Statement of Consistency with National and County Development Plan Planning Policy - In respect of Proposed Residential Development at Site at ...

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Statement of Consistency with National and County Development Plan Planning Policy - In respect of Proposed Residential Development at Site at ...
Statement of Consistency
    with National and County Development Plan
                  Planning Policy

                            In respect of

Proposed Residential Development at Site at Balscadden Road & Former
          Baily Court Hotel, Main St., Howth, County Dublin

                     Crekav Trading GP Limited

                             May 2018
Statement of Consistency with National and County Development Plan Planning Policy - In respect of Proposed Residential Development at Site at ...
STATEMENT OF CONSISTENCY                                                              SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

                                                                           Table of Contents

1.       Introduction ............................................................................................................................................. 5

2.       National and Regional Planning Policy ..................................................................................................... 6
     National Spatial Strategy (2002) ......................................................................................................................... 7
     National Planning Framework – Ireland 2040 .................................................................................................... 8
     Rebuilding Ireland; Action Plan for Housing and Homelessness (2016) ............................................................. 9
     Schools .............................................................................................................................................................. 11
     Density .............................................................................................................................................................. 12
     Urban Design Manual – A Best Practice Guide (2009)...................................................................................... 14
     Delivering Homes, Sustaining Communities (2008).......................................................................................... 20
     Design Manual for Urban Roads and Streets (DMURS) (2013) ......................................................................... 22
     Guidelines for Planning Authorities on Childcare Facilities (2001) ................................................................... 23
     Smarter Travel – A Sustainable Transport Future: A New Transport Policy for Ireland 2009-2020 ................. 24
     Guidelines for Planning Authorities on ‘The Planning System and Flood Risk Management (November 2009)’
     .......................................................................................................................................................................... 25
     Birds and Habitats Directive – Appropriate Assessment .................................................................................. 25
     Appropriate Assessment of Plans and Projects in Ireland Guidance for Planning Authorities (2009) ............. 26
     Draft Guidelines for Planning Authorities and An Bord Pleanála on carrying out Environmental Impact
     Assessment (2012). ........................................................................................................................................... 26
     Regional Planning Guidelines for the Greater Dublin Area (2010 – 2022) ....................................................... 26
     Transport Strategy for the Greater Dublin Area 2016 - 2035 ........................................................................... 28

3.       Local Planning Policy .............................................................................................................................. 29
     Fingal County Development Plan 2017 – 2023 ................................................................................................. 29
     Core Strategy & Settlement Strategy ............................................................................................................... 29
     Development Strategy for Howth – Objectives for Howth ............................................................................... 32
     Development Plan Zoning and Site Specific Local Objectives ........................................................................... 33
     Compliance with Residential Development Policies of the Fingal County Development Plan ......................... 34
     Energy Efficiency and Climate Change .............................................................................................................. 34
     Design Principles ............................................................................................................................................... 34
     Mixed Use and Vitality of Sustainable Communities ........................................................................................ 35
     Housing Mix ...................................................................................................................................................... 36
     Part V – Social Housing ..................................................................................................................................... 37
     Residential Densities ......................................................................................................................................... 37
     Apartment Development .................................................................................................................................. 37
     Open Space ....................................................................................................................................................... 38

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CREKAV TRADING GP LIMITED                                                                                                                                            MAY 2018
Statement of Consistency with National and County Development Plan Planning Policy - In respect of Proposed Residential Development at Site at ...
STATEMENT OF CONSISTENCY                                                            SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

     Childcare Facilities ............................................................................................................................................ 39
     Flood Risk .......................................................................................................................................................... 40

4.      Development Management Standards (Chapter 12 of Fingal Development Plan) .................................. 41
        Objective ....................................................................................................................................................... 42
        AA Screening ................................................................................................................................................. 42
        Detailed Design Statement ........................................................................................................................... 42
        Public Art ...................................................................................................................................................... 42
        Shopfronts/Signage ...................................................................................................................................... 42
        Green Roofs For SUDS and Green Corridors ................................................................................................. 42
        Utility Providers/ESB Substations ................................................................................................................. 43
        Dual Aspect ................................................................................................................................................... 43
        Floor to Ceiling Heights ................................................................................................................................. 43
        Units per Core ............................................................................................................................................... 43
        Minimum Gross Floor Areas ......................................................................................................................... 43
        Floor Area Standards .................................................................................................................................... 43
        Floor Plans indicating furniture .................................................................................................................... 43
        Separation Distances/Overlooking/Overshadowing .................................................................................... 44
        Daylight/Sunlight .......................................................................................................................................... 44
        Sound Transmission ...................................................................................................................................... 44
        Management Companies.............................................................................................................................. 44
        Communal Facilities ...................................................................................................................................... 45
        Communal Laundry/Storage ......................................................................................................................... 45
        Bin Storage/Refuse ....................................................................................................................................... 45
        Naming and Numbering................................................................................................................................ 45
        Height and Massing ...................................................................................................................................... 45
        Visual Harmony/Design ................................................................................................................................ 46
        Residential Character .................................................................................................................................... 46
        Open Space – Permeability ........................................................................................................................... 46
        Open Space Quantity .................................................................................................................................... 46
        Open Space – 10% of Site/Financial Contribution in lieu of shortfall ........................................................... 47
        Access to Public Parks ................................................................................................................................... 47
        Taking in Charge of Open Spaces .................................................................................................................. 47
        Open Spaces within Management Companies ............................................................................................. 47
        Playground Facilities ..................................................................................................................................... 48
        Tree Policy/Planting Plan .............................................................................................................................. 48
        Private Open Space – Apartments and Duplex ............................................................................................. 49
        Private Open Space ....................................................................................................................................... 49
        Roads - Design in accordance with DMURS and Traffic Impact Assessment ................................................ 49
        Objective DMS128 & DMS130 ...................................................................................................................... 49
        Car Parking Standards ................................................................................................................................... 50
        Bicycle Parking Standards ............................................................................................................................. 50
        Waste Management ..................................................................................................................................... 51
        Lighting Plan ................................................................................................................................................. 51
        Site Assessment ............................................................................................................................................ 51

