Townscape and Visual Appraisal Proposed Residential Development Ardee Street, Dublin 8 - Prepared by Model Works Ltd for Nrek 1 Limited November 2021

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Townscape and Visual Appraisal Proposed Residential Development Ardee Street, Dublin 8 - Prepared by Model Works Ltd for Nrek 1 Limited November 2021
Townscape and
Visual Appraisal

Proposed Residential
Development
Ardee Street,
Dublin 8

Prepared by Model Works Ltd for
Nrek 1 Limited

November 2021
Townscape and Visual Appraisal Proposed Residential Development Ardee Street, Dublin 8 - Prepared by Model Works Ltd for Nrek 1 Limited November 2021
Contents

1.0   Introduction                                                                       1
      1.1 Purpose                                                                        1
      1.2 Proposed Development                                                           1
      1.3 Methodology                                                                    1
2.0   Receiving Environment                                                              3
      2.1 The Site                                                                       3
      2.2 Historic Evolution of the Site Environs                                        9
      2.3 Key Townscape Elements and Character Areas of the Receiving Environment   13
      2.4 The Liberties, Dublin 8                                                   13
      2.5 Liberties LAP Character Areas                                             14
      2.6 Local Receiving Character Areas (LRCAs)                                   16
3.0   Relevant Policy                                                               19
      3.1 Dublin City Development Plan 2016-2022                                    19
      3.2 National Policy                                                           22
4.0   Proposed Development                                                          24
      4.1 Description of Development                                                24
      4.2 Development Typology/Uses                                                 25
      4.3 Site Layout                                                               25
      4.4 Public Open Space                                                         28
5.0   Assessment of Townscape Effects                                               29
      5.1 Townscape Sensitivity                                                     29
      5.2 Magnitude of Townscape Change                                             31
      5.3 Significance of Townscape Effects                                         33
6.0   Assessment of Visual Effects                                                  34
7.0   Conclusions                                                                   43

APPENDIX 1           LANDSCAPE/TOWNSCAPE & VISUAL IMPACT ASSESSMENT METHODOLOGY     ii

           Townscape and Visual Impact Assessment
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Townscape and Visual Appraisal Proposed Residential Development Ardee Street, Dublin 8 - Prepared by Model Works Ltd for Nrek 1 Limited November 2021
1.0 Introduction
1.1     Purpose
This report discusses the potential townscape and visual impacts of the proposed Strategic Housing Development
at a site bound by Newmarket Square to the North, Ardee Street to the West and Mill Street to the South,
Newmarket, Dublin 8 (including City House and Unit 3, Newmarket, Dublin 8).

1.2     Proposed Development
The site is located on the western end of an urban block at Newmarket, Dublin 8, situated approximately 3km to
the south-west of the city centre, on land that currently accommodates several 1970/1980s
commercial/industrial buildings.
Planning permission is sought for the demolition of all buildings/structures on the subject site and the
construction of a 6-9 storey building accommodating 134 no. build to rent apartments and a ground floor
commercial/retail unit of approx. 606 sqm. The proposed development also includes ancillary upgrade works to
the immediately surrounding paths and roadways.

1.3     Methodology
The townscape and visual appraisal was carried out with reference to the Landscape Institute Guidelines for
Landscape and Visual Impact Assessment 2013 (GLVIA), the Institute’s Information Note Townscape Character
Assessment 2017, and the EPA draft Guidelines on the Information to be Contained in Environmental Impact
Assessment Reports 2017. The appraisal methodology including explanation of the criteria and terms used is
provided in Appendix 1. Photographs of the existing views are included under separate cover, as will be
photomontages of the proposed scheme.
The assessment was carried out by David Bolt BA(Hons) CMLI of Model Works Ltd.
The European Landscape Convention defines landscape as “an area, as perceived by people, whose character is
the result of the action and interaction of natural and/or human factors”. The word ‘townscape’ is used in
urban/built-up areas. GLVIA requires that the effects on views and visual amenity be assessed separately from
the effects on the townscape, although the topics are linked:
   •   Townscape results from the interplay between the physical, natural and cultural components of our
       environment. Different combinations of these elements create variations in landscape/townscape
       character. Townscape impact assessment is concerned with the effects of a proposed development on
       the character and value of the townscape as an environmental, cultural and economic resource. The
       potential townscape impact of the Proposed Development is assessed in Chapter 5.
   •   Visual impact assessment is concerned with changes that arise in the composition of available views, the
       response of people to those changes and the overall effects on the area’s visual amenity. The potential
       effects on 7 no. viewpoints in the receiving environment are assessed in Chapter 6, informed by verified
       photomontages (provided under separate cover).
The Landscape and Visual Impact Assessment differs importantly from other environmental factors such as
heritage in that its focus is on the capacity of current physical environment to accommodate change of any type
of development, and while the cultural context is considered, the emphasis is placed on contemporary amenity
value of landscape character and views, and what difference in those values the changes brought about by the
Proposed Development would result. The conclusions will assist in arriving at a sound judgement of the merits of
the Proposed Scheme in terms of the effects on character and visual amenity and help guide decision making in
regard to the planning application.

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Townscape and Visual Appraisal Proposed Residential Development Ardee Street, Dublin 8 - Prepared by Model Works Ltd for Nrek 1 Limited November 2021
The report is organised in sections as follows:
   1.   Introduction
   2.   Receiving Environment
   3.   Proposed Development
   4.   Assessment of Landscape Effects
   5.   Assessment of Visual Effects
   6.   Preliminary Conclusions

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Townscape and Visual Appraisal Proposed Residential Development Ardee Street, Dublin 8 - Prepared by Model Works Ltd for Nrek 1 Limited November 2021
2.0 Receiving Environment
2.1       The Site
2.1.1     Location
The Subject Site is located in the Liberties area in the inner City area of Dublin, to the south of Newmarket Square,
and bounded by Ardee Street to the west and Mill Street to the south (see Figure 1). The Subject Site includes
City House and Unit 3, Newmarket, Dublin 8. To the east is the recently completed non-residential property
known as the ‘Eight Building’.

