Submission on Prussia Street Redevelopment

13 April 2021

by Cllr Joe Costello

See my submission to An Bord Pleanala on the redevelopment of Park Shopping Centre, Prussia Street.

In it I have highlighted

The over-concentration of student accommodation in the area and the need for more sustainable housing,
The excessive height and density of this development - 100 more student bedspaces than previously permitted under DCC permission and height of up to eight storeys
The impact this development will have on the neighbouring residential areas of St Joseph's Place/Court and Rathdown Square,
The impact on adjacent protected structures, the visual impact of this development on Prussia Street and the need for high quality design at this strategic location,
The need for a community liaison structure in the event that permission is granted.

A decision is due by 29th June 2021.

13 April 2021

Ref: 309657: Park Centre Prussia Street & 42-45 Prussia Street.

Dear Bord Pleanala

I wish to make the following observations in relation to the application for the redevelopment of the Park Shopping Centre.

I would state at the outset that the redevelopment of the Shopping Centre is welcome and understand that the site has enormous potential. I also understand that planning permission has already been granted (Ref 2038/17) for 485 student accommodation bedspaces on this site which is adjacent to the TU Dublin campus at Grangegorman. However, I am greatly concerned by the proposal to increase the height to eight storeys and the density by more than 100 bed spaces on the previous application, which in my view already represented over-development of the site.

There are serious concerns in the community about the proliferation of student accommodation in the Stoneybatter area. The Grangegorman Campus has attracted a large number of student accommodation developments in the vicinity. The experience of “studentification” of other Cities and the resulting policies on student accommodation should be taken into consideration. Research undertaken in areas of cities adjacent to third level institutions in the UK suggests that “when the student population reaches 20% serious difficulties begin to arise and that at 25% it challenges social cohesion” (Balanced Communities and Studentification, p.9).

The applicant references Edinburgh in their report on Student Accommodation. The Edinburgh City Council student housing guidelines while acknowledging that “a high student population can bring benefits” state that the “concentration of students as a proportion of the transient population can undermine the social and physical fabric which defines a community and place”. They further state that “Balanced sustainable communities require the dominant residential component to be permanent and not transient. The student population, when 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 make an area less attractive to all sections of the community”. The “studentification” of Stoneybatter will have a major impact on the character and integrity of the village.

Moreover, at this point it is unclear what the full impact of COVID-19 will have on the demand for Purpose-Built Student Accommodation. The proposed development of 203 bedspaces at 84 Prussia Street has been abandoned despite having received planning permission and it is unclear if it will ever resume.

A recent survey of student accommodation shows that 79% of residents of student accommodation are international students, but the number of international students coming to Ireland has been adversely impacted due to the COVID-19 crisis and the future is uncertain for this sector.

While acknowledging that student accommodation is a permissible use, I believe that this site presents a unique opportunity for quality residential development in the area. Almost all recent development in the area has been for student accommodation, despite the strong demand for residential family homes.

The Dublin City Development Plan requires that applications for student accommodation must provide “evidence to demonstrate that there is not an over-concentration of student accommodation within an area, including a map showing all such facilities within 1km”[1].

While a Report on student accommodation has been submitted this report by the applicant, it is lacking in very basic information and is disappointingly inaccurate. The map outlining all student accommodation applications within a 1 km radius is incomplete, by omitting a number of developments and no figures are provided on the number of bed spaces. The developments at Montpelier Hill(329), Blackhall Place (300 bed units), Stoneybatter (120 units) and Fitzwilliam Place(132) were all omitted. See Appendix 1 for an accurate table of the extent of Student Accommodation within a 1km and a 1.5km radius of this development.

This is not the first time that a developer has submitted inaccurate information in the student concentration report. It is unacceptable that developers submit inaccurate reports with planning applications and this is an issue that the Bord might consider separately.

I have further concerns about a number or aspects of the proposed management of this development. The Dublin City Development Plan defines a student for the purpose of student accommodation as being “a person who is registered with a third-level educational institution which is designated as such by the Department of Education and Science or by ACELS (Accreditation and Co-ordination of English Language Services) under the auspices of the DES.”[2] There is no such stipulation in the Management Plan and it is not clear how the management company will verify each potential resident’s student credentials.

In the event that permission is granted it should be conditioned that the students must meet the definition as outlined in the Dublin City Development Plan.

The management plan does not address how the scheme will be managed during academic summer holidays. I am conscious that a number of student developments are being let through Airbnb in the summer months, often for up to five months from May to September (inclusive). In all cases local residents have reported considerable problems in relation to this matter.

In the event that permission is granted I would request a condition preventing the letting of the property on Airbnb or similar short-term letting platforms.

While the provision of a limited number of apartments/family units is welcome, it is most disappointing that these are build-to-let units which tend to attract a more transient population.

Residents of St Joseph’s Place and St Joseph’s Court are particularly concerned that the development at 8 storeys in height, has unacceptable levels of overlooking and overshadowing on their cul de sac and is visually obtrusive. Residents’ homes will be dwarfed by this overbearing development on top of them which would totally eliminate their privacy. On the other side of the proposed development is Rathdown Square which will also be hugely impacted by way of overlooking and overshadowing.