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CREKAV TRADING GP LIMITED                                                                                                                                       MAY 2018
Statement of Consistency with National and County Development Plan Planning Policy - In respect of Proposed Residential Development at Site at ...
STATEMENT OF CONSISTENCY                                                        SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

     Archaeology .................................................................................................................................................. 52
     Protected Structures..................................................................................................................................... 52
     Architectural Heritage .................................................................................................................................. 52
     Architectural Conservation Areas ................................................................................................................. 52
     Signage in Architectural Conservation Area ................................................................................................. 52
     Biodiversity ................................................................................................................................................... 53
     Coastal Erosion ............................................................................................................................................. 53
     Flooding ........................................................................................................................................................ 54

5.   Conclusions ............................................................................................................................................ 55

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CREKAV TRADING GP LIMITED                                                                                                                                   MAY 2018
Statement of Consistency with National and County Development Plan Planning Policy - In respect of Proposed Residential Development at Site at ...
STATEMENT OF CONSISTENCY                         SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

1. Introduction

1.1      On behalf of the prospective applicant, Crekav Trading GP Limited, this Statement of
         Consistency with Planning Policy has been prepared to accompany a proposed
         planning application in relation to a proposed strategic housing development at a c.
         1.55 hectare (c.3.8 acres) site comprising a site located south of the Martello Tower
         on Balscadden Road & the former Baily Court Hotel, Howth, County Dublin.

         The development will consist of:
             •    The demolition of existing structures on site including the disused sports
                  building (c. 604 sq m) on the Balscadden Rd. Site and the Former Baily Court
                  Hotel Buildings on Main St (c. 2051 sq m) and a reduction in ground levels.
             •    Construction of 164 no. residential units in 3 no. separate apartment blocks
                  and 1 mews building, comprising 158 no. apartments and 6 duplexes which
                  includes 40 no. 1 bed units, 97 no. 2 bed units and 27 no. 3 bed units.
             •    Provision 397 no. bicycle parking spaces and a total of 120 no. car parking
                  spaces, which comprises 112 no. spaces in an underground basement in Block
                  C and 8 no. on-street parking spaces.
             •    Provision of commercial/retail space (c. 757 sqm), which includes a
                  community room (c. 161sqm), 2 no. retail units (c. 429sqm and c. 96sqm) and
                  a café (c. 71sq m).
             •    The main vehicular entrance to the scheme will be from Main Street to serve
                  the underground car park in Block C
             •    The scheme provides for a new linear plaza which will create a new
                  pedestrian link between Main St and Balscadden Rd to include the creation of
                  an additional 2 no. new public plazas and also maintains and upgrades the
                  pedestrian link from Abbey Street to Balscadden Road below the Martello
                  Tower. The public footpath on the opposite side of Balscadden Road will be
                  widened for the length of the site as part of the development.
             •    All other ancillary site development works, site services, a sub-station, public
                  lighting, plant, bin stores, bike stores, boundary treatments and landscaping;
             •    Commercial and retail signage (c. 75 sqm)

1.2      The final design has evolved through a lengthy collaborative process involving the
         planning and various local authority departments and the Marlet Design Team,
         including architecture, conservation as well as roads and drainage. The feedback from
         An Bord Pleanala following our pre-planning meeting has necessitated design changes
         to the development which been included in our final application.

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CREKAV TRADING GP LIMITED                                                                           MAY 2018
Statement of Consistency with National and County Development Plan Planning Policy - In respect of Proposed Residential Development at Site at ...
STATEMENT OF CONSISTENCY                       SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

1.3      The scheme provides for a new town centre quarter, at an appropriate and efficient
         residential density, a safe vehicular access arrangement, creation of new connections
         between the village core and Balscadden Road through the provision of new
         accessible streets and plazas which are accessible to all.

1.4      This statement of consistency with planning policy has been prepared to specifically
         address the requirements of the strategic housing development guidance document
         issued by An Bord Pleanala. This planning application is also accompanied by a
         Planning Report which includes further details in respect of the proposed
         development in relation to the site location and context, the development description
         and the relevant planning history. The planning policy section is included below.

1.5      This standalone planning policy consistency statement, prepared by Marlet Property
         Group Ltd., demonstrates that the proposal is consistent with the relevant national
         planning policy, guidelines issued under Section 28 of the Planning and Development
         Act 2000 (as amended), and with local planning policy. It should be read in conjunction
         with the accompanying detailed documentation prepared by CCK Architects, Murray
         & Associates Landscape Architects and OCSC Consulting Engineers as well as specialist
         input from conservation and archaeology.

1.6      For further details of consistency with the quantitative standards for residential units
         as set down in the Apartment Guidelines 2015, the Quality Housing for Sustainable
         Communities and the 2016-2022 Development Plan please refer to the Housing
         Quality Assessment document prepared by CCK Architects.