Figure 1: The Subject Site in context of the wider location of Dublin 8

2.1.2     Site Description
The site is currently occupied by several 1970/1980s 2-3 storey industrial/warehousing/office buildings that front
onto Newmarket Square, Ardee Street and Mill Street. The site has an irregular polygonal shape measuring c.
56m on Market Square, c. 54.3m on Ardee Street, and 17.15m along Mill Street. The boundary that is contiguous
with the adjacent building is staggered in two ‘steps’, totalling c. 22m east – west and c.50m north - south (see
Figure 2).
The recent occupants of the premises include the ‘Liberty Church’ and (on the West frontage), and a taxi
company, audio business, art school, offices and storage (on the north frontage). There is a curious octagonal
corrugated iron-clad tower above the church, which was constructed as a ventilation structure.
The existing structures are in varying states of repair, and none of the existing structures on site has architectural
or historic significance, as confirmed by the Architectural Conservation Report prepared by Mullarkey Pedersen
Architects and an Archaeological Desk-Based Impact Assessment has been prepared by Claire Walsh, Consultant
Archaeologist, both of which accompany this submission.

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Townscape and Visual Appraisal Proposed Residential Development Ardee Street, Dublin 8 - Prepared by Model Works Ltd for Nrek 1 Limited November 2021
The existing land use on the site is primarily industrial / warehousing. The adjoining uses consist of a mixture of
residential, commercial and office buildings. The southern boundary faces a construction site for a 7 storey mixed-
use accommodation for student and a BTR scheme. The submitted Architectural Design Statement also provides
a detailed description of the site and its surroundings.

                                           Black Pitts

                                                                                                                Oscar Square

                                                                                               Weavers Park

Figure 2: Aerial view of the Subject Site in context of Newmarket Square (blue wash indicates buildings to be demolished; red
dashed outline indicates planning boundary on the ground)

2.1.3   Access
The Subject Site is situated in Dublin City Centre, and more locally within The Liberties. It is advantageously
located for public transport connections, including a number of Dublin Bus routes running along Cork Street, and
is in close proximity to the Luas Line stops at Fatima and Stephens Green. Cork Street is also part of the proposed
Dublin City cycle network and is a short distance from 2 Dublin bike stations. Heuston Rail Station is within a
reasonable distance.
2.1.4   Urban Grain
While the regeneration of the area has long been overdue, conservation of the urban form has been a policy
objective of the Newmarket masterplan. The surrounding urban grain is a mixture of smaller plots to the west
with larger urban forms to the east marking the transition to the inner city.
2.1.5   Contiguous Land Use Areas
Since 2015/2016, Newmarket Square and its immediate surroundings have been undergoing significant changes
through the provision of large scale redevelopment and regeneration projects, many of which are currently under
construction. Surrounding streets are predominantly residential in character with older two storey semi-detached
and terraced dwelling houses generally situated to the west and south-west of the site and newer apartment
buildings located to the north and east.
The land and buildings adjacent to the development are described in detail in Section 5.0 of this report. CGIs have
been prepared by Model Works for 7no. views, provides views of the Proposed Development in the existing
context and views of it seen cumulatively with other permitted re-development schemes in the surrounding area.
The following are existing views of the site surrounds. The overwhelming impression of the areas immediately
adjacent to the Subject Site is one of disruption and transformation dominated by large-scale construction works

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Townscape and Visual Appraisal Proposed Residential Development Ardee Street, Dublin 8 - Prepared by Model Works Ltd for Nrek 1 Limited November 2021
and cranes. With reference to the aerial view in Figure 2, the following illustrative photographs and assessment
highlight characteristics of the surrounding urban environment.
                                                                        To the southwest of the site Ardee
                                                                        Street merges at two conjoined
                                                                        junctions with other local access roads,
                                                                        the surfaces of which, together with the
                                                                        sidewalks to either side, form expansive
                                                                        areas of tarmac. Land use is dominated
                                                                        by the neighbouring building currently
                                                                        under construction for BTR and student
                                                                        accommodation.           Ardee Street
                                                                        continues south to become Sweeney’s
                                                                        Terrace, a cul-de-sac terminating in a
                                                                        works yard serving construction
                                                                        vehicles and plant.

Figure 3: View form Sweeney’s Lane toward the Subject Site

                                                                       Further south and west, Ardee Street
                                                                       joins Oscar Square and Clarence
                                                                       Mangan Road through what is currently
                                                                       a relatively quiet and untrafficked
                                                                       residential neighbourhood. Properties
                                                                       to either side are mainly two story
                                                                       residential terraces with white rendered
                                                                       frontages and slate roofing, set back
                                                                       from the road with small, mostly well
                                                                       kept front gardens, behind gated railings
                                                                       or brick boundary walls. Oscar Square at
                                                                       this point is a road but leads to the gated
                                                                       public open space of the same name
                                                                       (see below).
Figure 4: Terraced houses on Clarence Mangan Road

                                                                        East from the Subject Site, Newmarket
                                                                        Square widens to a bland expanse of
                                                                        tarmac, currently used mainly for
                                                                        construction traffic and ad hoc parking.
                                                                        Land use is dominated by two active
                                                                        construction sites to the north of the
                                                                        Square. The Brewery site immediately
                                                                        north of the Subject Site is intended for
                                                                        BTR and student accommodation. The
                                                                        Brabizon Street site to the middle north
                                                                        side of the Newmarket is a mixed use
                                                                        complex with further residential units.
                                                                        artisan and ‘arts quarter’ style retail,
                                                                        hotel/hospitality, community and
                                                                        leisure premises.
 Figure 5: Newmarket Square, looking west towards the site

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Townscape and Visual Appraisal Proposed Residential Development Ardee Street, Dublin 8 - Prepared by Model Works Ltd for Nrek 1 Limited November 2021
To the immediate east of the Subject Site,
                                                                                   a new commercial office building and the
                                                                                   new Teeling Whiskey Distillery face the
                                                                                   square. The refurbished Teeling Whiskey
                                                                                   Distillery, fronting the central south side
                                                                                   of Newmarket Square, together with the
                                                                                   Dublin       Liberties   Distillery,  both
                                                                                   characterised by industrial style buildings
                                                                                   of an equivalent of 2-3 storeys in height
                                                                                   provides an indication of the style of
                                                                                   development and type of business
                                                                                   activity that the LAP objective aspire to
Figure 6: Newmarket Square looking East                                            encourage for the location.

                                                                                   To the west of Newmarket Square and
                                                                                   the Subject Site, the narrow, terraced-
                                                                                   lined Chamber Street leads past Weaver
                                                                                   Park to the north, intersecting Weaver
                                                                                   Square and Ormon Street. Chamber
                                                                                   Street has a mix of red brick on-street
                                                                                   properties that appear to be in a
                                                                                   reasonable state of repair and derelict
                                                                                   business premises that are attracting
                                                                                   graffiti whilst evidently awaiting
                                                                                   redevelopment. The linearity of the
                                                                                   street directs views towards Newmarket,
                                                                                   although at present there is no defining
                                                                                   features that indicate there may be a
Figure 7: Chambers Street looking east towards the site                            civic space ahead.

