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Strategic Housing Development: Planning Report and Statement of Consistency - Bluebell Residential ...
Kilcullen Road, Bluebell, Naas, Co Kildare   Planning Report & Statement of Consistency

Strategic Housing Development:
Planning Report and
Statement of Consistency
Residential Development
at
Kilcullen Road,
Bluebell,
Naas,
Co. Kildare

on behalf of
Ardstone Homes Ltd

                                                       November 2018

     Declan Brassil & Co.    Ref: 17/045                                                i
Strategic Housing Development: Planning Report and Statement of Consistency - Bluebell Residential ...
Kilcullen Road, Bluebell, Naas, Co Kildare                                                                                               Planning Report & Statement of Consistency

TABLE OF CONTENTS

1       INTRODUCTION ..................................................................................................................................................................... 1
        1.1         Prospective Applicant and Interest in Site ....................................................................................................... 1
        1.2         Characteristics of Proposed Strategic Housing Development ................................................................. 1

                    1.2.1              Nature & Purpose................................................................................................................................. 1

                    1.2.2              Possible Effects on the Environment ............................................................................................ 2
        1.3         Prior Consultations ................................................................................................................................................. 2
        1.3.1       Consultation with Planning Authority .............................................................................................................. 2
        1.3.2 Consultation with An Bord Pleanála ................................................................................................................. 2

2       SITE LOCATION & CONTEXT ............................................................................................................................................ 3
        2.1         Site Location.............................................................................................................................................................. 3
        2.2         Site Description ........................................................................................................................................................ 4

3       SITE HISTORY ......................................................................................................................................................................... 5
        3.1         Subject Site ................................................................................................................................................................ 5
        3.2         Adjoining or Adjacent Sites ................................................................................................................................. 5

4       PARTICULARS OF PROPOSED STRATEGIC HOUSING DEVELOPMENT ............................................................. 7
        4.1         Layout & Design ...................................................................................................................................................... 7
        4.2         Open Space, Access, Permeability & Parking ................................................................................................ 9
        4.3         Integration with Surrounding Land Use .......................................................................................................... 9
        4.4         Universal Access .................................................................................................................................................... 10
        4.4         Part V .......................................................................................................................................................................... 11
        4.5         Services Infrastructure .......................................................................................................................................... 11
        4.6         Architectural and Archaeological Heritage .................................................................................................. 12
        4.7         Possible Effects on the Environment .............................................................................................................. 13
        4.8         Traffic and Transportation .................................................................................................................................. 13

                    4.8.2              Public Transportation ....................................................................................................................... 14

                    4.8.2              Traffic Assessment and Conclusions ........................................................................................... 15

5       NATIONAL PLANNING POLICY CONTEXT ................................................................................................................. 16
        5.1         National Planning Framework .......................................................................................................................... 16
        5.2         Draft Regional Spatial and Economic Strategy for the Eastern and Midland Region ................... 17

6       LOCAL PLANNING CONTEXT - STATEMENT OF CONSISTENCY ....................................................................... 18
        6.1         Naas Town Development Plan 2011-2017 ..................................................................................................... 18

                    6.1.1              Zoning ................................................................................................................................................... 18

                    6.1.2              Statement of Consistency ............................................................................................................... 19
        6.2         Kildare County Development Plan 2017-2023 (KCDP) .............................................................................20

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Strategic Housing Development: Planning Report and Statement of Consistency - Bluebell Residential ...
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                        6.2.1              Core Strategy and Settlement Strategy .....................................................................................20

                        6.2.2              Density................................................................................................................................................... 21

                        6.2.3              Guiding Principles for Greenfield Edge Development .......................................................... 21

                        6.2.4              Housing Mix ........................................................................................................................................22

                        6.2.5              Traffic and Transport ........................................................................................................................22

                        6.2.6              Water Services and Infrastructure ................................................................................................23

                        6.2.7              Community Infrastructure ............................................................................................................. 24

                        6.2.8              Natural Heritage and Green Infrastructure ............................................................................. 24

                        6.2.9              Residential Development Standards ...........................................................................................25

                        6.2.10             Car Parking Standards .....................................................................................................................28

                        6.2.11             Bicycle Parking Standards ...............................................................................................................28

                        6.2.12             Statement of Consistency ...............................................................................................................28

7          SECTION 28 MINISTERIAL GUIDELINES - STATEMENT OF CONSISTENCY ....................................................30

                        7.1                Sustainable Residential Development in Urban Areas - Guidelines for Planning
                                           Authorities ............................................................................................................................................ 31

                        7.2                Sustainable Urban Housing: Design Standards for New Apartments (2018) ................ 31

                        7.3                Draft Urban Development and Building Heights – Guidelines for Planning Authorities
                                           (2018) .....................................................................................................................................................32

                        7.4                Design Manual for Urban Roads & Streets ............................................................................. 34

                        7.5                Childcare Facilities – Guidelines for Planning Authorities (2001) ..................................... 34

                        7.6                The Planning System and Flood Risk Management – Guidelines for Planning Authorities
                                            .................................................................................................................................................................35

                        7.7                Appropriate Assessment of Plans and Projects in Ireland – Guidelines for Planning
                                           Authorities ............................................................................................................................................35

APPENDIX A ...................................................................................................................................................................................... 37

PART V:................................................................................................................................................................................................ 37

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Strategic Housing Development: Planning Report and Statement of Consistency - Bluebell Residential ...
Kilcullen Road, Bluebell, Naas, Co Kildare                                 Planning Report & Statement of Consistency

1          INTRODUCTION

This Planning Report and Statement of Consistency accompanies a planning application by Ardstone
Homes Ltd for permission for a residential development of 125 no. units and associated works at a site of
approximately 3.76 ha, located in the townland of Bluebell, 1.4 km southwest of Naas town centre, County
Kildare.