2. National and Regional Planning Policy

2.1      The key provisions of national (including relevant Section 28 guidelines) and regional
         planning policy as it relates to the proposed development is set out in the following
         sections. The key policy and guidance documents of relevance to the proposed
         development are as follows:

         ➢ National Spatial Strategy (2002);
         ➢ National Planning Framework 2040 (2018)
         ➢ Rebuilding Ireland; Action Plan for Housing and Homelessness (2016)
         ➢ Guidelines for Planning Authorities on Sustainable Residential Development in
              Urban Areas (2009), and the accompanying Urban Design Manual;

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CREKAV TRADING GP LIMITED                                                                         MAY 2018
Statement of Consistency with National and County Development Plan Planning Policy - In respect of Proposed Residential Development at Site at ...
STATEMENT OF CONSISTENCY                       SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

         ➢ Delivering Homes, Sustaining Communities (2008) and the accompanying Best
              Practice Guidelines- Quality Housing for Sustainable Communities;
         ➢ Design Standards for New Apartments - Guidelines for Planning Authorities (March
              2018)
         ➢ Design Manual for Urban Roads and Streets (2013);
         ➢ Guidelines for Planning Authorities on Childcare Facilities (2001);
         ➢ Smarter Travel – A New Transport Policy for Ireland (2009-2020);
         ➢ The Planning System and Flood Risk Management (2009);
         ➢ Birds and Habitats Directive – Appropriate Assessment
         ➢ Guidance on Appropriate Assessment for Planning Authorities (2009)
         ➢ Draft Guidelines for Planning Authorities and An Bord Pleanála on carrying out
              Environmental Impact Assessment (2012).
         ➢ Regional Planning Guidelines for the Greater Dublin Area (2010 – 2022);
         ➢ Greater Dublin Area Transport Strategy 2016-2035

National Spatial Strategy (2002)
2.2      The National Spatial Strategy (NSS) provides a broad planning framework for the
         location of development in Ireland. The key objective of the National Spatial Strategy
         is to provide an overarching planning framework for the Country and to result in the
         achievement of more balanced regional development.

2.3      The NSS provides for increasing urbanisation of the population and achievement of
         critical mass in large urban areas. The National Spatial Strategy (NSS) is a twenty-year
         planning framework designed to achieve a better balance of social, economic, physical
         development and population growth between regions.

2.4      One of the core objectives of the NSS is the consolidation of the Greater Dublin Area
         (GDA) in a manner which protects local character and amenity through the
         achievement of higher development densities at sustainable locations proximate to
         public transport and services. The subject lands are located adjacent to the Bus Stop
         for Dublin Bus into the City and c. 800m from Howth DART Station (10 minute walk).
         The NSS supports the consolidation of the GDA in order to limit the spread of the GDA
         into surrounding counties and to ensure the efficient operation of the public transport
         system.

2.5      The proposed development seeks to deliver a new quarter for Howth Village, which is
         designed to take account of the village grain and scale and will open up new streets
         and plazas for the community.         It provides for appropriate new residential

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CREKAV TRADING GP LIMITED                                                                         MAY 2018
STATEMENT OF CONSISTENCY                       SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

         development which will help to promote local services & schools along quality
         transport routes. As such the development of these lands is considered to be fully in
         accordance with the recommendations of the National Spatial Strategy.

National Planning Framework – Ireland 2040
2.6      The Department of Housing Planning and Local Government, on behalf of the
         Government, has recently published the National Planning Framework called Ireland
         2040 Our Plan. The high-level objectives of the plan are as follows:

         1. In addressing future change, Ireland will continue on a path of economic,
         environmental and social progress that will improve our prosperity, sustainability and
         well-being.

         2. Ensuring that Ireland’s many unique assets can be built upon, with an emphasis on
         improving economic output and stability as well as quality of life, environmental
         performance and the liveability of Dublin, our cities, towns and rural areas.

         3. Setting out likely future change in Ireland and the spatial pattern required for
         effective and co-ordinated investment in a range of sectors to best accommodate and
         support that change.

         4. Putting in place a strategy for the sustainable development of places in Ireland and
         how that can be achieved, through planning, investment and implementation.

         In particular, the redevelopment of this zoned Town Centre/Residential site in Howth
         Village would contribute to compact growth. The proposed development, would
         ensure the much needed provision of residential units in an area and site that have
         has not seen housing development for a substantial period.

         It is submitted that the proposed development is consistent with the objectives of the
         NPF in seeking to consolidate and densify an urban area proximate to primary
         transport routes.

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CREKAV TRADING GP LIMITED                                                                         MAY 2018
STATEMENT OF CONSISTENCY                        SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

Rebuilding Ireland; Action Plan for Housing and Homelessness (2016)
2.7      In        2016,      the
         Government
         launched Rebuilding
         Ireland            which
         targeted solutions to
         the ongoing supply
         issues        in     the
         residential sector in
         the country.         The
         overarching aim of
         this Action Plan is to
         ramp up delivery of
         housing       from    its
         current under-supply
         across all tenures to            Figure 1: Five Pillars of the Rebuilding Ireland Action Plan
         help individuals and
         families meet their housing needs, and to help those who are currently housed to
         remain in their homes or be provided with appropriate options of alternative
         accommodation, especially those families in emergency accommodation.

         This Plan sets ambitious targets to double the annual level of residential construction
         to 25,000 homes and deliver 47,000 units of social housing in the period to 2021, while
         at the same time making the best use of the existing housing stock and laying the
         foundations for a more vibrant and responsive private rented sector. The five pillars
         of the action plan are as follows:

         The development proposed will directly contribute to Pillar 2 seeking to ‘Accelerate
         Social Housing’, and Pillar 3 which seeks to ‘Build More Homes’.

