of people living within the commuter band around Galway city depend on the gateway and GMA retaining its dynamic growth trend. It continues by stating that given it attracts significant inward investment and is a provider of regional services and facilities it is essential that the regional settlement strategy provides for the sustainable, dynamic development of the Galway Gateway and GMA to support the economic growth of the region.

The Board, in the previous SHD application (ABP-300009-17) acknowledged the “disparity between the vision for Bearna as set out in the ‘Strategic Vision for Bearna’ as outlined in the LAP and its role as set out in the County Development Plan, top of the hierarchy as part of the GMA”.

It was further noted that, in isolation, Bearna reads as a village/small town with a population of less than 2000 persons, however, in the Inspectors opinion, “it shouldn’t be examined in such isolation and should instead be assessed more strategically in terms of its role within the county hierarchy.” In this regard, the inspector concluded that the subject site should be classified as an ‘Outer Suburban/Greenfield’ site associated with cities and larger towns, with a density in the general range of 35-50 dwellings per hectare as per Section 5.11 of the guidelines.

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 11 The proposed development has a development density of 35 units per hectare when calculated based upon net development area, which excludes the OS zone which dissects the subject site. The proposed development therefore complies with the Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas’ (May 2009). 2.4 Galway County Development Plan 2015-2021 The overall development context of Bearna is set within the context of the County Development Plan and the site is governed by the policies and provisions contained in the Galway County Development Plan 2015-2021 (CDP).

The extant plan was adopted by the Members of Galway County Council on 26th January 2015 and the Plan is effective from 23rd February 2015. The CDP sets out an overall strategy for the proper planning and sustainable development of the functional area of Galway County Council. Chapter 2 sets out the overarching Spatial Strategy of the County, references the development options considered for the growth and details the preferred development option chosen. It details the Core Strategy, and sets out the application of regional population targets to the settlement hierarchy determined as part of the Spatial Strategy.

The Core Strategy is an integral component of the Spatial Strategy. It transposes the population targets for Galway set out in the Regional Planning Guidelines and allocates them throughout the County, which in turn determines the Settlement Hierarchy and provides a rationale for the amount and location of land required to accommodate the anticipated growth..

The Core Strategy Table in the current CDP includes a list of all key towns and larger villages and provides a population growth allocation for each for the period 2015 to 2021. The Core Strategy Table also includes an assessment of the quantum of residentially-zoned land available to meet the population growth allocation. Bearna along with Oranmore forms part of the Galway Metropolitan Area, which is on the first tier in the settlement hierarchy and has a total population allocation of 1,590 people under the Core Strategy in the Galway CDP.

2.5 Variation No.2(a) to the Galway County Development Plan 2015- 2021 (Bearna Plan) On the 23rd July 2018, Variation No.2(a) to the Galway County Development Plan 2015- 2021 was adopted by Galway County Council, which incorporated the Bearna Plan into the GCDP.

Accordingly, the proposed site is governed by the policies and provisions contained in the Bearna Plan. The Bearna Plan is underpinned by a common vision to guide the future growth, development and improvement of Bearna in a manner that is sustainable, achieves the overall objectives set for Bearna in the Galway CDP, including the Core Strategy; and reflects the existing landscape, environment, heritage, character and amenity of the village with the stated aim of improving the quality of life of the local community. The application site is subject to the following zonings:  RResidential (Phase 1);  OSOpen Space Recreation & Amenity;

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 12 The subject site is comprised of lands that are zoned for development within the Bearna Plan. The provisions and specific objectives of these zonings are discussed in section 3.1 below. 2.6 Galway Transportation and Planning Study The Galway Transportation and Planning Study (GTPS) was adopted in 1999 and later updated in 2003. This strategy sets out the spatial planning and transportation strategy for the future of the GTPS area.

Bearna is located within the GTPS area and is subject to the development policies and objectives that apply in this area under the Galway CDP.

2.7 Gaeltacht Local Area Plan 2008-2018 The subject lands, and the wider Bearna Village, are located within the Gaeltacht Area. There is a requirement under the Galway County Development Plan 2015-2021 and the existing Gaeltacht Local Area Plan to reserve 20% of all permitted dwellings for native Irish speakers within the Bearna area. Section 5.4.2.1 (C) of the Gaeltacht Local Area Plan reads as follows: “Within the Local Area Plan boundaries of Maigh Cuilinn, Bearna and Baile Chláir a Language Enurement Clause will be applied to 20% of the units in residential developments of two or more units and will be of 15 years duration.” Further to the above, 20% of any residential development on the subject lands (i.e.