                                                                                   North of the Subject Site, Ardee Street
                                                                                   intersects Cork Street and St Luke’s
                                                                                   Avenue. The narrow roadway is strongly
                                                                                   contained by Southgate, a contemporary
                                                                                   8 storey residential and office space
                                                                                   building with retail units on the Cork
                                                                                   Street frontage (Southside Angling).

Figure 8: Ardee Street junction with Cork Street, looking south towards the site

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               Proposed Residential Development, Ardee Street, Dublin 8                                                    6
Townscape and Visual Appraisal Proposed Residential Development Ardee Street, Dublin 8 - Prepared by Model Works Ltd for Nrek 1 Limited November 2021
Opposite, a once fine Georgian-fronted 3
                                                                                  storey residential block of dark brick,
                                                                                  adds an element of archaic character to
                                                                                  the mixed genre of structures within the
                                                                                  street scene (see Figure 11). The
                                                                                  partially demolished adjacent terrace,
                                                                                  revealing a still-intact ornate fire
                                                                                  surround on its upper floor, contributes
                                                                                  further to the sense of nostalgic loss.

Figure 9: No 10 Ardee Street, on the junction with Cork Street

                                                                                   Contemporary 5 to 6 storey residential
                                                                                   apartments are located North of St
                                                                                   Luke’s Avenue, on the Ardee Street
                                                                                  junction. With a well-articulated range
                                                                                  of elevations punctuated by recessed
                                                                                  balconies, and retail units on the ground
                                                                                  floor face the road, the contrasting
                                                                                  facades of buff brick and patinated
                                                                                  copper create a lively and interesting
                                                                                  urban statement. To the east, another
                                                                                  range of structures of contrasting
                                                                                  heights and geometries in pale red brick
                                                                                  further contributes to the tasteful
                                                                                  contemporary feel and returning
                                                                                  affluence of recent development in the
Figure 10: Contemporary architectural design - recent regeneration on St Luke’s
                                                                                  location. Although suffering from poor
Avenue / Ardee Street
                                                                                  quality timber finishing, the structures
                                                                                  potentially set standards to be followed.

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             Proposed Residential Development, Ardee Street, Dublin 8                                                   7
Townscape and Visual Appraisal Proposed Residential Development Ardee Street, Dublin 8 - Prepared by Model Works Ltd for Nrek 1 Limited November 2021
2.1.6    Conservation
Newmarket Square comprises a Conservation Area, contiguous with and overlapping the Subject Site’s northern
frontage, and there are protected structures in the vicinity of the site on Newmarket and Mill Street. it is also
located within the wider area of Zone of Archaeological Interest that covers an extensive part of the south inner
city. However, the Liberties LAP sets out clearly how development should proceed within the context of
identifying, defining and respecting heritage, integrating it with the key goal of economic and urban regeneration.

. Figure 11: Protected structure within Newmarket - red brick
former ECB enclosure

                                                                   Figure 12: Emblematic of urban decay, a semi-
                                                                   demolished Georgian terrace on Ardee Street

Figure 13: Oscar Square - nearby green space currently excluded
to public use

                                                                  2.1.7      Open Space and Vegetation
                                                                  Amenity Open Space near the site includes the
                                                                  relatively recently Weaver Park, which serves the
                                                                  areas mixed and diverse population with a
                                                                  playground skate park and lawn area, as well as
                                                                  providing greenery in the form of semi-mature
                                                                  deciduous street trees and a range of urban-tolerant
                                                                  shrubs/groundcovers. The site is also within walking
                                                                  distance of St. Kevin's Park, St. Stephen's Green and
                                                                  public greens at St. Luke's Church and Oscar Square.
                                                                  Community allotments are located nearby.
Figure 14: Weaver Park – a new public open space within a short
walk of the site

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2.2      Historic Evolution of the Site Environs
Newmarket comprises an historic square that is currently being regenerated under the auspices of the Liberties
LAP, as a new urban destination accommodating markets, event venues, al fresco dining and performance space.
                                                              When medieval ‘Dubline’ expanded, three gateways
                                                              were built outside the city walls along the Coombe, to
                                                              aid defence and the regulation of traffic and commerce,
                                                              as indicated in Figure 15 in a 1610 map. An area of high
                                                              ground by the Coombe (derived from com or ‘valley’)
                                                              extended from what is now Ardee Street to New Row,
                                                              south to Mill Street and was bordered by the Commons
                                                              Water, the Abbey Stream and the River Poddle. This
                                                              area eventually became the site of Weavers’ Square,
                                                              Newmarket and St Luke’s Church. Newmarket Square
                                                              was granted a ‘royal patent’ in 1674, modelled on
Figure 15: John Speed’s map of Dublin, 1610, showing the gate
along the Coombe north of what was to become Newmarket Smithfield to the north. Its basic form has remained
Square                                                        largely intact to the present.
Much of the surrounding street plan, which dates from the late seventeenth century, was once central to Dublin’s
cloth working, leather tanning and brewing/malting industries. Mill Street (to the immediate south of the site)
was so named as an access to Warrenmount Mills (later used as an ice and cold storage warehouse), complete
with mill pond. A brewery was located to the north of the site and a number of maltings were located nearby.
Many of the structures were constructed with the iconic Dutch ‘Billies’ gables frontages, unique in their context
and as distinctive to the Liberties as the Georgian terraces were of Fitzwilliam Street.

Figure 16: New Row, to the north east of Newmarket (with St             Figure 17: No. 10 Mill Street – a surviving example
Patrick’s Cathedral beyond; typical of the Dutch Billy frontage,        of the Dutch Billy style of brick frontage, once
now lost                                                                prevalent throughout the Liberties
By the early 20th century, the fine grain of the streetscape had been largely consolidation by incorporation of
individual businesses into larger footprint premises. This reportedly resulted in the loss of vibrancy within the
area’s street scene. Warehousing, workshops and a police station faced New Market and north of these,
residential properties lined Brabazon Road and the now lost Coombe Street. In keeping with the traditionally
industrial livelihoods of many of the businesses in the Newmarket area, the Subject Site had been occupied by a
fertilizer manufacturing factory.