This Report includes a statement setting out how the proposal is consistent with the objectives of the
relevant County Development Plan, the Naas Town Development Plan and relevant section 28 Ministerial
Guidelines.

1.1        Prospective Applicant and Interest in Site

The prospective Applicant is Ardstone Homes Ltd.

Ardstone Homes Ltd is registered under Company Register No. 589251 and has its offices at 48 Fitzwilliam
Square, Dublin 2.

Ardstone Residential Partners Fund ICAV is the legal owners of 3.51 ha of the application site, comprising
the main residential development site. Ardstone Residential Partners Fund ICAV has granted consent to
Ardstone Homes Ltd to submit a planning application to An Board Pleanála. A letter of consent from
Ardstone Residential Partners Fund ICAV accompanies this application.

The application boundary includes lands outside the main development site (approximately 0.25ha) under
the control of Arrow Finance Limited. This area of the site incorporates drainage infrastructure for the
proposed development, including an underground attenuation tank, a pumping station and associated
access off the Rathasker Road. A letter of consent from Arrow Finance Limited accompanies this
applicaiton.

Liam Queally, the owner of lands to the west of Rathasker Road, has provided a letter of consent to the
applicant for drainage infrastructure to discharge at the Bluebell Stream through a wayleave on his lands to
the west of the Rathasker Road.

1.2        Characteristics of Proposed Strategic Housing Development

1.2.1      Nature & Purpose

The proposed residential development provides for 125 no. new residential dwellings and associated
infrastructure on a site of 3.76 ha located on the western side of the Kilcullen Road (R448), in the townland
of Bluebell, Naas, Co Kildare. The site is located to the south of the Naas Inner Relief Road and 1.4 km from
Naas Town Centre. The proposed residential development directly adjoins the existing residential areas of
Broadfield View to the north and east. Pipers Hill, located approximately 500m to the southeast of the site,
on the opposite site of the Kilcullen Road, consists of an existing educational campus and a large mixed
use, primarily residential development currently under construction.

The proposed development provides for a range of dwelling types including terraced, semi-detached and
detached two storey houses. In addition, the proposed development includes 4 no. maisonette units in the

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north-eastern corner of the site, dormer style houses along the eastern boundary with Broadfield View and
apartment units in a 4 storey building along the western boundary.

The proposed development provides a total of 5,288 sqm of ancillary public open space (approx. 15% of
the residential development site); 228 no. ancillary residential car parking spaces; 23 no. visitor parking
spaces; an extension of the access road permitted under KCC Reg. Ref. 15/848 (ABP Reg. Ref. PL09.246859)
to provide pedestrian/cycle and vehicular access from the R448 Kilcullen Road to the east of the site;
internal roadways; and, all associated and ancillary infrastructure, landscaping, boundary treatments and
development works. The proposed development also includes the provision of a pumping station,
attenuation tank, associated drainage infrastructure and a maintenance access on the eastern side of the
Rathasker Road to the northwest of the main residential development site. This area is approximately 0.25
ha in extent and is zoned I for Agriculture in the Nass Town Development Plan 2011-2017. No proposed
dwellings are located outside lands zoned for residential development.

It is noted that the permitted access road (KCC Reg. Ref. 15/848 and ABP Reg. Ref. PL09.246859) to the
subject lands is currently under construction and connects to the recently upgraded Kilcullen Road (R448).

1.2.2     Possible Effects on the Environment

An Environmental Report, and an AA Screening Report, accompany this application. Having regard to the
context and character of the site and the receiving environment; the nature, extent, form and character of
the proposed development; the Environmental Report has concluded that the proposal will not result in
any significant adverse effects on the environment.

The project has been screened for AA under the appropriate methodology. It has found that the proposed
development does not present a risk of significant effects on the Qualifying Interests and Conservation
Objectives of Mouds Bog SAC, Red Bog SAC or Poulaphouca Reservoir SPA.

1.3       Prior Consultations

1.3.1     Consultation with Planning Authority

In accordance with Section 5(2) of the Planning and Development (Housing) and Residential Tenancies Act
2016, formal pre-planning consultation took place with Kildare County Council (KCC) on 3 April 2018 under
KCC pre-planning Reg. Ref. PP 4031. A revised site layout was issued to KCC on the 26 April 2018 by email
and an email response with feedback on the revised layout was received from KCC on 2 May 2018.

1.3.2     Consultation with An Bord Pleanála

In accordance with Section 5 (1) of the Planning and Development (Housing) and Residential Tenancies Act
2016, formal pre planning consultation took place with An Bord Pleanála (ABP) and Kildare County Council
on the 29 August 2018 under ABP Ref. ABP-302130-18.

Following pre-application consultation with An Bord Pleanála, the Bord issued a Notice of Pre-Application
Consultation Opinion on 20 September 2018. The manner in which the matters raised in the Opinion have
been incorporated into the drawings and documents submitted with this application are specifically
addressed in detail in separate correspondence accompanying this application.

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2         SITE LOCATION & CONTEXT

2.1       Site Location

The subject lands are approximately 3.76 ha, located in the townland of Bluebell, Naas, Co. Kildare. The site
is approximately 1.4 km to the south west of the centre of Naas and is connected from the R448 Kilcullen
Road via an access road to the east that is currently under construction.

Figure 2.1             Site Location

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Strategic Housing Development: Planning Report and Statement of Consistency - Bluebell Residential ...
Kilcullen Road, Bluebell, Naas, Co Kildare                                   Planning Report & Statement of Consistency

The landscape in the immediate vicinity of the residential development site is defined by the existing
residential estates of Esmondale, Broadfield View and Killashee View to the north and east, and by
agricultural land to the west and south. Residential development in the vicinity of the site is primarily in the
form of two storey detached and semi-detached houses, along with bungalow type dwellings in Broadfield
View. The Pipers Hill Educational Campus is located approximately 500m to the southeast of the site on
R448 Kilcullen Road and contains Pipers Hill College, Gaelscoil Nás Na Ríogh, St David’s National School
and the Educational and Training Boards of Ireland (ETBI). The Pipers Hill residential development,
adjoining the educational campus, is currently under construction.