         159 no. residential dwellings are proposed in a wide mix of unit types and sizes to fit
         a broad tenure demand. 10% of the units are proposed for transfer as social housing.
         The scheme will therefore indirectly assist in Pillars 1 and 4 which seek to ‘Address
         Homelessness’ and ‘Improve the Rental Sector’, respectively.

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CREKAV TRADING GP LIMITED                                                                            MAY 2018
STATEMENT OF CONSISTENCY                       SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

Guidelines for Planning Authorities on Sustainable Residential Development in Urban Areas
(2009)

2.8      The role of the Guidelines for Planning Authorities on Sustainable Residential
         Development in Urban Areas is to ensure the sustainable delivery of new development
         throughout the country. The Guidelines focus on the provision of sustainable
         residential development, including the promotion of layouts that:

         ➢ Prioritise walking, cycling and public transport, and minimise the need to use cars;
         ➢ Are easy to access for all users and to find one’s way around;
         ➢ Promote the efficient use of land and of energy, and minimise greenhouse gas
              emissions;
         ➢ Provide a mix of land uses to minimise transport demand.

2.9      The Guidelines also provide guidance on the core principles of urban design when
         creating places of high quality and distinct identity. The Guidelines recommend that
         planning authorities should promote high quality design in their policy documents and
         in their development management process. In this regard, the Guidelines are
         accompanied by a Design Manual discussed below which demonstrates how design
         principles can be applied in the design and layout of new residential developments, at
         a variety of scales of development and in various settings.

2.10     These Guidelines support a plan-led approach to development as provided for in the
         Planning and Development Act 2000. Section 2.1 of the Guidelines note that ‘the scale,
         location and nature of major new residential development will be determined by the
         development plan, including both the settlement strategy and the housing strategy’.

2.11     The Guidelines reinforce the need to adopt a sequential approach to the development
         of land and note in Section 2.3 and ‘the sequential approach as set out in the
         Departments Development Plan Guidelines (DoEHLG, 2007) specifies that zoning shall
         extend outwards from the centre of an urban area, with undeveloped lands closest to
         the core and public transport routes being given preference, encouraging infill
         opportunities…’.

2.12     Having regard to the above the subject site has been zoned to provide for residential
         development having a Town Centre zoning on the former Baily Court Hotel site and a
         Residential zoning on the Balscadden Road sites.

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CREKAV TRADING GP LIMITED                                                                         MAY 2018
STATEMENT OF CONSISTENCY                       SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

2.13     Sustainable neighbourhoods require a range of community facilities, and each
         district/neighbourhood will need to be considered within its own wider locality, as
         some facilities may be available in the wider area while others will need to be provided
         locally.

Schools
2.14     Section 4.4 of the Guidelines relates to the provision of school spaces with large scale
         residential development. It is respectfully submitted that there is a very good
         provision of school places in this area of the County. The following 9 no. schools and
         8 no. crèches are located within the Howth/Sutton/Dublin 13 area (within 5km from
         the site):

         Crèche/Montessori

         1. Deerpark Montessori School
         2. Bracken Hill Nursery School
         3. Little Rainbows, Sutton
         4. Rainbow Montessori, Sutton
         5. Sutton Playgroup
         6. The Cottage Montessori
         7. Howth pre-school playgroup
         8. Bumblebee Montessori & Childcare

         Primary Schools

         1. Howth primary school, Scoil Mhuire
         2. Sutton Park School
         3. St. Fintans National School
         4. The Burrow, National School, Sutton
         5. North Bay Educate Together

         Secondary Schools

         6. Santa Sabina Dominican College
         7. St. Fintan’s High School
         8. Pobalscoil Neasain
         9. Saint Marys for Girls, Baldoyle

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CREKAV TRADING GP LIMITED                                                                         MAY 2018
STATEMENT OF CONSISTENCY                       SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

Density
2.15     The subject lands would be considered to be lands adjacent to ‘Public Transport
         Corridors’ in the context of the densities required under the Guidelines for Planning
         Authorities on Sustainable Residential Development in Urban Areas (2009), as the
         lands are located within c. 1km of DART Station and the No. 31/A bus serves the site
         hourly with a bus stop situated directly outside the development site.

2.16     Section 5.8 of the Guidelines recommends that ‘in general, minimum net densities of
         50 dwellings per hectare, subject to appropriate design and amenity standards, should
         be applied within public transport corridors, with the highest densities being located
         at rail stations / bus stops, and decreasing with distance away from such nodes’.

2.17     The proposals for the lands is to provide for a net density of c. 106 units per hectare.
         Thus, the proposed development of the subject lands would be consistent with the
         guidelines in respect to residential density and regard to Government Guidelines and
         the Development Plan policies, with a mix of apartments and commercial &
         community space.

2.18     In addition to recommending appropriate densities, the Guidelines focus on the
         provision of sustainable residential development, including the promotion of layouts
         that:

         ➢ prioritise walking, cycling and public transport, and minimise car use;
         ➢ are easy to access for all users and to find one’s way around;
         ➢ promote the efficient use of land and of energy, and minimise greenhouse gas
              emissions; and
         ➢ provide a mix of land uses to minimise transport demand.
         ➢ reduce traffic speeds in housing developments

2.19     The proposed development incorporates design principles such to reduce traffic
         speeds with a no-through access road to eliminate the possibility of a rat-run. The
         layout is highly accessible for all users, with a permeable layout both internally and
         externally as new linkages are provided to surrounding land uses, with a new linear
         plaza being opened up which will bring pedestrians directly from Howth Village to
         Balscadden Road and the Howth SAAO lands. The layout is considered to be legible,
         with a clear distinction in design, character and treatment.