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Around the turn of the 21st century a further change in the townscape began, driven by the imperative to develop
sustainability. Construction of higher density developments took place on former industrial and institutional
lands, facilitated by the large landholdings, a history of large buildings on the sites, and better access to public
transport as well as other services.
                                                                                               However, despite major
                                                                                               road construction north of
                                                                                               Newmarket in the 1980’s,
                                                                                               including the widening of
                                                                                               the St Luke’s Avenue/Cork
                                                                                               Street R 110 to the north,
                                                                                               the historic form and
                                                                                               footprint of many of the
                                                                                               buildings           fronting
                                                                                               Newmarket lay unaltered
                                                                                               until       the      current
                                                                                               regeneration programme
                                          Site
                                                                                               begun. Figure 18 illustrates
                                                                                               an overlay of the 1890 OS6
                                                                                                inch OS map on a recent
                                                                                                aerial         photograph,
                                                                                                demonstrating how little
                                                                                                had changed within the
                                                                                                immediate vicinity       of
                                                                                                Market Square, Mill Street,
                                                                                                Chamber Street, and the
                                                                                                contiguous        southern
Figure 18: The 1890 OS 6 inch OSI map overlaid on a recent aerial photograph, highlighting the  section of Ardee Street.
Subject Site and Newmarket Square footprint, the historical configuration of which remains intact
despite significant regeneration of the built environment

The Architectural Conservation Report prepared by Mullarkey Pedersen Architects, which accompanies this
submission, confirms there are no historical buildings remaining on the application site and that none of the
existing structures on site has architectural or historic significance. In terms of surviving historic fabric, the report
confirms the above assessment, in that ‘Very little historic built fabric is retained at the western end of
Newmarket. The primary surviving significance is the retention of the spatial urban form of the 17th century
market itself.’
The outcome of the evolution described above is an emerging regenerated townscape characterised by a
structured land use that is focussed on providing much-needed residential accommodation with a sustainable
density, as well as retail and commercial space, leisure and hospitality premises and office space. Much of the
new development is being undertaken by DCC directly in response to acute affordable housing shortages within
the inner city of Dublin. Student accommodation has also been a focus of development, which has been a market
response to shortage of supply. New and upgraded public open space and parks have been or will be provided.
2.2.1    Site Planning Context
The Subject Site’s location falls under the auspices of which was by the Dublin City Development Plan 2016-2022
which endorsed the Liberties Local Area Plan 2009-2020 (LAP). Although the latter has now lapsed, it prescribed
specific standards and guidance for the Subject Site, under which the Proposed Development has been designed,
as have all schemes approved since 2009 within the area, The Liberties (and Newmarket) area is now designated
as Strategic Development and Regeneration Area 16 (SDRA 16). The site (fronting Ardee Street, and Newmarket,
and backing onto Mill Street) is zoned Z10 – ‘…facilitate and consolidate the development of Inner City and Inner

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Suburban sites for mixed-use developments, which office, retail and residential would be the predominant use'.
Lands zoned Z10 will cater for a relatively intensive form of development in accessible inner suburban locations.
Permitted uses in this zoning objective include residential, office, part off-licence, restaurant and shop
(neighbourhood). The Proposed Development falls within the strategic housing definition, as provided in the 2016
Act, which means the ‘development of 100 or more houses on lands zoned or residential use….’. Other uses
proposed comprises 700sqm of commercial use. The Proposed Development complies with the ‘strategic housing
development’ definition.
                                                                                     Where Newmarket Square sits
                                                                                     geographically within the Liberties
                                                                                     LAP      programme       of    urban
                                                                                     regeneration is shown in the
                                                                                     context      of    the     area-wide
                                                                                     redevelopment scope in Figure 19,
                                                                                     as illustrated in Chapter 2 of the
                                                                                     Liberties LAP, the Vision. The
                                                                                     Subject Site is located on the south
                                                                                     western end of the square. The
                                                                                     approximate site and Proposed
                                                                                     Development massing has been
                                                                                     highlighted for this report in blue.
                                                                                     Importantly, while much of the
                                                                                     ambitious vision set out in the LAP
                                                                                     has been realised (or is in the
                                                                                     process of being so), Dublin City
                                                                                     Council (DCC) has permitted it to
                                                                                      judiciously evolve in response to
                                                                                      prevailing economic and social
Figure 19: Illustration from the Liberties LAP, page 14, Chapter 2, showing scope of realities, as is evident by the
regeneration, Newmarket’s position within it (yellow highlight) and the approximate completed schemes within the
site/proposed massing (blue highlight).
                                                                                      Newmarket area.
Newmarket Square is a key component within the Liberties public realm strategy (LAW Pl. Ref. 2283/17) approved
in July 2017. Designed to create a high quality, multi-functional market square and city-wide destination and to
improve permeability throughout the area via enhanced links across St. Luke’s Avenue to the north and Mill Street
to the south, the aim is to encourage day and night time activities around the public open spaces. It also aims to
create a public realm that prioritises walking, cycling and easy street crossing with particular emphasis on
pedestrian priority. Public lighting in the area will be designed to improved safety and encourage the cultural and
tourist offer of Newmarket Square and its environs. Dividing the square into three zones, the Public Realm Plan
incorporates vehicular access on Brabazon street with parking at the western end. The remainder of Newmarket
Square would be pedestrianised and loosely zoned as a 'universal' and 'cultural' space. Regeneration of
Newmarket Square itself is to take place following the completion of redevelopment of key sites, including the
Subject Site. The assessment of the Proposed Development takes into consideration in its interface with the
public realm the existing context and the approved and anticipated future context cumulatively within the
baseline.
2.2.2   Site Planning History
The only planning application available directly regarding the Subject Site (DCC Ref. 5602/04) was granted by
Dublin City Council on the 09 March 2005, for internal alterations including the installation of a new first floor,
toilets and stairs; minor alterations to the external facade and change of use from light industrial to
community/place of worship use at Unit 3, Newmarket Square & corner of Ardee Street & Mill Street, Dublin 8.

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2.2.3    Planning History – Adjoining Lands
Appendix A of the submitted Planning Report summarises relevant planning history pertaining to the Z10 lands
around Newmarket Square and lands immediately surrounding the site. This information is presented in the form
of a map with numbered sites together with a corresponding table setting out details of the planning history and
a summary of the permitted and existing land uses surrounding the proposed development.
As a short summary, the numbers on Figure 3 below refer to the known current development contiguous with
the site, as listed beneath the diagram, including other known relevant developments in addition tot the site
itself. The site boundary is outlined in red, and the Proposed Development is highlighted in blue. The adjacent
newly constructed / development under construction are highlighted in yellow.