The site in question is located within a Z4 Zoning area the objective of which is “to provide for and improve mixed services facilities”. The area surrounding the site is Zoned Z1 “to provide, protect and improve residential amenities" The Dublin City Development Plan 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 (my emphasis). For instance, in zones abutting residential areas or abutting residential development within predominately mixed-use zones, particular attention must be paid to the use, scale, density and design of development proposals and to landscaping and screening proposals in order to protect the amenities of residential properties.” (Dublin City Development Plan, 14.7 Transitional Zone Areas).

It is clear that this development does not take into consideration the residential amenity of the neighbouring residential areas of St Joseph’s Place/Court or Rathdown Square.

In the event that permission is granted, I would request that the development is scaled back in terms of density and height.

The site is located within the Zone of Archaeological Constraint for the Recorded Monument, DU018-020 and is therefore subject to statutory protection under Section 12 of the National Monuments (Amendment) Act. The site is also contained within the Zone of Interest in the Dublin City Development Plan 2016-22. The site would be within a zone of potential for the medieval settlement of Grangegorman. I note that the Archaeological report is based on a desktop survey and no trial trenches were excavated. Any development on this site should be conditioned on an archaeologist being employed and on-site for all subsurface work undertaken.

A number of protected structures are located in the vicinity of the site including the Jameson House (currently Saor Ollscoil at 55 Prussia Street), 29 Prussia Street, 66/67 Prussia Street and the Grangegorman Boundary Wall.

Prussia Street is one of the oldest streets in Dublin and before its destruction (authorised and unauthorised) consisted mainly of early Georgian houses of varying size, height and design which created an attractive streetscape. The uncontrolled demolition of these buildings combined with the construction of nondescript edifices (i.e. shopping centre, apartment blocks of no architectural value and setback garage/workshops has deprived the street of much of its character and ethos.

Prussia Street has enough eyesores. What is now required is a development plan to help regenerate the street for the benefit of those living in the area rather than piecemeal planning applications. The street also needs more trees and green landscaping. There should be a more connected plan that includes improving the street layout (pavement widening, seating, cycle path) and adding green space, pollinator friendly planting and native trees.

The applicant’s Archaeology & Heritage report contends that the proposed development is a suitable structure and “has been designed to enhance the built environment around Jameson House (Saor Ollscoil) and provide a better cultural environment for the streetscape heritage”. A development at this site offers the opportunity to restore a semblance of good design and help return the street to its former glory and integrity. However the design of this proposed development at an important gateway into Stoneybatter Village is deeply disappointing. The assertion in the report that the “impact to the streetscape cultural heritage will be positive” is very questionable. From a design perspective the rendering and public facing elevations are poorly considered in relation to the surrounding areas or local architecture. The development is somewhat brutalistic in form especially facing onto Prussia Street.

This development will require the demolition of an entire Shopping Centre and a construction period of two – three years. It will have an enormous impact on the local community in terms of the range of the facilities it provides at present. It is virtually a little village in its own right. All the amenities will disappear overnight – including the Post Office, supermarket, medical centre, barbers, take-away, bakery, chemist, café, newsagent, hardware store and car-wash. It will be an enormous loss to the community in terms of amenities and employment .

The application includes the demolition of all existing structures on the site. No survey has yet been carried out in relation to hazardous products, such as asbestos, which may be onsite. The applicant should be requested to provide additional information in relation to what hazardous material is on the site.

In the event that An Bord Pleanala grants permission, a construction plan should be agreed in advance of work starting on the site between the planning authority and the developer and local residents and business groups. This plan should address issues of movement of hazardous materials, spoil and construction materials, construction parking, dust, noise and hours of work. In addition, there should be a condition for a liaison structure with the local community to resolve issues that may arise in the course of the development.

Yours sincerely

CLLR JOE COSTELLO

Appendix 1 Existing/Granted Units within a 1KM Radius

Location	Local Electoral Area (LED)	Planning Reference	No of Bed Spaces	Status
Blackhall Place	Arran Quay B	Existing	300	Existing
GGDA SDZ	Arran Quay B		2,000	Approved in SDZ
Prussia St Park Shopping Centre	Arran Quay B	2038/17	485	Granted (application for 581 Now submitted)
Prussia St/Joseph’s Road	Arran Quay B	4035/16	203	Construction started / stalled
Fitzwilliam Place North Grangegorman	Arran Quay B	3000/15	132	Constructed
3-11 Grangegorman Lower	Arran Quay B	2858/16	571	Constructed
51 Rathdown Road/252 NCR	Arran Quay B	4262/16	444	Constructed
Nolan Seafoods, Rathdown Road	Arran Quay B	SDH002/18	289	Granted
Doyle Triangle (Next to above application) Rathdown Road	Arran Quay B	4674/18	44	Granted & Under Construction
20 Stoneybatter	Arran Quay B	4261/16 4734/18	120	Granted
Montpelier Hill	Arran Quay D	3772/16	329	Completed
Broadstone	Arran Quay A	Existing	103	Existing
Total			5,020

Additional Existing/Granted Units within a 1.5 KM Radius

Location	Local Electoral Area (LED)	Planning Reference	No of Bed Spaces	Status
Phibsborough Shopping Centre	Cabra East A1	2628/17	341
27-31 Church Street	Inns Quay C	2990/14	243
Dorset Street	Inns Quay B	2838/15	463
58 Dominick Street	Inns Quay B	2080/17	247
Total			1,294
Total within a 1.5km radius			6370
Total including proposed development of 296 beds			6,666

[1] Variation to Development Plan September 2017

[2] Dublin City Development Plan