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CREKAV TRADING GP LIMITED                                                                         MAY 2018
STATEMENT OF CONSISTENCY                        SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

2.20     The Guidelines also provide guidance on the core principles of urban design when
         creating places of high quality and distinct identity. The Guidelines are accompanied
         by a Design Manual which demonstrates how design principles can be applied in the
         design and layout of new residential developments, at a variety of scales of
         development and in various settings.

2.21     In respect to pre-application consultations with the Planning Authority and An Bord
         Pleanala the design team had regard to the advice set down in the ‘In Practice’ section
         of the Urban Design Manual (2009), which recommends the following approach

         Development Brief: An analysis of the site was carried out which included reviewing
         the local development plan & framework plan, precedent, planning history, visual
         impact assessment, utilities and services etc.

         Site Analysis: The characteristics of the subject lands and surrounding context were
         established and potential linkages and vistas to adjoining lands were analysed.

         Concept Proposals: An initial proposal responding to the parameters established by
         the development brief and site analysis was prepared describing aspects of the
         scheme such as land use and density range, boundary conditions and connections.

         Pre-planning: Pre-planning consultation is designed to respond to initial designs to
         encourage an interactive process, particularly for sites in excess of approx. 50 units.

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CREKAV TRADING GP LIMITED                                                                          MAY 2018
STATEMENT OF CONSISTENCY                       SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

         Extensive pre-planning consultation was undertaken consisting of a series of
         preapplication consultations with the Planning Authority under Section 247. In
         addition, separate informal consultations were undertaken with relevant personnel in
         the Planning Authority to ensure all relevant matters have been addressed as part of
         the pre-application process. A pre-planning meeting was held with An Bord Pleanala
         and this application has been informed by the opinion received.

2.22     The above approach is reflected in the structure of the Conroy Crowe Kelly
         Architectural Design Statement.

2.23     The Design Manual sets out a series of 12 criteria which it recommends should be used
         in the assessment of planning applications and appeals. The 12 criteria are discussed
         in detail below.

2.24     This planning application is accompanied by a Design Statement, prepared by CCK
         Architects, which demonstrates how the proposed development has regard to and has
         been developed in accordance with best practice in respect to urban design. The
         Design Statement should be read in conjunction with this Statement of Consistency
         and the Planning Report and with the plans and particulars accompanying this
         planning application.

Urban Design Manual – A Best Practice Guide (2009).
2.25     The Design Manual sets out a series of 12 criteria which it recommends should be used
         in the assessment of planning applications and appeals. The 12 no. criteria are listed
         below, with a response to each provided, which should be read in conjunction with
         the Design Statement.

         Fingal County Development Plan states ‘To achieve good urban design in
         developments, the 12 Urban Design Principles set out in the Urban Design Manual –
         A Best Practice Guide (2009) should be taken into account in designing schemes. These
         principles are: Context, Connections, Inclusivity, Variety, Efficiency, Distinctiveness,
         Layout, Public Realm, Adaptability, Privacy/Amenity, Parking and Detailed Design.
         Every area of the County is different, therefore the rules of good design should, in so
         far as possible, respond to the characteristics, history and culture of a place to which
         they are applied’.

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CREKAV TRADING GP LIMITED                                                                         MAY 2018
STATEMENT OF CONSISTENCY                       SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

2.26     Context: How does the development respond to its surroundings?

         Response: As part of the preparation for the design for this project careful analysis
         was carried out to identify the important urban characteristics of the area. The
         proposal aims to provide a scheme design that creates a sustainable, liveable
         community within a quality landscaped environment that will also be an attractive
         addition and useful to Howth Village and environs. The development will be finished
         in materials of a high-quality design which integrates sympathetically with
         surrounding residential areas. The scheme has been designed with the Martello
         Tower, a protected structure, in mind. The scheme is lower than the level of the
         Martello Tower and provides for views from the top to the mound towards the church
         steeple on Main St. The entire scheme has been designed in a 3-D context to take
         account of the views towards Howth Village/Howth Head, which includes a detailed
         design on the roof plan which provides for well-designed roof gardens. This view
         across the roof gives visitors to the Martello Tower an appropriately designed green
         roof vista, which adds to the views from the Mound.

         The urban design of the scheme looks to take clues from the immediate context and
         the site layout is structured around forming a new street and making new connections
         between Howth Village and Balscadden Bay. The development encourages pedestrian
         and cyclist movements through enhanced permeability and will result in a high quality
         new residential neighbourhood.

         The subject site is located in Howth Village which makes it accessible to a wide range
         of shops, services and bus/DART routes to the city centre. It is well connected in terms
         of public transport links. The proposed development has been designed to respond
         positively to the existing residential developments surrounding.

2.27     Connections: How well is the new neighbourhood / site connected?

         Response: The proposal adds to existing context by;

              ➢ Creating pedestrian links between Howth Village and Balscadden Road and
                  beach through a new linear plaza
              ➢ Providing an access route that is DMURS compliant to provide access for all.
              ➢ Creating 2 no. new public open space plazas to serve the proposed and existing
                  community.

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CREKAV TRADING GP LIMITED                                                                         MAY 2018
STATEMENT OF CONSISTENCY                       SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

              ➢ Providing a wide range of unit size to allow for a diverse community.

         The proposed development will provide for a main vehicular access point from Main
         St. which will serve the underground carpark under Block C. Emergency vehicles will
         be able to traverse along the linear plaza to access the apartments located at the rear
         of the scheme in case of emergency.