23 dwellings) will required to be reserved for Irish speakers and this will be secured by way of a legal agreement attached to any planning permission. 2.8 Galway County Council Development Contribution Scheme 2016 The Galway County Development Contribution Scheme 2016, as adopted under Section 48, Planning & Development Act 2000 (as amended) outlines the monetary contributions which are required to be made by applicants in respect of the provision of certain public infrastructure and facilities provided by, or on behalf of, the local authority that generally benefit development in the area.

An assessment of the financial requirements for the development as proposed is included in Section 3.11 of this report.

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 13 3 PLANNING COMPLIANCE ASSESSMENT Having regard to the relevant policies pertaining to the subject site, the nature and scale of the proposed development and the nature of development in the immediate vicinity of the site, the key matters relating to the proposed development can be assessed under the following headings:  Principle of the proposed development  Design Approach  Transport  Landscape Character and Views  Impact on the Gaeltacht  Part V requirements  Water Services  Flood Risk  Ecology & Natura 2000 Sites  Landscaping  Community Gain  Development Contributions 3.1 Principle of the Proposed Development 3.1.1 Variation No.2(a) to the Galway County Development Plan 2015-2021 On the 23rd July 2018, Variation No.2(a) to the Galway County Development Plan 2015- 2021 was adopted by Galway County Council, which incorporated the Bearna Plan into the GCDP.

Accordingly, the proposed site is governed by the policies and provisions contained in the Bearna Plan.

Figure 3.1 : Extract from the Zoning Map, Bearna Plan

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 14 The vast majority of the site is located within the ‘R’ – Residential (Phase 1) which has the following stated objective: Objective LU2 - Residential (R): “Promote the development of appropriate and serviced lands to provide for high quality, well laid out and well landscaped sustainable residential communities with an appropriate mix of housing types and densities, together with complementary land uses such as community facilities, local services and public transport facilities, to serve the residential population of the area.

Protect existing residential amenities and facilitate compatible and appropriately designed new infill development, in accordance with the proper planning and sustainable development of the area.” As identified in Figure 3.1 above, the subject site is traversed in a north-south direction by the Trusky Stream and associated flood zone and a central portion of the site, following the course of the stream, is zoned as part of the overall OSOpen Space Recreation & Amenity. Objective LU5 seeks to “Promote the development of open spaces and recreational activities in accordance with best practice and on suitable lands with adequate access to the local community and retain existing open space and recreational facilities, unless it can be demonstrated to the satisfaction of Galway County Council that these uses are no longer required by the community.

Ensure that any flood risk areas within the OS zone are appropriately managed to avoid, reduce and/or mitigate, as appropriate, the risk and potential impact of flooding.” The proposed scheme comprises the development of 197 no. residential units and a community room on the lands zoned for ‘RResidential Phase 1’. No buildings development is proposed on the ‘OS’ designated land. The development proposal includes for landscaping improvements to the ‘OS’ lands to enhance the setting of the Trusky Stream, which dissects the application site. The development of a greenfield site on residential zoned land accords with the ‘R’ (Phase 1) residential zoning and ‘Objective RD1 – Residential Development Phasing of the plan, which requires that development be directed into lands which are zoned and serviced.

Accordingly, this report considers the development is acceptable in principle. As can be seen from Figures 3.1 above, the application site is dissected by the OS designation which is associated with the route of the Trusky Stream. As detailed within Figure 3.2 below a central tenant of the design scheme has been to respect the nature and character of the existing stream and to ensure that all required measures relating to flood risk are accommodated. Accordingly, no buildings would be located within the OSOpen Space Recreation & Amenity lands.

There would however be associated infrastructure located within the central OS zoning including roads, footpaths, bridges and carparking. It is noted the Bearna Plan permits Utilities Infrastructure with this zone subject to flood risk assessment. In this regard, the application is accompanied by a Site-Specific Flood Risk Assessment (SSFRA) which takes account of the utilities infrastructure within the OS zone. It is noted that at the meeting of Galway County Council on 23rd July 2018 “Objective CCF6- Inappropriate Development on Flood Zones” was inserted into the Bearna Plan. This objective stated that “where development/land use is proposed that is inappropriate within the Flood Zone, then the development proposal will need to be accompanied by a detailed hydrological assessment and robust SUDS design which demonstrates the capacity to withstand potential flood events to maintain water quality and avoid potential effects to ecological features “.