2.2       Site Description

The site is roughly rectangular in shape and consists of part of 3 no. agricultural fields. Overhead power
lines currently cross the site. Hedgerows and trees define the northern and eastern boundary with
Broadfield View. The site is bounded to the north and east by Broadfield View, and to the south and west
by agricultural lands and the Rathasker Road.            The Pipers Hill educational centre and residential
development is located on the opposite site of Kilcullen Road. The site will connect with the R448 Kilcullen
Road to the east via an access road permitted by Kildare County Council under Reg. Ref. 15/848 (ABP Reg.
Ref. PL 09.246859).

Figure 2.2             Aerial View of Application Site

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Strategic Housing Development: Planning Report and Statement of Consistency - Bluebell Residential ...
Kilcullen Road, Bluebell, Naas, Co Kildare                                   Planning Report & Statement of Consistency

3           SITE HISTORY

Provided below is an overview of recent relevant planning history relating to the proposed development
site and the lands in the immediate vicinity of the site.

3.1         Subject Site

A review of Kildare County Council’s (KCC) online planning register identified one application lodged in
respect of the subject site.

KCC Reg. Ref. 15/848 (ABP Reg. Ref. PL09.246859): On the 08 June 2016, KCC granted permission,
subject to 19 no. conditions, for development consisting of the construction of a new entrance, roadway
and all ancillary works to access land zoned residential at Bluebell, Naas, County Kildare.

On the 17 November 2015, KCC issued a Further Information Request for 20 no. items relating to the future
development of the site, a masterplan for the residential lands and details of foul water, surface water and
services.

The decision of KCC was subject to a third party appeal and on the 28 October 2016, An Bord Pleanála
upheld the decision of the planning authority to grant permission, subject to 6 no. conditions. The
following conditions are relevant:

    Condition 3: ‘The roadway shall be suitably fenced off from public use pending a grant of permission for
    development on the adjacent lands’.

    Condition 4: ‘The entrance and internal road network shall comply with the detailed standards of the
    planning authority for such road works’.

3.2         Adjoining or Adjacent Sites

A review of Kildare County Council’s (KCC) online planning register identified multiple permissions for
development relating to alterations to individual dwellings in the Broadfield View residential estate to the
north and the development of Kilashee View to the east. There is extensive planning history relating to the
ongoing development of Pipers Hill to the southeast, with relevant permissions detailed below.

KCC Reg. Ref. 05/500021: On the 03 April 2007, Naas Town Council granted permission for development
consisting of c.26m of access road to an educational campus submitted in a concurrent application; 271 no.
dwellings of 5 house types; 8 no. dwellings on the administrative boundary of the Town Council and Kildare
County Council; 18 no. apartments; 5 no. retail units and a single storey crèche on a site area of 14.9ha. The
proposed development is part of an overall integrated tourism, recreational, educational, commercial and
residential development on 130ha at Pipers Hill.

The statutory notice states that a concurrent clarification of further information/revised plans will be
submitted to Kildare County Council (KCC Ref. 05/437) for a post primary school and gym facility. The
statutory notice also states that the remaining part of the site is reserved for the educational campus; an 18
hole championship golf course, driving range and clubhouse; a 100 bedroom nursing home; 4 no.
enterprise office units; 274 no. dwellings plus the 8 no. dwellings that straddle the administrative boundary.

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Condition 2 states that ‘phasing of the development shall be agreed in writing with the Planning Authority
subject to the school and ancillary services being given advanced priority. In particular:

     a) No residential or neighbourhood centre development shall be occupied prior to the completion of
        the required foul sewer network linking the subject lands and the Osberstown Waste Water
        Treatment Plant.

     b) No residential or neighbourhood centre development shall be occupied prior to the completion of
        the direct connection of the Kilcullen Road to the Newbridge Road, and improvements from that
        connection point onto the Newbridge Road to the M7 Junction.

     c)   With the exception of the proposed school, no residential or neighbourhood centre unit may be
          occupied prior to the implementation of proposed road improvements on the Kilcullen Road’.

Condition 41 states that ‘the road improvements proposed under the Part 8 Procedure, located on the
Kilcullen Road, in agreement with the developer shall be completed prior to the commencement of
development’.

On the 14 April 2016, KCC issued a letter stating that conditions 2 (a), 2 (c) and 41 had been complied with.

On the 02 April 2012, KCC granted an extension of duration of permission for the proposed development
until 02 April 2017, under KCC Reg. Ref. 11/500088.

KCC Reg. Ref. 07/500176: On the 15 August 2008, Naas Town Council granted permission for
development consisting of an amendment of 05/500021 for a change of house types, consisting of the
substitution of 127 no houses with 117 no. detached two storey houses.

On the 04 June 2013, KCC granted an extension of duration of permission for the proposed development
until 02 April 2017, under KCC Reg. Ref. 13/50027.

It is noted that this amendment to parent permission 05/500021 has been subject to multiple additional
amendments including the following:

         KCC Ref. 08500152 – Amendments to elevational treatments

         KCC Ref. 16223 – Replacement of 7 no. houses with 9 no. houses

         KCC Ref. 16445 – Amendments to house types.

KCC Reg. Ref. 13500059: On the 31 January 2014, Naas Town Council refused permission for an
amendment to Reg. Refs. 05/500021 and 07/500176 consisting of replacement of approximately 163 no.
units with 188 units for 3 no. reasons including:

         Prematurity pending determination by the planning authority of the layout and implementation of
          improvement works to the R448 Kilcullen Road.

