An Bord Pleanala: Student Accommodation Development at 274 North Circular Road
21 July 2017
Re: DCC Reference 4262/16 274 North Circular Road
I wish to support the planning appeals against Dublin City Council’s decision to grant permission for the above development from the Rathdown Road, Great Western Square, Rosemount Road Residents Associations and Phibsboro Village Tidy Towns. I would also strongly support their request for an oral hearing on the subject. Given the explosion of student accommodation development in the Dublin 7 area, this is an issue of both local and national significance.
The decision by Dublin City Council to Grant Permission appears to be in contravention of the Dublin City Development Plan on a number of grounds.
Sustainable Development of the Area and over concentration of student accommodation
The Dublin City Development Plan Section 5.5.2 outlines key principles of development and states that “planning is about creating communities and further developing existing communities in a sustainable manner…”. The proposed student accommodation development makes no contribution to the development of a sustainable community in Phibsborough. It will in fact contribute to undermining the existing community through the introduction of a transient population outnumbering the traditional community of this Victorian suburb. The number of student bed spaces within a 1km radius of the new Grangegorman campus either granted permission or in the planning pipeline is 6,079. The experience of other cities should be taken into consideration and Edinburgh City Council’s guidelines note that “the student population not living at home can be a significant element of the transient population… excessive concentrations may over time result in poor quality of place, a diminished sense of community and an area less attractive to all sections of the community”. The Guidelines also state that “Where the student population is dominant, exceeding 50% of the population, there will be a greater potential imbalance within the community.” The Rathdown Road Residents’ Association has provided evidence that should this application be granted the transient student population will outnumber the existing permanent residents by 58% to 42%.
Dublin City Council Guidelines on Student Accommodation
Dublin City Council’s own guidelines state that student accommodation must be developed “in a manner which respects the traditional amenity and character of the surrounding area” (Policy QH32). Moreover, section 16.10.7 states that “in assessing proposals the planning authority will have regard to the pattern and distribution of accommodation in the locality and will resist the overconcentration in any one area”. Given the proliferation of student accommodation in the area, as outlined above with 6,079 bed-spaces granted permission or in the planning pipeline, the decision to grant permission to a further 444 units runs contrary to this policy in the Development Plan.
Guidelines on Architectural Conservation Areas and Residential Conservation Areas
The proposed development is adjacent to the Architectural Conservation Area (ACA) of Great Western Square and the Residential Conservation Z2 Zoned Rathdown Road and Rosemount Road.
Section 126.96.36.199 of the Dublin City Development Plan outlines that ACAs “have been designated in recognition of their special interest or unique historic and architectural character and important contribution to the heritage of the city”. The Development Plan states that development must not “harm the setting of a conservation area” or “” constitute a visually obtrusive or dominant form”.
In addition, section 188.8.131.52 states that within conservation areas it is important to ensure that “design is appropriate……. New development should have a positive impact on local character”.
The density massing and height of the proposed development will be detrimental to the setting of the Great Western Square ACA and will be visually obtrusive. The Great Western Square Residents have provided detailed drawings to demonstrate this point.
The site is zoned Z1 and is bounded by an Architectural Conservation Area at Great Western Square and Z2 Residential Conservation area on Rathdown Road and Rosemount Road and the North Circular Road. The objective of Z2 is “to protect and/or improve the amenities of residential conservation areas”. The Dublin City Development Plan states that “Dublin City Council will thus seek to ensure that development proposals within … Conservation Areas complement the character of the area”.
The Dublin City Development Plan also states that “it is important to avoid abrupt transitions in scale and use zones. In dealing with development proposals in these contiguous transitional zone areas, it is necessary to avoid developments that would be detrimental to the amenities of the more environmentally sensitive zones”.
The elegant two-storey Victorian houses of the neighbouring ACA and Z2 conservation areas will be overpowered and in many cases overshadowed and overlooked by the squat 7 storey apartment blocks in their midst. The 5-7 storey apartment blocks are totally incongruous with the local landscape and built environment.
The proposed development is detrimental to the conservation area from both the visual and sustainable development perspectives.
The application is contrary to proper planning and sustainable development of the area on a number of fronts and I respectfully submit that Bord Pleanala should reject this development outright.
At present, there is a housing and homeless crisis. This is an ideal site for a residential development.
However, should An Bord Pleanala be minded to grant permission, I would support the design requests submitted by Rathdown Road and Great Western Square residents in relation to reducing the height and removal of balconies. Moreover, a liaison structure should be put in place to ensure that residents are kept informed and consulted at each stage of the development.
Strict conditions should be imposed on ensuring that the accommodation is available only to registered students at accredited HEA institutions. The proposed use of the accommodation as tourist or hostel accommodation during summer months should not be permitted. I would also support the request that a condition be attached requiring 24-hour management of the facility.
I enclose the fee for €50 and request that you take these observations into consideration.
LABOUR PARTY SPOKESPERSON ON URBAN REGENERATION.