Objective CCF6 also outlines a

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 15 number of criteria which are to be met as part of a planning application, within lands that are subject to objective CCF 6. These include the following;  Any development proposals should be considered with caution and will be required to comply with The Planning System and Flood Risk Management Guidelines for Planning Authorities/Circular PL2/2014 and the associated Development Management Justification Test;  Climate Change should be duly considered in any development proposal;  Protect the riparian zones of watercourse systems throughout the plan area through a general 10 metre protection buffer from rivers within the plan area as measured from the near river bank, (this distance may be increased and decreased on a site by site basis, as appropriate);  Any development proposals submitted for this site will require a detailed ecological report(s), carried out by suitably qualified personnel for the purposes of informing Appropriate Assessment Screening by Galway County Council, the competent authority (in accordance with Objective OS 6 of the Galway CCDP 2015-2021);  The relevant lands will be outlined and flagged with a symbol on the land use zoning map and on the GIS system of Galway County Council so that staff and the public are aware of the special conditions/constraints attached;  A briefing will be provided to relevant staff within Galway County Council on the special conditions and constraints on relevant lands.

With regard to the addition of ObjectiveCCF 6, it should be noted a Site-Specific Flood Risk Assessment (SSFRA) has been carried out by O’Connor Sutton Cronin which has identified the exact pre and post development flooding profile on the subject site. This SSFRA clearly identifies the correct flooding profile of the site, which does not extend into the areas identified within Material Alteration 3 to the Bearna Plan and that area subject Objective CCF 6. That being said, the current application complies with the provisions of Objective CCF 6. In this regard, a SSFRA, which takes account of climate change, confirms no vulnerable development will be located within either Flood Zone A or B.

(See Figure 3.2 below). Furthermore, an Appropriate Assessment Screening Report and Ecological Impact Assessment Report have been prepared, which confirm that the proposed development will not impact the Trusky Stream or the associated Riparian Habitat.

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 16 Figure 3.2: Extent of Identified Flood Zones It is further noted that Objective CCF 6 seeks to protect the riparian zones of watercourse systems through a general 10 metre protection buffer from rivers within the plan area. Figure 3.3 below, highlights the 10-meter buffer of the Trusky Stream, which the objective clearly states is a “general buffer” and that can be “increased and decreased on a site by site basis, as appropriate”.

The total area of built development which would be located within 10 metres of the Trusky Stream within the portion of the site that is subject to Material Alteration 3 would be just 39.4 sqm or 0.4% the total area within the 10-metre buffer of the stream (9565.88 sqm).

Figure 3.3: Extent of development with the 10-meter buffer area

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 17 Figure 3.4: Extent of development with the 10-meter buffer area and areas subject to Material Alteration 3 3.1.1.1 Residential Development Phasing As identified in Figure 3.2 above, the subject site is comprised predominantly of Phase 1 Residential zoned lands. The Bearna Plan contains specific objectives in relation to focusing residential development into appropriately zoned and serviced areas in accordance with the land use zones/development areas and phased development framework.

Objective RD1 - Residential Development Phasing “Supports the development of lands designated as Residential (Phase 1) within the lifetime of the Plan, subject to normal planning, access and servicing requirements”. The proposed development is considered to be in compliance with the relevant zoning objectives contained within the Bearna Plan.

3.2 Compliance with Core Strategy Bearna and Oranmore are identified in the Galway County Development Plan (GCDP) as being located within Tier 1 - Galway Metropolitan Area (GMA). The GMA include Galway City and a number of adjacent electoral divisions that are deemed to be inextricably linked to the function of the Greater Galway City area. Section 2.6.2 of the GCDP states in relation to the GMA, the future prosperity of towns and villages near the city and the quality of life of people living within the commuter band around Galway city depend on the gateway and GMA retaining its dynamic growth character.

It continues by stating that given it attracts significant inward investment and is a provider of regional services and facilities it is essential that the regional settlement strategy provides for the sustainable, dynamic development of the Galway Gateway and GMA to support the economic growth of the region. As detailed in Section 2.3 above, the Inspector in the assessment of previous planning application (ABP-300009-17) acknowledged the disparity between the vision for Bearna as set out in the former BLAP and its role as set out in the County Development Plan, as part of the GMA. The inspector was unequivocal in stating that Bearna “shouldn’t be examined in such isolation and should instead be assessed more strategically in terms of its role within the county hierarchy.” Accordingly, in relation to compliance with the Core Strategy, it is clear that Bearna should be considered as part of the GMA which includes the other satellite settlement of Oranmore.

