Dublin Bay South | Observations on the proposed co-living development in Donnybrook

Observations on the planning application at: 22-24, Donnybrook Road (former Kiely's Public House), Donnybrook, Dublin 4

Planning Reference: 3301/20

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Dear Sir/Madam,

I write to you to submit observations on the planning application at 22-24, Donnybrook Road, Dublin 4 (ref: 3301/20).

Shared Living Schemes:

I support increasing the housing stock to end the 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 of Donnybrook. The developer has not adequately dealt with the threat posed by Covid-19 in its submission. For example, on the second floor of the development, the developer has, optimistically, provided floor plans which include the twenty residents of the floor sharing two dining tables. This is simply not a credible plan in the context of the pandemic and the developer’s Shared Accommodation Operational Management Plan does not adequately address how social distancing and the practical elements of food preparation and recreation time will work for the site. It would not be right for Dublin City Council to approve a development that may threaten public health, or which may preclude those with weaker immune systems from accessing the housing.

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, planning authorities 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 profile of prospective residents set out by the Shared Accommodation Operational Management Plan identifies them as young professionals, not from Dublin, earning a median income of up to $80,000 per annum. 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 (notably, the developer points to Facebook and other companies as prospective workplaces for tenants) is not a reliable target, in light of Covid-19; the council should prioritise housing which may be retained for the longer term.

Section 3.22 of the Shared Accommodation Operational Management Plan correctly states that wage growth has not kept pace of growing rents. However, a degradation of living standards is not a solution to this problem. Far from delivering quality value for money housing for renters, this model provides the best return on investment for developers as its units are not subject to the same minimum standards as other types of residential developments.

The Sustainable Urban Housing: Design Standards for New Apartments guidelines for planning authorities further state that the relatively new nature of shared living 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 imminently; 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.

A central tenet of  the Dublin City Sustainable Development Plan 2016-2022’s strategy for Z1 Sustainable Residential Neighbourhoods is the promotion of diversity in household types, age groups and tenures living in safe developments of a high quality. 100 adults living in single rooms with shared basic amenities during a pandemic does not evoke visions of sustainable communities. I am concerned that this proposed development will have a deleterious effect on the quality of life for residents in the locality. 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 .

Traffic:

Page 12 of the Building Life Cycle Report asserts that there is “ample on-street parking” on Donnybrook and adjoining roads. DCC will know that this is simply not the case and that multiple bottlenecks form in the area throughout the day, including outside of peak times. Providing housing to more than 100 people on-site with no contingency plans for increased traffic and parking provision is a hands-off approach which is sure to present future congestion difficulties in future.

Concerns of Local Businesses and Residents:

The Construction and Demolition Management Plan commits to consulting neighbouring building owners before beginning construction. I hope that the developer will be proactive and responsive in doing so to alleviate the grave concerns of residents and business-owners in the area. Regardless of whether DCC approves this planning appliation, the use of Mulberry Lane for access or parking must be prohibited during construction to allow the Party Shop Donnybrook to continue trading.  Furthermore, clearer graphics and CGI should be provided by the developer, as the plans are difficult to read by those who may be affected but are not experts in planning.

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

Yours Faithfully,

Senator Ivana Bacik