         A pedestrian access routes is also provided from Abbey St. along the bottom of the
         mound of the Martello Tower. This is currently an informal pedestrian route which is
         not well managed. This footpath will be brought into the development site and will
         be improved for universal access. Footpaths will be provided within the scheme rather
         than along the roadway. On suggestion by the Roads Dept., we have set back our
         scheme by 600mm from the road verge, which provides sufficient room to upgrade
         the size of the existing footpath on the opposite side of Balscadden Road. This would
         enable a footpath of 1.8m. As part of the scheme, safe pedestrian access crossing
         points are provided where the internal footpaths meet Balscadden Road. These
         proposals were agreed in conjunction with the Roads Dept and will enable safe and
         legible connectivity to Balscadden Bay and the Howth SAAO. A letter of consent has
         been proved by Fingal County Council to apply for the footpath widening on
         Balscadden Road.

2.28     Inclusivity: How easily can people use and access the development?

         Response: The main access point into the site is via the new vehicular, pedestrian
         access road off Main St.     It is proposed to provide a community building and
         retail/commercial on the new block at Main St. This commercial space will wrap
         around the ground floor of the building and will meet the new proposed plaza. On the
         far side of the public plaza is a proposed new community building. This will make a
         great addition for local people and will be very easily accessible. The street will not
         be heavily trafficked and will be used only for access to underground car park in Block
         C for the residents of the scheme. A new linear plaza is proposed through the site. At
         the end of the street where it meets Balscadden Road, a café is proposed which will
         have outdoor seating looking out onto a 2nd new plaza. This will be a new public space
         which will face Balscadden Bay and its fantastic views.

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CREKAV TRADING GP LIMITED                                                                         MAY 2018
STATEMENT OF CONSISTENCY                       SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

2.29     Variety: How does the development promote a good mix of activities?

         Response: The proposed development gives variety to the greater context of the
         Howth Village by providing a higher density in an existing area that is predominately
         made up of family houses with rear gardens.

         This development fills the gap by providing apartment units aimed at smaller
         households for which there is a great demand due to the changes in the demographics
         of the area. Variety is provided within the development in terms of architecture
         through a mix of unit types. The mix of unit types and sizes apartment ranging in size
         from c. 50 sqm to 100 sqm and caters for a variety of demographics. Architecture
         unity is ensured through the use of similar materials and finishes on all units.

         It is considered that the proposed development provides for the necessary ancillary
         land uses required for this large scale residential development, whilst having regard
         to the significant range of community, commercial and social infrastructure in the
         immediately surrounding area.

         This scheme proposes a community room, a large retail/cafe space on ground of Block
         A, 2 no. retail units on the ground floor of maisonette building facing civic plaza, &
         café on the corner of Block C facing Balscadden Bay.

2.30     Efficiency: How does the development make appropriate use of resources, including
         land?

         Response: The development aims to maximise the potential of the site by both
         conserving the views from the important areas of the landscape (Martello Tower and
         Balscadden Road) and by increasing the density in Howth Village, an area which is fully
         serviced with roads, piped infrastructure, public transport networks, schools, shops,
         services, restaurants etc. The proposed density is 106 units per hectare.

         The layout is designed to maximise natural sunlight, views and air into the open space.
         The proposed density makes efficient use of these valuable residential/town centre
         zoned lands and includes an appropriate quantum of public open space which will link

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CREKAV TRADING GP LIMITED                                                                         MAY 2018
STATEMENT OF CONSISTENCY                       SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

         to the wider green network of Howth. The layout and orientation of the scheme has
         been designed by CCK to have regard to aspect and views and ensure both dwellings
         and areas of open space achieve light throughout the day.

2.31     Distinctiveness: How do the proposals create a sense of place?

         Response: The proposed development will provide for a new quarter to Howth Village.
         It will connect the village with Balscadden Bay and the Martello Tower. It will be open
         an accessible to the public with proposed new civic plazas which will create a sense of
         place for Howth Village and for residents of the new scheme. The residents of the
         scheme will have a private area of open space which Block C has been designed around.
         This is also true of Block B. The residents will have access to semi-private roof gardens
         also. Native planting from the Howth SAAO species list is proposed in the planting
         scheme along Balscadden Road and this will provide a soft buffer boundary treatment
         along the Balscadden Road which is the main route to the SAAO lands.

2.32     Layout: How does the proposal create people-friendly streets and spaces?

         Response: The layout allows for new pedestrian connections onto public plaza areas,
         to Balscadden Bay and the Howth SAAO and The Martello Tower promoting
         connectivity and accessibility through safe, overlooked footpaths.
         A community building is providing on the new plaza off Main St. and a café is proposed
         on the second plaza on Balscadden Road with the aim of drawing people into the space
         and providing a friendly new quarter for all to enjoy. Furthermore, a large retail/café
         is proposed in Block A which faces onto Main St. and will provide for a large type
         restaurant/retail store.

2.33     Public Realm: How safe, secure and enjoyable are the public areas?

         Response: The layout and design of the proposed development has been heavily
         influenced by the level of security and overlooking obtained by the future residents.
         The design of the development has been carefully considered as to provide a high level
         of passive surveillance on areas of open space and publicly accessible areas. The

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CREKAV TRADING GP LIMITED                                                                         MAY 2018
STATEMENT OF CONSISTENCY                       SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

         design of the dwellings provides for direct frontage onto all public areas ensuring the
         provision of a safe, secure and enjoyable residential development. There will be
         beautiful views of the sea and the Martello Tower as you pass down the new
         pedestrian linear plaza to Balscadden Road. There will be improved access to the
         tower with an upgraded pedestrian footpath at the base of the mound. The new civic
         plaza at the junction with Main St. will be a great new addition to Howth Village.