                                                  04
                                                               03                           02                 01

                      14                                                                 16
          15

                                                             Site
                                           12                               05                   07
                                                                                                                  09
                 13                                                                    06
                                                                                                        08

                                                                       11

                                                                                                                    10

Figure 20: April 2021 Aerial photograph indicating Subject Site Application boundary and adjacent permitted development

With reference to Figure 20, currently known permitted development in land adjacent or near to the Subject Site
include the following:
1. 1997: Newmarket Street; DCC permissions for mixed use / residential 2 storey extension to existing building,
     completed.
2. 1998 – present: Barbizon Street; DCC and ABP permissions for 5, 7, and 8 storey complex with lower and basement
     ground parking, mixed-use development including residential, retail, office, leisure, hospitality and hotel
     accommodation, under construction.
3. 2019: The Brewery; ABP permissions for SHD 2 to 8 storey student accommodation, under construction.
4. 2020 – present: Nos. 10, 11 and ‘The Ramp’, Ardee Street; DCC permission for 3-4 storey offices, and
     duplex/apartments, awaiting construction.
5. 2017 – present: Mill Street; DCC permission for Indoor Market, Artist Studios and Office, completed
6. 2013: Teelings Distillery; DCC permission for Distillery and tourist attraction, completed.
7. 2006 – present: Permitted: Micro-Brewery incorporating bar and café/restaurant and Proposed: Mixed Use –
     Residential/Retail/Outdoor Market DCC; 2 – 6 storeys with basement, on-going.
8. 2014 – 2019: Whisky Distillery and Tourist Attraction; 2 storeys with basement, completed
9. 1993 – 1998: Hens Teeth etc, Wards Hill and Mill Street; DCC permissions for 2-4storey residential (with shops),
     completed.
10. 2009 – 2020: Warrenmount complex; Hotel, Student Accommodation and Tourist Accommodation; 9no. DCC and
     1no ABP permissions; completed.

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11. 2009 – 2019: Ardee/Mill Street l; 7no DCC and 2no, APB permissions for Student Accommodation and BTR
    Residential, under construction.
12. 2019 – present: Ardee Street and Chamber Street; Part 8 DCC permission for public housing property, 2 blocks of
    4 – 6 storeys of residential BTR and retail, under construction.
13. 2019 – present: Weavers Square; SHD residential apartments (south), Part 8 DCC permission for public housing
    property, under construction. (Ref. 3498/19)
14. 2019 – present: Chambers Street; SHD residential apartments (north), DCC property, under construction.
15. 2019: Weaver Park, DCC public open space, completed.
16. 2017: Newmarket / Liberties public realm strategy (LAW Pl. Ref. 2283/17); to be commenced following build-out
    of DCDP / SDRA 16 allocated development land approvals contiguous to Newmarket Square and linking streets.
Apart from identifying cumulative recently constructed, currently under-construction and recently approved
development, this list demonstrates the significant quantum of property that has and is being constructed within
the character and visual envelope of the Subject Site. With reference to the Dublin City Development Plan 2016-
2022, Zoning Map E, the majority of the development falls within Zone 10, residential, office and retail, which
allows for a ‘relatively intensive form of development’.
The Planning Statement accompanying this submission assesses the implications of the record of planning
approvals in relation to the lapsed Liberties LAP and both the Z10 and SDRA 16 provisions, which have a particular
impact on proposed building heights.

2.3     Key Townscape Elements and Character Areas of the Receiving Environment
The main potential receptors of townscape and visual change on the site are urban character areas that are
representative of the existing receiving environment. The key areas can be defined as a ‘regional’, district and
local level and neighbourhood level.

2.4     The Liberties, Dublin 8
The Subject Site is located within Dublin, a metropolitan city which is currently undergoing significant
development and change; the pace of change to the urban fabric has accelerated following successful financial
measures and changes to the planning system, introduction of new shared and build-to-rent (BTR)
accommodation models, a rising wealth demography, a reduction in household size, an increase in demand for
individual properties, and consequent rising property values due to a shortage of suitable accommodation.
As highlighted within the previous section, the Liberties is an historic district of Dublin which has, in areas,
retained the urban structure and grain of the past. Due to traditionally slow pace of economic activity within the
area, the area had experienced acute urban decay. While elements of the Liberties built environment reflect
vestige’s the culturally vernacular buildings and special form, much of this has been compromised by expedient
redevelopment and lack of upkeep/maintenance and is either unfit for continued use or renovation.
Development polices have therefore pragmatically aimed to retain the spirit of heritage within the layout and
place names, and to regulate the aesthetics of design and materials of new-build to reinstate a local character
that is inspired by, rather than a pastiche of, the past. Development policies have therefore provided clear
structure and guidance to ensure characteristics of the Liberties are sustained. While the LAP is no longer in
force, the analysis of the urban environment remains largely valid, as does the guidance and objectives upon
which the majority of recent, under construction and proposed development has been based, including that of
the Subject Site, as acknowledged and set out within Section 5.3.4 of the Planning Report accompanying this
submission.

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2.5         Liberties LAP Character Areas
The LAP identifies eight distinct urban landscape character areas (LCAs) within the Liberties used to identify
appropriate ‘broad brush’ development objectives (see Figure 21). While there will be an element of reciprocal
influence between all the nearest LCAs, the two most relevant to this assessment are:
   7. Newmarket / Chamber-Weavers’
   8. Cork Street / The Coombe Corridor
2.5.1       LAP Character Area 7, ‘Newmarket / Chamber-Weavers’
LAP Character Area 7, ‘Newmarket / Chamber-Weavers’ (LCA 7) is the receiving character area. The circumstances
and issues within LCA 7 identified by the LAP includes the following assessment:
   ‘Newmarket…eroded inline with general Post-War economic decline in the Liberties. The area differs
   greatly from its historical appearance as the great number of small plots in multiple ownership or leases
   has largely been replaced by a small number of large, impenetrable, single-use sites. The area is little
   known …outside the Liberties and has sparse outdoor activity. Newmarket Square is in the centre of the
   area and is surrounded by low-rise, industrial buildings that offer little or no activity on the space itself.’
The LAP section 5.1.8 described LCA 7 in 2007 (prior to the commencement of regeneration) with urban
characteristics and development objectives.
Key characteristics of LCA 7 include:
        •     Heritage buildings at the…the Mill on Mill Street
              and warehouse on Newmarket Square.
        •     Low rise industrial buildings.
        •     Primarily two storey houses arranged in terraces
              south of Chambers Street and Mill Street.
        •     Green open space at Oscar Square which
              remains locked and inaccessible.
        •     Heights range from 1-5 storeys.
        •     Materials generally slate, brick, render or
              pebble-dash cladding for houses and brick,
              render, stone, render, metal, concrete, timber
              cladding or stone cladding for other buildings.
                                                                  Figure 21: Liberties LAP Existing Character Areas Map, p. 59