         Proposed development would be contrary to the principals of DMURS.

         Proposed development fails to comply with the development management standards due to
          uniformity of layout, lack of diversity in design and the lack of quality open space

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KCC Ref. 16635: On the 14 February 2017, KCC granted permission for development consisting of 243
houses, a crèche and associated site works.

4         PARTICULARS OF PROPOSED STRATEGIC HOUSING DEVELOPMENT

4.1       Layout & Design

The proposed residential development provides for 125 no. new residential dwellings on a site of 3.76ha
(3.51ha residential development area) located 580m south of the Naas Inner Relief Road, in the townland of
Bluebell, approximately 1.4 km from Naas Town Centre, Co Kildare. The proposed residential development
is in close proximity to the Pipers Hill development and educational campus to the southeast, on the
opposite side of Kilcullen Road (R448).

The proposed residential development comprises 12 no. one bed dwellings; 64 no. two bed dwellings; 24
no. three bed dwellings and 25 no. four bed dwellings. The proposed development provides for a range of
dwelling types including terraced, semi-detached and detached two storey houses. In addition, the
proposed development provides single storey, dormer style houses along the eastern boundary with
Broadfield View and apartment units in a four-storey complex along the western boundary.

The layout has been primarily informed by the site location and context, along with the policies, objectives
and development standards of the Naas Town Development Plan 2011-2017 and the Kildare County
Development Plan 2017-2023. Table 4.3 below provides the key site statistics for the proposed
development.

A breakdown of residential units is provided in Table 4.1 below, Table 4.2 indicates the varied housing mix.

Table 4.1              Breakdown of Residential Units

 Description                                 Quantity         Mix %

 1 Bed Apartments                               8               6.4

 2 Bed Apartments                              20               16

 1 Bed Maisonette                               4               3.2

 2 Bed House                                   44              35.2

 3 Bed House                                   24              19.2

 4 Bed House                                   25               20

 TOTAL                                         125             100

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Kilcullen Road, Bluebell, Naas, Co Kildare                            Planning Report & Statement of Consistency

Table 4.2              Residential Unit Sizes

                                                No. of                   Area
   Type       Description                                    Beds                     Mix (%)
                                                Units                   (sqm)
    A1        Maisonette                          2               1       52
                                                                                        3.2%
    A2        Maisonette                          2               1       62
    B1        Detached Dormer                     5               3     105.4
                                                                                        4.8%
   B1A        Detached Dormer                     1               3     110.5
    B2        Two storey, End of Terrace         26               2      86.2
                                                                                       35.2%
    B3        Two Storey, Mid-Terrace             18              2      86.2

    C1        Two storey, Semi-Detached           16              3     112.2
                                                                                       14.4%
    C2        Two Storey, Semi-Detached           2               3     114.2

    D1        Two Storey, Semi-Detached           16           4        132.4

    D2        Two Storey, Semi-Detached           1               4     134.2           17.6%

    D3        Two Storey, Semi-Detached           5               4     143.6

    D4        Two Storey, Detached                3               4     143.6           2.4%

    Apt       1 bed apartment unit                8               1       52            6.4%
    Apt       2 bed (3 person) apartment unit     6               2       67
                                                                                         16%
    Apt       2 bed apartment (4 person) unit     14              2     74-76

Table 4.3              Key Site Statistics

 Site Statistics

 Total Site Area                                          3.76 ha

 Residential Development Area                             3.51 ha

 No. of Units                                               125

 Total Gross Floor Area Proposed                         11,845 sqm

 Footprint of Buildings                                  6922.1sqm

 Net Density                                              36 u/ha

 Plot Ratio                                                 0.32

 Site Coverage                                             18.4%

 Public Open Space                                       5,288 sqm

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Kilcullen Road, Bluebell, Naas, Co Kildare                                  Planning Report & Statement of Consistency

4.2       Open Space, Access, Permeability & Parking

The proposed development incorporates a total of 5,288 sqm (approximately 15% of the residential
development site) of public open space, primarily arranged around a spine of 3 no. areas of high quality,
usable, public open space.

A large open space area of 2,160 sqm (Open Space C) is centrally located and provides a focal point for the
scheme. The central open space incorporates a designated play area, kick about space and seating.

An open space area of 1,323 sqm (Open Space D) is located to the north of the central open space,
adjacent to the proposed apartment block and incorporates formal hard and soft landscaping with informal
natural play opportunities.

The third area of primary open space is situated to the southeast of the site (Open Space A & B), proximate
to the main entrance of the development. This space has a cumulative area of 1,486 sqm and has been
designed to create an attractive entrance to the proposed development, connecting with the road and
associated landscaping (under construction), permitted under ABP Reg. Ref. PL09-246859 (KCC Reg. Ref.
15/848). This open space area also provides a comprehensive screening solution from the Kilcullen Road
and integrates the proposed development with the adjoining agricultural lands to the south and west.

Two smaller areas of ancillary public open space are provided to the north (Open Space F) and south
(Open Space E) of the site.

Vehicular, pedestrian and cycle access will be primarily from the recently upgraded R448 Kilcullen Road to
the south-east of the site via the permitted and under construction access road (KCC Reg. Ref. 15/848 and
ABP Reg. Ref. PL09.246859). In addition, the proposed development incorporates future potential
pedestrian and vehicular connections on the north-western and south-western boundaries of the site to
adjoining agricultural lands to the west to future proof connections to those lands in the event that they re
zoned and prioritised for residential or other development in future reviews of the Naas LAP.

