Submission on Balroy House

Glenveagh Homes have recently submitted an application for the site at Balroy House on the Carpenterstown Road. After inspecting the application, and working with Local Councillor John Walsh (Castleknock), I have made a submission in writing to An Bord Pleanála, and this can be read below.

This application was also discussed by the Fingal County Council Area Committee for Dublin 15 on 5 December. A motion was proposed by Councillor John Walsh, and was agreed by the Area Committee and called for the rejection of the application by An Bord Pleanála, as it is contrary to proper planning and development of the area. This motion can be read here.


Strategic Housing Application for Development at Balroy House, Carpenterstown Road (SHDW/021/19)

Secretary

An Bord Pleanála

64 Marlborough St

Dublin 1

Dear Secretary,

We wish to make an objection to the strategic housing application for development of 192 units and associated works at Balroy House, Carpenterstown Road, Dublin 15.

We are objecting to the application on the following grounds.

Residential amenity

The scale and height of the proposed five block, five storey over basement development is inappropriate and out of keeping with the pattern of development in the surrounding area. Existing estates along the Carpenterstown Road such as Mulberry, Park Manor, Woodberry, College Gate, Burnell and Bramley consist of two storey detached or semi-detached houses, with a small number of estates, particularly in Hamilton Park, including a mixture of houses and apartments.

A development consisting of 5 five storey blocks will have a negative visual impact on surrounding estates in Park Manor and Cottonwood directly to the north of the site and Diswellstown Way to the south. The height of the development in a suburban area with a predominant pattern of two storey houses in estates such as Burnell, Mulberry, Park Manor, Bramley and Diswellstown is detrimental to residential amenity. The previous permitted development (FW12A/0054) on this site was for a 151 bedroom nursing home, which was restricted to two and three storeys and in terms of height was more in keeping with the surrounding area.

There is a substantial demand for homes for young families in the Carpenterstown area – even the projections of the applicant acknowledge a growing young population aged 0-19 (see below). This application has an inappropriate mix of housing units for the area, focusing mainly on one and two bedroom apartments which make up 89% of the available units (67 1 bedroom apartments and 104 2 bedroom apartments, compared to only 21 3 bedroom apartments): this is much too high and many of the assumptions made in the social infrastructure report are predicated on the idea that most occupants in the new development will not have families. Any development on this site should include adequate provision for three or four bedroom family homes on a similar basis to neighbouring estates.

Social infrastructure – schools and public transport

The social infrastructure report presented by the applicant is fundamentally flawed. Overall the report reveals a striking ignorance of local conditions in terms of provision for schools and other necessary social infrastructure. The development promotes an intensified level of development on this suburban site which is not supported by existing or planned infrastructure. The scale of the development will impose unsustainable pressure on schools and childcare places in the area which are already heavily over-subscribed.

Firstly, the claim that population growth in the Castleknock-Knockmaroon electoral division is focused mainly on the over 60 group between 2011 and 2016 is over-simplified and does not disclose the full picture. While the fastest growing cohort was the over 60s, the expansion was from a low base and this is still the second smallest cohort as a percentage of the population: all but one of the other age cohorts also showed an increase, including the youngest cohort aged 0-19 (3.2%) and the 40-59 cohort who are most likely to have families (7.2%). Overall the area shows steady demographic growth above the national average, which is consistent across all but one age cohort – it also worth noting that the youngest cohort requiring school and childcare places makes up 30% of the population. 

The applicant’s submission is unconvincing in arguing that ‘two bedroom dwellings are less likely to result in a significant demand for school places.’ No evidence from other research or demographic studies is presented to substantiate this assumption: the wider societal context suggests that the demand for school places will fall at the higher end of the scale provided by the applicant (8-47 primary school places and 2-12 post-primary places), if this is not in fact a significant underestimation of the eventual demand. Potential occupants seeking housing in the midst of a housing crisis may accept accommodation which does not fulfil all of their requirements. It cannot be assumed in the current context of high rents and a shortage of available housing that only occupants of three bedroom apartments are likely to have families.

The analysis of primary schools in the area is entirely inaccurate. While the report suggests (table 5.3) that there are eight primary schools which could serve this development, in fact the development is outside the catchment area for at least four of these schools, St Brigid’s Boys and Girls NS which are located in Blanchardstown village and serve the parish of Blanchardstown and St Francis Xavier’s senior and junior NS which are located in Glenville, serving the Coolmine and Delwood area. For the sake of clarity these schools are outside the Castleknock-Knockmaroon electoral division on which the demographic analysis relating to population and household size is based. A fifth school included in table 5.3, Castleknock Educate Together, does not have a strict catchment area but is also outside the electoral division as it is located on Beechpark Avenue close to Castleknock village. St Patrick’s National School which is the closest to the proposed development is heavily over-subscribed and has a substantial waiting list so that children from local estates such as Bramley, Warren and Luttrellstown were unable to access the schools for the coming academic year: the only way children from the proposed development would be able to attend this school is by displacing children from the existing catchment area. St Mochta’s National School is also heavily subscribed as it serves much of Clonsilla, Riverwood and parts of Luttrellstown and is shown as having zero capacity in the table provided by the applicant.