2.34     Adaptability: How will the buildings cope with change?

         Response: Each of the proposed dwellings meets or exceeds the minimum standards
         for residential unit size. For schemes over 100 units, guidelines state that the majority
         of apartments must exceed the minimum floor area by 10% . The size of the units are
         proposed to be 1 bed x c.50-55sq m, 2 bed x 85 sq m, 3 bed 100 sq m, thus the
         apartment sizes are compliant with the guidelines.

         The development provides a mix of 1, 2 & 3 bedroom units that can be easily
         reconfigured to adapt to the changing life cycles and personal needs of each resident.

2.35     Privacy / Amenity: How do the buildings provide a high quality amenity?

         Response: Each dwelling is provided with an area of useable private open space which
         meets or exceeds the Development Plan standards. All of the dwellings meet or
         exceed the Section 28 Guidelines unit size requirements. The design of dwellings has
         also had due regard to the siting and orientation of the development in order to
         maximise the views of the sea, views onto open space, solar gain and natural light
         aspect of each dwelling. The design of balconies maintains a high level of privacy and
         amenity obtained by residents, and reduces the level of overlooking and
         overshadowing.

         Class 2 open space is provided through a number of well-designed public open space
         and wide landscaped paths/plazas throughout the scheme (See Murray and Associates
         drawings for detailed design of the open spaces). These spaces include the Main
         Street Plaza and Balscadden Plaza, Linear Plaza, Martello Path and Plaza, Balscadden

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CREKAV TRADING GP LIMITED                                                                         MAY 2018
STATEMENT OF CONSISTENCY                       SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

         Path South and Public Right of Way and Public Plaza. (See Murray & Associates
         Drawing indicating this – Howth SHD_Open Space Areas). The layout is designed to
         maximise natural sunlight, views and air into the open space.

         2,686sqm of landscaped high amenity public open space is provided on site. 0.19 ha
         Class 2 Open Space is required for the proposed development. There is a shortfall of
         Class 1 Open Space. It is proposed to make a payment in lieu of Class 1 open space as
         per Objective PM53 of the Development Plan.

2.36     Parking: How will the parking be secure and attractive?

         Response: Parking is provided in an underground basement carpark under Block C. It
         is designed to be secure and attractive.

2.37     Detailed Design: How well thought through is the building and landscape design?

         Response: The proposed design of the development has been subject to a number of
         pre-application consultations between the design team and the Planning Authority.
         The design rationale from an urban design and architectural perspective is explained
         in the Design Statement prepared by CCK. The landscape design rationale is set out in
         the Landscape Design Statement prepared by Murray & Associates. We consider the
         end result of this collaborative process is a well thought out design which addresses
         the main concerns including relationship of the new scheme to the existing village’s
         grain and scale, impact on views, impact on buffer of the Howth SAAO.

         The proposed landscaping aims to enhance the amenity of the area by providing a
         quality overall character and visual amenity in the development. Full details on the
         rationale for the landscaping design can be found in the Landscape Design Report and
         Landscape Plan prepared by Murrays.

Delivering Homes, Sustaining Communities (2008)
2.38     The Department’s policy statement Delivering Homes, Sustaining Communities,
         Guidance provides the overarching policy framework for an integrated approach to

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CREKAV TRADING GP LIMITED                                                                         MAY 2018
STATEMENT OF CONSISTENCY                       SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

         housing and planning. The statement notes that demographic factors will continue to
         underpin strong demand for housing, which in turn will present considerable
         challenges for the physical planning of new housing and the provision of associated
         services. The quality of the housing environment is stated as being central to creating
         a sustainable community.

2.39     Sustainable neighbourhoods are areas where an efficient use of land, high quality
         design, and effective integration in the provision of physical and social infrastructure
         combine to create places people want to live in.

2.40     The Delivering Homes, Sustaining Communities policy statement is accompanied by
         Best Practice Guidelines entitled ‘Quality Housing for Sustainable Communities’. The
         purpose of these Guidelines is to promote high standards in the design and
         construction and in the provision of residential and services in new housing schemes.
         They encourage best use of building land and optimal utilisation of services and
         infrastructure in the provision of new housing; point the way to cost effective options
         for housing design that go beyond minimum codes and standards; promote higher
         standards of environmental performance and durability in housing construction; seek
         to ensure that residents of new housing scheme enjoy the benefits of first-rate living
         conditions in a healthy, accessible and visually attractive environment; and provide
         homes and communities that may be easily managed and maintained.

2.41     This planning application is accompanied by a Housing Quality Assessment (HQA)
         document prepared by CCK Architects which demonstrates the consistency of the
         proposed development with the relevant standards in the Quality Housing for
         Sustainable Communities document and the County Development Plan where
         relevant.

Design Standards for New Apartments - Guidelines for Planning Authorities (March 2018)

2.42     The new Apartments Guidelines are also intended to promote sustainable housing, by
         ensuring that the design and layout of new apartments provide satisfactory

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CREKAV TRADING GP LIMITED                                                                         MAY 2018
STATEMENT OF CONSISTENCY                      SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

         accommodation for a variety of household types and sizes, including families with
         children over the medium to long term.

2.43     This planning application is accompanied by a Housing Quality Assessment document,
         prepared by CCK Architects which demonstrates the compliance of the proposed
         development with the relevant quantitative standards required under the 2018
         Apartment Guidelines. The HQA illustrates how each apartment meets or exceeds the
         relevant standards for example in respect to apartment size, internal areas,
         dimensions, private open space, dual aspect etc.