The proposed development also provides for future pedestrian and cycle connectivity to Broadfield View to
the northeast of the site, via an adjoining area of public open space in Broadfield View. The indicative
location for a pedestrian pathway from the subject site through the open space area of Broadfield View has
been provided with this application. The layout of the proposed development ensures that the pedestrian
linkage can be readily facilitated. The delivery of the pedestrian connection is being progressed with Kildare
County Council.

A total of 251 car parking spaces are proposed to serve the proposed dwellings. 190 car parking spaces are
provided for each house and 38 parking spaces are provided within the curtilage of the apartment block.
23 visitor spaces are provided in a mix of parallel and perpendicular car parking distributed throughout the
site.

4.3       Integration with Surrounding Land Use

The residential development site is bound to the north and east by the Broadfield View residential estate
and by lands in agricultural use to the south and west. Residential development in the vicinity of the site is
primarily in the form of two storey detached and semi-detached houses, along with bungalow type
dwellings in Broadfield View.

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Kilcullen Road, Bluebell, Naas, Co Kildare                                      Planning Report & Statement of Consistency

The scale, height and design of the proposed dwellings have had due regard to the existing residential
developments to the north and east. The majority of dwellings are two-storey, with a four-storey apartment
block (approximately 12.8m in height), incorporating a recessed third floor located to the north west of the
site.

Dwellings along the northern boundary with Broadfield View are two storeys and incorporate appropriate
separation distances in excess of 22m to mitigate any residential amenity impacts on adjoining residents.
Dwellings along the eastern boundary with Broadfield View are single storey duplex units and have been
provided to prevent any potential overlooking of the existing single storey dwellings to the east and to
avoid overshadowing of amenity space.

Vehicular, cycle and pedestrian access to the development area will be provided via an extension of the
permitted and under construction access road (KCC Reg. Ref. 15/848 / ABP Reg. Ref. PL09.246859) from the
Kilcullen Road (R448). The proposed development integrates with the permitted and under construction
access road, which incorporates pedestrian footpaths and cycle paths from the recently upgraded Kilcullen
Road (R448). The recently completed upgrades to the Kilcullen Road (R448) included the provision of
improved pedestrian infrastructure and segregated cycle lanes.

Future potential pedestrian and vehicular connections to the adjoining agricultural lands are provided at
the north-western and south-western corners of the site. The development has also been designed to
facilitate a pedestrian and cycle connection to Broadfield View to the northeast of the site, via an adjoining
area of public open space. Indicative locations for the pedestrian pathway from the subject site through the
open space area of Broadfield View have been provided with this application and will be progressed with
Kildare County Council.

The accompanying architectural plans and site plan that illustrate the general relationship between houses,
accessibility, design quality of street and footpaths, permeability between open spaces and passive
surveillance of the public realm. This results in a housing scheme that is well connected and integrated with
its built and natural surroundings, and which has been designed to be attractive and safe for residents and
members of the existing community.

4.4       Universal Access

The proposed development has been designed with due regard to the principles of universal design,
including the ‘Building for everyone’ publications. Main features as follows:

All homes have level access and inaccessible areas have been eliminated as far as possible. All apartments
have access to both stair and lift cores. All houses are equipped with a habitable room and a visitable WC
at entry level. The public realm and landscaping will be fully compliant with the requirements of Part M and
is designed ensure accessibility on equal terms for people of a range of ages and physical mobility.

A range of house types have been proposed in terms of both size and design meeting the aspirations of a
range of people and households. The scheme includes both apartments and single storey dormer house
types, which provide bedrooms at ground level, and are particularly accessible for people with disabilities
as all accommodation can be provided on a single level.

These homes are one and two bedroom in size and each enjoy open plan living spaces which are easy to
negotiate for those with reduced mobility. The dormer houses are particularly fitting for families with

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accessibility needs, providing level access to generous gardens and easy circulation within and between
spaces.

Designated car parking is provided either within the curtilage of the homes or adjacent to the homes.
Accessible car parking will be provided within the scheme and visitor parking is spread throughout the
scheme reducing travel distances for visitors with reduced mobility.

The proposed development presents a positive and varied aspect, avoiding unnecessary physical and visual
barriers with legible, distinct and memorable character areas and spaces that aid wayfinding.

Future connections to adjacent lands subject to future development have been proposed. The network of
roads, paths and cycle routes ensure full permeability and connectivity throughout the scheme.

4.4       Part V

It is intended to comply with Part V of the Planning and Development Act 2000 (as amended) by the
transfer of built units on site. Based on the layout submitted herewith, it is envisaged that 13 no. units will
be transferred to the Planning Authority. These dwellings consist of 4 no. one bed Maisonette units (House
Type A1 and A2), 7 no. two bed terraced units (House Types B2 and B3) and 2 no. three bed semi-detached
units (House Type C1).

Consultations have taken place with the Housing Department of Kildare County Council in respect of
identification of units, methodology for calculating values of land, site costs, normal construction and
development costs and profit on those costs and other related costs. Appendix A includes the Part V letter
from Kildare County Council confirming submission of the Part V proposal, the Kildare County Council Part
V Proposal Sheet and associated unit costings, prepared by the applicant Ardstone Homes Ltd. A Part V
site layout prepared by John Fleming Architects is also submitted with the application.

Notwithstanding the information submitted herewith, all details of compliance with Part V requirements will
be agreed with the Planning Authority upon the issue of any grant of planning permission.

4.5       Services Infrastructure

An Infrastructure Design Report prepared by DBFL and is provided with this application.

The surface water drainage system will collect surface-water run-off generated from the proposed
residential development and has been designed in accordance with the Greater Dublin Code of Practice for
Drainage Works and the Greater Dublin Strategic Drainage Study (GDSDS) and the requirements of Kildare
County Council. The surface water outfall pipe is to be routed across adjacent lands to discharge to the
Upper Bluebell Stream, approximately 380m to the west of the site, with a wayleave agreement to be put in
place across third party lands. Letters of consent from the adjoining landowners regarding the surface and
foul drainage infrastructure for the proposed development have been provided with the application.

