Housing Development at Trusky East, Bearna, Co. Galway - Statement of Consistency
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Housing Development at Trusky East,
Bearna, Co. Galway
Statement of Consistency
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
180226 - Housing Development Trusky East, Bearna Statement of Consistency
Table of Contents
1 Introduction ............................................................................................ 1
1.1 Preamble...................................................................................................................1
1.2 Pre- Planning 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 ........................................................................................ 26
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
180226 - Housing Development Trusky East, Bearna Statement of Consistency
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 Pre- Application 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 Pre- Planning 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
McCarthy Keville O’Sullivan Ltd. 1
180226 - Housing Development Trusky East, Bearna Statement of Consistency
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 pre-
planning consultations with ABP was submitted on 29th March 2018 and a pre-
planning consultation meeting was held on 4th May 2018. An Bord Pleanala issued a
Notice of Pre- Application 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;
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180226 - Housing Development Trusky East, Bearna Statement of Consistency
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)
McCarthy Keville O’Sullivan Ltd. 3
180226 - Housing Development Trusky East, Bearna Statement of Consistency
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 multi-
purpose 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 pre- connection enquiry letter from
Irish Water confirms that there is sufficient capacity within the existing network to
accommodate the proposed development.
McCarthy Keville O’Sullivan Ltd. 4
180226 - Housing Development Trusky East, Bearna Statement of Consistency
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 pre-
planning consultations with An Bord Pleanala (The Board) was submitted on 27 August
2017 and a subsequent pre- planning consultation meeting was held on 4 September
2017. The Board issued a Notice of Pre- Application 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.
McCarthy Keville O’Sullivan Ltd. 5
180226 - Housing Development Trusky East, Bearna Statement of Consistency
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 Applicant Description of Decision
Ref development
03/4315 C&T Application for the Granted
Development demolition of existing
Ltd. dwelling, construction of 22
no. 2 storey dwellings with
treatment plant and
associated site works
04/3846 C&T Application for replacing Granted
Developments two storey semi- detached
Ltd dwellings with 5 no.
detached two storey
dwellings, revised
boundaries/driveways to
sites 9 to 16 and associated
external works (gross floor
space 5320sqm)
04/4249 C&T Application for construction Refused
Developments of 15 no. two storey
Ltd dwellings and associated
external works at
previously granted
residential development
(03/4315)
06/903 C&T Application to relocate a Granted
Developments wastewater treatment
system (originally granted
under planning permission
no's 03/4315 and 04/3846)
09/1278 Liam O'Toole Application for the Granted by Galway
demolition of 3 No. County Council but
sheds/outbuildings, the refused by An Bord
construction of 94 No. Pleanála (under
dwellings comprising of; 54 reference no Pl. 07.
No. two storey semi- 236240),
detached 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.
McCarthy Keville O’Sullivan Ltd. 6180226 - Housing Development Trusky East, Bearna Statement of Consistency
Planning Applicant Description of Decision
Ref development
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- Burkeway The demolition of existing Refused by An Bord
300009- Homes outbuildings and the Pleanala on 6th February
17 Limited construction of 113 No. new 2018
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.
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. In
McCarthy Keville O’Sullivan Ltd. 7180226 - Housing Development Trusky East, Bearna Statement of Consistency
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.
McCarthy Keville O’Sullivan Ltd. 8180226 - Housing Development Trusky East, Bearna Statement of Consistency
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.
McCarthy Keville O’Sullivan Ltd. 9180226 - Housing Development Trusky East, Bearna Statement of Consistency
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 place-
based 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.
McCarthy Keville O’Sullivan Ltd. 10180226 - Housing Development Trusky East, Bearna Statement of Consistency
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:
R- Residential (Phase 1);
OS- Open Space Recreation & Amenity;
McCarthy Keville O’Sullivan Ltd. 11180226 - Housing Development Trusky East, Bearna Statement of Consistency
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.
McCarthy Keville O’Sullivan Ltd. 12180226 - Housing Development Trusky East, Bearna Statement of Consistency
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
McCarthy Keville O’Sullivan Ltd. 13180226 - Housing Development Trusky East, Bearna Statement of Consistency 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 OS- Open 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 ‘R- Residential 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 OS- Open 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 McCarthy Keville O’Sullivan Ltd. 14
180226 - Housing Development Trusky East, Bearna Statement of Consistency
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 Objective- CCF 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.