Currently, a further key characteristic of LCA 7 is exceptionally rapid change to the built environment,
intentionally so.
2.5.2       LAP Character Area 8: Cork Street / The Coombe Corridor
The adjacent LAP Character Area 8: ‘Cork Street / The Coombe Corridor’ (LCA 8) creates a barrier between the
receiving LCA and the wider Liberties urban envelope, and interactively influences Newmarket due to the linking
roads and shared development parcels such as the Brewery and the Brabazon Street mixed use development.
Key characteristics of LCA 8 are:
   •        Mixture of residential & industrial uses.
   •        Varying building scales and heights.
   •        Heights range from 2-8 storeys.
   •        Area in transition; major development underway & more planned.

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•    Cork Street acts as a main traffic artery but has bottleneck effect at the Coombe (e.g., contiguous with
        LCA7).
The LPA assessment of LCA 8 notes that Cork Street had recently been widened to accommodate traffic flow,
inadvertently severing LCA7 from the Liberties hinterland; it noted the trend towards replacement of two and
three storey 18th and 19th century commercial and residential premises with larger new mixed-use residential
developments of increased scale and height of 6-8 stories, and that this appropriately redefined the contiguous
character of the urban environment.
2.5.3    LCA Development Objectives
Objectives the LAP put forward to mitigate these circumstances within LAP Character Area 7, ‘Newmarket /
Chamber-Weavers’ include to:
   •    Improve permeability throughout the area through new links across Cork Street to the north and Mill
        Street to the south.
   •    Deliver a high quality, multi-functional market square and city-wide well-known destination.
   •    Encourage … cafes, bars, restaurants and local shops.
   •    Provide active frontages along key walking routes and towards key local activity nodes.
   •    …encourage walking and cycling, providing shared surfaces and easy street crossing. Pedestrian priority
        should be particularly enhanced on the central market square.
Objectives for LAP Character Area 8: ‘Cork Street / The Coombe Corridor’ include to:
   •    Create a good sense of enclosure along the length of the street corridor.
   •    Provide active frontages along key walking routes and towards key local public spaces.
   •    … encourage walking and cycling, providing shared surfaces and easy street crossings.
   •    Improve permeability by delivering links from Cork Street to other areas, enhancing connectivity within
        the wider emerging street network in the Liberties.
   •    Create intervals of green space and enhanced public realm along the street including street tree planting.
   •    Ensure that all new developments along the Cork Street / Coombe Corridor are of an appropriate building
        height up to a maximum of 6-8 storeys, subject to sensitivity to local context...
                                                                       Section 7 of the Liberties LAP sets these objective
                                                                       out as site-specific development and design
                                                                       guidance for Newmarket, identified as ‘Site C’, and
                                                                       Section 7.8 identifies the Subject Site as site 4,
                                                                       noting it is an ‘opportunity for major
                                                                       redevelopment’.

Figure 22: Liberties LAP Character Areas Analysis p. 178 identifying
the Subject Site

Bearing the townscape character assessment and guidance in mind, any evaluation of effects of change must
consider how sensitive receptors will benefit from the changes, as much as if they will be adversely impacted. The
LAP makes it clear that the Newmarket, and the Subject Site, have a poor quality baseline character, and that
change is required to mitigate this, in compliance with the development guidance.

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2.6     Local Receiving Character Areas (LRCAs)
The following local receiving character areas (LRCAs) have been identified by distillation of the overlapping
characteristics of each area described above, focussing on the public realm. The divisions are not based on
delineated areas on a plan as each contains buildings or land that may overlap the adjacent area, but the
described characters have elements in common, such as similarities in land use, scale and type of public realm
and building frontage and quality of streetscape. Each area has been assessed to be potentially susceptible to
change and value in terms of urban characteristics and/or features located within it; conflating the value and
susceptibility determine the level of sensitivity that each location may be considered to have to the proposed
changes to the characteristics of the Subject Site.
   •    LRCA 1: Cork Street/St Luke’s Avenue Frontage
   •    LRCA 2: Western Chamber Street and Weavers
   •    LRCA 3: Ardee Street
   •    LRCA 4: Newmarket Public Realm
   •    LRCA 5: Oscar Square
   •    LRCA 6: Mill Street and Warrenmount
2.6.1   LRCA 1: Cork Street/St Luke’s Avenue Frontage
Cork Street/St Luke’s Avenue (R110) is a two-lane road with dedicated cycle paths in both directions and wide
pedestrian pavements. The road is c. 85m to the north of the Subject Site. The road’s status is elevated by its
function as the link between the city centre via Patrick Street and the M50 (c. 1km and 6km from the site
respectively). It is thus well served by Dublin Bus routes.
In the vicinity of the Subject Site, the land uses fronting the road corridor include residential properties, a
neighbourhood centre, extensive retail and hospitality outlets and Weavers Park. The road is screened from the
Subject Site by intervening buildings, including the Brewery site and the existing Southgate building on the Ardee
Street junction. Views from Cork Street are transitory to both vehicles/cyclists and pedestrians. Cork Street/St
Luke’s Avenue acts as a barrier to pedestrian north/south movement between Newmarket and the Liberties
hinterland, resulting in a change of characteristics between Liberties LAP LCA 7 (Newmarket) and the broader
Liberties LCAs. The key objective of LCA 8 (Cork Street / The Coombe Corridor) of providing shared surfaces and
easy street crossings (over Cork Street) is not fully realised; progress towards enhancing permeability within and
connectivity to the Newmarket emerging street network is in evidence through large scale DCC initiatives and
speculative development.
While it has high quality examples of new-build structures along its length, it is a functional main transit route.
Many of the original (heritage quality) buildings lining the route have been demolished. The LRCA has a low
susceptibility to change.
2.6.2   LRCA 2: Chamber Street
Chambers Street retains an intimate urban residential character, having on-street frontages of indeterminate age
(many of the frontages have been renovated or altered), with direct entry to the 2 storey terraced properties
from the street. It is narrow and contained, and its intimacy is reinforced by the permitted development to the
south east side of the street. The fate of Ardee House Bar is yet to be confirmed, but it is likely the scale of new
development will reflect a similar frontage. The new DCC residential blocks under construction to the western
end of Chamber Street introduce a scale that is similar to the Proposed Development, but strongly linked to the
existing properties by the linearity of the street.
As a small character area focussed on existing residential terraces that may comprise vestiges of original Dutch
Billy frontages, and surrounded by sympathetic new permitted development, the LRCA has a medium value and
medium susceptibility to change.

