After inspecting the design of the Royal Canal Park Phase 4 SHD, and working with Local Councillor Marie Sherlock (Cabra-Glasnevin), I have made a submission in writing to An Bord Pleanála. This can be read below.
Observation to appeal Re: PL29N.306167
Royal Canal Park Phase 4
An Bord Pleanála,
Dear Sir / Madam,
We are submitting an observation to express strong reservations about the proposed design of the Royal Canal Park Phase 4 SHD.
As public representatives of the area, we are acutely aware of the need for additional residential housing and for the development of the remaining part of the Royal Canal Park area. However, this SHD proposal amounts to overdevelopment of the area, it breaches the intent of Dublin City Council’s local area plan with regard to building heights for the area and it fails to adequately provide a broad mix of housing type with a disproportionate concentration on one and two bed units.
We believe there are four key concerns;
Composition of Housing
The composition of the 435 residential units breaches Objective HO2 of Dublin City Council’s Local Area Plan for Ashtown which stipulates that
“To ensure a minimum of 50% of large sized units, i.e., of 3+ bedrooms, are provided within the LAP area on completion of all development. Whilst percentages may be permitted to vary above or below this figure on a given site, any significant housing proposal will be required to demonstrate how it can contribute towards achieving the eventual 50% minimum across the LAP.“
The proposed SHD is made up of 218 one bed apartments and 217 two bed apartments. This insufficiently meets demand for family housing in the area and we believe the developers must offer a more diverse offering from one bed to three bed units.
The proposal for two 13 storey blocks appears to be unprecedented across the city council area and breaches Dublin City Council’s Local Area Plan for the area in terms of integration into the existing environment and the maximum six story height limit for the area. The proposed height will impose an overbearing presence on existing housing in the area and it will also pose a particular challenge for emergency service vehicular access.
There appears to be one vehicular exit point out of the development and little detail on what the sustainable mobility plan might be.
Furthermore, the developer appears to be putting much store on the availability of public transport to carry persons into and out of the Royal Canal Bank area given the proposed ratio of residential units to car parking spaces. However, public transport systems in the area are currently operating above capacity and so will not be an attractive and viable transport option for those living in the proposed units.
It is also important to note that additional train capacity on the Maynooth rail line is only set to increase by 25% over the medium term and will only become available at the end of 2021 and throughout 2022. The construction of Pelletstown Train will be a great addition to the area but will be of little use over the medium term if rail users cannot get on a train there.
Future School Demand
The submitted planning documents base their projections on Census 2016 data and suggest that the SHD will not drive significant additional pressure for school places. In particular they suggest a drop in secondary school demand in the area in 2024/2025 and beyond.
We believe this to be a flawed assessment of existing and future trends in the Royal Canal Bank area. Already there is a serious issue for families in being able to access secondary school places in the area due to the school catchment boundaries set by the Department of Education. Furthermore, we believe demand for secondary places is going to rise and with that more difficulties in accessing places. The developer’s expectation appears to be that the two bed units will not house families, but the extent of the housing crisis is that families will end up having to take up residence there and will therefore drive demand for both primary and secondary school places in the area. It is also worth noting that the promised permanent Educate Together primary school building has still not commenced construction work.
Ultimately, the proposed development amount to a daring attempt by developers to maximise over the short term as much profit from their site as possible with little regard to the medium-term sustainability of the development and its integration into the community along the Royal Canal Bank.
Joan Burton, General Election Candidate, Dublin West
Cllr. Marie Sherlock, Cabra-Glasnevin