McCarthy Keville O’Sullivan Ltd. 15180226 - Housing Development Trusky East, Bearna Statement of Consistency 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 McCarthy Keville O’Sullivan Ltd. 16
180226 - Housing Development Trusky East, Bearna Statement of Consistency
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
McCarthy Keville O’Sullivan Ltd. 17180226 - Housing Development Trusky East, Bearna Statement of Consistency
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)
McCarthy Keville O’Sullivan Ltd. 18180226 - Housing Development Trusky East, Bearna Statement of Consistency 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 McCarthy Keville O’Sullivan Ltd. 19
180226 - Housing Development Trusky East, Bearna Statement of Consistency
Table 3.1: Planning History for Phase 1 allocated lands at An Leac Liath, Bearna
Planning Description of development Decision No. of
Ref. Dwellings
14/1175 Construction of a two storey, four-bedroom, Granted 1
dwelling house, new entrance and associated
site works (gross floor space 259sqm)
14/1146 Construction of a two storey four-bedroom, Granted 1
dwelling house, new entrance and associated
site works (gross floor space 259sqm)
14/1174 Construction of a two storey four-bedroom Granted 1
dwelling house, new entrance and associated
site works (gross floor space 259sqm)
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.
McCarthy Keville O’Sullivan Ltd. 20180226 - Housing Development Trusky East, Bearna Statement of Consistency
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 Committed to Evidence of Relevant No of Description of
Ref Dev. Constraints Planning Units Constraints
Ref No’s:
01 No No N/A N/A None
02 Yes No Pl.Ref. 41 None
16/1262
03 No No N/A N/A None
04 No No N/A N/A None
McCarthy Keville O’Sullivan Ltd. 21180226 - Housing Development Trusky East, Bearna Statement of Consistency
05 Yes No Pl.Ref 76 None
17/1268
06/07 No No N/A N/A None
08 Yes Yes Pl.Ref. N/A Curtilage of a
16/1380 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.
McCarthy Keville O’Sullivan Ltd. 22180226 - Housing Development Trusky East, Bearna Statement of Consistency
Map Reference #09 – Lands at Oranhill and Moneyduff
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. It is also noted that
there is a potential costal and pluvial flood risk identified on site.
Over the lifetime of the GCDP (i.e. 2015-2021) the Core Strategy Bearna and
Oranmore, which are identified in the Galway County Development Plan (GCDP) as
being located within Tier 1 - Galway Metropolitan Area (GMA), can accommodate an
increase in population of 1,590 persons and an associated housing requirement for
538 new dwellings.
Following a review of the Phase 1 zoned lands, it is clear that only 167 new homes have
been granted, on 4 of the identified phase 1 sites, however no new multi-unit residential
developments have yet been commenced.
Accordingly, the proposed development is considered to be consistent with the
requirements of the Core Strategy and the Settlement Strategy which seeks to support
the development and function of the Galway Metropolitan Area. In addition to the
current under provision of housing, within identified Tier 1 settlements of Bearna and
Oranmore, it is noted that the National Planning Framework seeks to promote a
targeted pattern of development, which includes supporting the development of
“Accessible Centres of Scale”. In this regard Galway City and Suburbs is identified as
accommodating up to 45,000 additional people which would equate in excess of 19,500
new dwellings within the GMA up to the year 2040.
3.3 Design Approach
As part of the overall design approach, the development seeks to respond to the
topography and features of the site and the existing grain of the built form surrounding
the subject site. The existing site outside the stream contains a gentle slope from the
north of the site towards the village, following the line of the Trusky Stream.
Accordingly, the design team developed a design response which encompassed the
contours of the site thereby minimising the quantum of site excavation/ build up in
order to maximise the retention of existing features.
The proposed road layout includes vehicular links from the Moycullen road to Bearna
village through the adjacent development at Cnoc Fraoigh, situated along the sites
western boundary. The proposed design response has sought to integrate the
unaltered path of the Trusky Stream as the focal point of the development, establishing
a north-south pedestrian and amenity link through the site.
The development would comprise of 16 no. dwelling house types located throughout
the site, located along a series of ‘streets’ providing direct access to the main
landscape/public area, achieving a sense of enclosure and of clear identifiable zones.
Subtle variations on each house type enable the integration of the Galway vernacular
aesthetic through the use of materials, colour and detailing.
Ten separate apartment buildings, which would comprise 66 apartments and 24 own
door duplex apartments and would range in height from 3—4 storeys.
The Internal layout of all units are to the latest DoELG guidelines on Sustainable
Housing with all bedrooms, bathrooms, living and kitchen/dining rooms meeting or
exceeding the areas set out in the guidelines.
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