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2.6.3   LRCA 3: Weavers Square and Park
The character of Weavers Square has undergone a recent change of scale and character due to the construction
of Weaver Park and the two DCC apartment blocks to the south and east of the park. Fronted by small scale
residential terraces to the west, both Weaver Square and Weaver Park are contained and screened from the
Subject Site by the new apartments towards the east. The LRCA has a low susceptibility to change, having been
subject to considerable regeneration to date, but as a part of the Liberties strategic open space network, both
Weavers Square and Weavers Park are of high value.
2.6.4   LRCA 4: Ardee Street
Ardee Street has a largely homogenous, dense urban character. The structures on Ardee Street including the dark
brick of No. 10 Georgian frontage, and the massing and height of the Southgate building, together with the
residential building south of this, enclose Ardee Street and reducing its scale. Frontages align to the back of the
footpath on both sides, concealing the turns into both Chamber Street and Newmarket. Although there are a
mix of contemporary and heritage frontages, the alignment unifies the character, which reflects the synthesis of
style and form through material and textural references that the LAP objectives advocate and are similar in scale
to the extant permissions and Subject Site. The permitted development to the immediate west of the Subject Site
on Ardee Street reinforces the continuity of use, form and materials (red dark or buff brick, glazed balconies and
wide single-pane window openings). The Subject Site reflects this scale and massing, as does the student
accommodation block to the south of Mill Street. The southern end of Ardee Street widens and opens as it merges
with Sweeney’s Lane, which changes character from large scale residential apartments / commercial buildings to
functional non-residential uses (a DCC works department depot) which stands apart in terms of character. Two
storey residential houses of the Oscar Square LCRA also merge with the Ardee LCRA.
The LRCA is undergoing rapid and profound change and therefore its susceptibility is low, although it is the route
to the western entrance of Newmarket Square, as well as a link to Oscar Square, a key component of the Liberties
Open Space Strategy in the area.
2.6.5   LRCA 5: Newmarket Public Realm
Newmarket is a Conservation Area. The broad expanse of tarmac and width and length of Newmarket, together
with its continuous enclosure by building of a variety of mass, height and materials, comprise the key
characteristics of Newmarket. Street trees are present but do not dominate the space. The red brick ELC building,
to the central axis at the eastern end of the square, is a strong focal feature. Currently, the Teelings Distillery also
stands apart as a contemporary high quality redevelopment.
As a designated heritage asset, The LRCA is of high value. However, due to the rapid regeneration of adjacent
urban fabric, and approved plans for reconstruction of the Square itself, it is of low susceptibility to change.
2.6.6   LRCA 6: Oscar Square
Key characteristics are of a residential neighbourhood enclosing a large fenced and gated green space with a path
network and extensive grass and trees, and as described in section 2.1.5, it features access roads with paths
either side, fenced and gated front gardens to terraced white washed 2 storey houses.
The LRCA is of high susceptibility to change as a residential neighbourhood, and it is also of high value, containing
a green space that is a key component of the Liberties Open Space Strategy.
2.6.7   LRCA 7: Mill Street and Warrenmount
Focussed on a narrow street that intersects Ardee Street to the south west corner of the Subject Site, its key
characteristic is the blend of heritage structures with contemporary frontages, including the stone wall to the
south of the subject site and No. 10 Mill Street, a conserved Dutch Billy façade of a building of historic value. Mill
Street connects to Warrenmount Lane and an extensive student and BTL apartment complex and hotel. The
complex is locked to public access and is therefore of low value to the public urban realm. The LRCA has recently
undergone an extensive building programme and is subject to extant permitted development, and is therefore of
low susceptibility to change, despite retained heritage-quality building assets.

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LRCA 1 Cork Street/St. Luke’s Avenue

                                                                               Brabazon Street
                                                                                                 LRCA 5 Newmarket
                                                                                                 Square
                                             LRCA 2 Chamber
                                             Street
    LRCA 3 Weavers
    Square and Park
                                                         LRCA 4 Ardee Street
                                                                                                                                                Newma

                                                                                                   LRCA 7 Mill Street / Warrenmount Lane
                                               LRCA 6 Oscar Square

Figure 23: Local Receiving Character Areas

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3.0 Relevant Policy
3.1      Dublin City Development Plan 2016-2022
With reference to the Dublin City Development Plan 2016-2022 (DCDP) and to the Planning Report accompanying
this submission, the following provides an outline of those issues that are pertinent to townscape and visual
assessment of the Proposed Development (passages directly relevant to the LVIA are underlined by the author).
3.1.1    Zoning
The site is zoned Z10:
   ‘To consolidate and facilitate the development of inner city and inner suburban sites for mixed uses, with
   residential the predominant use in suburban locations, and office/retail/residential the predominant uses
   in inner city areas’.
The City Development Plan states the development vision for Z10 lands as follows:
   ‘The primary uses in this zone are residential,
   office and retail. An appropriate mix of uses for
   any given site will be influenced by site location
   and other planning policies applicable to the
   associated area. A range of smaller uses will also
   be facilitated. The concept of mixed-use is central
   to the development or re-development of these
   sites and mono uses, either all residential or all
   employment/office use shall not generally be
   permitted.’
   ‘Lands zoned Z10 will cater for a relatively
   intensive form of development, and the range of
   uses permitted will be similar to Z5 but not as
   intensive or wide-ranging, reflecting the location
   of the sites and interactions with surrounding
   established land-uses. Accessibility may be an Figure 24:Extract from Dublin City Development Plan 2016-2022,
   issue in the development of Z10 lands, and where Zoning Map E; Green is Z10; Subject Site outlined in turquoise
   significant numbers of employment and or
   residents are envisaged, a travel plan will be
   required.’
3.1.2    Strategic Development and Regeneration Area
As the Planning Report states, the Liberties area is designated as SDRA16 within the DCDP. Opportunities for new
development are focused on key re-development sites. Newmarket Square and its immediate surroundings have
been identified as a Key Development Area in the now lapsed Liberties LAP, but as the majority of current
development (constructed, in progress and proposed) has been based on the principles it set out, the LAP is
relevant to assessment of urban character and views of the Subject Site, as acknowledged in the DCDP:
‘…some progress has been made in delivering on these objectives, it is clear that the economic downturn has
significantly impacted upon the overall delivery of the objectives of the LAP. While it is acknowledged that some of these
objectives, including the redevelopment of the Council’s housing stock, will not be achieved within the life of the Plan,
there remains many other sites where development is to be encouraged and promoted within the context of the LAP.’
The DCDP sets out the overall guiding principles and objectives of the LAP, as follows:
        1. ‘To improve the quality of life so that the Liberties area becomes a great place for people to live,
           work and visit.