The proposed development incorporates the attenuation of storm water to limit discharge form the site,
with storage facilities and SUDs elements being designed to allow infiltration or reductions in run off
volumes and rates where possible. In addition, a flow control device will be provided downstream of the of
the drainage system to ensure that the total run off from the site will be limited to the greenfield run off

Declan Brassil & Co.    Ref: 17/045                                                                              11
Kilcullen Road, Bluebell, Naas, Co Kildare                                    Planning Report & Statement of Consistency

rate before final discharge. Attenuation structures have been designed to provide the required volume for
a 100 year storm event (+20% climate change).

It is noted that the drainage for the permitted road has been designed to work as a standalone infiltration
based system that will be constructed in advance of the proposed development.

Due to the topography of the site, the foul water network has been designed to discharge by gravity to a
proposed pumping station to the north-west of the site, adjacent to the Rathasker Road. A letter of consent
from the adjoining landowner regarding the surface and foul drainage infrastructure for the proposed
development have been provided with the application. The rising main from the pump station will be
directed through the site, along the permitted and under construction access road to discharge to the
existing Irish Water sewer in the Kilcullen Road (R448). A new discharge manhole will be placed on the
Kilcullen Road prior to connection to the existing network. Works between the site boundary and the
Kilcullen Road are to be constructed under ABP Reg. Ref. PL09.246859 (KCC Reg. Ref. 15/848). Pipe layouts
generally follow the proposed road layout and each residential unit is to be served by individual 100mm
diameter connections.

Detailed design measures for the pumping station and foul layout will be agreed with Irish Water. The
pumping station layout will be in accordance with the Irish Water Standard Detail STD-WW-26 and will
include a 24 hour emergency storage tank.

Foul connection for the proposed development can be facilitated, subject to a valid Irish Water connection
agreement being put in place. A Pre-Connection Enquiry Form has been issued to Irish Water, and its
response included with the application documentation (see appendix F of the Infrastructure Design Report).

With regard to water supply, the proposed development will have one new water main connection to the
existing 12” uPVC water main in the Kilcullen Road (R448). A spur from the Kilcullen Road (R448) is to be
constructed as part of the permitted road development. Individual houses will have their own connections
to distribution mains via service connections and meter/boundary boxes. The water main layout and
details, including valves, hydrants, metering etc. will be in accordance with Irish Water’s Code of Practice
and Standard Details for water infrastructure.

4.6       Architectural and Archaeological Heritage

An Archaeological Assessment, prepared by IAC was provided with the request for pre-planning
consultation with An Bord Pleanála. The first Archaeological Assessment for the site involved a detailed
study of the archaeological and historical background of the development site and the surrounding area.
This included information from the Record of Monuments and Places of Kildare, the topographical files in
the National Museum and all available cartographic and documentary sources for the area, along with a
field inspection to identify any previously unrecorded features of archaeological or historical interest.

The Assessment noted that the site does not contain any recorded monuments and no potential
archaeological features where recorded in historical maps or aerial photographs of the site. No features or
structures of obvious archaeological significance were identified within the site during the field inspection.
Archaeological investigations and stray finds from the wider landscape have produced evidence of human
settlement and activity in the region. The assessment concluded that ground disturbances associated with
the development may have an impact on previously unrecorded archaeological feature or deposits that
survive beneath the current ground level, with no surface expression. The report recommended a

Declan Brassil & Co.    Ref: 17/045                                                                                12
Kilcullen Road, Bluebell, Naas, Co Kildare                                  Planning Report & Statement of Consistency

programme of geophysical survey and targeted archaeological testing be carried out within the site and
that provision be made for the resolution of any archaeological features or deposits that may be identified,
if that is deemed the most appropriate manner to proceed with.

Further to the recommendations of the IAC report, a Geophysical Survey was not carried out on site due to
the presence of a standing crop. However, test trenching was undertaken on the subject site under licence
from the Department of Culture, Heritage and the Gaeltacht (Licence No. 18E0485) and in consultation with
the National Museum of Ireland. A revised Archaeological Assessment report, prepared by Archer Heritage
and containing the results of the test trenching is enclosed with the planning application documentation
and has been submitted to the Department of Culture, Heritage and the Gaeltacht. A total of 29 trenches
were excavated across the site under archaeological supervision and no archaeological features were
recorded during the course of the assessment. Due to the scale of the site and the constraints regarding
geophysical testing, the report concludes that there is a low-medium potential for the survival of
archaeological remains. The report recommends that any future development works be monitored by a
suitably qualified archaeologist under licence and in consultation with the National Museum of Ireland.

The site does not contain any protected structures or features of architectural significance and is not within
any Architectural Conservation Areas or area of Archaeological Significance. The nearest protected
structures and the Naas Architectural Conservation Area are located approximately 1.5km to the north of
the site within the Town Centre. Therefore, no direct impact on the architectural heritage will arise as a
result of the proposed development.

4.7       Possible Effects on the Environment

An Environmental Report, and an AA Screening Report, accompany this application. The Appropriate
Assessment Screening Report has been prepared by O’Callaghan Moran & Associates.

Having regard to the context and character of the site and the receiving environment; the nature, extent,
form and character of the proposed development; the Environmental Report concludes that the
assessments undertaken conclude that the proposal will not result in any significant adverse effects on the
environment. Mitigation measures have been proposed to avoid, remedy or reduce any identified impacts.