Similarly, the analysis of secondary school places is profoundly unreliable and inaccurate. While 4 second-level schools are identified offering places in the area, two of these (Coolmine Community School and Luttrellstown Community College) do not include the Carpenterstown Road in their catchment area and neither would accept any children from estates on the Carpenterstown Road unless supply of places exceeded demand in their existing catchment areas. Indeed Coolmine Community School is outside the educational planning area for Castleknock and Carpenterstown set by the Department of Education, while Luttrellstown Community College no longer includes the Carpenterstown Road in its catchment area. Castleknock Community College, the major second-level educational provider in the area, is heavily over-subscribed and has a waiting list of 60 within the catchment area for the forthcoming school year. Castleknock College, the fourth school identified by the report, is a fee-paying school and it cannot be assumed that residents would necessarily be in a position to secure admission to Castleknock College. Finally, an unfounded claim is made that ‘an additional secondary school with a capacity of 800 pupils is due to open in the area by 2020…as the Blanchardstown Educate Together Secondary School.’ The proposed secondary school is designed to serve the West Blanchardstown and Blanchardstown Village planning areas designated by the Department of Education, not the Carpenterstown planning area in which Balroy House is located: even when it is opened, the new school does not add a single school place to the capacity in the Carpenterstown area. Moreover, the DDLETB (not Educate Together as stated) has only been selected as the patron for this school in December 2019, no site has yet been identified even on a temporary basis, the design process has not even commenced and it will be at least three to four years before this school is fully operational.

It is simply wrong to argue (6.3 and 6.4) that any new demand for primary and post-primary schools can be easily accommodated without additional school places. All the primary and secondary schools in the Carpenterstown area or indeed the wider Castleknock-Knockmaroon electoral division are heavily over-subscribed and under severe pressure to meet existing community needs. No new primary school has opened in the Carpenterstown area since Scoil Choilm in 2007. The analysis of school places by the applicant in the social infrastructure report is completely inaccurate and should not be relied upon by the Board in its deliberations.

The report and the applicant’s submission overall gives only cursory attention to public transport which must be seen as an essential part of infrastructure for new development. The report indeed claims that the area ‘benefits from excellent public transport links (nearby railway stops at Castleknock and Coolmine) as well as bus services’. Unfortunately this claim is simply wrong – residents would not recognise the description of excellent public transport, due both to shortcomings in existing services and the uncertainty of plans for improvement. The Maynooth train service is currently running at capacity and is overcrowded at peak times. The applicant in their response to issues raised by the Board refers to electrification of the Maynooth rail line within the DART expansion programme to justify the car parking strategy proposed for the development (2.23-2.24). But Irish Rail in their recent presentation to Fingal Council’s Area Committee for Castleknock, Mulhuddart and Ongar, indicated that any improvement in capacity, even in advance of full electrification, would not take place for at least four years.  There is no timetable for electrification of the line and plans for electrification have not even reached design stage. The reality is that electrification is not going to occur until the second half of the 2020s at the earliest and reliance cannot be placed on the DART expansion programme either to justify a reduction in the number of required car parking spaces or to suggest that the area enjoys high quality public transport. In fact both the quality and frequency of public transport in Carpenterstown is significantly inferior to urban locations served by DART and LUAS lines, reflecting the reality that Carpenterstown remains an outer suburban area in terms of available road and public transport links.

Journeys to the city centre on the 37 from the nearest bus stop often take 1.5 hours at peak times. Moreover, the Carpenterstown Road is not part of the radial ‘B’ spine offering direct access to the city centre under the Bus Connects plan. Carpenterstown is currently served by the 37, which under the current iteration of Bus Connects would not serve the main city centre areas of College Green/Nassau Street and Grafton St.

Environment

The proposed development is located in a ‘Highly Sensitive Landscape’ according to the Fingal County Development plan and the implications of the development for the landscape and local environment have not been sufficiently considered. The application involves the removal of at least 79 mature trees and two hedges from the site – of these only five trees were deemed unsuitable for long-term retention in the applicant’s tree report. In the context of the emerging consciousness about the costs of cutting down trees in terms of our carbon impact and air quality, it would be advisable to look critically at the developer’s proposals to do away with such a substantial proportion of the trees on the site. Considering the close proximity of Balroy House to the M50, the retention of trees on the site is an important factor in limiting air pollution, which is already a significant problem for communities adjoining the M50. Replacement of mature trees by saplings will not in any way abate or reduce air pollution, while noise pollution will also increase with the loss of tree cover.

The decision of the Board is likely to have implications for development on neighbouring sites adjacent to Balroy House, which have similarly large houses on spacious grounds with significant tree cover. The loss of these trees and potentially other valuable forms of biodiversity which have not been mapped or investigated should not be allowed in the absence of a full environmental impact assessment. It is important to ascertain the extent to which Balroy and the adjacent properties contain plant and wildlife habitats, particularly involving birds and protected species such as bats, which have been sighted previously on the property. A proper survey of the trees, fauna and wildlife on the Balroy site is necessary and the desk based screening study conducted by the applicant is entirely inadequate in this sensitive location. It would be unwise to undertake any development until such studies have been carried out to the highest Irish, European and international standards.

Traffic

The traffic report, which focuses almost entirely on projected trip rates from the new development, fails to appreciate the extent to which the Carpenterstown Road already sees heavy traffic congestion at peak times. This road was designed to serve an outer suburban area and is not designed to accommodate the significant level of traffic in a well-established suburb, still less the additional traffic to be generated by this development.

Part V requirement

It is particularly regrettable that the statutory Part V requirement for this development is satisfied by providing all 20 public housing units within a single apartment block (Block D) of the proposed development. This type of housing segregation is inappropriate, regressive and should not be permitted.

Conclusion

This application is damaging to residential amenity; is detrimental to the local environment and involves an intensified level of development on this suburban site which is not supported by existing or planned infrastructure. The application should be rejected as it is contrary to proper planning and sustainable development of the area.

Yours Sincerely,

Joan Burton TD, Dublin West

Cllr John Walsh, Castleknock