Dublin Bay South | DCC must prioritise the building of sustainable communities

The week ending 9th August 2020, I submitted two observations on developments planned in Dublin Bay South - one is co-living and one is an apartment block in Ringsend without provision for social housing. I am urging Dublin City Countil to prioritise the building of sustainable neighbourhoods. Read my submissions below.

 

Observations on the planning application at: 11, 11A & 12, York Road, Ringsend, Dublin 4

Planning Reference: 3040/20

Dear Sir/Madam

I would like to submit observations onthe planning application for the demolition of the existing building and the construction of a new 15-storey development at 11, 11A &12 York Road, Ringsend.

Social housing provision:

• The council previously granted the developer, Melvin Properties Ltd., a social housing exemption (ref: 0024/20) and permission to build 26 apartments at the site (ref: 2043/20). In my view, a social housing exemption should not have been granted.
• Under Part V of the Planning and Development Act 2000, private developers must provide 10% social housing, unless the ground floor of the development is less than 1,000 square metres in size. It is under this regulation that this developer previously obtained permission for a social housing exemption certificate. However, just because the developer can apply for an exemption does not mean that the local authority should grant it. The removal of height restrictions under the previous national government means that this so-called loophole may be applied to many more developments than before. Given the context of the area in which the site is located, to grant an exemption during a housing crisis would be incongruent with Dublin City Council (DCC)’s Dublin City Sustainable Development Plan 2016-2022.
• A core strategy of the Dublin City Sustainable Development Plan 2016-2022 is the creation of sustainable neighbourhoods to support communities and to provide for a broad range of household types, age groups and tenures. The creation of good neighbourhoods and socially-inclusive communities applies to both the inner and outer city. Already, DCC has opted not to purchase its allocation of social homes in Boland’s Mills, 6 Hanover Quay and 8 Hanover Quay. Those developments would have provided 21 social homes for the area; DCC will buy 7 of the social homes in the area around Ringsend but the remaining 14 will be purchased elsewhere in Dublin. To pursue the same policy at this site would not be conducive to building or maintaining a socially-inclusive community and would not advance this core strategy for the Ringsend area.
• There is a significant shortage of housing, particularly long-term housing, in the area and throughout Dublin City. I am very much in favour of increasing the housing stock available to alleviate our housing and homelessness crisis. However, I believe that a housing development with no social housing provision is inadequate during a housing crisis and will not contribute to the creation of sustainable communities in the inner-city community of Ringsend.

Building height and design:

• The designand height of the proposed development is unsympathetic to and inconsistent with the character of the area. At 49.6 metres tall, the proposed development is in excess of the 28 metres permitted for City Centre residential developments, as stipulated in the Development Plan. If planning permission is granted, the development will dwarf existing residential buildings and will disrupt the skyline. Although the site for the proposed development is in a Residential (General) Zone 1 it borders a Residential (Conservation Areas) Zone 2. Where zones are back to back, any proposed development must have regard for adjoining zones. As such, the development must have due regard for the neighbouring buildings in the adjoining Residential (Conservation Areas) Zone 2. This development will have more storeys than its neighbours by a factor of 3 and will significantly disrupt the skyline.

Conclusion:

I am concerned that this proposed development falls short of what is envisaged for a Residential (General) Zone 1 area, which should provide a wide range of accommodation within sustainable communities. A lack of social and affordable housing in Ringsend has already forced some young families to move into overcrowded homes with their parents and grandparents, while others have been forced out of the area or out of Dublin completely. It is unsustainable not to guarantee reasonable social and affordable housing provision to a community such as this.

Ultimately, it is the State’s role to provide enough social housing to build diverse and sustainable neighbourhoods. However, in lieu of this taking place to a satisfactory level, local authorities ought not to allow developers to pursue policies leading to unsustainable gentrification of areas at the expense of local communities. For the reasons outlined above, I ask that, should permission be granted for the development in principle, that DCC would withhold a social housing exemption certificate.

Yours Faithfully,

Senator Ivana Bacik

 

Observations on the planning application at: 98, Merrion Road, Dublin 4

Planning Reference: 3019/20

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Dear Sir/Madam,

I write to you to submit observations on the planning application at 98 Merrion Road, Dublin 4 (ref: 3019/20). I note that the developer, Bartra Property Ltd., previously obtained permission for a 20-bed apartment block at the site (ref: 3671/17). This new planning application (referred to as a ‘Shared Living Residential Development’) seeks permission for 111 co-living units on the site, consisting of 96 single occupancy rooms, 3 accessible rooms and 6 double occupancy rooms, with shared kitchen and dining spaces.

I am very much in favour of increasing the housing stock available to alleviate our housing and homelessness crisis, but I have serious concerns about the nature of the co-living scheme that is being proposed and its impact on the wellbeing of those who will live in the facility, as well as the wider community in the locality. Higher density living and apartment living may constitute the future of housing in Dublin; but co-living, particularly in light of the uncertainty around Covid-19, is not a viable option. The Risk Assessment Covid19 report, submitted by Bartra Property Ltd. and compiled by Corporate Health Ireland does not adequately address concerns associated with Covid-19. Moreover, the report states that tenants will be required to book one-hour slots to access their own kitchens (as well as other facilities), to mitigate against the risk of spreading Covid-19. These restrictions are not conducive to sustainable, medium-to-long-term accommodation and set a dangerous precedent for the degradation of living standards in Ireland.

In the Planning Report (page 24), the developer refers to co-living as “landing pads” for short-term accommodation. However, a short stay is no justification for a poor quality of accommodation. The previous development proposed (3671/17) would have provided 3 1-bedroom units, 14 2-bedroom units and 3 3-bedroom units. These would be more spacious, with private amenities for tenants, providing safer, better accommodation and promoting diversity in household types, age groups and tenures living within the development, which is a central tenet of  the Dublin City Sustainable Development Plan 2016-2022’s strategy for Z1 Sustainable Residential Neighbourhoods and adjoining Z2 Residential Neighbourhoods (Conservation Areas). I am concerned that this proposed development will have a deleterious effect on the quality of life for residents in the locality. Poor quality housing inhibits the development and maintenance of sustainable communities. I would ask you in your deliberations to consider how this site could be better developed to contribute to the community and locality, as well as how it can best serve future tenants of the site – it is my view that this may be done by retaining the existing permissions and rejecting the application for a co-living scheme on the site.

The Department of Housing, Planning and Local Government’s Sustainable Urban Housing: Design Standards for New Apartments guidelines for planning authorities state that, when assessing proposals for co-living, the planning authority must have regard to the need for such a type of accommodation in an area with reference to the need to cater for particular employee accommodation needs. The developer makes multiple assertions that there will be future demand for “launch pad” and short-term shared housing for young professionals, such as migrant workers living in the locality for short stays to complete work associated with Foreign Direct Investment. In light of Covid-19, this is future demand not a surety; the council should prioritise housing which may be retained for the longer term, instead, as with the previous development proposal (3671/17).

The Sustainable Urban Housing: Design Standards for New Apartments guidelines for planning authorities further state that the relatively new nature of this form of accommodation means that the Department will monitor the emerging co-living sector and may issue further additional technical updates and regulations for it. Minister for Housing Darragh O’Brien TD has said that a review of co-living schemes will be due for completion and debate with the Joint Oireachtas Committee on housing as early as September; it could be described as unduly hasty to grant permission to a development such as this in advance of the report’s publication and in the midst of a deadly pandemic.

I hope that you will take the above observations into account when making a decision on this planning application.

Yours Faithfully,

Senator Ivana Bacik