4.8       Traffic and Transportation

A Traffic & Transport Assessment Report (TTA) prepared by DBFL is submitted with this application. The
scope of the TTA covers transport and sustainability issues including means of vehicular access, pedestrian,
cyclist and public transport connections. The principal objective of the report is to quantify any level of
impact across the local road network and subsequently ascertain both the existing and future operational
performance of the local road network. The TTA has been prepared in reference to both national and local
policy and guidance. Key publications consulted include:

         ‘Traffic and Transportation Assessment Guidelines’ (May 2014) National Roads Authority;

         ‘Traffic Management Guidelines’ Dublin Transportation Office & Department of the Environment
          and Local Government (May 2003); and

         ‘Guidelines for Traffic Impact Assessments’ The Institution of Highways and Transportation.

Declan Brassil & Co.    Ref: 17/045                                                                              13
Kilcullen Road, Bluebell, Naas, Co Kildare                                 Planning Report & Statement of Consistency

The proposed development connects to an access road and junction on the Kilcullen Road, which was
granted planning permission in October 2018 under ABP Reg. Ref. PL09.246859 (KCC Reg. Ref. 15/848). This
access road and junction are currently under construction. The road layout of the proposed development
provides for future potential vehicular and pedestrian connections to currently zoned agricultural lands to
the west of the site. The layout design also incorporates an additional future pedestrian link in the north -
eastern corner of the site to the adjoining Broadfield View Residential Estate, through public open space
within this estate. An indicative layout of a pedestrian route through the public open space has been
provided with this application and can be provided in consultation with Kildare County Council.

4.8.1     Pedestrian & Cycle Linkages

The Kilcullen Road (R448) is located to the south east of the site, is subject to a speed limit of 50 kph and
benefits form the provision of street lighting on both sides of the road. Pedestrians and cyclists benefit
from high quality pedestrian and cycle facilities along the route, which alternate between pedestrian
footways with adjacent cycle tracks, pedestrian footways with adjacent on-road cycle lanes, and shared
pedestrian/cycle tracks. A Toucan Cross is provided immediately to the north of the permitted and under
construction access route to the subject site and further crossings are provided at the Pipers Hill/Kilcullen
Road junction to the south. Pedestrian and cyclist facilities will be provided along both sides of the
permitted and under construction site access route currently under construction and will tie into the
Kilcullen Road infrastructure. Accordingly, the subject site will be highly accessible to both pedestrian and
cyclists with permeable connections provided to the neighbouring lands via this access / egress junction.

4.8.2     Public Transportation

JJ Kavanagh operates service number 139 along the Kilcullen Road corridor and connects Piper’s Hill (south
of the subject site) with Blanchardstown, also serving Naas, Sallins, Clane, Maynooth, Leixlip, and Ongar.
This service is highly accessible with the closest interchange opportunities located within 65m of the site
access junction currently under construction.

There are also a variety of other bus services available serving Naas Town Centre including the following:

         Bus Eireann: 123, 124. 126, 126N, 130

         JJ Kavanagh: 717, 8460, 736A, 129

         Dublin Coach: N7 Service

         KCoach from Monasterevin to Naas

The interchange locations for these bus services are located at the Naas Post Office on Main Street in the
town centre, located approximately 2km from the subject site.

The closest train station to the subject site is the Sallins & Naas Station located approximately 5.6km north
of the subject site. There are several high frequency peak period services operating daily to/from the
station serving the following routes:

         Dublin – Kildare / Portlaoise

         Dublin – Waterford

Declan Brassil & Co.    Ref: 17/045                                                                             14
Kilcullen Road, Bluebell, Naas, Co Kildare                                    Planning Report & Statement of Consistency

         Dublin – Galway

         Dublin – Westport / Ballina

There are 260 vehicle parking spaces available at the station, in addition to the provision of sheltered cycle
parking and cycle lockers.

4.8.2     Traffic Assessment and Conclusions

The TTA has carried out a range of assessments for an opening year of 2020 and future horizon years of
2025 and 2035. The TTA also considers the impact of committed residential development in the vicinity of
the subject site, particularly in relation to the Pipers Hill Phase 2 residential development (KCC Reg. Ref.
16/635 - 243 houses and a crèche of 560 sqm) located to the south east of the subject site on the opposite
side of the Kilcullen Road. In order to determine the predicted level of traffic generated from the third party
residential development, reference has been made to the Traffic Impact Assessment prepared by O’Connor
Sutton Cronin Consulting Engineers (September 2016) and submitted with the application.

Based upon the information and analysis detailed within the TTA the principal findings are as follows:

         The proposed residential development is located proximate to sustainable forms of travel including
          walking, cycling and public transport.

         The proposals are in accordance with the land use zoning for the subject development site.

         The proposals comply fully with the local authority’s development standards in terms of the
          quantum of car parking and bicycle parking spaces being provided on-site.

         The access junction and road from the Kilcullen Road (R448) to the subject site was granted by An
          Bord Pleanála in October 2016 (KCC Reg. Ref. 15/848 and ABP Reg. Ref. PL 09.246859) and is
          currently under construction.

         The analysis reveals that proposed residential development would result in an increase of only
          1.25% (28 vehicle trips) in the AM peak period and 1.96% (25 vehicle trips) in the PM peak period,
          during the 2035 future horizon year at the Pipers Hill/Kilcullen Road junction.

         The junction analysis revealed that the junction access to the site, currently under construction and
          operating as a priority controlled arrangement, will operate with significant reserve capacity in the
          years assessed.

         The increase in traffic flows as a result of the proposed development is below the 5% threshold on
          the Kilcullen Road (R448) corridor and at the neighbouring Pipers Hill/Kilcullen Road junction.

The TTA concludes that the subject development will generate minimal impacts across the local road
network, based on the anticipated levels of traffic generated by the proposed development, the existing
and future road infrastructure and the analysis conducted. It is considered that there are no significant
traffic or transportation related reasons that should prevent the granting of planning permission for the
proposed development.