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2. To provide for appropriate social and community infrastructure to support the existing population,
           which is growing and becoming increasingly diverse.
        3. To provide for a wide diversity and choice of housing that can cater for families and older people
           by including options for mixed tenure and a range of housing types and unit sizes.
        4. To stimulate the local economy and to include a critical mass of appropriate development and
           investment to provide significant employment opportunities, including in the digital media sector
           as the Digital Hub has the potential to rejuvenate the economic profile of the Liberties.
        5. To recognise the unique role the Liberties plays in Dublin’s character and to ensure that
           regeneration safeguards a strong sense of community identity.
        6. To identify and protect the distinctive heritage of the area and encourage sustainable and
           innovative re-use of historic spaces and structures.
        7. To ensure that the individual character of different areas within the Liberties is protected and
           enhanced by contemporary and high-quality design of new buildings.
        8. To promote the principles of good urban design including improving connectivity and enhancing
           the legibility and permeability of the Liberties in relation to the wider cityscape.
        9. To create a high-quality network of public spaces, parks and streets.
        10. To promote sustainable modes of transport by making them convenient and attractive, including
            walking and cycling routes, and by facilitating the provision of public transport infrastructure and
            optimising its use.
        11. To improve and encourage the cultural and tourist offer of the area.
        12. To encourage environmental sustainability by improving biodiversity, facilitating recycling, and
            minimising the use of non-renewable resources, including energy.’
Section 6.5.4:
   “The speedy re-development of extensive vacant/under-utilised sites, especially in the city centre zoned
   area, is critical to sustainable development. Putting in place a critical mass of investment and development
   in the short-term is essential to break the negative cycle of underdevelopment and to overcome the
   barriers to progress that have existed”.
3.1.3   Urban Form and Architecture
DCDP Section 16.2.1 states:
   “In the appropriate context, imaginative contemporary architecture is encouraged, provided that it
   respects Dublin’s heritage and local distinctiveness and enriches its city environment. Through its design,
   use of materials and finishes, development will make a positive contribution to the townscape and urban
   realm.”
Respecting and Enhancing Character and Context Section 16.2.1.1 states:
   “The city’s townscape is characterised by streets, buildings and spaces which have evolved over centuries,
   with established human scale and high quality of materials, craftsmanship and detail generally. The City
   Council will seek to ensure that the design of new development respects and enhances these and other
   elements that contribute positively to the cityscape and urban realm, the settings of protected structures,
   areas of special interest and important views and that such design incorporates high quality detail,
   materials and craftsmanship. Design must also recognise the diversity of the city environment and respond
   to the distinctiveness of Dublin as a capital city, a diverse residential community and a centre of business
   and commerce.

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“In assessing new development, consideration will be given to how the design has responded to the
   existing context and its relationship to the established pattern, form(s), density and scale of surrounding
   townscape, taking account of existing rhythms, proportion, symmetries, solid to void relationships, degree
   of uniformity and the composition of elevations, roofs and building lines. The design should be carried
   through to the detail, through use of attractive and durable materials and high standards of
   craftsmanship…. The suitability of the proposed design to its intended landuse and the wider land-use
   character of the area will also be considered, along with its relationship with and contribution to the public
   realm.”
The Proposed Development will beneficially add to regeneration of the Liberties area around Newmarket Square
due to its high-quality contemporary design. It complements the permitted Part 8 upgrade to the Square and
recently permitted/constructed development in the immediate vicinity. The mix of units proposed has been
considered in the context of the existing housing provision in the Liberties and the existing/future demographics
of the city, ensuring that a wide diversity of housing is provided in the area.
Additionally, DCDP Policy SC25 states:
    “To promote development which incorporates exemplary standards of high-quality, sustainable and
   inclusive urban design, urban form and architecture befitting the city’s environment and heritage and its
   diverse range of locally distinctive neighbourhoods, such that they positively contribute to the city’s built
   and natural environments. This relates to the design quality of general development across the city, with
   the aim of achieving excellence in the ordinary, and which includes the creation of new landmarks and
   public spaces where appropriate.”
As a corner site, the Proposed Development anchors the southwest threshold of Newmarket Square into place,
reinforcing the cultural heritage of the historic urban fabric, while putting in place a new element of the built
environment that complements both new and old in its applied form and materials.
3.1.4   Urban Density
DCDP Objective QH7, Integrated Land-use and Transportation, underpins the rationale for the proposed
development’s configuration:
   ‘To promote residential development at sustainable urban densities throughout the city in accordance with
   the core strategy, having regard to the need for high standards of urban design and architecture and to
   successfully integrate with the character of the surrounding area.’
Objective MTO1 adds to this approach:
   “To encourage intensification and mixed-use development along existing and planned public transport
   corridors and at transport nodes where sufficient public transport capacity and accessibility exists to meet
   the sustainable transport requirements of the development, having regard to conservation policies set out
   elsewhere in this plan and the need to make best use of urban land.”
Section 5.5.2, Policy QH8 likewise promotes the higher density of proposed development:
   “To promote the sustainable development of vacant or under-utilised infill sites and to favourably consider
   higher density proposals which respect the design of the surrounding development and the character of
   the area”.
3.1.5   Building Height
The site area is categorised as inner city low-rise in Section 16.7.2 of the Development Plan. These areas have a
building height limit of 28m. This limit excludes plant, flues and lift overruns ‘as long as they are set back and
properly screened and do not significantly add to the shadowing or otherwise of natural light beyond that of the
main structure’. This Development Plan policy has been superseded by national policy (the NPF and Building
Height Guidelines). See Section 3.2 below.

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