Accordingly, in assessing compliance with the Core Strategy it is

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 18 considered appropriate to review the current Phase 1 lands and associated planning history within both settlements. 3.2.1 Assessment of current Phase 1 allocated lands in Bearna Figure 3.5: Current Bearna Phase 1 lands The growth allocation for Bearna is approximately 175 new housing units up to 2021. The Phase 1 lands in the current plan (as indicated in figure 1 above), are as follows; A. Trusky East; B. Forramoyle East; C. An Leac Liath; A. Trusky East (Application site): Figure 3.6: Application Site (Trusky East)

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 19 The application site, as outlined above, comprises 7.2 hectares of land and would provide 197 dwellings, amounting to a density of 35 units per hectare. B. Forramoyle East; The Phase 1 lands located at Forramoyle East have an area of approximately 5 hectares. A recent planning application Pl. Ref. 17/1314 was granted for the provision of 48 dwellings. Figure 3.7: Phase 1 lands (Forramoyle East) C. An Leac Liath: The Phase 1 lands at An Leac Liath, as outlined in Figure 3.8 below, are located to the west of the village and as can be seen in Table 3.1 below, a portion of these lands have been the subject of low density one off housing developments which does not provide the envisaged contribution towards the aims of the Core Strategy in regard to meeting housing demand.

Figure 3.8: Phase 1 Lands at An Leac Liath

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 20 Table 3.1: Planning History for Phase 1 allocated lands at An Leac Liath, Bearna Planning Ref. Description of development Decision No. of Dwellings 14/1175 Construction of a two storey, four-bedroom, dwelling house, new entrance and associated site works (gross floor space 259sqm) Granted 1 14/1146 Construction of a two storey four-bedroom, dwelling house, new entrance and associated site works (gross floor space 259sqm) Granted 1 14/1174 Construction of a two storey four-bedroom dwelling house, new entrance and associated site works (gross floor space 259sqm) Granted 1 As set out above, the majority of the existing Phase 1 allocated land remains undeveloped, with just 50 units granted since the adoption of the core strategy, however no multi-unit developments have been commenced.

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 21 3.2.2 Assessment of current Phase 1 allocated lands in Oranmore: The Core Strategy of the GCDP estimates that the settlement of Oranmore can accommodation an increase in population of 1,170 people, with an associated requirement for 363 new homes. A review of all Phase 1 Residential lands in the settlement of Oranmore was undertaken in March 2018 are identified in Figure 3.8 below. Figure 3.8: Oranmore Phase 1 lands Table 3.2: Phase 1 Lands in Oranmore Map Ref Committed to Dev.

Evidence of Constraints Relevant Planning Ref No’s: No of Units Description of Constraints 01 No No N/A N/A None 02 Yes No Pl.Ref.

16/1262 41 None 03 No No N/A N/A None 04 No No N/A N/A None

180226 - Housing Development Trusky East, Bearna Statement of Consistency McCarthy Keville O’Sullivan Ltd. 22 05 Yes No Pl.Ref 17/1268 76 None 06/07 No No N/A N/A None 08 Yes Yes Pl.Ref. 16/1380 N/A Curtilage of a protected Structure 09 No Yes N/A N/A Potential costal and pluvial flood risk identified on site. Each site with a Phase 1 residential designation in Oranmore was assessed to establish whether any development had taken place or was underway. The sites were also assessed to establish whether there were any constrains on the lands and whether there were any extant planning permissions on the lands.

This information is set out in Table 3.2 above and discussed further below.

Map Reference #01 – Lands at Garraun South On the 20th March 2018 a site inspection indicated that no residential development had taken place or was taking place on the lands. There are no pending or extant planning permissions for multi-unit residential developments on this site. Map Reference #02 – Lands at Garraun South Planning Permission was granted, under Pl. Ref. 16/1262 for the construction of 41 units at this site, however on the 20th March 2018 a site inspection indicated that no residential development had taken place or was taking place on the lands. Map Reference #03 – Lands at Carrowmoneash On the 20th March 2018 a site inspection indicated that no residential development had taken place or was taking place on the lands.

There are no pending or extant planning permissions for multi-unit residential developments on this site Map Reference #04 – Lands at Carrowmoneash On the 20th July 2018 a site inspection indicated that no residential development had taken place or was taking place on the lands. There are no pending or extant planning permissions for multi-unit residential developments on this site Map Reference #05 – Lands at Frenchfort Planning Permission was granted, under Pl. Ref. 17/2168 for the construction of 76 units at this site, however on the 20th July 2018 a site inspection indicated that no residential development had taken place or was taking place on the lands Map Reference #06 and #07 – Lands at Oran Beg On the 20th July 2018 a site inspection indicated that no residential development had taken place or was taking place on the lands.

There are no pending or extant planning permissions for multi-unit residential developments on this site. Map Reference #08 – Lands at Oranmore On 27 April 2017, Planning Permission was granted for the construction of a two-storey tourist lodge building and a bird watching hut. On the 20th July 2018 a site inspection indicated that no residential development had taken place or was taking place on the lands There are no extant planning permissions for multi-unit residential development on this site.

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