Declan Brassil & Co.    Ref: 17/045                                                                                15
Kilcullen Road, Bluebell, Naas, Co Kildare                                 Planning Report & Statement of Consistency

5         NATIONAL AND REGIONAL PLANNING POLICY

5.1       National Planning Framework

The recently published National Planning Framework (NPF) is the Government’s high-level strategic plan
for shaping the future growth and development of Ireland to the year 2040 and replaces the National
Spatial Strategy 2002-2020. The NPF requires the preparation of Regional Spatial and Economic Strategies
(RSES’s) for each region by the Regional Assemblies to supersede the Regional Planning Guidelines, to be
completed in early 2019.

Regarding future housing development, National Policy Objective 32 of the NPF sets at target for the
delivery of of 550,000 additional households by 2040. To meet projected population and economic growth,
as well as increased household formation, annual housing output will need to increase to 30,000 to 35,000
homes per annum to 2027, with an average output of at least 25,000 new homes between 2018 and 2040.

The key emphasis of the NPF is to ensure balanced regional growth, the promotion of compact
development and the need to avoid urban sprawl. It is the aim of the NPF to have a ‘roughly 50:50
distribution of growth between the Eastern and Midland region, and the Southern and Northern and
Western regions, with 75% of growth to be outside of Dublin and its suburbs.’ The NPF sets targets ‘for at
least 40% of all new housing to be delivered within the existing built-up areas of cities, towns and villages
on infill and/or brownfield sites. The rest of our homes will continue to be delivered at the edge of
settlements and in rural areas.’

The NPF also promotes the provision of lifetime adaptable homes that can accommodate the changing
needs of a household over time and a move from historical low density housing development to avoid
urban sprawl, noting that apartments will become a more prevalent form of housing. This is underpinned
by on-going population growth, movements towards smaller household sizes, an ageing and more diverse
population, greater mobility in the labour market and a higher proportion of households in the rented
sector. It is stated that an increase in the proportion of more compact forms of growth in the development
of settlements of all sizes can contribute to the viability of services, shops and public transport, increase
housing supply and enable more people to be closer to employment and recreational opportunities, as
well as to walk or cycle more and use the car less.

Kildare, Meath and Wicklow are included in the Mid-East area of the Eastern and Midland Region in the
NPF. Under National Policy Objective 1b, the population of the Eastern and Midland Region is to increase
by 490,000 – 540,000 to around 2.85 million people by 2040. Key future planning, development and place-
making policies for the Eastern and Midlands Region include:

    ‘Enabling the complementary development of large and county towns in the wider Greater Dublin Area
    and Midland areas on the key strategic and public transport routes in a regionally co-ordinated manner,
    with an enhanced emphasis on measures to promote self-sustaining economic and employment based
    development opportunities to match and catch-up on rapid phases of housing delivery in recent years.’

Section 4.3 of the NPF states that there is a need to encourage population growth in towns of all sizes that
are strong employment and service centres, where potential for sustainable growth exists, also supported
by employment growth. National Policy Objective 5 promotes the development of cities and towns of

Declan Brassil & Co.    Ref: 17/045                                                                             16
Kilcullen Road, Bluebell, Naas, Co Kildare                                    Planning Report & Statement of Consistency

sufficient scale and quality to compete internationally and to be drivers of national and regional growth,
investment and prosperity.

Section 6.6 of the NPF states that Ireland’s future homes will:

         Be located in places that can support sustainable development – places which support growth,
          innovation and efficient provision of infrastructure, are accessible to a range of local services, can
          encourage the use of public transport, walking and cycling and help tackle climate change.

         Be delivered in our cities and larger towns (where large scale housing demand exists), where
          homes and the appropriate supporting services can be delivered more efficiently and effectively at
          less cost to the State in the long-run.

The proposed residential development is situated to the south of Naas, which acts as important economic
driver in Kildare, accommodating a range of employment options and community services for the resident
population and hinterland areas. In addition, the proposed development is located proximate to the
pedestrian, cycle and public transport services along the Kilcullen Road, the emerging neighbourhood
district and facilities provided in the Educational Campus to the southeast of the site at Pipers Hill. In
accordance with the National Planning Framework, it is submitted that the proposed development will
contribute to the housing growth targets and objectives regarding the consolidation of existing urban
areas.

The proposed density is 36 units per hectare incorporating a range of dwelling types, including traditional
semi-detached and detached units, terraced 2 bed units, single storey dormers and apartments. The range
of dwellings provided ensures that the development can accommodate a range of household types with
varying needs. The dwellings have also been designed to be adaptable to changing needs over time.

5.2       Draft Regional Spatial and Economic Strategy for the Eastern and Midland Region

The Draft Eastern and Midland Region Spatial and Economic Strategy (RSES) was published on 5 November
2018 for public consultation. Submissions or observations on the draft strategy can be submitted until 23
January 2019.

The statutory purpose of the RSES is to support the implementation of National Framework Plan, Project
Ireland 2040 and the economic policies and objectives of the Government by providing a long-term
strategic planning and economic framework for the development of the Regions. Local Authorities will
implement the RSES by way of review of all development plans after the adoption of the Strategy. In
accordance with the policies and objectives of the National Framework Plan, the RSES targets a greater
proportion of future housing development (up to 50% in Dublin, up to 30% in other towns) to be
accommodated within and close to the existing built up urban areas.

Section 1.3 of the RSES provides the settlement strategy for the region and identifies Naas as a ‘Key Town’
in the Hinterland Area. The preferred settlement strategy contained in the RSES includes the consolidation
of Dublin and the Regional Growth Centres of Athlone, Dundalk and Drogheda, supported by the growth
of a limited number of self-sustaining settlements (Key Towns) such as Naas.

Declan Brassil & Co.    Ref: 17/045                                                                                17
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