2.44     The proposed apartment buildings and units are considered to be suitability located
         on the subject site, integrated within the landscape and well connected to adjacent
         facilities including public transport, and will provide high quality residential
         development on the subject site. In additional following pre-planning with An Bord
         Pleanala, a decision was made to reduce the level of parking on the site in line with
         National Guidance for sites located within a 10 minute walk of a DART Station. The
         level of bicycle parking is in excess of Development Plan standards and complies with
         the New Apartment Guidelines. A total of 397 no. bicycle parking spaces are provided
         with the aim of promoting sustainable transport modes. In addition, it is proposed to
         provide 3 no car sharing spaces in the underground basement for use by the residents.

Design Manual for Urban Roads and Streets (DMURS) (2013)
2.46     The Design Manual for Urban Roads and Streets (DMURS), 2013, sets out design
         guidance and standards for constructing new and reconfiguring existing urban roads
         and streets in Ireland. It also outlines practical design measures to encourage more
         sustainable travel patterns in urban areas. The Engineering Infrastructure Report, and
         DMURS Statement of Compliance prepared by OCSC Consulting Engineers provides
         further detail in respect of the compliance of the proposed development with DMURS.

2.47     DMURS aims to end the practice of designing streets as traffic corridors, and instead
         focus on the needs of pedestrians, cyclists, and public transport users. The Manual
         sets out design guidance and standards for constructing new and reconfiguring
         existing urban roads and streets in Ireland. Incorporating good planning and design
         practice and focus on the public realm, it also outlines practical design measures to
         encourage more sustainable travel patterns in urban areas. The principle design
         guidance of DMURS has been considered in the design of this development. The

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CREKAV TRADING GP LIMITED                                                                        MAY 2018
STATEMENT OF CONSISTENCY                       SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

         proposed development seeks to prioritise pedestrian and cyclists throughout and
         around the site in accordance with the policies set out in DMURS.

2.48     In line with DMURS and on the advice of An Bord Pleanala the linear plaza has been
         created to replace a trafficked street. Surface car parking was also omitted. This has
         created a wonderful pedestrian and cycle friendly urban environment within this new
         proposed quarter of Howth Village.

2.49     Connectivity and permeability are encouraged throughout the development.
         Pedestrian linkages in the form of a new linear plaza have also been proposed to
         encourage and improve connectivity in the wider area.

2.50     DMURS also suggests that measures should be considered that reduce the dominance
         of the vehicle in favour of pedestrian and cyclists having dominance within a street.
         This is provided within the scheme, with local access provided and no through traffic
         allowed which will encourage sustainable modes of transport.

2.51     The Design Manual for Urban Roads and Streets notes that drivers are more likely to
         maintain lower speeds over shorter distances than over longer ones, therefore the
         proposed road layout has been designed according to this principle.

Guidelines for Planning Authorities on Childcare Facilities (2001)
2.52     Guidelines for Planning Authorities on Childcare Facilities (2001) indicate that
         Development Plans should facilitate the provision of childcare facilities in appropriate
         locations. These include larger new housing estates where planning authorities
         should require the provision of a minimum of one childcare facility with 20 places for
         each 75 dwellings. The threshold for provision should be established having regard to
         existing location of facilities and the emerging demography of the area where new
         housing is proposed. Following a review of creches in the area and an assessment of
         the requirement of the scheme, a childcare demand assessment was prepared which
         concludes that a creche within the scheme would not be viable. It is proposed that
         the community room could be used for a dual use, with mother and toddlers groups
         being accommodation.

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CREKAV TRADING GP LIMITED                                                                         MAY 2018
STATEMENT OF CONSISTENCY                        SITE AT BALSCADDEN ROAD & FORMER BAILY COURT HOTEL, HOWTH

Smarter Travel – A Sustainable Transport Future: A New Transport Policy for Ireland
2009-2020
2.53     The Government has committed in ‘Smarter Travel – A Sustainable Transport Future:
         A New Transport Policy for Ireland 2009 – 2020’ to reducing the total share of car
         commuting from 65% to 45%, a rise in non-car trips by 55% and that the total vehicle
         miles travelled by the car fleet will not increase. The key targets are as follows:

         Future population employment growths will predominantly take place in sustainable
         compact forms which reduces the need to travel for employment and services;

         ➢ 500,000 more people will take alternative means to commute to work to the
              extent that the total share of car commuting will drop from 65% to 45%;
         ➢ Alternatives such as walking, cycling and public transport will be supported and
              provided to the extent that these will rise to 55% of total commuter journeys to
              work;
         ➢ The total kilometres travelled by the car fleet in 2020 will not increase significantly
              from current levels;
         ➢ A reduction will be achieved on the 2005 figure for Greenhouse gas emissions from
              the transport sector.

2.54     Key to the achievement of these targets is better alignment between land-use and
         transport to minimise travel demand. The subject site is located within a 10 minute
         walk from Howth DART station and is also served by Dublin Bus services. There are
         QBC’s located along the Howth Road and along the Clontarf Road from Raheny into
         the City Centre. Thus, the principle of a residential development at a density in excess
         of 35 units per hectare in this location would be in accordance with the principles set
         down in Smarter Travel.

         It is proposed to provide c. 0.7 spaces per residential unit based on the high level of
         public transport available to the residents of the scheme. This is in keeping with the
         principles of Smarter Travel. As mentioned previously, 397. No bicycle parking spaces
         will be provided which is in excess of Development Plan Standards.

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CREKAV TRADING GP LIMITED                                                                          MAY 2018
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